WHO Expert Committee On Biological Standardization, 1011
WHO Expert Committee On Biological Standardization, 1011
WHO Expert Committee On Biological Standardization, 1011
1011
adoption of international recommendations for the production W H O Te c h n i c a l R e p o r t S e r i e s
and control of vaccines and other biological substances, and the
establishment of international biological reference materials. 1011
Following a brief introduction, the report summarizes a number
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W H O Te c h n i c a l R e p o r t S e r i e s
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This report contains the collective views of an international group of experts and
does not necessarily represent the decisions or the stated policy of the World Health Organization
WHO Expert Committee on Biological Standardization: sixty-eighth report
(WHO Technical Report Series, No. 1011)
ISBN 978-92-4-121020-1
ISSN 0512-3054
vi
WHO Expert Committee on Biological Standardization
17 to 20 October 2017
Committee members1
Professor K. Cichutek, Paul-Ehrlich-Institut, Langen, Germany (Chair)
Dr M. Darko,2 Food and Drugs Authority, Accra, Ghana
Dr J. Epstein, Center for Biologics Evaluation and Research, Food and Drug Administration,
Silver Spring, MD, United States of America (USA) (also Blood Regulators Network
(BRN) representative)
Dr S. Hindawi, Blood Transfusion Services, Jeddah, Saudi Arabia
Mrs T. Jivapaisarnpong, Lad Prao, Bangkok, Thailand (Rapporteur for the plenary sessions
and for the vaccines and biotherapeutics track)
Dr H. Klein, National Institutes of Health, Bethesda, MD, the USA (Vice-Chair)
Dr C. Morris, National Institute for Biological Standards and Control, Potters Bar, the United
Kingdom (Rapporteur for the blood products and in vitro diagnostics track)
Mr V.R. Reddy, South African National Blood Service, Weltevreden Park, South Africa
Dr P. Strengers, Sanquin, Amsterdam, Netherlands
Dr Y. Sohn, Seoul National University, Seoul, Republic of Korea
Dr D. Teo, Health Sciences Authority, Singapore
Dr J. Wang, National Institutes for Food and Drug Control, Beijing, China
Temporary Advisers
Dr E. Griffiths, Kingston-upon-Thames, the United Kingdom (Rapporteur for the plenary
sessions and for the vaccines and biotherapeutics track)
Dr M. Gruber,3 Center for Biologics Evaluation and Research, Food and Drug Administration,
Rockville, MD, the USA
Dr H. Hamel, Biologics and Genetic Therapies Directorate, Health Canada, Ottawa, Canada
1
The decisions of the Committee were taken in closed session with only members of the Committee
present. Each Committee member had completed a Declaration of Interests form prior to the meeting.
These were assessed by the WHO Secretariat and no declared interests were considered to be in conflict
with full meeting participation.
2
Unable to attend.
3
Participated via teleconference.
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WHO Expert Committee on Biological Standardization Sixty-eighth report
Dr E. Lacana,4 Center for Drug Evaluation and Research, Food and Drug Administration,
Bethesda, MD, the USA
Dr J. Reinhardt, Paul-Ehrlich-Institut, Langen, Germany (Rapporteur for the blood products
and in vitro diagnostics track)
Dr Y. Sun, Paul-Ehrlich-Institut, Langen, Germany
Dr M. Udell, Medicines and Healthcare Products Regulatory Agency, London, the United
Kingdom
Dr A.M.H.P. van den Besselaar,4 Leiden University Medical Centre, Leiden, Netherlands
Dr A.L. Waddell, Stanley, the United Kingdom (Freelance writer)
Participants
Dr F. Agbanyo, Biologics and Genetic Therapies Directorate, Health Canada, Ottawa,
Canada (also BRN representative)
Dr N. Almond, National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr P. Bowyer,5 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr J. Boyle,5 National Institute for Biological Standards and Control, Potters Bar, the United
Kingdom
Dr C. Burns, National Institute for Biological Standards and Control, Potters Bar, the United
Kingdom
Dr G. Cooper,5 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr B. Cowper,5 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
WHO Technical Report Series, No. 1011, 2018
4
Unable to attend.
5
Participated via teleconference.
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WHO Expert Committee on Biological Standardization
Dr S. Govind,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr E. Gray,6 National Institute for Biological Standards and Control, Potters Bar, the United
Kingdom
Dr I. Hamaguchi, National Institute of Infectious Diseases, Tokyo, Japan (also BRN
representative)
Dr C.C. Ilonze, National Agency for Food and Drug Administration and Control, Lagos,
Nigeria
Dr A. Kato, National Institute of Infectious Diseases, Tokyo, Japan
Dr D. Kaslow, Chair of the Product Development for Vaccines Advisory Committee,
Center for Vaccine Innovation and Access, Seattle, WA, the USA
Dr J. Kress,6 Paul-Ehrlich-Institut, Langen, Germany
Dr F-X. Lery, European Directorate for the Quality of Medicines & Healthcare, Strasbourg,
France
Dr K. Markey,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr C. Metcalfe,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr H. Meyer, Paul-Ehrlich-Institut, Langen, Germany
Dr P. Minor, Consultant, St Albans, the United Kingdom
Dr K. Nam, Ministry of Food and Drug Safety, Chungcheongbuk-do, Republic of Korea
Dr M. Ochiai, National Institute of Infectious Diseases, Tokyo, Japan
Dr H. Oh, Ministry of Food and Drug Safety, Chungcheongbuk-do, Republic of Korea
Dr D. Padley,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr M. Page,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr S. Prior,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr S. Rijpkema,6 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr S-r. Ryu, Ministry of Food and Drug Safety, Chungcheongbuk-do, Republic of Korea
6
Participated via teleconference.
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WHO Expert Committee on Biological Standardization Sixty-eighth report
Dr C. Schärer, Swiss Agency for Therapeutic Products, Bern, Switzerland (also BRN
representative)
Dr H. Scheiblauer, Paul-Ehrlich-Institut, Langen, Germany
Dr C. Schneider, National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr G. Smith, Therapeutic Goods Administration, Woden, ACT, Australia (also BRN
representative)
Dr J. Southern, Representative of South African National Regulatory Authority, Simon’s
Town, South Africa
Dr D. Stahl, Paul-Ehrlich-Institut, Langen, Germany (also BRN representative)
Dr P. Stickings, National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr L. Studholme,7 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr C. Thelwell,7 National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
Dr R. Thorpe, Consultant, Welwyn, the United Kingdom
Dr A. Vasheghani, Food and Drug Organization, Tehran, the Islamic Republic of Iran
Dr N. Verdun, Center for Biologics Evaluation and Research, Food and Drug Administration,
Rockville, MD, the USA (also BRN representative)
Dr D. Williams, University of Melbourne, Melbourne, Australia
Dr D. Wilkinson, National Institute for Biological Standards and Control, Potters Bar, the
United Kingdom
WHO Technical Report Series, No. 1011, 2018
Dr M. Xu, National Institutes for Food and Drug Control, Beijing, China
Dr S.H. Yoo, Ministry of Food and Drug Safety, Chungcheongbuk-do, Republic of Korea
Dr C. Zhang, National Institutes for Food and Drug Control, Beijing, China
7
Participated via teleconference.
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WHO Expert Committee on Biological Standardization
WHO Secretariat
Regional Office
AFRO – Dr B.D. Akanmori
Headquarters
Dr S. Hill, Director, EMP
Ms E. Cooke, Head, RHT/EMP
8
A maximum of two representatives of the DCVMN and two representatives of the IFPMA were present in
the meeting room during discussion of any one agenda item.
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WHO Expert Committee on Biological Standardization Sixty-eighth report
Dr I. Knezevic, TSN/EMP (Committee Secretary, a.i.; Lead for the vaccines and biotherapeutics
track)
Dr M. Nübling, TSN/EMP (Lead for the blood products and in vitro diagnostics track)
Ms S. Jenner, TSN/EMP
Dr M. Friede, IVB/IVR
Dr H-N Kang, TSN/EMP
Dr A. Khadem, RSS/EMP
Dr S. Kopp, TSN/EMP
Dr D. Lei, TSN/EMP
Dr R. Meurant, PQT/EMP
Dr D. Mubangizi, PQT/EMP
Dr U. Rosskopf, RSS/EMP
Dr I. Shin, TSN/EMP
Dr M. Ward, RSS/EMP
Dr T. Zhou, TSN/EMP
Dr I.A. Cree, IARC/WHO, Lyon
WHO Technical Report Series, No. 1011, 2018
xii
Abbreviations
Ad human adenovirus
Ag antigen
anti-CCP anti-cyclic citrullinated peptide
anti-dsDNA antibody to double-stranded DNA
APTT activated partial thromboplastin time
ASTM ASTM International
BDBV Bundibugyo ebolavirus
BRN WHO Blood Regulators Network
BSE bovine spongiform encephalopathy
CBER Center for Biologics Evaluation and Research
ChAd3 chimpanzee adenovirus type 3
CHO Chinese hamster ovary
CEG Core Expert Group
CHIKV chikungunya virus
CLSI Clinical and Laboratory Standards Institute
CMV cytomegalovirus
CRF circulating recombinant form
CTP cell therapy product
CV coefficient of variation
CVV candidate vaccine virus
DCVMN Developing Countries Vaccine Manufacturers Network
DNA deoxyribonucleic acid
EBOV Ebola virus
ECSPP WHO Expert Committee on Specifications for Pharmaceutical
Preparations
EDQM European Directorate for the Quality of Medicines & HealthCare
EIA enzyme immunoassay
ELISA enzyme-linked immunosorbent assay
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WHO Expert Committee on Biological Standardization Sixty-eighth report
xvi
1. Introduction
The WHO Expert Committee on Biological Standardization met in Geneva
from 17 to 20 October 2017. The meeting was opened on behalf of the Director-
General of WHO by Dr Suzanne Hill, Director of Essential Medicines and Health
Products (EMP) and currently Acting Assistant Director-General for the Health
Systems and Innovations Cluster. Dr Hill welcomed the Committee, other meeting
participants and observers, and briefly outlined several key changes in WHO staff
and structures that had occurred since the previous meeting of the Committee.
The election of the new Director-General, Dr Tedros Adhanom Ghebreyesus, in
May 2017 meant that this was a time of transition for the Organization.
Three new clusters had now been formed from the previous Health
Systems and Innovations Cluster, and senior management posts filled. One of
the new clusters – Access to Medicines, Vaccines and Pharmaceuticals – would
be led by a new Assistant Director-General, Dr Mariângela Batista Galvão Simão.
Dr Hill also announced that Dr David Wood, Coordinator, Technologies,
Standards and Norms – and Secretary to the Committee – had retired in April,
and that Dr Francois-Xavier Lery, previously of the European Directorate for the
Quality of Medicines & HealthCare, had been appointed as his successor.
Dr Hill highlighted the commitment of the Director-General to champion
universal health coverage, including through improved access to medicinal
products of assured quality, safety and efficacy. It was envisaged that this would
be achieved through a coherent country ownership approach backed up by
the strong normative efforts of WHO. As the longest-standing WHO Expert
Committee, the WHO Expert Committee on Biological Standardization has long
emphasized the importance of pursuing a coherent approach to improving access
to medicines and strengthening WHO’s normative work in this area. There would
now be an opportunity to review the ways in which the Committee functioned
and to decide how best to prioritize its substantial workload. On behalf of WHO,
Dr Hill expressed her thanks to the Committee, to WHO Collaborating Centres,
and to all the experts, institutions and professional societies working in this
field, whose efforts provided vital support to WHO programmes in global public
health. She concluded by reminding participants that Committee members acted
in their personal capacities as experts and not on behalf of their organizations
or countries.
Dr Ivana Knezevic, Acting Secretary to the Committee, outlined the
working arrangements of the meeting before moving on to the election of
the meeting officials. Professor Klaus Cichutek was elected as Chair and
Dr Elwyn Griffiths as Rapporteurs for the plenary sessions and for the track
considering vaccines and biotherapeutics. Mrs Teeranart Jivapaisarnpong was
also Rapporteur for the vaccines and biotherapeutic track. Dr Harvey Klein
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WHO Expert Committee on Biological Standardization Sixty-eighth report
was elected as Chair and Dr Clare Morris and Dr Jens Reinhardt as Rapporteurs
for the track considering blood products and in vitro diagnostics. Dr Klein was
also elected as Vice-Chair for the plenary sessions of the Committee.
Dr Knezevic then gave a brief overview of WHO Expert Committees
and of their important and greatly valued role in providing assistance to WHO
Member States. She noted that the meeting of the WHO Expert Committee on
Specifications for Pharmaceutical Preparations meant that two WHO Expert
Committees were meeting concurrently. Also meeting during the same week
were the WHO Strategic Advisory Group of Experts (SAGE) on Immunization
and the annual Consultation on International Nonproprietary Names (INN) for
Pharmaceutical Substances. Dr Knezevic introduced the members of the 2017
Expert Committee on Biological Standardization and presented the declarations
of interests made by Committee members, Temporary advisers and participants.
After evaluation, WHO had concluded that none of the declarations made
constituted a significant conflict of interest and that the individuals concerned
would be allowed to participate fully in the meeting.
Following participant introductions, the Committee adopted the
proposed agenda (WHO/BS/2017.2331).
WHO Technical Report Series, No. 1011, 2018
2
2. General
2.1 Current directions
2.1.1 Strategic directions in the regulation of medicines
and other health technologies
Ms Emer Cooke, newly appointed Head of Regulation of Medicines and other
Health Technologies (RHT), presented an overview of WHO strategic directions
in the regulation of medicines and other health technologies, with a particular
focus placed on biologicals. After outlining the overall vision of the new Director-
General, Ms Cooke provided more details of the new WHO Cluster on Access to
Medicines, Vaccines and Pharmaceuticals. The cluster would comprise EMP and
the two underlying groups, Innovation, Access and Use (IAU) led by Dr Sarah
Garner and RHT. RHT would consist of Technologies, Standards and Norms,
Regulatory System Strengthening, the WHO Prequalification Team and Safety
and Vigilance. Mention was made of the fact that the WHO Prequalification
Team now had responsibility for medical devices and vector-control products in
addition to vaccines, medicines and diagnostics. Ms Cooke then expressed her
thanks to Dr Knezevic, who had been the Acting Secretary to the Committee
since the retirement of Dr Wood in May 2017, for her invaluable support and
that of her team.
Ms Cooke noted that two strategic aspects of EMP activities which
particularly impacted upon biologicals were access to medicines and public
health emergencies. Since the previous meeting of the Committee, an Expert
Consultation on improving access to and use of similar biotherapeutic products
(SBPs) 1 had been held in Geneva, as had a WHO Informal Consultation on
options to improve regulatory preparedness to address public health emergencies.2
In addition, an EMP strategic framework entitled “Towards Access 2030” 3
had been published, with a supporting RHT strategy now under development.
Furthermore, a new Strategic Advisory Group of Experts on In Vitro Diagnostics
(SAGE IVD) had been established. The SAGE IVD would act as an advisory
body to WHO on matters of global policies and strategies related to IVDs.
1
Report on the Expert Consultation on improving access to and use of similar biotherapeutic products.
Geneva, 2–3 May 2017. Geneva: World Health Organization; 2017 (http://www.who.int/medicines/access/
biotherapeutics/FINAL_Report-improving-access-to-and-use-of-biotherapeutics_October2017.pdf,
accessed 2 April 2018).
2
WHO Informal Consultation on options to improve regulatory preparedness to address public health
emergencies. Geneva, 17–19 May 2018. Geneva: World Health Organization; 2017 (http://www.who.int/
medicines/news/2017/PHEmeeting-reportIK-EG16_Nov_2017.pdf, accessed 2 April 2018).
3
Towards Access 2030. WHO medicines and health products programme strategic framework 2016–
2030. Geneva: World Health Organization; 2017 (WHO/EMP/2017.01; http://www.who.int/medicines/
publications/Towards_Access_2030_Final.pdf?ua=1, accessed 2 April 2018).
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WHO Expert Committee on Biological Standardization Sixty-eighth report
the need to map out current emergency provisions in LMIC and to address
legal or regulatory deficiencies, to clarify and revise the current EUAL procedure
based on experience to date, and to consider a possible “pre-EUAL” submission
process for priority pathogens. Clarification was also needed of what happens
following a EUAL procedure regarding, for example, national licensing, product
procurement, importation and liability issues. It had been proposed that
WHO guidance be developed on procedures and pathways to enable the use of
unlicensed products during a public health emergency, including guidance on
the minimum competencies required by NRAs to deal with such situations. The
possibility of a diagnostics preparedness consortium was raised, as was the use
of “mock-up” exercises in expediting the review of submissions or clinical trials
in emergency contexts. A trial tabletop exercise was scheduled to take place at
the end of November 2017. The Committee was informed that WHO would now
4
General
reflect on all the recommendations made for moving this agenda forward, with
a view to developing an action plan based on priorities and available resources.
The Committee was then reminded of the two main strategic roles of
EMP – namely, to act as a facilitator, supporting innovation and promoting
access to health products, and as a guardian in efforts to strengthen regulatory
capacity and practices and thus ensure the quality, safety and efficacy of products
in order to secure health gains. An integrated approach across all RHT activities
would be needed to achieve these goals. This would include strengthening
the ability of NRAs to effectively regulate medicines, and promoting, where
appropriate, the concept of regulatory reliance. Ms Cooke emphasized that the
work of the Committee was a fundamental enabler of many of the normative
activities of WHO, and noted its strong links with other WHO activities and
entities such as the SAGE on Immunization. In addition, WHO initiatives in the
area of public health emergencies – including the WHO Blueprint for Research
and Development: Responding to Public Health Emergencies of International
Concern (R&D Blueprint) and collaboration with other international initiatives
such as the Coalition for Epidemic Preparedness Innovations – would continue
to depend upon sound regulatory science, standards and norms.
The Committee thanked Ms Cooke for sharing this helpful overview of
current WHO developments in the regulation of medicines and other health
technologies and raised a number of issues for clarification. In particular,
clarification was sought of the remit of the newly established SAGE IVD and
of how its work would complement the longstanding responsibilities of the
Committee in this area. Ms Cooke indicated that this was not yet clear but
agreed that it would be very important to avoid both excessive workload and
the overlapping of responsibilities. It was also noted that the Committee would
normally provide the SAGE on Immunization with a report of its work on
vaccine standardization and related issues. However, this year both groups were
meeting in parallel and so representatives of the Committee were only able to
participate in parts of the SAGE on Immunization meeting. A full report of the
work of the Committee in this regard would be presented at the next SAGE on
Immunization meeting. The Committee requested that consideration be given
by WHO to improving the coordination of meetings at WHO headquarters of
all the various advisory and other groups working in this area.
infections on blood supply; and (e) issues related to the First WHO International
Standard for anti-rubella immunoglobulin.
The ICDRA blood products workshop recommendations emphasized
the need for countries to implement blood regulations, to regulate reagents
and devices associated with the use of blood, to model new regulations on
already-existing regulations in other countries and to regulate snake antivenoms.
In support of this, WHO was urged to provide assistance in the assessment of
national blood regulation, provide training for inspectors and assessors with a
focus on regional networks, update the global database on snakes and antivenoms,
develop regional reference standards for venoms, and continue in its assessment
and listing of snake antivenoms.
The Committee was informed that snake-bites lead to more than
100 000 fatalities each year, with women and children in rural areas being the
8
General
most affected. However, at present, antivenoms are still widely unregulated and
often of unknown quality. WHO had therefore implemented its programme
of assessment and listing of snake antivenoms in response to the need for
antivenoms of assured quality. Manufacturers of antivenoms are invited to
submit a dossier for evaluation along with product samples for laboratory testing
of their efficacy and other characteristics. GMP inspections are also carried
out. Following a call to manufacturers of antivenoms specifically intended for
use in sub-Saharan Africa, seven dossiers had been submitted for evaluation
and five product samples for laboratory testing. Antivenoms meeting WHO
requirements and with a favourable risk–benefit ratio will be listed on the WHO
website for easy access by procurement agencies and other relevant parties. Dr
Nübling indicated that a WHO prequalification process for antivenoms may be
developed if the conducting of the risk–benefit assessments indicates that this
would generate significant public health benefits.
The Committee was informed that an invited assessment of the Zambia
Medicines Regulatory Agency (ZAMRA) by staff from the WHO Regional Office
for Africa and WHO headquarters, together with a member of the BRN, had
taken place in 2017. The assessment indicated that although legal preconditions
and medicines regulation is in place, blood regulation in Zambia is still at a very
early stage. The Zambia National Blood Transfusion Service (ZNBTS) was not
overseen by ZAMRA but instead was auto-regulated. It was considered that the
current medicines regulations should be used as a blueprint for blood regulation
in the country. Advancing blood regulation would require both training – which
could be delivered using ZNBTS expertise – and twinning with (or having greater
reliance on) mature NRAs in other countries.
Dr Nübling reported that a WHO Global Technical Expert Consultation
on estimating the impact of emerging infections on the blood supply: requirements
for risk estimation and decision-making support had been held in Geneva on
14–15 June 2017. Consultation participants had noted that regulatory decisions
on the protection of the blood supply are often taken on an ad hoc basis when
confronted with the emergence of a pathogen. Such decisions may include the
introduction of a new test for screening blood donors, deferral of certain donors
from blood donation or quarantining of blood components. In these situations,
promoting the public perception of “safe blood” or political expectations were
sometimes more dominant factors than scientific considerations. There was
thus a recognized need for consistency in estimating threats to the blood supply
and making subsequent regulatory decisions. It was proposed that a prototype
guidance tool could be developed covering different aspects (such as quantitative
risk estimates, potential interventions and the evaluation of risk outcomes
in terms of benefits and costs) in order to guide the potential scientific,
epidemiological and regulatory considerations involved. Such considerations
would include whether or not the pathogen is novel and previously unknown,
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WHO Expert Committee on Biological Standardization Sixty-eighth report
and the extent to which the precautionary principle may therefore prevail. In
cases where an infection is re-emerging there would be far fewer uncertainties in
relation to potential interventions and outcomes. Since considerable differences
exist between low-, middle- and high-income countries not only in the experience
of using decision tools but also in the considerations to be taken into account,
the pilot testing of such a tool should include users in a range of countries.
Dr Nübling then informed the Committee of the outcomes of a WHO
Consultation on the First WHO International Standard for anti-rubella
immunoglobulin held in Geneva in June 2017. The current international
standard was comprised of polyclonal antibodies and was used in standardizing
the different results of assays of different design and purpose. This raises issues
when working with the immunity threshold of 10 IU/ml and questions have been
raised as to the commutability of this International Standard. It was concluded
that the International Standard is well characterized and should continue to be
used but that the lack of commutability must be clearly communicated to users
in the instructions for use (IFU). However, uncertainty remained as to whether
the immunity threshold was still appropriate and whether this standard should
still be used in qualitative assays of high specificity. Further work would be
necessary to resolve the outstanding issues and, depending on the conclusions
reached, the revision of WHO guidelines and regulatory requirements may need
to be considered.
