Joint Pharmaceutical Analysis Group
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A recent meeting discussed technical and regulatory issues surrounding the use of rapid microbiological methods and the substantial advantages they offer to the pharmaceutical industry for product quality control and process analytical technology. Joe
Chamberlain reports
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The meeting, organised by the Joint Pharmaceutical Analysis Group, took place at the Royal Pharmaceutical Society's London headquarters on 18 March. Dr Joe Chamberlain is a former editor of The Journal of Pharmacy and Pharmacology
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How analytical science contributes to rapid microbiological assessment
The pharmaceutical industry is facing unprecedented pressures, said
Paul Newby, GlaxoSmithKline, Barnard Castle, County Durham, with research
and development costs increasing year on year and reduced profits from
fewer blockbusters, reduced exclusivity periods and increased patent
challenges. Possible relief from these pressures will come from process
optimisation by way of process analytical technology (PAT). Rapid microbiological
methods (RMMs) have a significant part to play in achieving PAT objectives.
Some barriers to the introduction of RMMs are technical ones. Many test
systems are designed for different industrial sectors and there may be
lack of understanding of pharmaceutical sector requirements. Guidance
for the new user may be unclear and suitable suppliers with an understanding
of good manufacturing practice and validation requirements may be lacking.
Other barriers may be cultural and organisational. The pharmaceutical
industry is a highly conservative one with a reluctance to change from
compendial methods. The industry is uncertain of regulatory acceptance.
There is often a lack of managerial commitment because managers may see
no clear business requirement and have a perception that current traditional
microbiological methods are simple and inexpensive.
These barriers may be overcome by considering RMMs as part of a wider
design for the release of finished goods under PAT. It is important to
spread the knowledge within the company, convince local management and
the regulatory affairs department and build an effective business case.
Significant resources, it must be recognised, are required for development
and implementation. There must be a clear view of what is required and
there must be close collaboration with suppliers and regulators, being
realistic about implementation and the benefit to be expected.
RMMs are needed because current microbiological methods are potential
bottlenecks to product release and cannot deliver real-time results.
Dr Newby explained that GSK is interested in RMMs for product testing
and in-process control optimisation and the main technological contenders
in this area are adenosine triphosphate (ATP) bioluminescence and solid-phase
laser cytometry. The GSK implementation strategy is based on the important
document from the Parenteral Drug Association: PDA Technical Report No
33, “Evaluation, validation and implementation of new microbiological
testing methods”. This report is intended to provide a general
approach to the introduction of new microbiology methods in a government-regulated
environment. It is also intended to provide guidance for the successful
evaluation, validation and implementation of new microbiological
methods needed by the pharmaceutical, biotechnology and medical device
industries to assure product quality and provides a valuable guide to
those developing and introducing RMMs into the product cycle. Genotypic and phenotypic methods
Jim Bruce, Accugenix, Newark, Delaware, presented his contribution
by satellite link. As long ago as 1980, Fox et al (Science 1980;209:457–63)
proposed a natural system of classification based on phylogenetics
rather than taxonomic characters. In many cases taxonomic characters
are not phylogenetically valid; that is, morphological characters such
as cell shape, mode of cell division and lack of cell wall can be misleading.
Phylogenetic taxonomy is a universal system because all microbes have
16S RNA genes. No prior knowledge of identity is required and it is
reproducible from laboratory to laboratory and over time. DNA sequences
do not change according to how the organism was cultured or who is
performing the test. Data are easily shared, transported and included
in a database. It is more informative than phenotypic identification
and there are no specific growth requirements.
A study was undertaken to determine species level accuracy and reproducibility
using known ATCC (American Type Culture Collection)-type strains of organisms
typically found in the pharmaceutical manufacturing environment. Eighteen
ATCC strains were run in triplicate. Accuracy was evaluated according
to whether the correct species was identified and reproducibility was
evaluated according to how often the same result was achieved.
Genotypic methods were assessed using the MicroSeq microbial identification
system from Applied Biosystems and the iboPrinter microbial characterisation
system from DuPont Qualicon. Phenotypic methods were assessed using the
Sherlock microbial identification system from MIDI (identification based
on patterns of cellular fatty acids), the MicroLog MicroStation from
Biolog (identification based on carbon use), and the Vitek apparatus
from bioMérieux (identification based on substrate use). Sample
data were interpreted according to the manufacturers’ published
guidelines. The study found that genotypic systems are more accurate
and reproducible than phenotypic systems. 16S DNA sequencing provides
phylogenetic information even when species identification cannot be made.
