Mirabilis: Towards the prediction of purge factors A tool for predicting the purging of (potentially) mutagenic impurities during synthesis 43rd ICGM, March 2016 New Orleans Chris Barber [email protected] Benefits of a purge argument under ICH M7 Risk of potential mutagenic impurity Ames Ames or 2 in silicoTest models -ve Treat as a nonmutagen Present a purge argument for absence… +ve Control & monitor in final API Risk mitigated A recap on the control options in M7 Option Details 1 • Test impurity in API and show below threshold level • Periodic testing may be possible if can show sufficient consistency otherwise routinely measure 2 • Test in precursor (or reagent..) to show below threshold level 3 • Test in precursor (or reagent..) with acceptance ABOVE threshold level when also supported by evidence that final impurity levels are below threshold following subsequent process steps 4 • Demonstrate understanding of process and consequent purge sufficiently to not need any analytical testing A cross-industry consortium… • 11 companies sponsoring development of s/ware and science • Product release scheduled for end of 2016 • 2016 plans • Agree standard approach to calculating purge factors • Identify gaps in knowledge • Prioritise work for collecting specific data • Provide data to support a prediction • Test / use the software prototypes • Engage with regulators Introducing Mirabilis • Software to support estimating & expert-review of purge values • Web-based to support collaborative (internal) use • Support a consistent industry-standardised approach • Provide supporting commentary and data for expert review • Generates reports suitable for regulatory submission A theoretical approach to estimating purge factors 2013, 17, 221 Physicochemical Parameters Reactivity Solubility Volatility Ionisability Physical Processes – chromatography Purge Factor Highly Reactive = 100 Moderately reactive = 10 Low Reactivity / un-reactive = 1 Freely Soluble = 10 Moderately soluble = 3 Sparingly Soluble = 1 Boiling point >200C below that of the reaction/ process solvent = 10 Boiling point +/− 100C that of the reaction/ process solvent = 3 Boiling point >200C above that of the reaction/ process solvent = 1 Ionisation potential of GI significantly different to that of the desired product Chromatography – GI elutes prior to desired product = 100 Chromatography – GI elutes after desired product = 10 Others evaluated on an individual basis Scope of science needed chromatography Scavenger resins Physical processes Recrystallisation Reactivity 1 Mirabilis Solubility Precipitation Liquid-liquid extractions Solid-liquid extractions Evaporation Reaction grid - origins • Internal tool from AZ to assign a reactivity purge factor • Summarised expert knowledge of impurity reactivity under common reaction conditions 8 Reaction grid - matching reaction + impurity class Impurity Class Reaction types 10 • Values agreed by expert elicitation • High level factors – 1, 10, 100 • Conservative by design Mirabilis – supporting expert assessment of purge 2015 2016 • • • Expert elicitation of purge factors Standardised ‘best practise’ Scientifically accepted approach • Data to support an expert decision Knowledge alert Machine-learnt support Supporting kinetic studies Proposed PMI / MI Purge Factor Decision Tree (Roland Brown, Vinny Antonucci, Mike Urquhart) Impurity requires management as PMI or MI Establish PMI / MI strategy based upon comparison of Predicted purge factor (Mirabilis) vs Required purge factor calculated from TTC or PDE requirements > 1000x ICH M7 Option 4 Data collection not required Include predicted purge factors in submission > 100x ICH M7 Option 4 > 10x Potential M7 Option 4 Collect experimental data on purge properties (solubility, reactivity, etc.) to support scientific rationale. Measure purge factors, including trace analyses as required, to support scientific rationale. Include predicted purge factors in submission for developmental API route(s). Additionally, include supporting experimental data on purge properties in submission for commercial API route. Include predicted and measured purge factors in submission. Typically, more detailed datasets are expected for commercial vs. developmental API routes ICH M7 Option 1,2,3 Analytical testing and/or specification(s) required at SMs, Intermediates, or API, including trace analyses (as required). If measured purge factor is insufficient, then ICH M7 Option 4 is not justified What supporting information is needed? • The amount of supporting information needed is dependent upon the size of the overall purge • Two key users • Submitting (process) chemist • Regulatory reviewer What supporting information is needed? • For the process chemist… • Why that purge value? • Mechanistic explanation, literature support, examples • Will it hold up in my specific case? • Are there exceptions? • What is the impact of my conditions? • Where is there uncertainty (risk)? • What information could I provide to reduce this? • Has the approach been validated; is it conservative? • How should I present this information? • What experimental details are needed? Knowledge Alert • Summary • Brief synopsis • Overall purge value • Range / confidence • Additional information to support / provide confidence • Mechanistic rationale & expert assessment • Impact of key parameters • • • • • • • Specific substrate Specific reagents Impact of solvent Time No. of equivalents Temperature Potential competing / alternative reactions Machine mined approach to reaction purge Apply filters: Reaction database 1) Transformation class 2) Functional group Dataset of similar reactions • Mining a library of ~1 million patent reactions • Still in research • Aim to present supporting examples where the impurity is • stable to these conditions • reactive to these conditions • Identify relevant examples to underpin an expert decision • Support expert commentary • Sensitivity of purge to changes Using kinetic studies to support a purge value 2015, 19, 1517 • Measure rates of loss of ‘impurity’ whilst changing temp • Can derive rate constant (k) and activation energy (Ea) Undertaking experiments to fill knowledge gaps 17 Objectively assessing the approach • Starting to undertake ‘benchmarking’ within the consortium • “How well do the purge values match experimental results?” • Identification of gaps (in process or knowledge) • A peer-reviewed publication to help adoption of the approach • Defining what detail is needed to support a submission • Produce some guidance as to what to include • cf Establishing best practise in the application of expert review of mutagenicity under ICH M7. Reg Tox and Pharm 2015, 73, 367 • …..not about software – but about the science! Software • • Impurities highlighted “Tramlines” track impurities through synthetic route Next steps • Mirabilis interim releases being evaluated by consortium • Product release scheduled for end 2016 • Collaborative publications • To ensure peer-reviewed and accepted approach • Initial scientific focus on reaction-based purge • Other mechanisms for purge under initial investigation • Solid/Liquid - liquid extraction, solubility, volatility… Questions • Acknowledgements • Lhasa consortia members • Dr Andy Teasdale (AZ) • Lhasa staff • • • • Liz Covey-Crump Martin Ott Susanne Stalford Sam Webb A theoretical approach to estimating purge factors Teasdale..Risk assessment of genotoxic impurities in new chemical entities: Strategies to demonstrate control. Organic Process Research and Development, 2013, 17(2), 221 ICH M7 guidelines allow for in silico purge arguments What supporting information is needed? • For the reviewer… • Why that purge value? • Can I be confident in the knowledge behind this? • Access to an explanation, literature support, examples • Will it hold up in this specific case? • Are there exceptions? • What is the impact of varying the conditions? • What is the risk in accepting this prediction? • Has the approach been validated; is it conservative? • Is there anything that could reduce this risk? • Has the approach been applied consistently? • Software should ‘standardise’ the application
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