Dr Nübling concluded by outlining the documents and measurement
standards in the areas of blood products and in vitro diagnostics to be considered
for adoption and establishment respectively by the Committee this year. These
consisted of two WHO prequalification guidance documents, one on the
performance evaluation of HIV rapid diagnostic tests (RDTs) and another on
establishing the stability of in vitro diagnostic medical devices (see sections 3.3.2
and 3.3.3 respectively); three measurement standards for blood products and
related substances (see sections 6.1.1–6.1.3) and 10 measurement standards for
WHO Technical Report Series, No. 1011, 2018
2.2 Reports
2.2.1 Report from the WHO Blood Regulators Network
Dr Christian Schärer began by reminding the Committee that the objectives
of the BRN were to identify issues and share expertise and information,
to promote the science-based convergence of regulatory policy (including
through fostering the development of international consensus on regulatory
10
General
specific vaccine guidelines. It had been concluded that a case could be made
for simplifying guidelines on the quality, safety and efficacy of specific vaccine
types by focussing only on the major points to be considered for such vaccines.
A proposal was therefore made to change and simplify the present structure of
product-specific vaccine guidelines – a structure which could be considered
duplicative and which had now been in use for many years. It was proposed that
a pilot guidelines document be developed for group B meningococcal vaccines
focussing only on the key points to consider, and possibly taking the form of a
discussion paper.
Although the Committee was sympathetic to this suggestion, and
considered that drafting groups might indeed welcome a reduction in workload
when preparing such guidelines, little support was expressed for this proposal.
Although the idea might seem to have merit in principle, there were concerns
12
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that in practice such a document would not meet the needs of users of WHO
guidelines, who often required a comprehensive document – and one which
could potentially be adopted as national guidelines. In addition, WHO guidelines
were also used to inform decisions on the WHO prequalification of vaccines
and thus on United Nations procurement.
to establish the Third WHO International Standard for erythromycin due to low
stocks of the existing standard.
Dr Buchheit then discussed a number of recent activities of the EDQM
biological standardization programme – the goal of which is to establish
European Pharmacopoeia biological reference preparations and to standardize
methods. The programme of work is established by a Steering Committee and,
whenever possible, collaboration and common projects were undertaken with
WHO and non-European partners. Current EDQM projects of potential interest
to the Committee included the ongoing development of an ELISA to replace the
current in vivo potency test for human rabies vaccines.
Dr Buchheit reminded the Committee that the development of
alternatives to animal experiments remained a major EDQM commitment in
line with European Union directives. WHO was once again strongly urged to
consider the incorporation of the 3Rs principles (Replacement, Reduction,
Refinement) into its written standards and other guidance where appropriate.
Such a step would be key to the global acceptance of these principles. The
Committee was also reminded that one of the main outcomes of a 2015
International Alliance for Biological Standardization meeting on the 3Rs
concept was a formal request to WHO to initiate steps to delete the abnormal
toxicity test from all its written standards.
Dr Buchheit concluded by proposing that the Committee evaluate the
possibility of its more active involvement in the validation of alternative quality
control assays aligned with the 3Rs principles. In addition, there was need for the
Committee to reflect upon the consequences of replacing in vivo potency assays
with in vitro assays.
The Committee thanked Dr Buchheit and noted his report.
Center for Biologics Evaluation and Research (CBER), Silver Spring, MD, the USA
Dr Jay Epstein informed the Committee that CBER was currently involved in
several international projects evaluating new vaccine-related standards. These
included a study into the potential use of a pneumococcal reference serum as a
standard in the pneumococcal opsonophagocytosis assay (OPA), the international
collaborative study to establish the First WHO International Standard for Zika
virus antibodies (see section 7.1.10) and the international collaborative study
to establish the First WHO International Standard for antiserum to respiratory
syncytial virus (see section 8.1.5). CBER had also provided support for the
development of new vaccine technologies, including the development of a
sequence database to facilitate detection of novel adventitious viruses using next
generation sequencing (NGS). CBER had also participated in a series of projects
on the standardization of influenza vaccines.
In the area of blood products, CBER had distributed a number of both
European and WHO international standards. The limited supply and restricted
distribution of one such standard – the Second WHO International Standard
for thrombin – was highlighted and a recommendation made to develop a
replacement standard. CBER also recommended developing an international
standard for human activated factor X (FXa) to support the development of
genetically modified FXa therapies.
CBER was also actively involved in developing reference preparations for a
range of different IVDs. FDA support had also been provided in the development
of technical guidance documents on the WHO prequalification of IVDs, including
one on HIV rapid diagnostic tests (RDTs) scheduled for consideration by the
Committee this year (see section 3.3.2). In addition, funding provided through
WHO Technical Report Series, No. 1011, 2018
to delivery to the patient. Within this overall context, the ECSPP has to date
actively overseen the development and publication of 85 official WHO guidance
texts and guidelines on medicines, quality assurance and related regulatory
standards. A new CD‑ROM including all guidelines and the International
Pharmacopoeia had been produced. In 2017, seven new or revised annexes
were to be proposed for adoption by the ECSPP, which meets each year during
the same week as the Committee.
Dr Kopp outlined a number of cross-cutting issues across the two Expert
Committees, including: (a) good regulatory practices (GRP); (b) the definition of
a stringent regulatory authority (SRA); (c) the use of a collaborative procedure
for medical products; (d) aspects of GMP; (e) issues related to the transition from
microbiological to physicochemical assays in monographs on capreomycin API
and products; (f) the need for additional data for products already on the market;
and (g) comparison between microbiological and chemical methods of analysis.
Dr Kopp indicated that some of these issues could appear on the agenda of the
Expert Committee on Biological Standardization in future and that a working
group might be established to deal with some of them.
Dr Kopp then informed the Committee that the ECSPP also oversees
the revision of the International Pharmacopoeia and the establishment
of International Chemical Reference Substances (ICRS). In 2017, 17 new
specifications and general texts were adopted for inclusion in the International
Pharmacopoeia and four new ICRS established.
The Committee thanked Dr Kopp for the update on the activities of the
ECSPP. During subsequent discussion it was noted that several of the above
issues of common interest to the two Expert Committees will require proactive
coordination, and the example of the WHO Global Benchmarking Tool was
given as an issue that was to be discussed this year at both Expert Committees.
heard that there had been several revisions of the proposed tool, extensive global
discussion and a number of pilot studies, with work still ongoing. The integration
of the blood products assessment criteria into the WHO GBT had involved
support from the WHO BRN.
The Committee thanked Dr Khadem for his report and raised a number
of points. The value of a harmonized tool was acknowledged and it was suggested
that linking NRA assessment to the WHO prequalification scheme may provide
an additional incentive for countries to undertake an NRA assessment. The
Committee was informed that internal WHO discussions along these lines had
already been scheduled. It was further suggested that reliance between regulatory
agencies might become less of an issue once the results of assessment are widely
accepted. A number of other important points were then raised in relation to
the use of the unified tool. Topics discussed included the need for transparency
in the criteria used to define a stringent NRA, whether the definition of blood
included plasma and plasma-derived products, and the selecting of countries for
piloting of the tool. The need to ensure precision in the questions asked was also
highlighted, for example to ascertain whether all relevant guidance from WHO
and ICH was being implemented rather than simply being in place.
and regulations, NRAs and other interested parties. Dr Ward then outlined the
concept of GRP as:
Internationally recognised processes, systems, tools and methods for
improving the quality of regulations. GRP systematically implements
public consultation and stakeholder engagement as well as impact
analysis of government proposals, before they are implemented to
make sure they are fit for purpose and will deliver what they are set
out to achieve.4
4
See: http://www.oecd.org/gov/regulatory-policy/asean-oecd-good-regulatory-practice-
conference-2015.htm
18
General
The Committee was informed that a draft document had been developed
and subjected to public consultation. The document included sections on
background and scope, on the principles of GRP and on the implementation of
regulations. Three appendices cover the details of regulatory impact assessment,
legal instruments and international regulatory cooperation. Although the
draft document was well received, and considered to be helpful for regulatory
convergence, public consultation indicated a need for streamlining and other
refinements of the content. Further inputs from a consultation held in July 2017
included requests for the text to be made more understandable and usable by its
intended readers, and to become more guidance-like in nature, while ensuring
that key messages were both clear and relevant to LMIC. Other suggestions
included the addition of practical tools such as examples and checklists to assist
in the implementation of the guidance provided. Revision was now underway
and it was expected that a final draft would be available for presentation to the
ECSPP for endorsement in 2018. It had been suggested that the path forward
should also include exploration of a pilot phase that would serve to validate the
relevance and usability of the guideline in LMIC.
The Committee thanked Dr Ward for his report and raised a number
of points in relation to the language used in the document, its content and
the applicability of some of the specific guidance given, especially in LMIC.
A number of potential challenges in implementation were also raised, including
the need to avoid damaging existing national systems, and the need for high-
level advocacy and political engagement in this area.
updating of the WHO antivenoms website 5 and the revision and expansion of
antivenom manufacturer data, which now included package inserts and published
literature citations for each product. In addition, the names and photographs of
snake species are being updated along with information on their geographical
distribution. Links to clinical treatment information resources are also now being
incorporated into the WHO website.
A WHO assessment of antivenoms intended for use in sub-Saharan Africa
had also been initiated. A call for applications for the evaluation of products
suitable for use in this region resulted in the submission of nine applications.
Following an initial assessment and selection process, five products are now
undergoing laboratory evaluation, including physicochemical characterization,
specific venom immune-recognition and potency testing. Corresponding GMP
inspections of production facilities in Costa Rica, India, Mexico, South Africa
and the United Kingdom are also ongoing. Once these studies and inspections
are completed, WHO will be in a position to recommend suitable products to
procurement agencies.
Where GMP deficiencies have been found, manufacturers had
demonstrated a willingness to respond but resources are very limited and further
support from WHO and other stakeholders is needed. Dr Williams indicated that
a roadmap for addressing snake-bite envenoming issues is being developed and
will be supported by a WHO technical working group. A stakeholders meeting
is planned for 2018 prior to the publication of the roadmap but resources and
funding will be required if the plan is to be implemented. There is however
growing political will to address this issue and a draft World Health Assembly
resolution has been developed, led by Costa Rica and supported by 30 other
WHO Member States. It is expected that the resolution will go to the WHO
Executive Board in January 2018 and to the World Health Assembly in May 2018.
The Committee thanked Dr Williams for his report and discussed
some of the issues raised. In response to one query, Dr Williams pointed out
WHO Technical Report Series, No. 1011, 2018
that although there are around 260 medically relevant snake species there was
also some degree of commonality of toxins. The production of antisera against
the venoms of around 100 different snake species might allow for the treatment
of most snake-bites. It should also be possible to prepare polyvalent sera that
can neutralize several different snake venoms. However, the characterization of
antivenoms based on ED 50 was challenging. It was further pointed out that the
standardization of venom would be crucial, with the importance of reference
venoms having been identified at the previous ICDRA meeting and efforts
already under way in some countries to produce reference standards. Both
the improved characterization of venoms to help assure the quality of the raw
5
See: http://www.who.int/bloodproducts/snake_antivenoms/en/
20
General
material used to raise animal antisera and the development of in vitro assays
for potency testing to replace ED 50 testing would likely result in significant
improvements in future. One other issue of concern was that animal welfare
standards in some countries were not always sufficiently addressed which had
led to legitimate concerns by animal-rights campaigners and which potentially
jeopardized antivenom manufacture.
The Committee thanked Dr Kaslow for his helpful update and noted the
specific points raised for its consideration. In particular, the interest expressed
by PDVAC in the new projects outlined complemented that of the Committee.
An international standard for RSV antiserum along with proposed new projects
on international standards for candidate influenza vaccines based on conserved
antigens were scheduled for consideration by the Committee this year (see
sections 8.1.5 and 8.2.4/5). It was also pointed out that WHO guidance is already
available on the clinical evaluation of vaccines to be used in heterologous prime-
boost regimens.6 The issue of recent developments in nucleic acid based vaccines
was another topic of common interest to both PDVAC and the Committee, with
a WHO consultation on this subject planned for 2018.
6
Guidelines on clinical evaluation of vaccines: regulatory expectations. In: WHO Expert Committee on
Biological Standardization: sixty-seventh report. Geneva: World Health Organization; 2017: Annex 9
(WHO Technical Report Series, No. 1004; http://www.who.int/entity/biologicals/expert_committee/WHO_
TRS_1004_web_Annex_9.pdf?ua=1, accessed 6 April 2018).
7
Guidelines on evaluation of similar biotherapeutic products (SBPs). In: WHO Expert Committee on
Biological Standardization: sixtieth report. Geneva: World Health Organization; 2013: Annex 2 (WHO
Technical Report Series, No. 977; http://who.int/biologicals/publications/trs/areas/biological_therapeutics/
TRS_977_Annex_2.pdf, accessed 6 April 2018).
8
Guidelines on evaluation of monoclonal antibodies as similar biotherapeutic products (SBPs). In: WHO
Expert Committee on Biological Standardization: sixty-seventh report. Geneva: World Health Organization;
2017: Annex 2 (WHO Technical Report Series, No. 1004; http://who.int/biologicals/biotherapeutics/WHO_
TRS_1004_web_Annex_2.pdf?ua=1, accessed 6 April 2018).
22
General
Two pathways had been proposed for the pilot project – an abridged
assessment of SRA-approved innovator products or SBPs (which may lead to
waivers for requirements) and full assessment of SBPs already registered by non-
SRAs using the SRA-approved reference biotherapeutic product as a comparator
and marketed in the authorized country. Dr Mubangizi provided details of the
proposed process, which would involve the concept of reliance and the exchange
of relevant information between WHO and the SRA or applicant. One major issue
arising from the public consultation process was the need to better distinguish
between the two assessment pathways – that is, for applicants with products
approved by an SRA and those with products approved by other NRAs.
The Committee thanked Dr Mubangizi for his presentation and looked
forward to being updated on the outcome of this project.
9
Guidelines for independent lot release of vaccines by regulatory authorities. In: WHO Expert Committee
on Biological Standardization: sixty-first report. Geneva: World Health Organization; 2013: Annex 2 (WHO
Technical Report Series, No. 978; http://www.who.int/biologicals/TRS_978_Annex_2.pdf?ua=1, accessed
8 April 2018).
23
WHO Expert Committee on Biological Standardization Sixty-eighth report
prequalified vaccines. The Committee also noted that lot release certificates
needed to convey relevant information to the recipient on the vaccine lot
released which may not be covered in the general format presented. One point
to consider would be whether lot release was on the basis of independent testing
by the releasing NCL or on the basis of testing by the manufacturer followed by
review of the lot summary protocol by the releasing NRA. The latter procedure
is considered to be the minimum basis for vaccine lot release and this may be
an important consideration for some NRAs. There was also the question of the
impact of using a harmonized model lot release certificate on the product-specific
model lot release certificates usually provided in WHO Recommendations and
Guidelines for vaccines.
10
WHO Informal Consultation on options to improve regulatory preparedness to address public health
emergencies. Geneva, 17–19 May 2017. Meeting report. Geneva: World Health Organization; 2017
(http://www.who.int/medicines/news/2017/PHEmeeting-reportIK-EG16_Nov_2017.pdf, accessed 8 April
2018).
26
General
11
Recommendations for the preparation, characterization and establishment of international and other
biological reference standards (revised 2004). In: WHO Expert Committee on Biological Standardization:
fifty-fifth report. Geneva: World Health Organization; 2006: Annex 2 (WHO Technical Report Series, No. 932;
http://www.who.int/immunization_standards/vaccine_reference_preparations/TRS932Annex%202_
Inter%20_biol%20ef%20standards%20rev2004.pdf?ua=1, accessed 8 April 2018).
27
WHO Expert Committee on Biological Standardization Sixty-eighth report
more relevant examples. Currently the document makes reference only to the
development of reference standards for vaccine potency assessment, and no
reference to topics such as commutability assessment and calibration of secondary
standards. It was urged that any revision process take into consideration all the
different target audiences and seek their views and inputs.
After highly detailed and wide-ranging technical discussion, the
Committee concluded that further guidance was evidently needed on all
of the many issues raised. It would be very timely to now review in detail the
current WHO Recommendations and to develop up-to-date guidance on the
production and evaluation of international standards for IVDs, blood products,
biotherapeutics and vaccines. The Committee also considered it worthwhile to
explore the need for a companion document primarily directed towards the
users of international standards and other reference preparations which could
include guidance on the calibration of secondary standards, as well as broader
metrological considerations. The Committee requested that the broad range of
issues raised be discussed by WHOCCs and that specific proposals be presented
to the Committee for consideration at its next meeting.
WHO Technical Report Series, No. 1011, 2018
28
3. International Recommendations, Guidelines and
other matters related to the manufacture, quality
control and evaluation of biological substances
3.1 Biotherapeutics other than blood products
3.1.1 Guidelines on procedures and data requirements for
changes to approved biotherapeutic products
Changes are essential for the continual improvement of the manufacturing
process and for maintaining state-of-the-art controls on biotherapeutic products,
and such changes often need to be implemented after the product has been
approved (that is, when it has been licensed or when marketing authorization has
been received). Changes may be made for a variety of reasons including: (a) to
maintain routine production (for example, replenishment of reference standards
or change of raw materials); (b) to improve product quality, or the efficiency and
consistency of manufacture (for example, changes in the manufacturing process,
equipment or facility, or adding a new manufacturing site). Changes may also
need to be made to the product labelling information to reflect, for example, a new
indication, a change in the dosage regimen, information on co-administration
with other medicines or improvement in the management of risk by the addition
of a warning statement for a particular target population.
Biotherapeutic products are an increasingly important component of
global health care and several WHO guidelines on their regulatory evaluation are
available. During international consultations on the development of these WHO
guidelines, and during their implementation, it became clear that there was a
need to develop specific WHO guidelines on changes to approved biotherapeutic
products in order to help address the complexity and other challenges associated
with the global life-cycle management of such products. In May 2014, the 67th
World Health Assembly adopted two relevant resolutions: one on promoting
access to biotherapeutic products and ensuring their quality, safety and efficacy
(WHA67.21) and the other on regulatory systems strengthening (WHA.67.20).
In support of these resolutions, WHO had been requested to provide guidance,
particularly on how to deal with increasingly complex biotherapeutic products,
including SBPs. In addition, it had been recommended during the 16th ICDRA
that WHO assist Member States in ensuring regulatory oversight throughout the
life-cycle of biotherapeutic products.
A WHO Guidelines document had therefore been prepared to provide
guidance to NRAs and manufacturers on the regulation of changes to already
licensed biotherapeutic products, including SBPs, in order to assure their
continued quality, safety and efficacy, as well as continuity of supply and access.
These WHO Guidelines note that the implementation of new regulations
should not adversely affect product supply and accessibility. Therefore, NRAs are
29
WHO Expert Committee on Biological Standardization Sixty-eighth report
since then. At that time, the Committee had recognized that new cell-based
medicinal products – referred to as cell therapy products (CTPs) – have great
potential in the treatment of various diseases and would become important
future public health interventions. There was also a clear consensus within the
Committee that global harmonization in the cell therapy field is needed and that
WHO should become engaged in this area. The Committee had recommended
that WHO collaborate with a range of international groups active in cell therapy,
with the goal of providing a common guideline document.
It was felt that the document should focus on somatic and not stem cell
therapy and should include quality considerations. An agreed definition of cell
therapy would also be helpful, along with clarification of whether genetically
modified cells should be included or considered under gene therapy. At the 16th
ICDRA in 2014, it had been concluded that products containing genetically
30
International Recommendations, Guidelines and other matters
12
Instructions for compilation of a product dossier. Prequalification of In Vitro Diagnostics Programme.
Geneva: World Health Organization; 2014 (PQDx_018 v3, 27 August 2014; http://www.who.int/entity/
diagnostics_laboratory/evaluations/141015_pqdx_018_dossier_instructions_v4.pdf?ua=1, accessed 7
April 2018).
33
WHO Expert Committee on Biological Standardization Sixty-eighth report
months comprising case studies for IVD medical devices. Clarification was
sought and confirmation received that the additional annex would constitute a
“how to” guide complementing the principles provided in the main document.
The possibility of separately reviewing and adopting the additional annex at a
later date via a WebEx meeting of the WHO network of collaborating centres
for blood products and in vitro diagnostics was raised and it was agreed that this
suggestion would be presented to the Committee during its closed session.
The Committee considered the document WHO/BS/2017.2304 and
recommended that it be adopted and attached to its report (Annex 5).
Consideration of the additional annex with a view to its adoption would be
undertaken prior to the next meeting of the Committee in 2018.
However, IVD manufacturers, regulators and assay users should be made aware
(through the amending of the IFU) of its potential lack of commutability when
used as a calibrant. At the same time, diagnostic expert committees, vaccine
efficacy evaluators and regulators should be encouraged to reconsider the
appropriateness of quantitative anti-rubella determinations. Other discussion
points raised included the continuing relevance of using 10 IU/ml as an assumed
immunity threshold and the potential need for further studies to resolve this and
other issues. In general, the question remains of whether the current standard
should continue to be made available following changes to the IFU and if so what
mechanisms should be used to ensure that stakeholders are made aware of the
relevant issues and WHO recommendations.
The Committee agreed that the First WHO International Standard
for anti-rubella immunoglobulin should continue to be made available as a
well-characterized reference material. The Committee further agreed that
manufacturers, regulators and assay users should be made aware of its potential
lack of commutability and other limitations in the IFU, and that stakeholders in
the diagnostic field should be encouraged to reconsider both the appropriateness
of quantitative anti-rubella measurement for the determination of immune
status and the use of 10 IU/ml as a cut-off point for assessing immune protection.
To establish the protection status of individuals, anti-rubella determination
using high-specificity qualitative assays should be considered as an alternative
approach to antibody quantitation. In conclusion, the Committee proposed that
the outcomes of the consultation and its own subsequent conclusions should
be disseminated to technical and relevant clinical audiences, for example in a
scientific publication in a high-impact journal and through targeted distribution
of this Committee report.
3.4.1
The Committee was reminded that as part of ongoing WHO efforts to support
the development of Ebola vaccines, draft WHO Guidelines had been prepared
on the scientific and regulatory considerations relating to their quality, safety
and efficacy. The proposal to develop such Guidelines had been endorsed by
the Committee in 2014 and various drafts had now been prepared and reviewed
during a series of WHO informal consultations and public consultation, and by
the Committee itself. The Committee was reminded that work had started on
the Guidelines during the evolving Ebola epidemic. With the end of the large-
scale outbreak in Africa in 2016, Ebola disease had returned to its previous
sporadic pattern. This epidemiological situation made the evaluation of Ebola
vaccine efficacy and licensing more challenging. Interest also shifted away
from monovalent Ebola Zaire vaccines to multivalent preparations directed
36
International Recommendations, Guidelines and other matters
against more than one Ebola strain as well as the Marburg virus. Developing the
Guidelines had therefore presented many challenges, not least in keeping up to
date in a rapidly evolving situation.
At its meeting in 2016, the Committee had considered a version of the
WHO Guidelines for adoption but after extensive discussion agreed that the
guidance given on multivalent Ebola vaccines and on the clinical evaluation
of vaccine candidates using innovative clinical trial designs would benefit
from expansion. There was also a need to provide guidance on how to evaluate
and license Ebola vaccines subsequent to the potential licensure of one of the
advanced vectored vaccines. Further revision of the document was therefore
undertaken to address the comments received from the Committee and other
experts. These revisions were reviewed through a process of international public
consultation through the WHO website in 2017 and no further key issues were
identified. The majority of comments received concerned improvements in
clarity or the updating of cited publications. Respondents generally considered
the document to be very comprehensive and of value in the evaluation of
vaccines other than Ebola vaccines.