Despite the often high capital cost, the effective price (cost per identification)
of DNA sequencing is comparable with other systems. Outsourcing the
microbial identification function of a pharmaceutical laboratory may
provide more benefit at a lower cost with rapid results, concluded Dr
Bruce. ATP bioluminescence
ATP is considered an indicative component of living cells and its presence
can be demonstrated by its participation in an enzyme reaction resulting
in the production of light energy. Dr Newby delivered a paper by
Christopher Randell, Wyeth Pharmaceuticals, Havant, Hampshire, on a detailed
review
of the use of ATP bioluminescence as a rapid biological method, including
a survey of the main commercial instruments: Rapiscreen from Celcis,
MicroStar from Millipore, and Pallchek from Pall/Gelman. The method
is primarily qualitative and acts as a screening process for products
or for environmental samples. It uses test protocols similar to the
conventional methods and any growth can be identified for information.
The assay generally reduces laboratory time and increases flexibility.
This RMM encourages inventory savings, with material spending less
time on storage in the warehouse. Although primarily used in the
cosmetic and toiletries industry, it has been shown to be a useful technology
in the pharmaceutical industry and has gained regulatory approval.
However, Dr Newby said, there are initial investment and servicing
costs, running costs can be higher than with traditional methods
and
sensitivity can be too good. Laser-scanning cytometry
Robert Johnson, Pliva Pharmaceuticals, Petersfield, Hampshire, described
the operation of the ChemScanRDI from Chemunex which uses laser-scanning
cytometry for rapid microbiological measurements. The analysis is
carried out in three steps: membrane filtration, cell labelling and laser
scanning.
The data processing facility evaluates the signal according to colour,
shape and light intensity. Using the system, results are available
in two hours, with enhanced sensitivity (single cell detection is
claimed). It detects bacteria, yeast, moulds and spores in a single test
protocol,
and the results are independent of culture conditions. There is good
recovery of injured or stressed organisms and sample analysis is
automated. However, samples must be filterable and sample preparation
is labour-intensive.
There is no facility to identify micro-organisms, although morphological
attributes (rods, cocci, spores) can be discerned. Sample preparation
limits the ability to recover micro-organisms for further evaluation.
The method can be applied to routine analysis of pharmaceutical grade
waters, sterility testing, environmental monitoring, material testing
and in-process control.
A thorough evaluation of the equipment showed that the ChemScanRDI
consistently met defined operational parameters. False positive results
were minimal.
Good reproducibility, accuracy, linearity and precision ensured the
system could be used without microscope confirmation. For routine
water monitoring,
the ChemScanRDI provides better results than the standard plate count.
ChemScanRDI accurately and precisely detected different bacterial strains,
bacterial spores, yeast and fungi within a mixed culture; equivalent
or better results were obtained compared with those obtained by the
standard plate method. The ChemScanRDI is a more sensitive technology
for the
detection of biofilms compared with current methods. ChemScanRDI is
the only current technology with the sensitivity and near real-time
results
for supporting in-process monitoring.
Dr Johnson concluded that the ChemScanRDI would build quality into
pharmaceutical products during processing and therefore supports the
ideals of PAT and
parametric release. Technological progress
Stephen Denyer, University of Wales, Cardiff, reviewed progress in
RMMs, recognising the term “rapid” was a relative one. Professor
Denyer placed emphasis on the European perspective, performance characteristics
and future developments.
Microbiological tests could be either for detection (qualitative tests
for the presence or absence of micro-organisms, quantitative tests for
the enumeration of micro-organisms) or for identification (classically
biochemical and morphological characterisation, now incorporating compositional
analysis). The tests themselves could be classified as growth-based methods
(techniques offering early detection of growth, and media development
to improve detection), direct measurement by direct observation, or cell
component analysis (either phenotypic characteristics or genotypic characteristics).
Professor Denyer foresaw that the important growth-based technologies
would be those based on impedance or bioluminescence methods. Direct
measurements would be based on solid-phase cytometry and flow cytometry.
