3.2.P — Drug Product
Drug product quality information: composition, development, manufacture, control, stability
Requirements by Phase
Drug product quality information: composition, development, manufacture, control, stability
Requirements by Phase
IND Phase 1: required IND Phase 2: required IND Phase 3: required NDA: required
Content (NCE/Small Molecule)
- Complete drug product quality documentation covering description, development, manufacture, control of excipients, control of drug product, reference standards, container closure, and stability
Expected Deliverables
- Drug product quality dossier (Module 3.2.P)
ICH Guidelines: Q6A, Q6B, Q8
Regulatory Requirements (FDA IND PHASE 2 3 CMC)
- [All] Certain information traditionally submitted in information amendments, identified as corroborating information, can be submitted in an annual report.
- [Phase 2] Limited phase 2 corroborating information recommended in section III need not be submitted before initiation of phase 2 studies and can be generated during phase 2 drug development.
- [Phase 3] Phase 3 corroborating information recommended in section IV need not be submitted before the initiation of phase 3 studies and can be generated during phase 3 drug development.
- [All] Corroborating information and a summary of CMC safety information submitted during a subject-reporting period should be included in the annual report, eliminating the need for general CMC updates at the end of phase 1 or phase 2.
- [All] CMC safety information should be submitted to support the safe use of the drug.
- [Phase 2] The CMC safety information identified in section III (Phase 2 Studies) should be submitted before initiation of the phase 2 studies.
- [Phase 3] The CMC safety information identified in section IV (Phase 3 Studies) should be submitted before initiation of the phase 3 studies.
- [All] When new information becomes available that relates to the safe use of the drug or when there are changes in previously submitted CMC safety information, it should be submitted during IND clinical trials in an information amendment.
- [All] For changes with a significant potential to affect the safety of the product, an information amendment should be submitted describing the changes and containing relevant information at a level of detail sufficient for an adequate review and assessment.
- [Phase 2] Corroborating information specified in section III (Phase 2 Studies) that is generated during phase 1 need not be submitted until the first annual report after initiation of phase 2 studies.
- [Phase 2] Corroborating information specified in section III (Phase 2 Studies) that is generated during phase 2 studies should be submitted in the next annual report after the information becomes available.
- [Phase 3] Corroborating information specified in section IV (Phase 3 Studies) that is generated earlier during phase 1 and phase 2 need not be submitted until the first annual report after initiation of phase 3 studies.
- [Phase 3] Corroborating information specified in section IV (Phase 3 Studies) that is generated during phase 3 studies should be submitted in the next annual report after the information becomes available.
- [Phase 2] Updates on the brief description of the drug substance and a more detailed description of the configuration and chemical structure for complex organic compounds should be provided.
- [Phase 2] The addition, deletion, or change of any manufacturer of the drug substance from that specified during phase 1 should be reported.
Source: ICH Q8(R2); ICH Q6A; 21 CFR 312.23(a)(7)(ii)
References
Sections
Description of dosage form and quantitative composition including overages
Development of dosage form, formulation, manufacturing process, container closure, and microbiological attributes
Drug substance compatibility with excipients, excipient choice rationale
Formulation development, overages justification, physicochemical/biological properties
Manufacturing process development and optimization studies
Suitability of container closure system for its intended use
Microbiological attributes of the dosage form including preservative effectiveness
Compatibility with reconstitution diluents and dosing devices
Name, address, responsibility of each drug product manufacturer
Batch formula including all components and their amounts per batch
Flow diagram and narrative of drug product manufacturing process with critical steps
In-process controls for critical manufacturing steps
Process validation and/or evaluation for drug product manufacturing
Specifications for each excipient used in the drug product
Analytical procedures for testing excipients
Validation of analytical procedures used for excipient testing
Justification for excipient specifications not based on pharmacopeial standards
Information on excipients derived from human or animal sources (TSE risk assessment)
Full safety data package for novel excipients not previously used in approved products
Drug product release and shelf-life specifications
Analytical procedures for drug product testing
Validation of drug product analytical procedures
Batch analysis results for clinical and development batches
Identification and characterization of degradation products in the drug product
Scientific rationale for drug product specification and acceptance criteria
Reference standards or materials used in drug product testing
Description and suitability of container closure system for the drug product
Drug product stability summary and conclusions on storage conditions and shelf life
Post-approval stability protocol for drug product ongoing monitoring
Drug product stability data from long-term, accelerated, and stress conditions
Related Sections
Up toModule 3: QualityDrug substance quality information: characterization, manufacture, control, reference standards, stability
Quality appendices for biotech products: facilities, adventitious agents, novel excipients
Region-specific quality information (executed batch records, comparability protocols, methods validation)
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