The Committee was reminded of the overall structure and content of the
Guidelines which include guidance on regulatory expectations in relation to the
quality, nonclinical and clinical aspects of vaccines submitted for full licensure.
Additional text considers those aspects of Ebola vaccine development which
might be accelerated during a public health emergency. Particular attention
is given to viral-vectored vaccines as these are currently the most advanced
vaccine candidates. The latest revision of the Guidelines (WHO/BS/2017.2327)
also takes into account the fact that Ebola vaccine development had been
discussed by the WHO SAGE on Immunization. This allowed for a number of
streamlining enhancements, notably the replacement of an earlier appendix on
Ebola vaccines currently in clinical trials with a reference to the report of the
SAGE Ebola Working Group which includes a detailed listing of such vaccines.
The Committee noted the comments and suggestions which had been
received by WHO and expressed its agreement on the way in which these had
been addressed. After making a number of further clarifications to the text, the
Committee recommended that the document WHO/BS/201.2327 be adopted
and attached to its report (Annex 2). The Committee also commended the WHO
Secretariat and the drafting group for all their efforts in developing the document
under such difficult and rapidly changing circumstances.
37
4. International reference materials – antibiotics
All reference materials established at the meeting are listed in Annex 6.
38
5. International reference materials –
biotherapeutics other than blood products
All reference materials established at the meeting are listed in Annex 6.
is a recognized global need for their standardization to ensure the quality, safety
and efficacy of such products. A proposal to develop an international standard
for rituximab had been endorsed by the Committee in 2014. The Committee
was reminded that WHO international standards for the biological activity of
therapeutic mAbs were intended for the evaluation of bioassay performance,
including the calibration and validation of potency assays and must be clearly
differentiated from the reference product mAb used to determine biosimilarity.
In the case of rituximab, the proposed WHO international standard would
be expected to facilitate assessment of the biological activities of products by
different stakeholders and thus enable the development of rituximab SBPs that
are consistent in terms of quality and efficacy. The proposed standard would
define bioactivity units for rituximab but would not define specific activity (IU/
mg) requirements.
40
International reference materials – biotherapeutics other than blood products
1998 and has been extremely successful in the treatment of various autoimmune
diseases or disorders associated with increased TNF-α and resultant excess
inflammation. Current therapeutic indications include rheumatoid arthritis (in
combination with methotrexate), Crohn’s disease, ulcerative colitis, ankylosing
spondylitis, psoriatic arthritis and psoriasis.
Following recent patent expiration in Europe and imminent expiry in
the USA, infliximab is an important target for SBP manufacturers with several
such products already approved in the European Union, the USA and several
other countries worldwide. The availability of a WHO international standard
for infliximab with a bioactivity expressed in IU would facilitate determination
of the biological activity of infliximab products and enable its harmonization
worldwide, thus ensuring patient access to products which are consistent in
quality and effectiveness.
The Committee was informed that a proposed WHO international
standard had now been developed in collaboration with the European
Pharmacopoeia following endorsement of the project by the Committee in 2012.
The Committee was further informed that despite its clinical and commercial
success, there are a number of safety and efficacy issues surrounding its use and
that monitoring to rationalize treatment strategies was now being considered.
Studies had shown that monitoring infliximab serum trough levels as a basis for
clinical decision-making had increased both therapeutic and cost effectiveness
in a number of indications. Commercially available ELISAs or newly developed
mass spectrometry methods were currently used to monitor serum drug trough
levels. For each of these methods the availability of an international standard
would serve to qualify the in-house reference standards used thus globally
harmonizing therapeutic infliximab monitoring.
A preparation of recombinant infliximab expressed in SP2/0 cells had
been donated by Celltrion. This was then filled at NIBSC following standardized
WHO Technical Report Series, No. 1011, 2018
43
6. International reference materials – blood
products and related substances
All reference materials established at the meeting are listed in Annex 6.
With the exception of one laboratory, similar potencies were obtained for
the coded duplicates provided. The overall geometric mean potency determined
by purified reagent assays was 10.48 IU/ampoule, with values of 11.67 and 12.10
IU/ampoule produced by assays based on APTT and NAPTT respectively. The
results obtained using TGT were similar to those obtained using purified reagent
assays. Given some degree of uncertainty concerning the influence of other
components involved in clot- and plasma-based assays on the measurement
of FIXa it was proposed by NIBSC that the value assigned to the replacement
standard should be based on the results of purified reagent assays only – as had
been the case with the current WHO international standard.
The Committee considered the report of the study (WHO/BS/2017.2325)
and recommended that the candidate material 14/316 be established as the
Second WHO International Standard for activated blood coagulation factor IX
(human) with an assigned potency of 10.5 IU/ampoule.
with reasonable precision, and that this data set could be used for assignment of
both FXII:C and FXII:Ag values to the candidate material.
Twenty laboratories took part in a collaborative study to assign FXII:C
and FXII:Ag values to the Second WHO International Standard for blood
coagulation factor XI (plasma, human) (NIBSC code 15/180). Value assignment
was against local normal pooled plasmas which were assumed to have 1 U/ml of
functional activity or antigen content. For FXII:C, 28 sets of results from one-
stage clotting assays using 13 different APTT reagents against local plasma pools
(total number of donors = 566) were returned. Intra-laboratory GCVs were in
the range 1–20%, with the majority being < 10%. The overall geometric mean
was 0.86 IU/ampoule, with an inter-laboratory GCV of 10%. For FXII:Ag, nine
sets of results obtained using three different commercial kits/paired antibody
sets and one in-house reagent were analysed against local plasma pools (total
number of donors = 216). Intra-laboratory GCVs were in the range 4–12%, with
the majority being < 10%. The overall geometric mean was 0.80 IU/ampoule,
with an inter-laboratory GCV of 11%.
The Committee considered the report of the study (WHO/BS/2017.2326)
and recommended that the First WHO International Standard for blood
coagulation factor XII (human, plasma) be established via assignment of an
FXII:C unitage of 0.86 IU/ampoule and an FXII:Ag unitage of 0.80 IU/ampoule to
the current Second WHO International Standard for blood coagulation factor XI
(plasma, human).
47
7. International reference materials – in vitro diagnostics
All reference materials established at the meeting are listed in Annex 6.
In all laboratories and for all test methods used, the candidate material
exhibited anti-dsDNA reactivity. In approximately half of the laboratories,
the material behaved in an apparently similar way to local standards and, by
inference, to the previous international standard. However in a similar number of
laboratories there was observable non-parallelism and no quantitative traceability
to the unitage of the previous international standard could be established.
Moreover, across the entire study, it was not possible to establish commutability,
as a consistent ranking order for the three patient samples was not obtained.
Given the apparent lack of qualitative comparability of this candidate
material with the previous international standard, it was considered unwise to
establish it as a replacement international standard with a defined unitage in IU
based on the previous international standard. It was proposed that candidate
material 15/174 be established de novo as the First WHO International Standard
48
International reference materials – in vitro diagnostics
for lupus anti-dsDNA serum with a nominal potency of 100 IU/ampoule, noting
the name change from the previous standard for anti-dsDNA serum. Moreover,
it was proposed that information be provided to users emphasizing that caution
would be needed in transferring the new unitage to existing assay methods.
The Committee questioned why plasma from only one patient had been
used for candidate material generation. Despite this also being the case for the
establishment of the previous international standard it was suggested that as
each patient has different autoantibodies, the use of a pooled sample would be
better for the preparation of an international standard for anti-dsDNA serum.
The Committee also concluded that it would not be appropriate to establish a
first WHO international standard with a similar reagent for the same analyte
based on a name change alone and that the previous international standard
could not be replaced by any preparation due to the inability to maintain
continuity of unitage. The Committee considered the report of the study
(WHO/BS/2017.2306) and recommended instead that the candidate material
15/174 be established as the First WHO Reference Reagent for lupus anti-
dsDNA serum with a nominal value of 100 U/ampoule. The Committee further
indicated that labelling should inform users of the lack of continuity to the First
WHO International Standard for anti-double-stranded DNA serum, and that
parallelism and commutability had not been established.
7.1.3 Fourth WHO International Standard for HIV‑1 RNA for NAT-based assays
The advent of NAT-based assays in the 1990s allowed for the direct detection of
HIV, thus providing a positive indication of infection weeks in advance of the
traditionally used serological tests. However, inter-assay sensitivity varied greatly
and the need for harmonization across this new technology was recognized,
including in the field of blood transfusion safety where concerns had been raised
regarding the risk of transfusion transmitted infections occurring through
false-negative screening results.
In 2015, the Committee had been informed that stocks of the current
international standard were diminishing and the proposal to develop a
replacement standard was endorsed. A candidate material (NIBSC code 16/194)
was therefore developed using an HIV-1 primary isolate (subtype B) which
derived from the same viral stocks used for the production of the two most
50
International reference materials – in vitro diagnostics
Kingdom and the USA, along with a negative human plasma sample, for inclusion
in the panel. A total of 17 laboratories in four countries (predominantly in the
United Kingdom and the USA) returned 26 data sets from three categories of
assay – neutralization of live Ebola virus, neutralization of Ebola pseudotypes and
enzyme immunoassays (EIAs). It was highlighted that a number of laboratories
using neutralization methods reported the negative plasma sample as positive,
particularly laboratories using a lentivirus-vector system. In addition, as potency
values derived for convalescent plasma samples from Norway, Italy and the
United Kingdom were near the detection limit for some assays, some values
were reported as negative. EIA data were analyzed separately and presented as
relative potency expressed against the candidate international standard material
(NIBSC code 15/262) and the current reference reagent (NIBSC code 15/220).
GCVs were lower in all samples when expressed against the candidate material
and were in the range 41–92%. The stability of the candidate material 15/262
was demonstrated to be suitable for its use as an international standard and
for its shipment at ambient temperatures. Due to the paucity of materials no
stability data could be generated for the proposed reference panel members
(NIBSC code 16/344).
During discussion, the Committee expressed concern that the stability
of the proposed reference panel members had not been assessed, and suggested
that their real-time stability should be assessed annually to ensure fitness for
purpose. Concern was also expressed regarding a specific proposal made to
assign an IU value to a single panel member as an international standard would
also be available, and as stability data were lacking.
The Committee considered the report of the study (WHO/BS/2017.2316)
and recommended that the candidate material 15/262 (a freeze-dried pool
of convalescent plasma from Sierra Leone) be established as the First WHO
International Standard for Ebola virus antibodies (plasma, human) with an
assigned potency of 1.5 IU/ml. The Committee further recommended that the
WHO Technical Report Series, No. 1011, 2018
candidate material 16/344) be established as the First WHO Reference Panel for
Ebola virus antibodies (plasma, human) without assigned units. The Committee
highlighted that the labelling of the reference panel should clearly indicate the
potential for a false-positive result for the negative panel member in some assay
types. The Committee also agreed that the current First WHO Reference Reagent
for Ebola virus antibodies should remain available for use with its originally
assigned potency of 1 U/ml.
WHO Reference Panel for genomic KRAS codons 12 and 13 mutations. The
value details of each panel member, relating to genotype, consensus mutation
percentage, consensus mutant KRAS copy number and consensus total KRAS
copy number were to be provided in the IFU.
a relative potency assessment. This effect was also mirrored in the HHV-6A
candidate material. Evaluation of the stability of candidate material 15/266 up to
a 6-month time point indicated no loss in potency. Stability data indicated that
this material was stable at −20 °C and at higher ambient temperatures that reflect
global shipment. Although study data showed that both candidate materials
performed equally well, HHV-6B has the greater clinical diagnostic significance.
It was therefore proposed that the candidate material 15/266 be established as the
international standard with a value assignment of 7.75 log 10 IU/ml. It was pointed
out that this value had been derived only from the quantitative estimates.
The Committee considered the report of the study (WHO/BS/2017.2321)
and recommended that the candidate material 15/266 be established as the First
WHO International Standard for human herpes virus 6B DNA for NAT-based
assays with an assigned potency of 7.75 log 10 IU/ml.
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International reference materials – in vitro diagnostics
First WHO International Standard for chikungunya virus RNA for NAT-based
assays with an assigned unitage of 2.5 x 10 6 IU/ml. It was noted that although
shipping on dry ice was proposed, the data suggested that shipping at ambient
temperature might be acceptable. It was suggested that the stability of the
material at ambient temperature should be further monitored in the follow-up
stability studies.
laboratories could receive and ensuring that the material was only used in the
calibration of kits, assays or secondary reference materials which would be made
available to others. It was suggested that such an approach would also promote
alignment to the primary standard.
The Committee endorsed the proposal (WHO/BS/2017.2320) to develop
a First WHO Reference Panel for cancer mutation detection.
least 1.3 million adults in the USA and approximately 1–2% of adults worldwide.
RF binds to IgG Fc resulting in immune-complex formation, inflammation and
joint damage and is a diagnostic marker of rheumatoid arthritis.
The current First WHO International Reference Preparation for
rheumatoid arthritis serum (lyophilized) has been distributed worldwide and
is used to calibrate assays and diagnostic test kits which measure RF levels in
patient serum. It is used by clinical laboratories, test kit manufacturers and
research institutes to calibrate their working standards. Stocks of this material
are now running low and a proposal was made to develop a replacement
standard to ensure the continuity of test result comparability across laboratories.
The replacement preparation will be calibrated against the current reference
preparation by end users in a collaborative study using methods which are not
RF-isotype specific. In addition, nominal values for specific RF isotypes (IgM,
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International reference materials – in vitro diagnostics
IgA and IgG) may be assigned based on the results obtained using isotype-
specific detection methods. It was pointed out that different antibody subclasses
have different prevalences in different geographical areas of the world.
The Committee endorsed the proposal (WHO/BS/2017.2320) to develop
a Second WHO International Standard for rheumatoid factor.
with different protozoan species present in the eastern and western hemispheres.
It is estimated that there are over 1 million new cases each year with varying
levels of clinical manifestation. Early detection and diagnosis improves treatment
efficacy and it was proposed that the development of both an international
standard and a species-specific reference panel would facilitate this.
It is intended that preparations will be formulated from cultured pathogens
and a range of species types assessed in an international collaborative study. The
candidate material demonstrating the largest degree of assay harmonization
would be used as the proposed WHO international standard, while the other
species types would be used in a WHO reference panel. Depending on the
availability of source materials, it is anticipated that the study report will be
presented to the Committee in either 2019 or 2020. During discussion the issue
of using a common matrix for testing was discussed. It was clarified that as
laboratories often use tissue preparations instead of whole blood the suitability of
the reference materials should be evaluated in both matrix types.
The Committee endorsed the proposal (WHO/BS/2017.2320) to develop
a First WHO International Standard for cutaneous leishmaniasis and a First
WHO Reference Panel for cutaneous leishmaniasis.
characteristic of the clinical stage and the inability of diagnostic tests to detect
the hypnozoite stage of the life-cycle. The availability of standards that would
allow for the development of assays with improved sensitivity to P. vivax LDH
and the inclusion of serological markers for hypnozoites would significantly
improve the diagnostic field.
A proposal was made to develop a First WHO International Standard
for Plasmodium vivax antigens and a First WHO Reference Reagent for anti-
malaria (Plasmodium vivax) serum for evaluation in two separate collaborative
studies. Each of the projects would be undertaken in conjunction with the
Foundation for Innovative New Diagnostics (FIND). It was pointed out that
obtaining P. vivax other than from clinical isolates was problematic and such
isolates may be difficult to source in the quantities required. In addition, the
standards developed would need to appropriately address the need for assay
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International reference materials – in vitro diagnostics
RNA assays. The study had highlighted wide variability in reporting based on
different MERS-CoV assays. In addition, there was a high possibility of under-
reporting of MERS incidence owing to the patient sampling sites utilized.
In some infected individuals MERS-CoV was not always detected in upper
respiratory tract samples. Furthermore, upper and lower respiratory tract swabs,
potentially containing only low concentrations of MERS-CoV RNA, are the most
commonly used diagnostic samples.
A proposal was made to develop a first WHO international standard
for MERS-CoV RNA. Following the earlier identification of a potential source
of suitable stock material the intention was to provide this to NIBSC as a heat-
inactivated high-titre tissue culture that could further be diluted into a suitable
matrix. This material would then be evaluated in an international collaborative
study. Although sourcing suitable clinical material for the study may be
problematic, the group responsible for conducting the external quality assessment
study outlined above had indicated that they may be able to assist with this. It is
anticipated that the results of the collaborative study would be presented to the
Committee in 2019.
During discussion it was noted that MERS-CoV has a rapidly changing
genome and attention would need to be given to ensuring the relevance of the
chosen sample to circulating strains. The sequence of the candidate material
would have to be determined and a broad range of variants included in the study
to better understand the efficiency of variant detection.
The Committee endorsed the proposal (WHO/BS/2017.2320) to develop
a First WHO International Standard for MERS-CoV RNA for NAT-based assays.
reference materials for use in NAT-based assays. In addition to its use in the safety
testing of blood donations, and in testing for HCV in cells, tissues and organs,
NAT-based assays are also widely used in the management of HCV infection,
particularly in the diagnosis of disease and the initiation and monitoring of
antiviral therapies.
Despite efforts to ensure its exclusive use in the calibration of secondary
reference materials, demand for this international standard remains high. As
HCV cannot be propagated in tissue culture, standard development relies upon
sourcing HCV-positive plasma of suitable volume and titre. Historically, this has
proved problematic and has led to the production of small batches (< 2000 vials).
The proposal to replace the current international standard was being brought to
the Committee with sufficient lead time to allow for an attempt to be made to
source higher volumes of starting material. At the current rate of dispatch, there
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67
8. International reference materials –
vaccines and related substances
All reference materials established at the meeting are listed in Annex 6.
now low, with the development of a replacement standard having been endorsed
by the Committee in 2014.
The Committee was informed that a frozen preparation of PTx
manufactured by the Serum Institute of India had been donated to NIBSC where it
had been formulated and freeze-dried in sealed glass ampoules. An international
collaborative study had then been conducted to determine the suitability of the
candidate material (NIBSC code 15/126) to replace the current international
standard. A total of 14 laboratories from 12 countries took part in the study
with 11 performing HIST, 14 performing CHO cell clustering assay and three
performing biochemical assays to measure the enzymatic and carbohydrate-
binding activities of the toxin.
Study data confirmed that the candidate material 15/126 exhibited
biological activity both in HIST and CHO cell assays. However, unlike the current
international standard, the levels of activity in HIST and CHO cell assays did not
accord and the use of an individual unitage for each assay type was proposed.
The candidate material also exhibited activity in the biochemical assays used.
Accelerated degradation studies indicated that the material would be stable at
recommended storage conditions with further stability studies showing that the
material is less stable once reconstituted – a characteristic of other PTx materials.
The Committee considered the report of the study (WHO/BS/2017.2315)
and after discussion recommended that the candidate material 15/126 be
established as the Second WHO International Standard for pertussis toxin with
an assigned unitage of 1881 IU/ampoule for HIST and 680 IU/ampoule for the
CHO cell clustering assay.
the methods used are currently not well standardized between individual
laboratories and different reference materials are in use. The intended use of
WHO international standards for Vi PS was to provide globally standardized
Vi PS quantification with the aim of harmonizing measurement of the Vi PS
content of typhoid vaccines.
The standards would be used to facilitate calibration of the various assays
and in-house reference materials, and were likely to be in considerable demand,
particularly by manufacturers and NCLs in low- and middle-income countries.
The Committee was reminded that at its meeting in 2015 it endorsed a project
to develop WHO international standards for Salmonella Typhi Vi PS and for
C. freundii Vi PS, since both have been used to produce conjugate vaccines.
Source materials had been donated by the Novartis Vaccines Institute
for Global Health (now the GSK Vaccines Institute for Global Health) and
by GlaxoSmithKline Biologicals for the development of C. freundii and
Salmonella Typhi Vi PS international standards respectively. These materials
had been filled into ampoules at NIBSC and assigned the NIBSC codes 12/244
(C. freundii Vi PS) and 16/126 (Salmonella Typhi Vi PS). An international
collaborative study had then been conducted involving 20 laboratories from
12 countries. During the study, two separate evaluations were made – one to
assign unitage using qNMR to quantitate Vi PS/ampoule using the N-acetyl and
O-acetyl resonances and the second to assess the suitability of the candidate
materials in determining the Vi PS and O-acetyl content of vaccine samples using
commonly used physicochemical assays and immunoassays and in comparison
with in‑house standards. Stability studies performed over 6 months indicated
that both candidate materials were stable at temperatures used for storage
(−20 °C) and during laboratory manipulation (4 °C). Accelerated degradation
studies showed no observable size reduction for either material following storage
at up to 56 °C for 6 months. The amount of polysaccharide per ampoule remained
constant under all conditions. Further real-time and accelerated stability studies
were ongoing.
The Committee considered the report of the study (WHO/BS/
2017.2310) and after further discussion and clarification of the need for the
two international standards recommended that: (a) the candidate material
12/244 be established as the First WHO International Standard for Citrobacter
freundii Vi polysaccharide with a content of 1.94 ± 0.12 mg/ampoule; and
(b) the candidate material 16/126 be established as the First WHO International
Standard for the Salmonella Typhi Vi polysaccharide with a content of 2.03 ±
0.10 mg/ampoule. The Committee further noted that the intended use of
both WHO international standards was for the quantification of the Vi PS
component of vaccines containing Vi PS using the HPAEC-PAD, ELISA, rate
nephelometry or rocket immuno-electrophoresis assays, with the observation
that the latter may not be suitable for all bulk Vi PS conjugates.
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valid estimates, the NIBSC ELISA (using biotinylated Vi) showed no concordance
with the VaccZyme ELISA, suggesting that the modification of Vi makes these
types of ELISAs unsuitable as an alternative to the VaccZyme ELISA. Study
data indicated that the candidate material 16/138 would be suitable for use as a
reference standard for anti-Vi IgG serum (human) in the VaccZyme ELISA and
in in-house ELISAs where the commutability of 16/138 with the coded samples
and Vi-IgG R1, 2011 was evident. Stability evaluation of candidate material 16/138
indicated adequate stability when stored at −20 °C.
The Committee considered the report of the study (WHO/BS/2017.2307)
and, following considerable discussion and clarification of a number of points,
recommended that the candidate material 16/138 be established as the First
WHO International Standard for anti-typhoid capsular Vi polysaccharide IgG
(human) with an assigned unitage of 100 IU/ampoule. Relative unitages of 54 IU/
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International reference materials – vaccines and related substances
ampoule and 163 IU/vial were also assigned to candidate material 10/126 and
Vi‑IgG R1, 2011 respectively. The Committee agreed that a follow-up collaborative
study might be helpful in clarifying whether in-house ELISAs based on
poly‑L‑Lysine and native Vi could be suitable alternatives to the commercial
VaccZyme ELISA.
sample behaved differently from the human serum samples and that a more
suitable standard should be considered for these sample types. This would not
be an issue for the establishment of a WHO international standard as its main
role would be to look at neutralizing antibody activity in human serum mostly
produced during RSV vaccine clinical trials.