Phenotypic methods of cell component analysis would continue to be based
on fatty acid profiles and biochemical assays based on physiological
reactions. Genotypic methods would depend on nucleic acid amplification
techniques, ribosomal rDNA amplification and sequencing, and automated
genetic fingerprinting or ribotyping.
Future trends, said Professor Denyer, will involve immunoaffinity (magnetic)
capture, advances in laser scanning for both DNA fluorescent probes and
immunofluorescent probes, adenylate kinase use for ATP amplification,
and real-time detection of products of polymer chain reactions. A regulatory viewpoint
The Medicines and Healthcare products Regulatory Agency (MHRA) has
actively encouraged the pharmaceutical industry over the past 15 years
to investigate
and implement rapid microbiological methods, said Paul Hargreaves,
MHRA, London, for the reason that this improves patient safety. Industrial
microbiologists are enthusiastic about RMMs and many submit superb
validation protocols. The MHRA is more than willing to discuss RMMs,
review validation protocols and discuss possible uses ranging from
screening tests, bioburden and even sterility testing.
It is disappointing, therefore, that RMMs have not been introduced
more widely. Mr Hargreaves made a special offer to the audience; to
encourage
a wider uptake, MHRA assessors and inspectors are inviting an interest
group such as the Parenteral Society or the Parenteral Drug Association
to submit a dummy application for MHRA assessment and feedback.
The MHRA is keen to assist in lowering or removing any perceived regulatory
barriers. Influence can be used at the European level through the EMEA
quality working party and the ad hoc GMP inspectors group. If communication
is a barrier, then the decision makers in the company that the MHRA needs
to communicate with need to be identified to eliminate a 15-year impasse,
and the MHRA is willing to organise a meeting or conference specifically
for the decision makers. The MHRA has excellent communication with the
key people at the US Food and Drug Administration with regard to RMMs
and the MHRA and the FDA can work together prior to a submission to smooth
the way. There may well be some issues, but now is the ideal time with
the momentum generated by the PAT initiative to work together to introduce
RMMs to the advantage of the patient and to the industry.
There may be barriers with regard to the validation and acceptance of
RMMs. There is much less pressure to accept many of the new alternative
methods. There appears to be less academic interest and few published
papers that address pharmaceutical aspects. Extravagant and misleading
claims by equipment manufacturers do much harm and can set back the acceptance
of the technology by many years. It is important that the theoretical
basis for the test be fully documented. It is not acceptable to rely
upon the manufacturer’s claims or advertising and these are not
an adequate substitute for refereed papers in reputable journals. Articles
written by manufacturers in trade journals are also unlikely to be acceptable.
Transfer technology is another perceived barrier. It is not easy to transfer
technology from the food and medical microbiology sector to the pharmaceutical
industry. Whereas the food industry is looking for indicative numbers
of micro-organisms and medical microbiology deals with large numbers
of micro-organisms from swabs, the pharmaceutical industry requires new
and different protocols and the specific problems, including equipment
validation, validation of the technician and validation of the method
must be addressed.
RMMs may play a significant role in improving the quality of medicinal
products by enumerating and perhaps identifying micro-organisms that
would previously have gone undetected. The introduction of RMM techniques
for the counting and identification of micro-organisms in liquids and
on surfaces may lead to radical changes to pharmaceutical microbiology.
Control of biofilm in water systems may become the major challenge over
the next few years.
Development of RMMs should be encouraged, said Mr Hargreaves, but their
suitability will be subject to scientific assessment. RMMs will provide
the means of enhancing patient safety, particularly for immunocompromised
patients. The use of RMMs will require the employment of qualified microbiologists
who are able to understand the basis of the techniques used, he
concluded. Equivalence
A panel discussion involving all the speakers followed the main presentations.
A particular concern was the matter of demonstrating equivalence
of the newly developed methods with the existing methods. It was emphasised
that demonstration of equivalence meant demonstration that the new
method was at least as good as the existing method for the purpose
intended. It would be perverse to try to prove that the rapid method
was as bad as the existing method.
In fact it was noted that, because of the increased sensitivity of
the new methods, the FDA did not insist on demonstration of equivalence.
This debate served to emphasise that the new methods being developed
as rapid methods were, in fact, improving the overall analytical situation
and thereby improved the quality and safety of the products. |