Stability data for 16/284 indicated a low predicted loss in activity per
year (< 0.01%) when stored at −20 °C, suggesting that it is sufficiently stable
to serve as a WHO international standard. A long-term stability-monitoring
programme will be needed to show that candidate material 16/284 remains
stable over its lifetime. Stability data for 16/322 were not currently available
but it too will be monitored for stability over its lifetime. Furthermore,
stability analysis indicated that the candidate materials were also stable after
reconstitution. Both candidate materials showed loss of activity at 37 °C after
2 weeks, with 16/322 showing a greater loss than 16/284.
The Committee considered the report of the study (WHO/BS/2017.2318)
and recommended that the candidate material 16/284 be established as the
First WHO International Standard for antiserum to respiratory syncytial virus
with an assigned unitage of 1000 IU/vial. The Committee also assigned a unitage
of 960 IU/vial to candidate material 16/322 as a potential future replacement
standard.
children and infants are particularly vulnerable. Oral cholera vaccine (OCV),
inactivated, is the most cost-effective measure to contain and prevent the disease
in such settings. Three such vaccines have now been prequalified by WHO
and are part of a WHO-maintained stockpile. To be effective, cholera vaccines
require appropriate regulation at the national level to ensure their efficacy. As
standardization is a prerequisite for achieving appropriate quality control of
these vaccines the availability of WHO standards for the lipopolysaccharides
(LPS) of O1 Inaba, O1 Ogawa and O139 V. cholera would be expected to support
the assay development needed for the technology transfer and quality control
of inactivated OCV.
Purified LPS O1 Inaba, O1 Ogawa and O139 will be obtained from the
International Vaccine Institute, Republic of Korea, and the material filled and
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International reference materials – vaccines and related substances
The Committee was informed that the proposed project would therefore
be conducted in two phases and would take more time than a more typical
standardization project. In the first phase of the project, candidate materials
will be sent to a small number of laboratories and tested for HA stem-binding
antibodies using their in-house assays. The materials will also be evaluated in
terms of their ability to harmonize assay results. Based on the outcome of this
first study, a second larger study would then be undertaken which would include
the best performing standard types identified in the first study, as well as samples
from human clinical trials.
The Committee considered this to be an exciting and forward-looking
project and expressed its support in principle. However, it also noted the
exploratory nature of the first phase of the project and therefore endorsed the
first exploratory phase of the proposal (WHO/BS/2017.2319) to develop a First
WHO International Standard for antibody to the influenza virus haemagglutinin
stem domain. The Committee asked that NIBSC report back at its next meeting
on the progress made, as well as on the state of the influenza vaccine field, to
allow for further review and consideration of the proposal by the Committee.
Animal tests are also subject to variability and the ferret safety test is no
exception. Having standards that allow for the bench-marking of the test will lead
to better understanding of test results and greater confidence in them. Moreover,
this proposal is in line with moves towards reducing the use of animals in the
research and development of biological medicines. Instead of comparing every
new CVV with its respective wild-type parental virus, the occasional testing of
the standard viruses would be conducted, thus reducing the overall number of
ferrets required. The use of standard viruses in this way – in combination with
defined cut-off values/ranges – will not only reduce the number of animals used
but will also provide a means of assessing CVVs derived from parental wild-
type viruses which are non-pathogenic in ferrets, which cannot currently be
demonstrated to be attenuated as per the existing WHO guidance.
Following discussion and clarification of how the proposed standards
would be used the Committee endorsed the proposal (WHO/BS2017.2319) to
develop the First WHO international standards for influenza virus pathogenicity
for safety testing. However, in view of ongoing discussions on the revision of the
existing WHO biosafety risk assessment and guidelines for the production and
quality control of human influenza pandemic vaccines, the Committee requested
that it be updated on the progress made in this project and on all other relevant
developments at its next meeting.
stocks of the current international standard are nearing depletion and are now
under restricted sales. A replacement standard was now urgently needed as
many national regulatory requirements for rabies IgG potency assays state that a
reference preparation calibrated in IU must be used.
The development of a new international standard would require the
donation of human immunoglobulin preparations from manufacturers. As the
ability of manufacturers to donate such preparations is currently uncertain there
is concern that the current international standard may become depleted before its
replacement is established. The calibration of a candidate replacement standard
would require a collaborative study in the usual way. In this case, the aim of the
collaborative study would be to calibrate the candidate material in IUs against
the current international standard in assays such as the rapid fluorescent focus
inhibition test, the mouse neutralization test and the plaque reduction assay.
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79
Annex 1
WHO Recommendations, Guidelines and other documents
related to the manufacture, quality control and evaluation
of biological substances used in medicine
WHO Recommendations, Guidelines and other documents are intended to
provide guidance to those responsible for the production of biological substances
as well as to others who may have to decide upon appropriate methods of
assay and control to ensure that products are safe, reliable and potent. WHO
Recommendations (previously called Requirements) and Guidelines are scientific
and advisory in nature but may be adopted by an NRA as national requirements
or used as the basis of such requirements.
Recommendations concerned with biological substances used in
medicine are formulated by international groups of experts and are published
in the WHO Technical Report Series 1 as listed below. A historical list of
Requirements and other sets of Recommendations is available on request from
the World Health Organization, 20 avenue Appia, 1211 Geneva 27, Switzerland.
Reports of the WHO Expert Committee on Biological Standardization
published in the WHO Technical Report Series can be purchased from:
WHO Press
World Health Organization
20 avenue Appia
1211 Geneva 27
Switzerland
Telephone: + 41 22 791 3246
Fax: +41 22 791 4857
Email: [email protected]
Website: www.who.int/bookorders
Individual Recommendations and Guidelines may be obtained free of
charge as offprints by writing to:
Technologies Standards and Norms
Department of Essential Medicines and Health Products
World Health Organization
20 avenue Appia
1211 Geneva 27
Switzerland
1
Abbreviated in the following pages to “TRS”.
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WHO Expert Committee on Biological Standardization Sixty-eighth report
Pharmaceutical products, storage and transport Adopted 2010, TRS 961 (2011)
of time- and temperature-sensitive
Pneumococcal conjugate vaccines Revised 2009, TRS 977 (2013)
Poliomyelitis vaccines (inactivated) Revised 2014, TRS 993 (2015)
Poliomyelitis vaccines (inactivated): guidelines Adopted 2003, TRS 926 (2004)
for the safe production and quality control of
inactivated poliomyelitis vaccine manufactured
from wild polioviruses
Poliomyelitis vaccines (oral) Revised 2012, TRS 980 (2014)
Quality assurance for biological products, Adopted 1991, TRS 822 (1992)
guidelines for national authorities
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Annex 1
2
Available online at: http://www.who.int/biologicals/publications/en/whotse2003.pdf
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Annex 2
Guidelines on the quality, safety and efficacy of Ebola
vaccines
Introduction 91
Purpose and scope 92
Terminology 94
General considerations 97
Part A. Guidelines on the development, manufacture and control of
Ebola vaccines 102
A.1 General manufacturing guidelines 103
A.2 Control of source materials 105
A.3 Control of Ebola vaccine production 112
A.4 Filling and containers 122
A.5 Control tests on final lot 123
A.6 Records 125
A.7 Retained samples 125
A.8 Labelling 125
A.9 Distribution and transport 126
A.10 Stability testing, storage and expiry date 126
Part B. Nonclinical evaluation of Ebola vaccines 128
B.1 General remarks 128
B.2 Product characterization and process development 128
B.3 Pharmacodynamic studies 129
B.4 Nonclinical safety studies (toxicity testing) 132
B.5 Pharmacokinetic (biodistribution) studies 133
B.6 Environmental risk 133
Part C. Clinical evaluation of Ebola vaccines 134
C.1 General considerations 134
C.2 Demonstration of effectiveness of candidate Ebola vaccines 138
C.3 Safety evaluation of candidate Ebola vaccines 145
C.4 Ethical considerations 147
C.5 Statistical considerations 147
C.6 Serological and diagnostic assays 149
C.7 Special populations 151
C.8 Post-marketing surveillance 154
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Abbreviations
Ad human adenovirus
AESI adverse event of special interest
AR attack rate
ARU attack rate in unvaccinated individuals
ARV attack rate in vaccinated individuals
BCG bacillus Calmette–Guérin
BDBV Bundibugyo ebolavirus
BSL biosafety level
CBER Center for Biologics Evaluation and Research
CEF chick embryo fibroblast
ChAd3 chimpanzee adenovirus type 3
DCVMN Developing Countries Vaccine Manufacturers Network
DNA deoxyribonucleic acid
EBOV Ebola virus
ELISA enzyme-linked immunosorbent assay
ELISpot enzyme-linked immunospot
ERA environmental risk assessment
EUAL WHO emergency use assessment and listing (procedure)
EVD Ebola virus disease
GLP good laboratory practice(s)
GMO genetically modified organism
GMP good manufacturing practice(s)
GP glycoprotein
HIV human immunodeficiency virus
HVAC heating, ventilation and air conditioning
IFPMA International Federation of Pharmaceutical Manufacturers
& Associations
ICH International Council for Harmonisation of Technical
Requirements for Pharmaceuticals for Human Use
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Introduction
The unprecedented scale and severity of the Ebola virus disease (EVD) epidemic
in West Africa in 2014–2016 led to calls for the urgent development and licensing
of an Ebola vaccine (1, 2). A considerable amount of work was subsequently
undertaken over a short period of time and a series of international consultations
held on related public health issues and on Ebola vaccine development, evaluation
and licensing (2–4). The development of Ebola vaccines and implications for
future immunization policy recommendations are being monitored by the WHO
Strategic Advisory Group of Experts (SAGE) on Immunization (5). In addition,
as part of ongoing WHO measures to support the development of Ebola vaccines,
guidance was prepared on the scientific and regulatory considerations relating
to their quality, safety and efficacy. In March 2015, WHO convened an informal
consultation in Geneva attended by scientific experts, regulatory professionals
and other stakeholders involved in Ebola vaccine development, production,
evaluation and licensure. The purpose of this consultation was to review initial
draft guidelines prepared by a drafting group, and to seek consensus on key
technical and regulatory issues (6). The draft guidelines were revised in the light
of comments made, and then underwent public consultation which resulted in a
large number of further comments and suggestions. The draft guidelines, together
with the comments, were discussed by the WHO Expert Committee on Biological
Standardization at its meeting in October 2015. During 2016, further revisions
were made following public consultations and working group discussions. One
major challenge during the development of these Ebola vaccine guidelines was
that they were initially prepared during the rapidly evolving epidemic situation
when the need for a vaccine was most urgent. With the end of the large-scale EVD
outbreak in Africa, declared by WHO in June 2016, EVD returned to its previous
sporadic pattern – an epidemiological situation which made the evaluation of
Ebola vaccine efficacy, and thus licensing, more challenging. Interest also shifted
from the development of monovalent Ebola virus (EBOV) Zaire vaccines to
multivalent preparations directed against more than one EBOV strain, as well as
against the Marburg virus (MARV).
The WHO Expert Committee on Biological Standardization reviewed the
draft document again in October 2016 and after extensive discussion agreed that
the guidance should be extended to include multivalent Ebola vaccines and the
clinical evaluation of candidate vaccines using innovative clinical trial designs.
There was also a recognized need to provide guidance on how to evaluate and
license Ebola vaccines subsequent to the potential licensure of one of the advanced
vectored vaccines. These WHO Guidelines are the result of these discussions.
This document provides information and guidance on the development,
production, quality control and evaluation of candidate Ebola vaccines in the
form of WHO Guidelines rather than WHO Recommendations. This allows
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WHO Expert Committee on Biological Standardization Sixty-eighth report
for greater flexibility with respect to the expected future of Ebola vaccine
development, production, quality control and evaluation. Given that this is a very
dynamic field both in terms of technologies and clinical trial designs, these WHO
Guidelines should be read in conjunction with other relevant recent guidelines.
A model protocol for the manufacturing and control of viral-vectored
Ebola vaccines is provided in Appendix 1 of these WHO Guidelines. This
protocol outlines the information that should be provided as a minimum by a
manufacturer to the NRA in support of a request for the release of a vaccine
for use. The protocol is not intended to apply to material intended for clinical
trials. A Lot Release Certificate signed by the appropriate NRA official should be
provided if requested by a manufacturer, and should certify whether or not the
lot of vaccine in question meets all national requirements and/or Part A of these
WHO Guidelines. The purpose of this is to facilitate the exchange of vaccines
between countries, and should be provided to importers of the vaccines. A model
NRA Lot Release Certificate is provided in Appendix 2.
effectiveness information.
Although recombinant viral-vectored Ebola vaccines are the main
category of vaccine considered in this document, some aspects of the guidance
provided are relevant to other approaches. General guidance on other technologies
relevant to Ebola vaccine development has been published elsewhere by WHO,
including guidance on:
■■ inactivated vaccines (7–9)
■■ protein antigens produced by recombinant technology (10–13)
■■ DNA vaccines (14, 15).
In the past 10 years, WHO has convened two consultations to consider
the development, production and evaluation of viral-vectored vaccines in general,
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and the reports of those meetings provide useful discussion and opinions on the
quality, safety and efficacy aspects of such vaccines (16, 17). A regional guideline
is also available for live recombinant viral-vectored vaccines (18).
Although recombinant viral-vectored Ebola vaccines are by far the most
advanced candidates, other approaches to the development of Ebola vaccines are
also being investigated. These include different production platforms, such as
recombinant DNA vaccines expressing an EBOV antigen produced in Escherichia
coli (19), Ebola virus-like particles (VLPs) expressed from recombinant baculovirus
in insect cells, and other forms of subunit vaccines. Most developmental
approaches to Ebola vaccines involve recombinant DNA technology.
Part A of this document focuses on the development, manufacturing
and quality control issues relevant to viral-vectored vaccines against EBOV.
Although the key principles related to nonclinical development (Part B) and
clinical development (Part C) may apply to vaccine approaches other than those
based on viral vectors, special considerations and guidance would be required
for such products – and they are therefore not elaborated upon in this document.
Any mention of specific vaccines is for information only and should not be
considered as an endorsement of a particular candidate.
Parts A, B and C provide guidance in general terms on the full quality,
nonclinical and clinical requirements for a license submission for viral-vectored
Ebola vaccines. The document also considers the principles which may be
applied to product development, manufacturing and control – and to nonclinical
and clinical evaluation – during a public health emergency to allow for the rapid
introduction of an Ebola vaccine. Wherever appropriate, discussions on the
minimum dataset required are highlighted and aspects of vaccine development
which may be accelerated during a public health emergency are indicated. These
context-specific discussions and indications are shown as indented smaller text
in Parts A, B and C. In addition, special considerations regarding the quality
requirements at different stages of clinical development are discussed in sections
A.2.4, A.3.6, A.3.7 and A.3.8.
These WHO Guidelines should be read in conjunction with other
relevant WHO guidelines such as those on nonclinical (20, 21) and clinical (22)
evaluation of vaccines, as well as relevant documents that describe the minimum
requirements for an effective National Pharmacovigilance System (23). Other
WHO guidance, such as that on the evaluation of animal cell cultures as substrates
for the manufacture of biological medicinal products and for the characterization
of cell banks (24), should also be consulted as appropriate.
It should be noted that there remain knowledge gaps in the scientific
understanding of EVD and Ebola vaccines which are being addressed by
ongoing research and development. This document has been developed in the
light of the available knowledge to date, and with regard to the currently most
advanced candidate Ebola vaccines.
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Terminology
The definitions given below apply to the terms as used in these WHO Guidelines.
These terms may have different meanings in other contexts.
Adventitious agents: contaminating microorganisms of a cell culture
or source materials, including bacteria, fungi, mycoplasmas/spiroplasmas,
mycobacteria, Rickettsia, protozoa, parasites, transmissible spongiform
encephalopathy (TSE) agents and viruses that have been unintentionally
introduced into the manufacturing process of a biological product.
Adverse event of special interest (AESI): an adverse event (serious
or non-serious) that is of scientific and medical concern specific to the
sponsor’s product or programme, and for which ongoing monitoring and rapid
communication by the investigator to the sponsor can be appropriate. Such
an event might warrant further investigation in order to be characterized and
understood. Depending on the nature of the event, rapid communication by the
trial sponsor to other parties (for example, regulators) might also be warranted.
Attenuated virus: a strain of virus in which pathogenicity has been
reduced so that the virus strain will initiate an immune response without
producing the disease.
Benefit–risk assessment: a decision-making process for evaluating
whether or not the benefits of a given medicinal product outweigh the risks.
Benefits and risks need to be identified from all parts of a dossier – that is, the
quality, nonclinical and clinical data – and integrated into the overall assessment.
Candidate vaccine: an investigational vaccine which is in the research and
clinical development stages and has not been granted marketing authorization or
licensure by a regulatory agency.
Cell bank: a collection of appropriate containers whose contents are of
uniform composition, stored under defined conditions. Each container represents
WHO Technical Report Series, No. 1011, 2018
process. A final lot must therefore have been filled from a single vessel of final
bulk or prepared in one working session.
Heterologous gene: a transgene from the disease-causing organism that
is integrated into the genomic sequence of the viral vector.
Immune correlate of protection (ICP): an immunological response
that correlates with vaccine-induced protection from disease and is considered
predictive of clinical efficacy. The ICP may be mechanistic (that is, causative for
protection) or it may be non-mechanistic (that is, an immune response that is
present in persons protected by vaccination but that is not the cause of protection).
Immunogenicity: the capacity of a vaccine to elicit a measurable immune
response.
Marketing authorization: a formal authorization for a medicine
(including vaccines) to be marketed. Once an NRA approves a marketing
authorization application for a new medicine, the medicine may be marketed
and may be available for physicians to prescribe and/or for public health use (also
referred to as product licensing, product authorization or product registration).
Master cell bank (MCB): a quantity of well-characterized cells of animal
or other origin, derived from a cell seed at a specific population doubling level
(PDL) or passage level, dispensed into multiple containers, cryopreserved and
stored frozen under defined conditions (such as the vapour or liquid phase of
liquid nitrogen) in aliquots of uniform composition. The MCB is prepared from
a single homogeneously mixed pool of cells. In some cases, such as genetically
engineered cells, the MCB may be prepared from a selected cell clone established
under defined conditions. Frequently, however, the MCB is not clonal. It is
considered best practice for the MCB to be used to derive working cell banks.
Monovalent vaccine: a vaccine containing immunizing antigen, or a gene
encoding an immunizing agent, against a single strain or type of disease agent.
Platform technology: a production technology in which different viral-
vectored vaccines are produced by incorporating heterologous genes for different
proteins into an identical viral vector backbone.
Multivalent vaccine: a vaccine containing a mixture of more than one
immunizing antigen or genes encoding several immunizing agents active against
more than one strain or type of disease agent.
Pooled virus harvest: a homogeneous pool of two or more single virus
harvests.
Public health emergency: an extraordinary event that is determined, as
provided in the International Health Regulations (25), to: (a) constitute a public
health risk to other States through the international spread of disease; and
(b) potentially require a coordinated international response.
Seed lot: a system according to which successive batches of viral-vectored
vaccine are derived from the same virus master seed lot of viral vector at a given
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passage level. For routine production, a virus working seed lot is prepared from
the virus master seed lot. The final product is derived from the virus working
seed lot and has not undergone more passages from the virus master seed lot
than the vaccine shown in clinical studies to be satisfactory with respect to safety
and efficacy.
Single virus harvest: a quantity of virus suspension of one virus strain
harvested from cell cultures derived from the same working cell bank and
prepared from a single production run.
Vaccine efficacy: measures direct protection (that is, protection induced
by vaccination in the vaccinated population sample). Vaccine efficacy is most
commonly a measure of the proportionate reduction in disease attack rate (AR)
between the control group that did not receive vaccination against the infectious
disease under study (ARU) and the vaccinated group (ARV). Vaccine efficacy
(expressed as a percentage) can be calculated from the relative risk (RR = ARV/
ARU) of disease when comparing the vaccinated group to the unvaccinated
control group as [(ARU-ARV)/ARU] x 100 – that is, as (1-RR) x 100. This estimate
may be referred to as absolute vaccine efficacy. Alternatively, vaccine efficacy may
be defined as a measure of the proportionate reduction in disease AR in a group
vaccinated with the candidate vaccine relative to a control group vaccinated with
a licensed vaccine against the infectious disease under study. This estimate may
be referred to as relative vaccine efficacy (22).
Vaccine effectiveness: an estimate of the protection conferred by
vaccination. It is usually obtained by monitoring the disease to be prevented by
the vaccine during routine use in a specific population. Vaccine effectiveness
measures both direct and indirect protection (for example, the estimate may in
part reflect protection of unvaccinated persons secondary to the effect of use of
the vaccine in the vaccinated population) (22). Evidence for vaccine effectiveness
may also be derived from challenge-protection studies conducted in animal
WHO Technical Report Series, No. 1011, 2018
General considerations
Ebola viruses, Ebola virus disease and epidemiology
Ebola viruses belong to the Filoviridae family of filamentous, negative-stranded
RNA, enveloped viruses consisting of three genera: Ebola virus, Marburg virus
and Cueva virus – the latter being a pathogen of bats in Spain (26). There are five
distinct species of EBOV: Zaire ebolavirus (ZEBOV), Sudan ebolavirus (SUDV),
Tai Forest ebolavirus (TAFV), Reston ebolavirus (RESTV) and Bundibugyo
ebolavirus (BDBV) (26, 27). Marburg virus (MARV) appears to be antigenically
stable and at present there is only a single species. The first recognized MARV
outbreak in humans was in 1967 and was linked to infected monkeys imported
from Uganda that infected laboratory workers in Marburg and Belgrade (28).
Bats are believed to be the natural reservoir of all filoviruses. EBOV and MARV
cause severe haemorrhagic fever in humans and non-human primates alike, with
high morbidity and mortality rates (29, 30). Outbreaks of infection with Ebola
filoviruses have been noted since 1976, mainly in Central Africa, and recur at
intervals. Prior to the 2014–2016 EVD epidemic in West Africa there had not
been such a large-scale outbreak and the disease had not been recorded in West
Africa, apart from a single infection with TAFV.
The incubation period following infection with EBOV and prior to
the onset of symptoms is believed to be approximately 2–21 days, with initial
symptoms being similar to diseases such as influenza or malaria (31, 32).
Patients then progress rapidly to a life-threatening disease (33). From a practical
perspective, infected individuals rarely if ever become infective before symptoms
appear, but those who survive remain infective until the virus is cleared from
their blood and other bodily fluids. It has been reported that viable EBOV can
persist in ocular fluid for at least 9 weeks following clearance of viraemia (34).
EBOV has also been detected in semen for months following recovery from EVD,
which is consistent with the possible persistence of the virus within immune-
privileged tissue sites in the body (35, 36). Presumptive sexual transmission of
EBOV from recovered individuals has also been reported (37, 38). Individuals
suffering from EVD have been treated aggressively with oral and intravenous
fluids, including electrolyte replacements, to combat severe diarrhoea and
dehydration, with some surviving the infection (33).
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a document – Ebola virus disease (EVD) vaccine target product profile (60)
– which provides guidance on WHO preferred options in relation to two
categories of Ebola vaccine (reactive use and prophylactic use). Encouraging
results on the immunogenicity and safety of these candidate options, as well
as on their clinical efficacy based on disease end-points, have already been
generated and their evaluation in larger Phase II and Phase III trials is ongoing.
This includes novel trial design clinical studies (ring vaccination) using the
rVSV-ZEBOV vaccine (32, 54, 61–64). A prime-boost approach, using a two-
dose schedule with different vector vaccines, is also being explored. Boosting
of Ad26.ZEBOV responses by MVA-BN-Filo resulted in sustained elevation of
specific immunity with no vaccine-related serious adverse responses reported
(56, 57). Administration of rVSV-ZEBOV vaccine resulted in low-level viraemia
detectable by polymerase chain reaction (PCR) during the first and sometimes
second week after vaccination (63). The vaccine virus was also detected by PCR
in the urine and saliva of a minority of the recipients. An unexpected safety
signal was detected in one study when mild-to-moderate and generally short-
lived arthritis developed during the second week following immunization in a
minority of recipients and at one site in particular (63). In subsequent studies
in healthy North American and European adults which carefully assessed
joint-related adverse events, transient post-vaccination arthritis was noted in
approximately 5% of vaccine recipients (65, 66). However, the epidemiological
situation has now changed significantly. Using strict infection control and public
health measures, the EBOV epidemic has been ended – though there will still
be a risk of new Ebola cases or clusters occurring through, for example, sexual
transmission or new introduction of the virus into the human population. WHO
declared Sierra Leone free of EBOV transmission in March 2016 and Guinea
and Liberia free of EBOV transmission in June 2016, bringing to an end the
large-scale Ebola outbreak in the three African countries mainly affected (67).
In the absence of ongoing disease transmission, the assessment of Ebola vaccine
WHO Technical Report Series, No. 1011, 2018
In some cases, even if the nature of a public health emergency affects the
benefit–risk balance in such a way as to justify the accelerated development and
approval of a vaccine for use in a public health emergency, the manufacturer
would still be responsible for completing the full development work to the same
standard required for a new vaccine under non-emergency conditions should it
be decided to subsequently submit the product for full licensure. The required
supplementary data and timelines for submission should be agreed between the
applicant and the NRA.
Similar considerations apply to the nonclinical evaluation of candidate
Ebola vaccines. For nonclinical evaluation during a public health emergency,
it is paramount to determine a minimum nonclinical package (see section B.4)
that can reasonably support initiation of early Phase I clinical trials. This should
take into account the characteristics and novelty of candidate vaccines and the
supportive information derived from the platform technology on which the
vaccine is based. For example, the presence of nonclinical data and/or clinical
experience gained with the same vector may support the omission of a specific
safety test or toxicity testing programme. For a candidate vaccine derived from
a novel platform, a certain amount of toxicity data (see section B.4) should at
a minimum be obtained, and should focus on unexpected direct and indirect
consequences that might result from vaccination.
In general, the use of a minimum safety package during nonclinical
evaluation should be backed up by the continuous assessment of additional data
collected during clinical development. At the time of the licensing application,
the complete nonclinical programme data appropriate for a particular vaccine
should be submitted, or the application should be otherwise adequately justified.
Clinical development of an Ebola vaccine in the setting of an outbreak is
complex, and close collaboration between public health authorities, NRAs, the
community, clinical investigators and the vaccine developer is essential to ensure
that studies will meet authorization requirements, including requirements for
WHO Technical Report Series, No. 1011, 2018
RNA encoding the VP40 and L genes and again is intended to standardize assays
directed only at these genes. Both preparations are packaged in non-replicating
lentiviral vectors (LVVs) with the EBOV genes incorporating mutations that
make them inactive. Collectively the two materials were established as the First
WHO reference reagents for Ebola virus RNA for NAT-based assays with assigned
unitages of 7.5 log 10 U/ml and 7.7 log 10 U/ml respectively.
The First WHO Reference Panel for Ebola virus VP40 antigen was
established by the 2016 WHO Expert Committee on Biological Standardization
(78). The panel consists of different recombinant VP40 antigens and may be
suitable for the evaluation and quality control of Ebola antigen assays based on
VP40 detection.
All the reference materials listed above are available from the National
Institute for Biological Standards and Control, Potters Bar, the United Kingdom.
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For the latest list of appropriate WHO international standards and reference
materials, the WHO Catalogue of International Reference Preparations (79)
should be consulted.
on the resulting amino acid sequence (that is, it should be a conservative change)
or on the antigenic characteristics of the vaccine.
vectors) and in vitro yield should also form part of the characterization. For
replicating vectors, in vivo growth characteristics in a suitable animal model may
also be informative and should be performed if justified. For some vectors (for
example, adenoviral vectors), particle number should be measured in addition to
infectivity titre.
A subset of the above studies should be applied to the virus working seed
lot and justification for the chosen subset should be provided.
Information should be given on the testing carried out for adventitious
agents.
During a public health emergency it is anticipated that the majority
of the above information should be available and submitted in full for
evaluation since it is essential to demonstrate the suitability and safety of
the product.
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A.2.3 Source materials used for cell culture and virus propagation
If serum is used for the propagation of cells it should be tested to demonstrate
the absence of bacteria, fungi and mycoplasmas, as specified in the requirements
given in Part A – section 5.2 (80) and section 5.3 (81) – of the WHO General
requirements for the sterility of biological substances. Testing should also be
conducted to demonstrate freedom from adventitious viruses.
Detailed guidance on detecting bovine viruses in serum used to establish
MCBs and WCBs is provided in Appendix 1 of the WHO Recommendations
for the evaluation of animal cell cultures as substrates for the manufacture of
biological medicinal products and for the characterization of cell banks (24) and
should be applied as appropriate. This same guidance may also be applicable
to production cell cultures. As an additional monitor of quality, sera may be
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antibiotics may be used at any stage of manufacture, provided that the quantity
present in the final product is acceptable to the NRA.
Non-toxic pH indicators may be added (for example, phenol red at a
concentration of 0.002%). Only substances that have been approved by the NRA
may be added.
process parameters and lot release specifications. Any materials added during
the purification process should be documented and their removal should be
adequately validated or residual amounts tested for, as appropriate. Validation
should also demonstrate that the manufacturing facility and equipment have been
qualified, cleaning of product contact surfaces is adequate, and critical process
steps (such as sterile filtrations and aseptic operations) have been validated.
The purified viral vector bulk and intermediates should be maintained
under conditions shown by the manufacturer to ensure the retaining of the
desired biological activity. Hold times should be defined.
During early clinical trials it is unlikely that there will be data from
sufficient batches to validate/qualify product manufacture. However, as
development progresses, data should be obtained from subsequent manufacture
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directly from the production cell expansion series for the batch which is subject
to the test. If primary cells are used for production then a different batch of
that primary cell type should be used for the test than was used for production.
Samples of each pool should also be tested in human cells and in a simian kidney
cell line. At least one culture vessel of each kind of cell culture should remain
uninoculated as a control.
The inoculated cultures should be incubated at the appropriate growth
temperature and should be observed for cytopathic effects for a period of at
least 14 days.
Some NRAs require that, at the end of this observation period, a
subculture is made in the same culture system and observed for at least an
additional 7 days. Furthermore, some NRAs require that these cells should be
tested for the presence of haemadsorbing viruses.
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For the tests to be valid, not more than 20% of the culture vessels should
have been discarded for any reason by the end of the test period.
agents (viral pathogens and mycoplasmas) in the cell harvest or bulk substance,
or replacing it with validated PCR tests, could be evaluated subject to the
agreement of the NRA. The method of production should be taken into account
when deciding upon the nature of any specified viruses being sought.
Additional considerations for this approach are that no animal-derived
raw materials are used during manufacture, and that the manufacturing facility
operates under a GMP certificate (where applicable) with assurances that
prevention of cross-contamination is well controlled within the facility. Samples
should be retained for testing at a later date if required.
have been shown not to impair the potency and safety of the vaccine in the
concentrations used.
Similarly, if adequately justified, not all of the proposed assays may need
to be completed for clinical trial batch release. If it can be justified that
product safety and potency are not compromised, that completion of
the test(s) would delay product availability for use in clinical trials, and/
or that the test(s) would use up an unacceptably large volume of the
product urgently required for clinical trials, it may be possible to omit or
delay the test, or replace it with one that is more acceptable in terms of
the overall aims of the clinical trials in an emergency situation.
A.3.4.1.1 Purity
The degree of purity of each monovalent bulk vaccine should be assessed using
suitable methods. This should include testing for the presence of fragments,
aggregates or empty particles of the product, as well as for contamination by
residual cellular proteins. Residual cellular DNA levels should also be assessed
when non-primary cell substrates are used for production. The content and
size of host cell DNA should not exceed the maximum levels agreed with the
NRA, taking into consideration issues such as those discussed in the WHO
Recommendations for the evaluation of animal cell cultures as substrates for the
manufacture of biological medicinal products and for the characterization of cell
banks (24).
Process additives should also be controlled. In particular, if any antibiotics
are added during vaccine production, the residual antibiotic content should be
determined and should be within limits approved by the NRA.
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These tests may be omitted for routine lot release upon demonstration
that the process consistently clears the residuals from the monovalent bulk
vaccine, subject to the agreement of the NRA.
A.3.4.1.2 Potency
Each monovalent bulk vaccine should be tested for potency using a combination
of the following methods.
Particle number
For relevant vectors (for example, adenovirus vectors) the total number of
virus particles per millilitre, quantitated by techniques such as qPCR or high-
performance liquid chromatography, should be determined for each batch of
monovalent bulk.
Infectivity
The infectious virus titre for each batch of monovalent bulk should be
determined as a measure of active product. Direct methods such as a plaque-
forming assay or indirect methods such as qPCR (if suitably correlated with a
direct measure of infectivity) could be considered. The particle/infectivity ratio
should also be specified.
Expression of the heterologous antigen in vitro
The ability of the viral particles to express the heterologous gene should be
demonstrated (for example, by the generation of immunoblots using antigen-
specific antibodies) following amplification of the vector in a suitable cell line.
WHO Technical Report Series, No. 1011, 2018
A.3.4.1.3 Identity
Tests used for assessing relevant properties of the viral vector – such as antigen
expression, restriction analysis, PCR with a specific probe or sequencing – will
generally be suitable for assessing the identity of the product.
is used, it should not impair the safety or potency of the vaccine; the intended
concentration of the preservative should be justified and its effectiveness should
be validated (85).
A.3.5.1.1 Identity
See section A.3.4.1.3.
final container closure system are generally required for the qualification of
containers, and may be needed as part of stability assessments.
If multi-dose vaccine vials are used and these vaccines do not contain
preservative then their use should be time-restricted, as is the case for
reconstituted vaccines such as bacillus Calmette–Guérin (BCG) and measles-
containing vaccines (85). In addition, the multi-dose container should prevent
microbial contamination of the contents after opening. The extractable volume
of multi-dose vials should be validated.
The manufacturers should provide the NRA with adequate data to prove
the stability of the product under appropriate conditions of storage and shipping.
A.5.2 Appearance
The appearance of the vaccine should be described with respect to its form
and colour.
A.5.3 Identity
See section A.3.4.1.3. For multivalent vaccine each antigen component should
be identified.
A.5.6 Purity
Testing for purity should be performed unless it is performed on the monovalent
bulk or final bulk vaccine. However, limited purity testing of the final lot may
be required even if purity is tested on the final bulk vaccine if, after taking
the manufacturing process and nature of the vector into consideration, it is
considered possible that the purity may have changed. This should be considered
on a case-by-case basis.
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A.6 Records
The requirements given in section 17 of WHO good manufacturing practices for
biological products (70) should apply.
A.8 Labelling
The requirements given in section 14 of WHO good manufacturing practices for
biological products (70) should apply.
The label on the carton, the container or the leaflet accompanying the
container should state:
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For vaccine licensure, the stability and expiry date of the vaccine in its
final container, when maintained at the recommended storage temperature,
should be demonstrated to the satisfaction of the NRA using final containers
from at least three final lots made from different vaccine bulks. During clinical
trials, fewer data are likely to be available. However, the stability of the vaccine
under the proposed storage conditions should be demonstrated for at least the
expected duration of the clinical trial.
Following licensure, ongoing monitoring of vaccine stability is
recommended to support shelf-life specifications and to refine the stability
profile (91). Data should be provided to the NRA according to local regulatory
requirements.
The final stability-testing programme should be approved by the NRA
and should include an agreed set of stability-indicating parameters, procedures
for the ongoing collection and sharing of stability data, and criteria for rejecting
vaccines(s).
In-use stability should also be specified and justified with adequate data
generated under real-time conditions.
In an emergency situation and during early clinical trials, limited stability
data on the monovalent or final bulk vaccine and finished product may
be acceptable to preserve scarce stocks of product for use in clinical
trials, or if there is insufficient time to generate real-time stability data.
Data from one batch of bulk and final product may be sufficient initially
but this should be supplemented with data from at least two more
batches of bulk and final product as material that is surplus to clinical
trial requirements becomes available.
lots produced for nonclinical good laboratory practice (GLP) safety studies
should be manufactured with production process, formulation and release
specifications similar to those of the lots intended for clinical use. Supporting
stability data generated under conditions of use should be provided.
For a live viral-vectored vaccine, the degree of attenuation and the
stability of the phenotype should be evaluated. The critical genetic and phenotypic
markers of stability of the vector genome should as far as is practical be defined.
Phenotypic markers are useful for the detection of reversion events and may
include, though are not restricted to, vector replication efficiency, induction of
viraemia and level of virulence, and neurovirulence. The need for neurovirulence
testing is discussed below in section B.4.
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be considered. The protective activity of the vaccine with respect to each of the
Ebola strains targeted should be assessed.
As in any challenge-protection animal study, the end-points used to
define protection should normally correlate with the desired effect in humans
– typically a survival benefit or attenuation of severe disease indicators such as
viral shedding, body weight changes and other relevant clinical signs. Other
key characteristics of the experimental design include the use of appropriate
challenge virus strains, dose(s) and route of challenge. The challenge dose should
be sufficiently high to produce an appropriate degree of lethality in the control
group of animals so that the vaccine protective effect can be shown with adequate
statistical power. For example, doses of 100–1000 plaque-forming units (PFU)
have been used (92).
The collection of challenge-protection data should take account of
the proposed indication for use – that is, pre-exposure versus post-exposure
prophylaxis against EVD. Appropriate timing of the challenge is another
important consideration. For pre-exposure prophylaxis, animals are usually
challenged at the time when the peak level of vaccine response (for example, peak
antibody titres) has developed post-vaccination. Where feasible, it would also be
informative for various public health vaccine strategies to challenge animals at
other times (for example, before the peak response or after the immune responses
have waned). For post-exposure prophylaxis, challenge at various time points
should be considered.
that this document focuses on, toxicity studies were not required during
the 2014–2016 EVD epidemic.
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vaccines should be avoided to optimize the safety evaluation. The study design
may include sequential dose-escalation whereby subjects enrolled in lower-dose
cohorts are closely monitored for safety for a defined period (for example, 1–2
weeks or as appropriate for the characteristics of the vaccine) and the resulting
data are reviewed before subsequent enrolment of additional subjects in
successively higher-dose cohorts. All study participants should be actively and
closely monitored for safety.
appropriate for the specific vaccine), development may in some cases proceed to
Phase II studies in parallel with the continued collection of longer-term safety
data from Phase I studies. Phase II studies provide further information on safety
and immunogenicity to determine the optimal dose and dosing regimen, and
to support initiation of Phase III studies. Phase II studies typically involve up
to several hundred subjects and are frequently randomized, double-blind and
controlled. The comparator is usually an inert placebo or a control vaccine that
provides protection against disease unrelated to EVD. Phase II trials should be
of sufficient size to test hypotheses on dose and dosing regimen. Phase II studies
should be conducted in the proposed target population or in a population
similar to the target population in terms of demographic and ethnic factors, and
other factors that might impact on vaccine effectiveness or safety (for example,
concomitant infections). Detailed safety and immunogenicity data should be
obtained in Phase II studies.
specified primary end-point (for example, EVD confirmed by PCR); (e) pre-
specified important secondary end-points (for example, EVD not laboratory
confirmed); (f) pre-specified, detailed clinical case definitions for the primary
end-point; (g) validated diagnostic assays to support the pivotal efficacy analyses;
(h) unbiased case-ascertainment methods; and (i) adherence to relevant
statistical principles. Measures to reduce potential bias are important in all trials,
but particularly so for designs other than randomized, double-blind, controlled
trials with a parallel control group. Specific considerations regarding the design
of clinical end-point efficacy studies and diagnostic tests for EVD are discussed
below in sections C.2.3.2 and C.6.1, respectively. Consideration should be given
to the establishment of an independent data-monitoring committee for clinical
end-point efficacy studies of Ebola vaccines in order to advise the sponsor on the
continuing validity and scientific merit of the study.
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compatible with EVD are recruited into the study and tested for the disease.
Vaccine effectiveness is estimated by comparing the odds of vaccination in
subjects testing positive for Ebola (cases) to the odds of vaccination in subjects
testing negative (controls).
Test-negative case control studies are relatively low cost and easy to
conduct. However, controlling for potential bias in this non-randomized design
is particularly challenging because vaccinated and unvaccinated individuals
may have different risk factors for disease.
Test-negative case control studies are also subject to the same sources of
bias and measurement error as other non-randomized studies – some of which
may not be recognized or adequately adjusted for in the statistical analyses.
Furthermore, it may be difficult to assure comparable disease severity across
participants at study entry or to achieve complete ascertainment of vaccination
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status. Potential sources of bias and limitations inherent in this design need to
be carefully considered in planning study procedures and statistical analysis, as
well as in interpreting the results.
Importantly, Phase II and Phase III clinical trials should attempt to identify
ICPs and should evaluate the kinetics of the immune response and induction of
immunological memory.
the study protocol. A longer-term safety follow-up period for the assessment
of SAEs (for example, through the 12 months following the last vaccination)
may be warranted for some vaccines (for example, vaccines containing
novel adjuvants). Long-term safety follow-up (that is, for 6–12 months post-
vaccination) may be accomplished by telephone follow-up or other methods
appropriate for the setting.
Phase II studies are for selecting the final optimal dose and dosing
regimen and should be rigorously designed and analysed. The potential role of
immunogenicity data should be taken into consideration to ensure the adequacy
of data to support licensure if necessary.
Phase III studies are designed to provide robust data on vaccine
effectiveness and more-extensive data on safety. The study protocols should
clearly describe the procedures for randomization and blinding, primary and
secondary objectives, end-points to be analysed, null and alternative hypotheses
to be tested, level of type I error, sample size calculations, statistical methods for
assessing each end-point, and analysis populations (per-protocol and intent-to-
treat). If interim analyses for efficacy are planned, detailed information should
be included in the protocol regarding the timing of interim analyses, type I
error allocated to each analysis, and stopping rules. The study reports should
include detailed information on subject disposition. Statistical estimates should
be presented along with confidence intervals.
appropriate for the study design and study objectives. If inference will be at
the usual individual level rather than the cluster level, sample size calculations
and statistical analysis methods should appropriately address the within-cluster
correlation, as feasible. Randomization should be carefully planned to avoid
imbalance in disease risk or incidence rate between clusters randomized to be
vaccinated or to serve as controls. As mentioned in section C.2.3.2.2, seeking
to confine a trial to individuals at relatively high risk of EVD (as with the ring
vaccination trial design) may have higher statistical power to detect vaccine
efficacy than a trial in a population at lower risk of disease and, as a consequence,
can potentially require a smaller sample size and achieve faster completion time
compared to other study designs.
When ICPs established in animal challenge studies are being used to
define immune response end-points for effectiveness evaluation or to infer
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clinical benefit under other alternative licensure pathways, these studies (for
example, in non-human primates) should be conducted using an appropriate
dose range and an adequate number of animals such that the relationship
between immune response and protection, and the protective threshold, can be
estimated with satisfactory precision (see Part B).
in, or expressed by, the vaccine may be prone to yielding false-positive results.
Other issues for consideration are the source of virus antigen used in the ELISA
(reduced cross-recognition between virus strains), conformational changes of
the antigen upon binding to the plate and antigen stability over time.
Since ELISAs are not necessarily informative of functional immunity,
assays that measure virus neutralization and cell-mediated responses have been
developed. The neutralization assays generally employ pseudovirions (such as
VSV in which the GP gene has been replaced with that of EBOV) or lentivirus
packaging systems. Consideration should be given as to whether virus-
neutralizing activity detected in these in vitro assays is predictive of EBOV-
neutralizing activity in vivo. It is also important to consider false positivity
through the use of ELISA plates coated with non-EBOV vaccine components.
For example, non-EBOV antibodies generated in response to receipt of a
VSV-vectored Ebola vaccine may have an impact on the performance of VSV-
based neutralization assays. This is less of a problem for neutralization assays
using wild-type EBOV as the target virus but it highlights the need for careful
evaluation of assay specificity as part of assay validation.
Although not well established, there is evidence supporting the
importance of T cell-mediated responses in preventing EVD. In a study of
an Ad5-vectored Ebola vaccine in non-human primates, depletion of CD8+
T cells in vaccinated animals before challenge abrogated protection (111).
Several different types of tests for cell-mediated immunity have been developed,
including the ELISpot and ICS tests. These tests present additional challenges,
including determination of the appropriate peptide pools to be used and
logistical and safety issues concerning the collection and storage of peripheral
blood mononuclear cells, as well as assay validation issues.
In general, there are few published data on the performance of assays to
detect immunological responses to EBOV infection or to Ebola vaccines. Where
available, international standards or reference reagents (see section A.1.1) should
be used to standardize assay performance, and improve comparison of results
across vaccines, across studies and across different assay platforms.
early neonatal period; and (c) limiting the spread of EVD from pregnant women
during labour and delivery to health-care workers in an outbreak setting (113).
The following concepts should be considered when planning clinical
trials in pregnant women. Details regarding such trials should be discussed
with the respective NRA(s) and can also be found in the WHO Guidelines on
clinical evaluation of vaccines: regulatory expectations (22). Prior to enrolling
pregnant women in clinical trials, developmental toxicity studies in animal
models are needed to address the potential reproductive risk of the product
(see section B.4). In addition, supportive safety data from completed Phase
I and Phase II clinical trials in healthy men and non-pregnant women should
be available. The consent form should include information on what is known
and unknown regarding the potential risks and benefits of the investigational
product to both mother and infant, and should reflect available data from non-
pregnant adults and nonclinical studies. A reasonable effort should be made to
accurately calculate gestational age for pregnant participants prior to enrolment,
taking into consideration the standard of care in the region where the clinical
trial is being conducted. For studies of preventive vaccines in general (including
Ebola vaccines), consideration should be given, as part of a cautious approach, to
excluding women in the first trimester of pregnancy.
Safety data specific to both the pregnant mother and her fetus should
be collected. Information on pregnancy-related outcomes (such as spontaneous
abortion or intrauterine growth restriction) and on pregnancy-related
complications (such as new-onset gestational diabetes or placenta previa)
should be collected. In addition, severity scales used for the grading of adverse
outcomes should be based on pregnancy-specific physiological and laboratory
values, if available. Efforts should be made to monitor infants for developmental
abnormalities.
Paediatric populations
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C.7.2
A paediatric clinical development plan for a vaccine to protect against EVD
should be considered early (prior to Phase III) and should take into account
the incidence and prevalence of EVD, as well as existing therapies, in the
paediatric population, including neonates. In general, enrolment of children in
Ebola vaccine studies should be considered when there is sufficient evidence
to support the safety of studies in the paediatric population and there is
a reasonable demonstration of a sufficient prospect of direct benefit from
animal and/or human adult studies to justify the risks. Scientific and ethical
considerations regarding the initiation of paediatric studies of Ebola vaccines
should be discussed with the relevant NRA early in clinical development.
Available preclinical data and clinical data in older age groups should support
the paediatric dose and regimen to be evaluated, and should guide decisions on
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the potential need for incremental evaluation in older paediatric groups first,
followed by younger children and possibly infants. Safety considerations will be
critical when deciding upon the potential study of Ebola vaccines based on live,
replication-competent viral vectors in infants younger than 1 year of age.
Whether evidence of effectiveness can be extrapolated from adults to
specific paediatric age groups or from older to younger paediatric age groups
will depend on the similarities between the relevant age groups with respect to
factors such as the course of the disease and the immune response to vaccination.
Consideration may also be given to bridging effectiveness from older to younger
populations on the basis of a comparison of immune responses, as measured
by a validated assay using an immune marker that is thought to predict clinical
benefit. In some cases, immunological markers that are thought to contribute
to protection may be used to bridge across age groups even if they are not
scientifically well-established correlates of protection.
If the adult formulation of a vaccine is not suitable for certain paediatric
age groups (for example, due to the large dose volume), sponsors should plan for
the development of an age-appropriate paediatric formulation.
In paediatric studies, grading scales for adverse events and normal ranges
for laboratory tests should be specifically tailored to the age group studied.
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156
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and Control, the United Kingdom; Dr C.V. Munoz, European Centre for
Disease Prevention and Control, Sweden; Dr J. Russell, National Institutes of
Health, the USA; Dr R. Sheets, Grimalkin Partners, the USA; Dr A.K. Tahlan
and Mr S. Kumar, Central Research Institute, India; M. Xydia-Charmanta and
Dr J. Wolf, Merck & Co. Inc., the USA (respectively coordinated and provided
the consolidated comments of the IFPMA); Dr K. Zoon, National Institutes of
Health, the USA; and Dr M.R. Balakrishnan, Dr C. Maure and Dr P.L. Zuber,
World Health Organization, Switzerland.
The document WHO/BS/2015.2276 was subsequently reviewed at the
meeting of the WHO Expert Committee on Biological Standardization held in
Geneva, Switzerland, 12–16 October 2015. A sixth draft document was then
prepared by the above WHO Drafting Group, taking into account comments
received during both the previous public consultation and the meeting of the
158
Annex 2
WHO Expert Committee. The resulting document was then posted on the WHO
Biologicals website for a second round of public consultation from January to
March 2016. Acknowledgments are due to the following experts who provided
written comments: Dr G. Coleman, Health Canada, Canada; Dr A.G. Fula
Argüello, Dr M.A. Alarcón Mora and Dr J.A. García Cortés, Instituto Nacional
de Vigilancia de Medicamentos y Alimentos; Dr A. Hacker, Janssen-Cilag
Ltd, the United Kingdom; Dr G. Raychaudhuri, United States Food and Drug
Administration, Center for Biologics Evaluation and Research, the USA; Dr A.
Rinfret, Health Canada, Canada; Dr J. Wang, National Institutes for Food and
Drug Control, China; Dr J. Wolf, Merck & Co., Inc., the USA (provided the
consolidated comments of the IFPMA); and Dr M. Nübling and Dr P.L. Zuber,
World Health Organization, Switzerland.
Acknowledgments are also due to the following participants in a WHO
working group meeting on guidelines on the quality, safety and efficacy of Ebola
vaccines held in Geneva, Switzerland, 4–5 May 2016: Dr E. Griffiths, Consultant,
Kingston-upon-Thames, the United Kingdom; Dr M. Gruber, United States
Food and Drug Administration, Center for Biologics Evaluation and Research,
the USA; Dr Y. Sun, Paul-Ehrlich-Institut, Germany; Dr M. Udell, Medicines
and Healthcare Products Regulatory Agency, the United Kingdom; Dr G.
Coleman, Health Canada, Canada; Dr M. Darko, Food and Drugs Authority,
Ghana; Mr D. Etuko, National Drug Authority, Uganda; Dr S. Kennedy,
University of Liberia, Liberia; Dr J. McEwen, Canberra, Australia; Dr P. Minor,
National Institute for Biological Standards and Control, the United Kingdom;
Dr R. Sheets, Consultant, Grimalkin Partners, Silver Spring (MD), the USA;
Dr J. Southern, Medicines Control Council of South Africa, South Africa; Dr K.
Zoon, National Institutes of Health, the USA; and Dr M. Friede, Dr I. Knezevic,
Dr O.C. Lapujade, Dr D. Wood, Dr T.Q. Zhou and Dr P.L. Zuber, World Health
Organization, Switzerland.
A further revised version (WHO/BS/2016.2279) was then prepared by
the above WHO Drafting Group, taking into account comments received from
the above consultations.
Acknowledgments are due to the following experts who provided written
comments in response to the posting of document WHO/BS/2016.2279 on the
WHO Biologicals website between July and September 2016 for a third round of
public consultation: Prof. S. Efstathiou, National Institute for Biological Standards
and Control, the United Kingdom; Dr A. Hacker, Janssen-Cilag Ltd, the United
Kingdom; Dr H. Mao and Dr X. Yu, CanSino Biotechnology Inc., China; Dr G.
Raychaudhuri, United States Food and Drug Administration, Center for Biologics
Evaluation and Research, the USA (provided the consolidated comments of the
Center for Biologics Evaluation and Research); Dr A. Rinfret, Health Canada,
Canada; and Dr J. Wolf, Merck & Co., Inc., the USA (provided the consolidated
comments of the IFPMA).
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WHO Technical Report Series, No. 1011, 2018
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Appendix 1
Model protocol for the manufacturing and control of
viral-vectored Ebola vaccines
The following provisional protocol is intended for guidance. It indicates the
information that should be provided as a minimum by the manufacturer to
the NRA after the vaccine product has been granted a marketing authorization.
The protocol is not intended to apply to material intended for clinical trials.
Since the development of these vaccines is incomplete at the time of
writing this document, detailed requirements are not yet finalized. Consequently
only the essential requirements are provided in this appendix. Information and
tests may be added or omitted (if adequate justification is provided) as necessary
to be in line with the marketing authorization approved by the NRA. It is therefore
possible that a protocol for a specific product will differ from the model provided
here. The essential point is that all relevant details demonstrating compliance
with the licence and with the relevant WHO Guidelines on a particular product
should be given in the protocol submitted.
The section concerning the final product should be accompanied by
a sample of the label and a copy of the leaflet that accompanies the vaccine
container. If the protocol is submitted in support of a request to permit
importation, it should also be accompanied by a Lot Release Certificate from the
NRA of the country in which the vaccine was produced and/or released stating
that the product meets national requirements as well as Part A of these WHO
Guidelines.
Target group:
Expiry date:
Storage conditions:
3.2.2 Tests
■■ Adventitious virus tests:
■■ Bacteria/fungi/mycoplasmas:
■■ Virus titre:
■■ Virus concentration:
■■ Name and concentration of added substances (for example, diluent,
stabilizer if relevant):
■■ Volume(s), storage temperature, storage time and approved storage
period:
3.3.2 Tests
■■ Identity:
■■ Purity:
■■ Residual HCP:
■■ Residual HC DNA (if non-primary cell lines):
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■■ Potency:
–– Particle number (for adenovirus):
–– Infectious virus titre:
–– Particle-to-infectivity ratio (for adenovirus):
–– Expression of heterologous antigen in vitro:
■■ Replication competence (for adenovirus):
■■ pH:
■■ Preservative content (if applicable):
■■ Endotoxin:
■■ Sterility or bioburden:
3.4.2 Tests
■■ Identity:
■■ Sterility or bioburden:
■■ Concentration of antimicrobial agent, if relevant:
1
With the exception of provisions on distribution and shipping, which the NRA may not be in a position
to assess.
2
WHO Technical Report Series, No. 1011, Annex 4.
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Name (typed)
Signature
Date
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Appendix 2
Model NRA Lot Release Certificate for viral-vectored
Ebola vaccines
This certificate is to be provided by the NRA of the country where the vaccine
has been manufactured, on request by the manufacturer.
Certificate no.
The following lot(s) of Ebola vaccine produced by 1
in 2
whose lot numbers appear on the labels of the
final containers, complies with the relevant specification in the marketing
authorization and provisions for the release of biological products 3 and Part A4
of the WHO Guidelines on the quality, safety and efficacy of Ebola vaccines 5 and
comply with WHO good manufacturing practices for pharmaceutical products:
main principles,6 WHO good manufacturing practices for biological products,7
and Guidelines for independent lot release of vaccines by regulatory authorities.8
The release decision is based on 9
numbers if necessary);
1
Name of manufacturer.
2
Country of origin.
3
If any national requirements are not met, specify which one(s) and indicate why release of the lot(s) has
nevertheless been authorized by the NRA.
4
With the exception of provisions on distribution and shipping, which the NRA may not be in a position
to assess.
5
WHO Technical Report Series, No. 1011, Annex 2.
6
WHO Technical Report Series, No. 986, Annex 2.
7
WHO Technical Report Series, No. 999, Annex 2.
8
WHO Technical Report Series, No. 978, Annex 2.
9
Evaluation of product-specific summary protocol, independent laboratory testing, and/or specific
procedures laid down in a defined document, etc., as appropriate.
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Annex 3
Guidelines on procedures and data requirements for
changes to approved biotherapeutic products
1. Introduction 184
2. Purpose and scope 185
3. Terminology 186
4. General considerations 191
5. Special considerations 193
5.1 Comparability exercise 193
5.2 Bridging studies 194
5.3 Similar biotherapeutic products 194
6. Reporting categories for quality changes 195
6.1 Major quality changes 196
6.2 Moderate quality changes 196
6.3 Minor quality changes 197
6.4 Quality changes with no impact 197
7. Reporting categories for safety, efficacy and/or product labelling
information changes 198
7.1 Safety and efficacy changes 199
7.2 Product labelling information changes 200
7.3 Urgent product labelling information changes 201
7.4 Administrative product labelling information changes 201
8. Procedures 202
8.1 Procedures for prior approval supplements 206
8.2 Procedures for minor quality changes and quality changes with no impact 209
8.3 Procedures for urgent product labelling
information changes 210
8.4 Procedures for administrative product labelling information changes 211
9. Authors and acknowledgements 211
10. References 214
Appendix 1 Reporting categories and suggested review timelines 216
Appendix 2 Changes to the drug substance 219
Appendix 3 Changes to the drug product 247
Appendix 4 Safety, efficacy and product labelling information changes 276
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Abbreviations
ALIFAR Asociación Latinoamericana de Industrias Farmacéuticas
BSE bovine spongiform encephalopathy
DNA deoxyribonucleic acid
GCP good clinical practice
GLP good laboratory practice(s)
GMP good manufacturing practice(s)
HPLC high-performance liquid chromatography
HSA Health Sciences Authority
ICH International Conference on Harmonisation of Technical
Requirements for Registration of Pharmaceuticals for
Human Use
IFPMA International Federation of Pharmaceutical Manufacturers
& Associations
IGBA International Generic and Biosimilar Medicines Association
IQ installation qualification
MCB master cell bank
NRA national regulatory authority
OQ operational qualification
PAS prior approval supplement
PDA Parenteral Drug Association
PK/PD pharmacokinetic/pharmacodynamic
PPTA Plasma Protein Therapeutics Association
PQ performance qualification
SBP similar biotherapeutic product
TSE transmissible spongiform encephalopathy
WCB working cell bank
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1. Introduction
Biotherapeutic products are an increasingly important component of global
health care. Several WHO guidelines on the evaluation of biotherapeutic
products have been produced (1–3) that provide a set of principles on the
regulatory evaluation of such products. During international consultations on
the development of these guidelines, and their subsequent implementation, it
became clear that there was a need for WHO guidance on making post-approval
changes to biotherapeutic products in order to help address the complexity
and other challenges associated with the global life-cycle management of such
products. In May 2014, the Sixty-seventh World Health Assembly adopted
two relevant resolutions: one on promoting access to biotherapeutic products
and ensuring their quality, safety and efficacy (4) and the other on regulatory
systems strengthening (5). In support of these resolutions, WHO was requested
to provide guidance on how to deal with increasingly complex biotherapeutic
products, including similar biotherapeutic products (SBPs). In addition, the 16th
International Conference of Drug Regulatory Authorities recommended that
WHO assist Member States in ensuring regulatory oversight throughout the life-
cycle of biotherapeutic products (6).
This document is intended to provide guidance to national regulatory
authorities (NRAs) and manufacturers on regulating changes to already licensed
biotherapeutic products in order to assure their continued quality, safety and
efficacy, as well as continuity in supply and access. The term “biotherapeutic
products” as used in this document collectively includes the originator products
and SBPs (also called “biosimilars”).
Changes are essential for the continual improvement of the manufacturing
process and for maintaining state-of-the-art control of biotherapeutic products,
and often need to be implemented after the product has been approved (that is,
WHO Technical Report Series, No. 1011, 2018
when it has been licensed or when marketing authorization has been received).
Changes may be made for a variety of reasons, including: (a) to maintain routine
production (for example, replenishment of reference standards, or change of raw
materials); (b) to improve product quality, or the efficiency and consistency of
manufacture (for example, changes in the manufacturing process, equipment or
facility, or adding a new manufacturing site); (c) to make safety or efficacy changes
(for example, adding a new indication, changing the dosage regimen, or adding
information on co-administration with other medicines); (d) to update product
labelling information (for example, improvement of the management of risk by
addition of a warning statement for a particular target population, or limiting the
target population); or (e) to address administrative changes (for example, change
in the proper/nonproprietary or trade name of a biotherapeutic product).
NRAs and marketing authorization holders should recognize that:
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3. Terminology
The definitions given below apply to the terms used in these WHO Guidelines.
They may have different meanings in other contexts.
Acceptance criteria: criteria, expressed by numerical limits, ranges or
other suitable measures, which should be met to release the drug substance or
drug product or materials at different stages of their manufacture.
Biotherapeutic product: a biological medicinal product with the
indication of treating human disease. For the purpose of these WHO Guidelines,
WHO Technical Report Series, No. 1011, 2018
a medicine. It also refers to a person or legal entity allowed to apply for a change
to the marketing authorization or licence.
Master cell bank (MCB): an aliquot of a single pool of cells which
generally has been prepared from the selected cell clone under defined conditions,
dispensed into multiple containers and stored under defined conditions.
Primary packaging site: site involved in the activity of putting a drug in
its primary container which is, or may be, in direct contact with the dosage form.
Process validation: documented evidence which provides a high degree
of assurance that a specific process will consistently result in a product that
meets its predetermined specifications and quality characteristics.
Product labelling information: refers to printed materials that
accompany a prescription medicine and all labelling items, namely:
■■ prescribing information (an instruction circular that provides
product information on indication, dosage and administration, safety
and efficacy, contraindications, warnings and a description of the
product for health-care providers (also referred to as “summary of
product characteristics” or “package insert” in various countries);
■■ patient labelling or consumer information;
■■ inner label or container label;
■■ outer label or carton.
Quality attribute: a physical, chemical, biological or microbiological
property or characteristic.
Quality change: a change in the manufacturing process, product
composition, quality control testing, equipment or facility. Also referred to as
“chemistry manufacturing and control (CMC) change” in other documents.
Raw materials: a general term used to denote the culture media
components, reagents or solvents intended for use in the production of starting
material, drug substance, intermediates or drug products.
Real-time release testing: testing that provides the ability to evaluate
and ensure the quality of in-process and/or final product based on process data,
which typically include a valid combination of measured material attributes and
process controls (16, 17).
Reference standards/materials: well-characterized materials used as
references against which batches of biological products are assessed. These
materials remain fundamental to ensuring the quality of biological products as
well as the consistency of production, and are essential for the establishment of
appropriate clinical dosing.
Safety and efficacy change: a change that has an impact on the clinical
use of the biotherapeutic product in relation to safety, efficacy, dosage and
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in the original application for the marketing authorization (or product licence)
or any other notification to add to (that is, to supplement) the information in
the original marketing authorization or product licence file. A prior approval
supplement (PAS) is a supplement requiring approval from the NRA prior to
implementation of the change. Also referred to as “change application dossier” in
other documents.
Validation: the demonstration, with documentary evidence, that any
procedure, process, equipment, material, activity or system will consistently
produce a result meeting predetermined acceptance criteria.
Working cell bank (WCB): the working cell bank is prepared from
aliquots of a homogeneous suspension of cells obtained from culturing the
master cell bank under defined culture conditions.
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4. General considerations
Changes to approved biotherapeutic products or SBPs are categorized on the
basis of a risk analysis which takes into consideration the complexity of the
production process and product, the patient population and the proposed
changes. When a change affects the manufacturing or the control strategy, the
assessment should include evaluation of the impact of the change on quality (that
is, identity, strength, purity and potency) as it may relate to the safety and/or
efficacy of the product. When a change affects the clinical use of a product or of
product labelling information, this assessment should include evaluation of the
effect of the change on the safety and efficacy of the product.
Prior to implementing a change with a potential impact on quality, the
marketing authorization holder should demonstrate through appropriate studies
(analytical testing, functional assays and, if needed, clinical and/or nonclinical
studies) that the pre-change and post-change products are comparable in terms
of quality, safety and efficacy.
For each change, the marketing authorization holder should decide if the
information in the original marketing authorization or product licence needs
to be supplemented (that is, requires an official submission of a supplement to
the NRA) based on the recommendations provided in these WHO Guidelines.
Supplements requiring approval by the NRA prior to the implementation of a
change – that is, for changes that potentially have a major or moderate impact
– are referred to as prior approval supplements (PASs) and must be submitted
in advance to the NRA. For supplements that do not require approval prior
to implementation – that is, for changes that potentially have a minor impact
on product quality – the NRA should be notified following implementation of
the change.
For each change, the supplement should contain information developed
by the marketing authorization holder to allow the NRA to assess the effects
of the change. All changes, regardless of their impact on quality, safety and
efficacy, should be recorded and retained by the manufacturer or marketing
authorization holder in accordance with the applicable regulatory requirements
for document retention (8, 9).
For manufacturing changes not specifically described in these WHO
Guidelines, the marketing authorization holder is encouraged to use scientific
judgement, leverage competent regulatory authority guidance or to contact the
NRA to determine the potential impact of the change on quality, safety and
efficacy in order to discuss the appropriate reporting category.
Assessment of the extent to which a quality change (also referred to as a
manufacturing change) affects the quality attributes of the product is generally
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approved by another competent NRA, the NRA receiving the submission may
choose to recognize this approval decision or may make an independent decision
based on its own assessment. Foreign approval documentation may accompany
the required information and may be used as supporting evidence for the post-
approval change, as outlined in this document. The responsibility for the final
regulatory decision on the approval of the change still lies with the receiving
NRA (see section 8 and Appendix 1).
To ensure product supply and encourage adequate reporting of changes
by manufacturers, NRAs should consider establishing procedures for the
concurrent (that is, parallel) review of changes to the product. The manufacturing
of biotherapeutic products requires, for example, the replenishment of biological
starting materials such as WCBs and secondary/working reference standards
which are considered as routine changes. Consequently, these changes often
need to be reviewed concurrently with other manufacturing or safety and efficacy
changes. Conversely, clinical safety and efficacy changes, such as the addition of a
new indication or new age group for the use of a biotherapeutic product, require
considerable supporting data including clinical studies; thus, review time should
not impact the review of unrelated manufacturing changes or the immediate
implementation of urgent changes to product labelling information. However,
multiple related changes, or those supported by the same information, may be
submitted in the same supplement (see “Multiple changes” in section 8).
In these WHO Guidelines, descriptions of the reporting categories
for quality changes are provided in section 6, and the reporting categories for
information changes on safety, efficacy and product labelling are provided in
section 7. Proposed regulatory procedures for the reporting of changes to NRAs
are described in section 8. Examples of suggested review timelines for changes in
the various categories are given in Appendix 1. A comprehensive list of quality
changes and the type of information that should be included in a supplement
application are provided in Appendix 2 (for the drug substance and intermediates)
and in Appendix 3 (for the drug product). Examples of changes that affect clinical
use of a product and product labelling information (on safety, efficacy, dosage,
administration and product components) are provided in Appendix 4.
5. Special considerations
5.1 Comparability exercise
The need for – and extent of – a comparability exercise depends upon the
potential impact of the change(s) on the quality, safety and efficacy of the
product. Comparability exercises can range from analytical testing alone (for
example, where process changes have no impact on any quality attribute) to a
comprehensive exercise requiring nonclinical and clinical bridging studies. For
example, a change in the culture conditions or in the purification process may
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cause the alteration of the glycosylation profile of the product, including site-
directed glycosylation. Alteration of glycosylation profiles may cause a change
in the pharmacokinetic/pharmacodynamic (PK/PD) profile of the product (see
also section 5.2 on “Bridging studies”). If comparability can be demonstrated
through analytical studies alone, nonclinical or clinical studies with the post-
change product are not necessary. However, where the relationship between
specific quality attributes and safety and efficacy has not been established, and/
or differences are observed between some critical quality attributes of the pre-
change and post-change product, it may be necessary to include a combination
of quality, nonclinical and/or clinical studies in the comparability exercise (1, 11).
of administration; and (f) a new dosing schedule. For these and comparable
changes, any proposed use of alternative approaches to a bridging study must be
justified and discussed with the NRA.
given to the reference product after approval of an SBP should not automatically
be given to the SBP. However, when new safety information on the reference
product is added after the original approval of the SBP, the labelling information
changes of the SBP should follow the changes made for the reference product
unless it can be demonstrated that the new information on the reference product
is not relevant to the SBP.
support each change. The quality changes listed in Appendices 2 and 3 should
be reported or recorded in the appropriate categories, as recommended in
this section and in the appendices. If a quality change may potentially have an
impact on the quality, safety and efficacy of the biotherapeutic product, but is
not included in Appendix 2 or 3, the NRA may be consulted for the correct
classification. When procedures and timelines for such consultations are not in
place, manufacturers should determine the classification of the change on the
basis of a change-specific risk assessment using the principles and examples
provided in these WHO Guidelines. The NRA should consider establishing a
mechanism that allows for its guidelines to be updated to address technological
changes requiring regulatory category classifications.
(d) updated product labelling information. In some cases, major quality changes
may also require nonclinical and/or clinical data. Relevant considerations on
the data required can be found in the WHO Guidelines on the quality, safety
and efficacy of biotherapeutic protein products prepared by recombinant DNA
technology (1).
requirements for the PAS for moderate quality changes are the same as those
for major quality changes (see section 6.1); however, the amount of supporting
data required will generally be less than that required for major changes and the
review timeline should be shorter.
1
Some NRAs consider that changes in the route of administration or strength may require a new marketing
authorization.
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Product labelling information changes are changes to the labelling items that
have the potential to improve the management of risk to the population for
which use of the biotherapeutic product is currently approved through:
■■ the identification or characterization of any adverse event resulting
in the addition or strengthening of risk-management measures
for an adverse event considered to be consistent with a causal
association with the biotherapeutic product concerned;
■■ the identification of subgroups for which the benefit-to-risk profile
of the biotherapeutic product has the potential to be less favourable;
and
■■ the addition or strengthening of risk-management measures,
including instructions on dosing or any other conditions of use.
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8. Procedures
The establishment of procedures and criteria for the adequate oversight of
changes to approved biotherapeutic products is the responsibility of the
regulator. Therefore, NRAs should establish written instructions regarding
submission procedures and timelines (with action dates) for consultation by
marketing authorization holders as they prepare to submit a supplement for
a change. These instructions should cover: (a) the identification of emergency
use; (b) expanded access; and (c) expedited and/or priority review, timelines
and procedures for life‑saving medications to address an unmet need. As
supplements for a major quality change or an efficacy and safety change require
extensive documentation and data, the review times should be longer than those
for supplements for moderate quality changes or product labelling information
changes. Furthermore, NRAs may establish different timelines for the review of
major quality changes that do not require clinical data as compared with safety
and efficacy changes that do require clinical data. Appendix 1 provides examples
of different regulatory categories and their suggested review timelines.
If a change is not included in Appendices 2, 3 or 4, marketing
authorization holders are encouraged to use scientific judgement, leverage
competent regulatory authority guidance or to contact the NRA to determine the
appropriate category of a supplement prior to submission of the information in
WHO Technical Report Series, No. 1011, 2018
exchange information effectively, and that the roles and responsibilities of each
unit are clearly defined, particularly when they operate as separate entities. When
multiple units are involved in the evaluation of a supplement, a formal decision-
making process should be in place to discuss, for example, whether a change may
require a GMP inspection or may be reviewed during the next routine inspection.
Procedures should also be established so that the outcomes of inspections are
verified or taken into account prior to the approval of supplements. Good
coordination and communication between different units of the NRA are pivotal
in ensuring continuity of supply and access to products of assured quality, safety
and efficacy. Some regulatory authorities may be willing to cooperate more
closely and to share information on GMP inspections under a mutual agreement
(for example, the Pharmaceutical Inspection Cooperation Scheme – PIC/S).
relevant changes.
■■ The NRA performs an assessment of the decision of the NRA of the
licensing country to determine whether recognition of that NRA’s
decision is appropriate. The submission consists of:
–– the covering letter from the marketing authorization holder
informing the procuring NRA of the change;
–– a copy of the approval letter issued by the NRA of the licensing
country;
–– assessment reports and relevant correspondence from the NRA
of the licensing country (if made available by the NRA);
–– a detailed description of the change; and
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Multiple changes
Multiple related changes, involving various combinations of individual changes,
may be submitted in the same supplement. For example, a manufacturing site
change may also involve changes to the equipment and manufacturing process.
For submissions that include multiple changes, the marketing authorization
holder should clearly specify which data support each change.
Multiple major or moderate quality changes for the same product may be
filed in a single submission provided that the changes are related and/or supported
by the same information. Minor quality changes that were implemented previously
and that are related and/or consequential to a moderate or major quality change
should be described in the PAS for the moderate or major quality change. If
the proposed changes are related, the marketing authorization holder should
indicate the association between them. The marketing authorization holder
should also clearly specify which supporting data support which change. Such
changes could affect both the drug substance and the drug product. If too many
changes are filed within the same submission, or if major issues are identified
with a change and extensive time would be required to review them, the NRA
may ask the marketing authorization holder to divide the changes into separate
submissions and to resubmit the file. If the recommended reporting categories
for the individual changes differ, the submission should be in accordance with
the most restrictive of the categories recommended for the individual changes.
In the case of numerous changes of the same category, the NRA may reclassify
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the submission to the next higher level on the basis of the potential impact of the
totality of the changes on the quality, safety and efficacy of the biotherapeutic
product or SBP. This reclassification should be communicated to the marketing
authorization holder at the start of the assessment.
The NRA should establish procedures and timelines for the review of
marketing authorization holders’ responses to the notification of noncompliance
in cases where the review has been stopped. Documentation subsequent to
the original supplement submission (in response to information requests or
notifications of noncompliance) should be submitted and filed as amendments
to the original supplement, and all communications with sponsors should be
properly recorded.
Appeal procedures should be established for resolving disagreements
and disputes between the NRA and the marketing authorization holder. Such
procedures should allow the marketing authorization holder to request a
re‑evaluation of the submitted application in case the application is initially
rejected by the NRA.
NRAs may consider the use of a “comparability protocol” when a
marketing authorization holder submits changes:
Comparability protocol
A comparability protocol (also referred to as “post-approval change management
protocol” in other documents) establishes a framework for a well-defined plan
WHO Technical Report Series, No. 1011, 2018
for future implementation of a quality change. This will include the tests to be
done and acceptable limits to be achieved when assessing the effect of specific
changes on the quality, safety or efficacy of a biotherapeutic product or SBP. For
some changes, the routine quality tests performed to release the drug substance
or drug product are not considered sufficient for assessing the impact of the
change, and additional in-process tests and characterization tests may be needed.
Comparability protocols are often used for the routine replenishment of WCBs
and reference standards used in quality control tests when the remaining aliquots
of reference standards expire or diminish.
The purpose of a comparability protocol is to provide transparency in
the data requirements for changes and increase the predictability of the effects
of changes. This allows for the more expedient distribution of a product by
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Production documents
Production documents (that is, executed batch records) are not generally
required to support changes to the marketing authorization dossier or product
licence. However, such documents may be requested during review and should
be made available to the NRA on request. These documents should be retained
in accordance with GMP and should be available in their local official language
during inspections. If English translations are required, NRAs are encouraged
to establish a mechanism to make this requirement known to marketing
authorization holders accordingly.
dedicated to minor changes. The documents or files for all minor quality changes
should be available to the NRA on request or during inspection.
NRAs may audit minor quality changes by requesting and reviewing the
supporting data, as deemed appropriate during an inspection or review of related
changes. If the classification of a change or the supporting data are not considered
to be acceptable then the marketing authorization holder may be requested to file
a supplement for a major or moderate quality change.
Minor quality changes that have previously been implemented and are
related and/or consequential to a major or moderate quality change should be
described in the relevant parts of the documentation when submitting a PAS for
the major or moderate change. As for all minor quality changes, the supporting
data for these changes do not need to be included in the supplement but should
be retained by the manufacturer.
Changes that have no impact on the quality, safety and efficacy of the
product are not reported, but if the NRA determines (during an inspection or a
review of related changes) that the information for the change fails to demonstrate
the continued safety or efficacy of the product manufactured using the changes,
the NRA may work to resolve the problem with the marketing authorization
holder. If the NRA finds that the product in distribution poses a danger to public
health, or if it determines that there are unresolved issues, it may require the
marketing authorization holder to cease distribution of the product manufactured
using the changes or to remove the product from distribution pending resolution
of the issues related to the changes.
10. References
1. Guidelines on the quality, safety and efficacy of biotherapeutic protein products prepared by
recombinant DNA technology. In: WHO Expert Committee on Biological Standardization: sixty-
fourth report. Geneva: World Health Organization; 2014: Annex 4 (WHO Technical Report Series,
No. 987; http://www.who.int/biologicals/biotherapeutics/TRS_987_Annex4.pdf?ua=1, accessed
12 December 2017).
2. Guidelines on evaluation of similar biotherapeutic products (SBPs). In: WHO Expert Committee
on Biological Standardization: sixtieth report. Geneva: World Health Organization; 2013:
Annex 2 (WHO Technical Report Series, No. 977; http://who.int/biologicals/publications/trs/areas/
biological_therapeutics/TRS_977_Annex_2.pdf, accessed 12 December 2017).
3. Guidelines on evaluation of monoclonal antibodies as similar biotherapeutic products (SBPs). In:
WHO Expert Committee on Biological Standardization: sixty-seventh report. Geneva: World Health
Organization; 2017: Annex 2 (WHO Technical Report Series, No. 1004; http://who.int/biologicals/
biotherapeutics/WHO_TRS_1004_web_Annex_2.pdf?ua=1, accessed 17 March 2018).
4. Resolution WHA67.21. Access to biotherapeutic products including similar biotherapeutic
products and ensuring their quality, safety and efficacy. Sixty-seventh World Health Assembly,
Geneva, 18–26 May 2014. Geneva: World Health Organization; 2014 (http://apps.who.int/gb/
ebwha/pdf_files/WHA67/A67_R21-en.pdf, accessed 12 December 2017).
5. Resolution WHA67.20. Regulatory system strengthening for medical products. Sixty-seventh
World Health Assembly, Geneva, 18–26 May 2014. Geneva: World Health Organization; 2014
(http://apps.who.int/gb/ebwha/pdf_files/WHA67/A67_R20-en.pdf, accessed 12 December 2017).
6. Recommendations of the 16th International Conference of Drug Regulatory Authorities, Rio
de Janeiro, Brazil, 24–29 August 2014 (http://www.who.int/medicines/areas/quality_safety/
regulation_legislation/icdra/16_ICDRA_Recommendations2014.pdf?ua=1, accessed 12 December
2017).
7. Guidelines on procedures and data requirements for changes to approved vaccines. In: WHO
Expert Committee on Biological Standardization: sixty-fifth report. Geneva: World Health
Organization; 2014 2015: Annex 4 (WHO Technical Report Series, 993; http://www.who.int/
biologicals/vaccines/Annex4_Guidelines_changes_to_approved_vaccines_eng.pdf?ua=1,
accessed 12 December 2017).
8. WHO good manufacturing practices for biological products. In: WHO Expert Committee on
WHO Technical Report Series, No. 1011, 2018
Biological Standardization: sixty-sixth report. Geneva: World Health Organization; 2016: Annex 2
(WHO Technical Report Series, No. 999; http://www.who.int/biologicals/areas/vaccines/Annex_2_
WHO_Good_manufacturing_practices_for_biological_products.pdf?ua=1, accessed 12 December
2017).
9. WHO good manufacturing practices for pharmaceutical products: main principles. In: WHO
Expert Committee on Specifications for Pharmaceutical Preparations: forty-eighth report. Geneva:
World Health Organization; 2014: Annex 2 (WHO Technical Report Series, No. 986; http://www.
who.int/medicines/areas/quality_safety/quality_assurance/TRS986annex2.pdf?ua=1, accessed
12 December 2017).
10. WHO general guidance on variations to multisource pharmaceutical products. WHO Expert
Committee on Specifications for Pharmaceutical Preparations: fiftieth report. Geneva: World
Health Organization; 2016: Annex 10 (WHO Technical Report Series, No. 996; http://www.who.
int/medicines/publications/pharmprep/WHO_TRS_996_annex10.pdf, accessed 17 March 2018).
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Appendix 1
Reporting categories and suggested review timelines
It is recommended that NRAs establish review timelines to allow marketing
authorization holders or applicants to plan the implementation of changes. The
review timelines are established taking into consideration the country or regional
situation, the capability of the NRA, the impact of the change and the amount of
data required to support the change. Consequently, the review time frames for
major changes should be longer than those for moderate changes. The suggested
review times in the table below are shown as examples; they are based on the
experience of several NRAs and apply to situations where the NRA performs a
full review or assessment of the supplement. The review time would start when
the supplement has been accepted for review and found to be complete, and
would end at the time when the initial assessment is shared with the marketing
authorization holder by the issuance of either a notification of approval or a
notification of noncompliance with a list of comments and deficiencies. In case
of the latter, the marketing authorization holder may seek approval for the change
by submitting an amendment to the supplement with responses to all the
comments in the notification of noncompliance. The NRA should also establish
timelines for the secondary review cycle following the receipt of responses from
the marketing authorization holder. If minor deficiencies are identified during
the initial review cycle, the NRA may communicate these to the marketing
authorization holder without stopping the review clock in order to try to finalize
the assessment within the established timeline (see section 8.1).
Expedited implementation procedures should be in place for dealing
with product labelling information changes which address urgent safety issues
(see section 8.3).
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Table continued
Safety, efficacy and product labelling information changes
Reporting category Procedure Suggested review timeline
Safety and efficacy PAS 10 months
changes
Product labelling PAS 5 months
information changes
Urgent product labelling PAS for urgent safety Immediate implementation
information changes c restrictions on receipt of supplement
by the NRA
Administrative product PAS 30 days
labelling information
Do not require N/A
changes
approval prior to
implementation d
N/A: not applicable.
a
Each NRA is responsible for determining the timeline for reporting the notification (for example, annually).
However, NRAs should establish a mechanism to ensure that notifications are received no later than one year
post-implementation. In a case where a minor quality change results from the use of a comparability protocol, the
change should be notified to the NRA immediately after implementation.
b
Minor quality changes impacting the registered details may be bundled with moderate or major quality changes,
if needed.
c
Urgent product labelling information changes are applicable only to label changes which address urgent safety
updates or have the potential to have an impact on public health, with immediate implementation allowed after
prior agreement between NRAs and marketing authorization holders.
d
Administrative product labelling information changes that do not require approval prior to implementation and
that have been implemented since the last approved product labelling information change should be reported by
including all changes in subsequent PAS for safety and efficacy changes or product labelling information changes
when updated product labelling information is included.
NRAs that procure biotherapeutic products from countries other than their own
are encouraged to establish alternative accelerated timelines for changes that
have previously been approved by the other NRAs. Accordingly, those NRAs
should create a list of the NRA approvals they will recognize. On the basis of
the regulatory pathway options provided in section 8, the following examples
of accelerated timelines could be established:
■■ The NRA recognizes the decision of other regulatory authorities
and does not perform a review of supporting data but is informed
of the change. Using this approach, NRAs could allow changes to be
implemented immediately after receipt of the change notification.
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Appendix 2
Changes to the drug substance
The examples presented in this appendix are intended to assist with the
classification of changes made to the quality information for the drug substance.
The information summarized in the table below provides guidance on:
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authorized by the NRA in the case of major and moderate quality changes and
to changes that have been implemented in the case of minor quality changes.
For example, the qualification of a new lot of reference standard against the
approved reference standard may be considered a minor quality change if the
qualification of a new standard is performed in accordance with an approved
protocol and specification. Nevertheless, these changes must be reported to the
NRA or national control laboratory as appropriate.
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Manufacture
Description of change Conditions to Supporting Reporting
be fulfilled data category
1. Change to a drug substance manufacturing facility:
Note: For the purpose of this change, manufacturing refers to unit operations in the
manufacturing process of the drug substance and is not intended to refer to quality control
testing, storage or transportation.
a. Replacement or addition of a None 1–4, 6–8 Major
manufacturing facility for the
bulk drug substance or any 1–3 1–8 Moderate
intermediate
b. Conversion of a drug 4 9, 10 Moderate
substance manufacturing
facility from single-product
to multi-product
c. Deletion of a manufacturing 5, 6 None Minor
facility or manufacturer
of an intermediate drug
substance, or bulk
Conditions
1. The proposed facility is an approved drug substance facility for biotherapeutics (for
the same company/marketing authorization holder).
2. Any changes to the manufacturing process and/or controls are considered either
moderate or minor (for example, duplication of product line).
3. The new facility/suite is under the same quality assurance/quality control oversight.
4. The proposed change does not involve additional containment requirements.
5. There should remain at least one site/manufacturer, as previously authorized,
performing the same function as the one(s) to be deleted.
6. The deletion should not be due to critical deficiencies in manufacturing (for
example, recurrent out-of-specification events, environmental monitoring failures,
etc.).
Supporting data
1. Evidence of GMP compliance of the facility.
2. Name, address and responsibilities (for example, fermentation, purification) of the
proposed facility.
3. Summary of the process validation studies and results.
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Table continued
4. Comparability of the pre-change and post-change drug substance with
respect to physicochemical properties, biological activity, purity, impurities and
contaminants, as appropriate. Nonclinical and/or clinical bridging studies may
be required if quality data alone are insufficient to establish comparability. The
extent and nature of nonclinical and/or clinical studies should be determined on
a case-by-case basis, taking into consideration the quality comparability findings,
the nature and level of the knowledge of the product, existing relevant nonclinical
and clinical data, and aspects of their use.
5. Justification for the classification of any manufacturing process and/or control
changes as moderate or minor.
6. Description of the batches and summary of in-process control and release testing
results as quantitative data, in a comparative tabular format, for at least three
consecutive commercial-scale batches of the pre-change and post-change drug
substance. Comparative pre-change test results do not need to be generated
concurrently; relevant historical testing results are acceptable. Matrixing,
bracketing, use of smaller-scale batches, use of fewer than three batches and/or
leveraging data from scientifically justified representative batches, or batches not
necessarily manufactured consecutively, may be acceptable where justified and
agreed by the NRA.
7. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug substance batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
commit to undertake real-time stability studies to confirm the full shelf-life/hold-
time of the drug substance under its normal storage conditions and to report
WHO Technical Report Series, No. 1011, 2018
to the NRA any failures in these ongoing long-term stability studies. Matrixing,
bracketing, use of smaller-scale batches and/or use of fewer than three batches of
drug substance for stability testing may be acceptable where justified (6).
8. Updated post-approval stability protocol.
9. Information describing the change-over procedures for shared product-contact
equipment and the segregation procedures, as applicable. If no revisions, the
manufacturer should state that no changes were made to the change-over
procedures.
10. Cleaning procedures (including data in a summary validation report and
the cleaning protocol for the introduction of new products, as applicable)
demonstrating lack of carry-over or cross-contamination.
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Table continued
5. Comparability of the pre-change and post-change drug substance with respect to
physicochemical properties, biological activity, purity, impurities and contaminants,
as appropriate. Nonclinical and/or clinical bridging studies may occasionally be
required when quality data are insufficient to establish comparability. The extent
and nature of nonclinical and/or clinical studies should be determined on a case-
by-case basis, taking into consideration the quality-comparability findings, the
nature and level of knowledge of the product, existing relevant nonclinical and
clinical data, and aspects of its use.
6. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for at least three consecutive
commercial-scale batches of the drug substance derived from the new cell bank.
Matrixing, bracketing, use of smaller-scale batches, use of fewer than three
batches and/or leveraging data from scientifically justified representative batches,
or batches not necessarily manufactured consecutively, may be acceptable where
justified.
7. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug substance batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
commit to undertake real-time stability studies to confirm the full shelf-life/hold-
time of the drug substance under its normal storage conditions and to report to the
NRA any failures in these ongoing long-term stability studies. Matrixing, bracketing,
the use of smaller-scale batches and/or the use of fewer than three batches of drug
substance for stability testing may be acceptable where justified (6).
8. Updated post-approval stability protocol.
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
7. Change to the purification process, involving the following:
a. A critical change (a change None 1, 2, 5–7, 9, Major
with high potential to have 11, 12
an impact on the quality
of the drug substance or
drug product, for example, a
change that could potentially
have an impact on the viral
clearance capacity of the
process or the impurity profile
of the drug substance)
b. A change with moderate 1, 3 1, 2, 5–7, Moderate
potential to have an impact 10–12
on the quality of the drug
substance or drug product
(for example, a change in the
chemical separation method,
such as ion-exchange HPLC 1
to reversed-phase HPLC)
c. A noncritical change with 1–4 1, 2 Minor
minimal potential to have
an impact on the quality
of the drug substance or
drug product (for example,
addition of an in-line filtration
step equivalent to the
approved filtration step)
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1
HPLC = high-performance liquid chromatography.
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Table continued
Conditions
1. The change does not have an impact on the viral clearance data or the chemical
nature of an inactivating agent.
2. There is no change in the drug substance specification outside the approved limits.
3. There is no change in the drug substance impurity profile outside the approved
limits.
4. The change is not necessitated by recurring events arising during manufacture or
because of stability concerns.
5. The change does not affect the purification process.
6. The change in scale is linear with respect to the proportionality of production
parameters and materials.
7. The new fermentation train is identical to the approved fermentation train(s).
8. There is no change in the approved in vitro cell age.
9. The change is not expected to have an impact on the quality, safety or efficacy of
the final product.
10. There is no change in the proportionality of the raw materials (that is, the change
in scale is linear).
11. The change in scale involves the use of the same bioreactor (that is, it does not
involve the use of a larger bioreactor).
12. The need for reprocessing is not due to recurrent deviations from the validated
process, and the root cause triggering reprocessing is identified.
13. The proposed reprocessing steps have been shown to have no impact on product
quality.
Supporting data
1. Justification for the classification of the change(s) as critical, moderate or
noncritical in terms of its impact on the quality of the drug substance.
2. Flow diagram (including process and in-process controls) of the proposed
manufacturing process(es) and a brief narrative description of the proposed
manufacturing process(es).
3. If the change results in an increase in the number of population doublings or
subcultivations, information on the characterization and testing of the post-
production cell bank for recombinant product or of the drug substance for non-
recombinant product.
4. For drug substance obtained from, or manufactured with, reagents obtained
from sources that are at risk of transmitting bovine spongiform encephalopathy/
transmissible spongiform encephalopathy (BSE/TSE) agents (for example,
ruminant origin), information and evidence that the material does not pose a
potential BSE/TSE risk (for example, name of manufacturer, species and tissues
from which the material is a derivative, country of origin of the source animals, use
and previous acceptance of the material) (7).
5. Process validation results.
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Table continued
6. Comparability of the pre-change and post-change drug substance with
respect to physicochemical properties, biological activity, purity, impurities
and contaminants, as appropriate. Nonclinical and/or clinical bridging studies
may occasionally be required when quality data are insufficient to establish
comparability. The extent and nature of nonclinical and/or clinical studies should
be determined on a case-by-case basis, taking into consideration the quality–
comparability findings, the nature and level of knowledge of the product, existing
relevant nonclinical and clinical data, and aspects of its use.
7. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for at least three consecutive
commercial-scale batches of the pre-change and post-change drug substance.
Comparative pre-change test results do not need to be generated concurrently;
relevant historical testing results are acceptable. Matrixing, bracketing, the use
of smaller-scale batches, the use of fewer than three batches and/or leveraging
data from scientifically justified representative batches, or batches not necessarily
manufactured consecutively, may be acceptable where justified.
8. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for one commercial-scale
batch of the pre-change and post-change drug substance. Comparative pre-
change test results do not need to be generated concurrently; relevant historical
testing results are acceptable. Batch data on the next two full-production batches
should be made available on request and should be reported by the marketing
authorization holder if outside the specification (with proposed action). The use of
a smaller-scale batch may be acceptable where justified and.
9. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug substance batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months and one batch of real-time data could
be acceptable if properly justified (for example, it can be proven that the relevant
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10. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes with at least one commercial-scale
drug substance batch produced with the proposed changes under real-time/
real-temperature testing conditions. Comparative pre-change test results do
not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Test results that cover a minimum of
6 months in real-time/real-temperature conditions should also be provided. A
possibility of 3 months of real-time data could be acceptable if properly justified
(for example, it can be proven that the relevant effect, if present, can already be
observed within 3 months). Additionally, the manufacturer should commit to
undertake real-time stability studies to confirm the full shelf-life/hold-time of the
drug substance under its normal storage conditions and to report to the NRA
any failures in these ongoing long-term stability studies. Matrixing, bracketing,
the use of smaller-scale batches and/or use of forced degradation or accelerated
temperature conditions for stability testing may be acceptable where justified.
11. Updated post-approval stability protocol and stability commitment to place the
first commercial-scale batch of the drug product manufactured using the post-
change drug substance into the stability programme.
12. Information assessing the risk with respect to potential contamination with
adventitious agents (for example, impact on viral clearance studies and BSE/TSE
risk) (7).
13. Data describing the root cause triggering the reprocessing, as well as validation
data (for example, extended hold-times, resistance to additional mechanical
stress) to help prevent the reprocessing from having an impact on the drug
substance.
14. Demonstration that the new or revised holding step has no negative impact on
the quality of the drug substance (data from one commercial-scale or scientifically
justified representative drug substance batch should be provided).
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
b, Introduction of new None 1, 3–5 Moderate
equipment with the same
operating principles but 3, 4 1, 4, 5 Minor
different product contact
material
c. Introduction of new None 1–3, 5 Moderate
equipment with different
operating principles but 4 1, 2, 5 Minor
the same product contact
material
d. Replacement of product- None 3 Minor
contact equipment with
equivalent equipment
e. Change of product-contact 1, 2 1, 6 Minor
equipment from dedicated to
shared
f. Relocation of major 2, 4, 5 None Minor
equipment to another room
in the same facility/suite/
premises
Conditions
1. The site is approved as a multi-product facility.
2. The change has no impact on the risk of cross-contamination and is supported by
validated cleaning procedures.
3. The manufacturing process is not impacted by the change in product-contact
WHO Technical Report Series, No. 1011, 2018
equipment.
4. The change has no impact on product quality.
5. Re-qualification of the equipment follows the original qualification protocol.
Supporting data
1. Information on the in-process control testing.
2. Process validation study reports.
3. Description of the batches and summary of results as quantitative data, in a
comparative tabular format, for one commercial-scale batch of the drug substance
produced with the approved and proposed product contact equipment/material.
Batch data on the next two full-production batches should be made available
on request and reported by the marketing authorization holder if outside
specification (with proposed action).
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4. Information on leachables and extractables.
5. Information on the new equipment and comparison of similarities and differences
regarding operating principles and specifications between the new and the
replaced equipment.
6. Information describing the change-over procedures for the shared product-
contact equipment.
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Table continued
7. The test does not concern a critical attribute (for example, content, impurity, any
critical physical characteristics or microbial purity).
8. The change is for compendial raw materials of biological origin (excluding human
plasma-derived materials).
Supporting data
1. Revised information on the quality and controls of the materials (for example,
raw materials, starting materials, solvents, reagents and catalysts) used in the
manufacture of the post-change drug substance.
2. Updated drug substance specification, if changed.
3. Copies or summaries of analytical procedures if new analytical procedures are used.
4. For drug substance obtained from, or manufactured with, reagents obtained
from sources that are at risk of transmitting bovine spongiform encephalopathy/
transmissible spongiform encephalopathy (BSE/TSE) agents (for example,
ruminant origin), information and evidence that the material does not pose a
potential BSE/TSE risk (for example, name of manufacturer, species and tissues
from which the material is a derivative, country of origin of the source animals, use
and previous acceptance of the material) (7).
5. Comparative table or description, where applicable, of pre-change and post-
change in-process tests/limits.
6. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for one commercial-scale
batch of the pre-change and post-change drug substance. Comparative pre-
change test results do not need to be generated concurrently; relevant historical
testing results are acceptable. Batch data on the next two full-production batches
should be made available on request and reported by the marketing authorization
holder if outside specification (with proposed action). The use of a smaller-scale
batch may be acceptable where justified.
7. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for three consecutive
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Table continued
Supporting data
1. Revised information on the controls performed at critical steps of the
manufacturing process and on intermediates of the proposed drug substance.
2. Updated drug substance specification, if changed.
3. Copies or summaries of analytical procedures if new analytical procedures are used.
4. Comparative table or description, where applicable, of pre-change and post-
change in-process tests/limits.
5. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for one commercial-scale
batch of the pre-change and post-change drug substance. Comparative pre-
change test results do not need to be generated concurrently; relevant historical
testing results are acceptable. Batch data on the next two full-production batches
should be made available on request and reported by the marketing authorization
holder if outside specification (with proposed action). The use of a smaller-scale
batch may be acceptable where justified.
6. Description of the batches and summary of in-process and release testing results
as quantitative data, in a comparative tabular format, for three consecutive
commercial-scale batches of the pre-change and post-change drug substance.
Comparative pre-change test results do not need to be generated concurrently;
relevant historical testing results are acceptable. Matrixing, bracketing, the use
of smaller-scale batches, the use of fewer than three batches and/or leveraging
data from scientifically justified representative batches, or batches not necessarily
manufactured consecutively, may be acceptable where justified.
7. Justification/risk assessment showing that the attribute is non-significant.
8. Justification for the new in-process test and limits.
9. Evidence that the new company/facility is GMP-compliant.
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Conditions
1. The reduction in design space is not necessitated by recurring problems arising
during manufacture.
Supporting data
1. Manufacturing development data to support the establishment of, or changes to,
the design space.
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Supporting data
1. Revised drug product labelling information, as applicable.
2. Updated copy of the proposed drug substance specifications.
3. Where an in-house analytical procedure is used and a pharmacopoeial standard/
monograph is claimed, results of an equivalency study between the in-house and
pharmacopoeial methods.
4. Copies or summaries of validation reports if new analytical procedures are used.
5. Justification of specifications with data.
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
e. Change from an in-house None 1–5 Moderate
analytical procedure to a
recognized compendial/ 2, 6 1–3 Minor
pharmacopoeial analytical
procedure
f. Widening of an approved None 1, 5, 6 Moderate
acceptance criterion
g. Narrowing of an approved 1, 4, 7 1 Minor
acceptance criterion
Conditions
1. The change does not result from unexpected events arising during manufacture
(for example, new unqualified impurity, change in total impurity limits).
2. There is no change in the limits/acceptance criteria outside the approved limits for
the approved assays used at release/ stability.
3. The addition of the test is not intended to monitor new impurity species.
4. The method of analysis is the same and is based on the same analytical technique
or principle (for example, change in column length or temperature, but not a
different type of column or method) and no new impurities are detected.
5. The modified analytical procedure maintains or improves performance
parameters of the method.
6. The change does not concern potency-testing.
7. Acceptance criteria for residual solvent are within recognized or approved
acceptance limits (for example, within ICH limits for a Class 3 residual solvent, or
pharmacopoeial requirements).
8. The change is from one pharmacopoeial assay to another pharmacopoeial assay or
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Table continued
Supporting data
1. Justification for the change in reference standard.
2. Information demonstrating qualification of the proposed reference standards
or materials (for example, source, characterization, certificate of analysis,
comparability data).
3. Justification of the change to the reference standard qualification protocol.
4. Updated reference standard qualification protocol.
5. Summary of stability testing and results to support the extension of reference
standard shelf-life.
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Table continued
4. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating parameters with commercial-scale drug
substance material using several container batches (for example, three different
batches) produced with the proposed changes and stored under accelerated and/
or stress conditions for a minimum of 3 months. Test results that cover a minimum
of 6 months in real-time/real-temperature conditions should also be provided. A
possibility of 3 months of real-time data could be acceptable if properly justified
(for example, it can be proven that the relevant effect, if present, can already be
observed within 3 months). Comparative pre-change test results do not need to
be generated concurrently; relevant historical results for batches on the stability
programme are acceptable. Additionally, the manufacturer should commit to
undertake real-time stability studies to confirm the full shelf-life/hold-time of the
drug substance under its normal storage conditions and to report to the NRA any
failures in these ongoing long-term stability studies. Matrixing, bracketing, the use
of smaller-scale batches and/or the use of fewer than three container batches for
stability testing may be acceptable where justified (6).
5. Comparative table of pre-change and post-change specifications of the container
closure system.
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Table continued
3. Test results that cover a minimum of 6 months in real-time/real-temperature
conditions should also be provided. A possibility of 3 months of real-time data could
be acceptable if properly justified (for example, it can be proven that the relevant
effect, if present, can already be observed within 3 months). Comparative pre-
change test results do not need to be generated concurrently; relevant historical
results for batches on the stability programme are acceptable. Additionally, the
manufacturer should commit to undertake real-time stability studies to confirm the
full shelf-life/hold-time of the drug substance under its normal storage conditions
and to report to the NRA any failures in these ongoing long-term stability studies.
Matrixing, bracketing, the use of smaller-scale batches and/or the use of fewer
than three batches of drug substance for stability testing may be acceptable where
justified (6).
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6. Results of method validation demonstrate that the new or modified analytical
procedure is at least equivalent to the approved analytical procedure.
7. The new or modified analytical procedure maintains or tightens precision,
accuracy, specificity or sensitivity.
8. The change is within the range of approved acceptance criteria.
Supporting data
1. Updated copy of the proposed specification for the primary container closure
system.
2. Rationale for the change.
3. Description of the analytical procedure and, if applicable, validation data.
Stability
Description of change Conditions to Supporting Reporting
be fulfilled data category
32. Change in the shelf-life of the drug substance or for a stored
intermediate of the drug substance, involving the following:
a. Extension None 1–5 Moderate
1–4 1, 2, 5 Minor
b. Reduction None 1–5 Moderate
5 2–4 Minor
Conditions
1. There are no changes to the container closure system in direct contact with the
drug substance with the potential of impact on the drug substance, or to the
recommended storage conditions of the drug substance.
2. Full long-term stability data are available covering the proposed shelf-life and are
based on stability data generated on at least three commercial-scale batches.
3. Stability data were generated in accordance with the approved stability protocol.
4. Significant changes were not observed in the stability data.
5. The reduction in the shelf-life is not necessitated by recurring events arising
during manufacture or because of stability concerns (Note: Problems arising during
manufacturing or stability concerns should be reported for evaluation).
Supporting data
1. Summary of stability testing and results (for example, studies conducted, protocols
used, results obtained).
2. Proposed storage conditions and shelf-life, as appropriate.
3. Updated post-approval stability protocol and stability commitment.
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Table continued
4. Justification for the change to the post-approval stability protocol or stability
commitment.
5. Results of stability testing (that is, full real-time/real-temperature stability data
covering the proposed shelf-life generated on stability testing of at least three
commercial-scale batches unless otherwise justified). For intermediates, data to
show that the extension of shelf-life has no negative impact on the quality of the
drug substance. Under special circumstances, interim stability-testing results and
a commitment to notify the NRA of any failures in the ongoing long-term stability
studies may be provided. In such cases, the extrapolation of shelf-life should be
made in accordance with ICH Q1E guidelines (8).
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Supporting data
1. Copies or summaries of analytical procedures if new analytical procedures are used.
2. Validation results if new analytical procedures are used.
3. Proposed storage conditions and/or shelf-life, as appropriate.
4. Updated post-approval stability protocol including justification for the changes,
and stability commitment.
5. If applicable, stability-testing results to support the change to the post-approval
stability protocol or stability commitment (for example, data to show greater
reliability of the alternative test).
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References
1. The common technical document for the registration of pharmaceuticals for human use:
quality – M4Q(R1) (Step 4 version). Geneva: International Conference on Harmonisation of
Technical Requirements for Registration of Pharmaceuticals for Human Use; 2002 (http://
www.ich.org/fileadmin/Public_Web_Site/ICH_Products/CTD/M4_R1_Quality/M4Q__R1_.pdf,
accessed 12 December 2017).
2. CTD Quality (M4Q) guideline. M4Q Implementation Working Group: Questions & Answers (R1) –
M4Q Q&As (R1). Geneva: International Conference on Harmonization of Technical Requirements
for Registration of Pharmaceuticals for Human Use; 2003 (http://www.ich.org/fileadmin/
Public_Web_Site/ICH_Products/CTD/M4_R1_Quality/M4_Quality_Questions_Answers_R1.pdf,
accessed 12 December 2017).
3. WHO good manufacturing practices for biological products. In: WHO Expert Committee on
Biological Standardization: sixty-sixth report. Geneva: World Health Organization; 2016:
Annex 2 (WHO Technical Report Series, No. 999; http://www.who.int/biologicals/areas/vaccines/
Annex_2_WHO_Good_manufacturing_practices_for_biological_products.pdf?ua=1, accessed
12 December 2017).
4. Guidelines on the quality, safety and efficacy of biotherapeutic protein products prepared by
recombinant DNA technology. In: WHO Expert Committee on Biological Standardization: sixty-
fourth report. Geneva: World Health Organization; 2014: Annex 4 (WHO Technical Report Series,
No. 987; http://www.who.int/biologicals/biotherapeutics/TRS_987_Annex4.pdf?ua=1, accessed
12 December 2017).
5. Comparability of biotechnological/biological products subject to changes in their manufacturing
process. ICH Guideline Q5E. Geneva: International Conference on Harmonisation of Technical
Requirements for Registration of Pharmaceuticals for Human Use; 2004 (http://www.ich.org/
fileadmin/Public_Web_Site/ICH_Products/Guidelines/Quality/Q5E/Step4/Q5E_Guideline.pdf,
accessed 12 December 2017).
6. Stability testing of biotechnological/biological products. ICH Guideline Q5C. Geneva: International
Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for
Human Use; 1995 (https://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/Guidelines/
Quality/Q5C/Step4/Q5C_Guideline.pdf, accessed 12 December 2017).
7. WHO guidelines on transmissible spongiform encephalopathies in relation to biological and
WHO Technical Report Series, No. 1011, 2018
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Appendix 3
Changes to the drug product
The examples presented in this appendix are intended to assist with the
classification of changes made to the quality information of the drug product.
The information summarized in the drug product table provides guidance on:
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to changes that have been implemented in the case of minor quality changes.
For example, the qualification of a new lot of reference standard against the
approved reference standard may be considered a minor quality change if the
qualification of a new standard is performed in accordance with an approved
protocol and specification. Nevertheless, these changes must be reported to the
NRA or national control laboratory as appropriate.
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Table continued
Supporting data
1. Revised drug product labelling information, as applicable.
2. Characterization data demonstrating comparability of the new dosage form and/
or formulation.
3. Description and composition of the dosage form if there are changes to the
composition or dose.
4. Discussion of the components of the drug product, as appropriate (for example,
choice of excipients, compatibility of drug substance and excipients, leachates,
compatibility with new container closure system).
5. Information on the batch formula, manufacturing process and process controls,
controls of critical steps and intermediates, process validation results.
6. Control of excipients if new excipients are proposed (for example, specification).
7. Information on specification, analytical procedures (if new analytical methods are
used), validation of analytical procedures (if new analytical methods are used),
batch analyses (certificate of analysis for three consecutive commercial-scale
batches should be provided). Bracketing for multiple-strength products, container
sizes and/or fills may be acceptable if scientifically justified.
8. Information on the container closure system and leachables and extractables,
if any of the components have changed (for example, description, materials of
construction and summary of specification).
9. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug product batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
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Manufacture
Description of change Conditions to Supporting Reporting
be fulfilled data category
37. Change in the approved design space, involving the following:
a. Establishment of a new None 1 Major
design space
b. Expansion of the approved None 1 Major
design space
c. Reduction in the approved 1 1 Minor
design space (any change
that reduces or limits the
range of parameters used to
define the design space)
Conditions
1. The reduction in design space is not necessitated by recurring problems that have
arisen during manufacture.
Supporting data
1. Pharmaceutical development data to support the establishment or changes to
the design space.
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
d. Deletion of a drug product 6, 7 None Minor
manufacturing facility or
packaging site
Conditions
1. The proposed facility is an approved formulation/filling facility (for the same
company/marketing authorization holder).
2. There is no change in the composition, manufacturing process and drug product
specification.
3. There is no change in the container/closure system and storage conditions.
4. The same validated manufacturing process at critical steps (that is, compounding
and filling) is used.
5. The newly introduced product is in the same family of product(s), or in the same
therapeutic classification, as the products already approved at the site, and also
uses the same filling process/equipment.
6. There should remain at least one site/manufacturer, as previously authorized,
performing the same function as the one(s) to be deleted.
7. The deletion should not be due to critical deficiencies in manufacturing (for example,
recurrent out-of-specification events, environmental monitoring failures, etc.).
Supporting data
1. Name, address and responsibilities (for example, formulation, filling, primary/
secondary packaging) of the proposed production facility involved in
manufacturing and testing.
2. Evidence that the facility is GMP-compliant.
3. Confirmation that the description of the manufacturing process of the drug
product has not changed (other than the change in facility), or submission of
supporting data on the revised description of the manufacturing process if the
process has changed.
4. Comparative description of the manufacturing process, if different from the
approved process, and information on the controls performed at critical steps of
the manufacturing process and on the intermediate of the proposed final product.
5. Summary of the process validation studies and results.
6. Description of the batches and summary of in-process control and release testing
results as quantitative data, in a comparative tabular format, for at least three
consecutive commercial-scale batches of the pre-change and post-change drug
product. Comparative pre-change test results do not need to be generated
concurrently; relevant historical testing results are acceptable. Bracketing for
multiple-strength products, container sizes and/or fills may be acceptable if
scientifically justified.
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Table continued
7. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug product batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
commit to undertake real-time stability studies to confirm the full shelf-life/
hold-time of the drug product under its normal storage conditions and to report
to the NRA any failures in these ongoing long-term stability studies. Matrixing,
bracketing, the use of smaller-scale batches and/or the use of fewer than three
batches of drug product for stability testing may be acceptable where justified (6).
8. Rationale for considering the proposed formulation/filling facility as equivalent.
9. Information describing the change-over procedures for shared product-contact
equipment and the segregation procedures, as applicable. If there are no revisions,
the manufacturer should state that no changes were made to the change-over
procedures.
10. Cleaning procedures (including data in a summary validation report and the
cleaning protocol for the introduction of new products, as applicable)
demonstrating lack of carry-over or cross-contamination.
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Description of change Conditions to Supporting Reporting
be fulfilled data category
d. Addition of a new step (for 3 1–6 Moderate
example, filtration)
e. Product-contact equipment 6, 7 2, 9 Minor
change from dedicated
to shared (for example,
formulation tank, filter
housing, filling line and head,
lyophilizer)
Conditions
1. The proposed scale uses similar/comparable equipment to the approved
equipment. Note: Change in equipment size is not considered as using similar/
comparable equipment.
2. Any changes to the manufacturing process and/or to the in-process controls
are only those necessitated by the change in batch size (for example, the same
formulation, controls and standard operating procedures are utilized).
3. The change should not be a result of recurring events that have arisen during
manufacture or because of stability concerns.
4. There is no change in the principle of the sterilization procedures of the drug
product.
5. Replacement of equipment with equivalent equipment; the change is considered
“like for like” (that is, in terms of product contact material, equipment size and
operating principles).
6. The site is approved as a multi-product facility.
7. The change has no impact on the risk of cross-contamination and is supported by
validated cleaning procedures.
8. The change does not affect the lyophilization step.
Supporting data
1. Description of the manufacturing process, if different from the approved process,
and information on the controls performed at critical steps of the manufacturing
process and on the intermediate of the proposed drug product.
2. Information on the in-process control testing, as applicable.
3. Process validation results (for example, media fills), as appropriate.
4. Description of the batches and summary of in-process control and release testing
results as quantitative data, in a comparative tabular format, for at least three
consecutive commercial-scale batches of the pre-change and post-change drug
product. Comparative pre-change test results do not need to be generated
concurrently; relevant historical testing results are acceptable. Bracketing for
multiple-strength products, container sizes and/or fills may be acceptable if
scientifically justified.
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Table continued
5. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug product batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
commit to undertake real-time stability studies to confirm the full shelf-life/
hold-time of the drug product under its normal storage conditions and to report
to the NRA any failures in these ongoing long-term stability studies. Matrixing,
bracketing, the use of smaller-scale batches and/or the use of fewer than three
batches of drug product for stability testing may be acceptable where justified (6).
6. Information on leachables and extractables, as applicable.
7. Information on the new equipment and comparison of similarities and differences
regarding operating principles and specifications between the new and the
replaced equipment.
8. The rationale for regarding the equipment as similar/comparable, as applicable.
9. Information describing the change-over procedures for the shared product-
contact equipment.
process limits
b. Addition of new in-process 2, 3, 6 1–5, 8 Minor
test and limits
c. Deletion of a non-significant 2–4 1, 4, 7 Minor
in-process test
d. Widening of the approved None 1–4, 6, 8 Moderate
in-process limits
1–3 1, 4, 5, 8 Minor
e. Deletion of an in-process test None 1, 4, 6,8 Moderate
which may have a significant
effect on the overall quality of
the drug product
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
f. Addition or replacement of None 1–4, 6, 8 Moderate
an in-process test as a result
of a safety or quality issue
41. Change in in-process 1–3, 5, 6 9 Minor
controls testing site
Note: Transfer of in-process control
testing to a different facility
within a GMP-compliant site is
not considered to be a reportable
change but is treated as a minor
GMP change and reviewed during
inspections.
Conditions
1. There is no change in drug product specification outside the approved limits.
2. There is no change in the impurity profile of the drug product outside the
approved limits.
3. The change is not necessitated by recurring events arising during manufacture or
because of stability concerns.
4. The test does not concern a critical attribute (for example, content, impurities, any
critical physical characteristics or microbial purity).
5. The replaced analytical procedure maintains or improves precision, accuracy,
specificity and sensitivity, if applicable.
6. There is no change in the in-process control limits outside the approved limits.
7. The test procedure remains the same, or changes in the test procedure are minor.
Supporting data
1. Revised information on the controls performed at critical steps of the
manufacturing process and on intermediates of the proposed drug substance.
2. Updated drug product specification if changed.
3. Copies or summaries of analytical procedures if new analytical procedures are used.
4. Comparative table or description, where applicable, of current and proposed
in‑process tests.
5. Description of the batches and summary of in-process control and release testing
results as quantitative data, in a comparative tabular format, for one commercial-
scale batch of the pre-change and post-change drug product (certificates of
analysis should be provided). Comparative pre-change test results do not need to
be generated concurrently; relevant historical testing results are acceptable. Batch
data on the next two full-production batches should be made available on request
and reported by the marketing authorization holder if outside specification (with
proposed action). The use of a smaller-scale batch may be acceptable where justified.
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Table continued
6. Description of the batches and summary of in-process control and release testing
results as quantitative data, in a comparative tabular format, for at least three
consecutive commercial-scale batches of the pre-change and post-change drug
product (certificates of analysis should be provided). Comparative pre-change test
results do not need to be generated concurrently; relevant historical testing results
are acceptable.
7. Justification/risk assessment showing that the attribute is non-significant.
8. Justification for the new in-process test and limits.
9. Evidence that the new company/facility is GMP-compliant.
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Table continued
4. Acceptance criteria for residual solvents are within recognized or approved
acceptance limits (for example, within ICH limits for a Class 3 residual solvent or
pharmacopoeial requirements).
5. The deleted test has been demonstrated to be redundant compared to the
remaining tests or is no longer a pharmacopoeial requirement.
6. The analytical procedure remains the same, or changes in the test procedure are
minor.
7. The change does not result from unexpected events arising during manufacture
(for example, new unqualified impurity, change in total impurity limits).
8. An alternative test analytical procedure is already authorized for the specification
attribute/test and this procedure has not been added through a minor change
submission.
Supporting data
1. Updated excipient specification.
2. Where an in-house analytical procedure is used and a recognized compendial
standard is claimed, results of an equivalency study between the in-house and
compendial methods.
3. Justification of the proposed excipient specification (for example, demonstration
of the suitability of the monograph to control the excipient and potential impact
on the performance of the drug product).
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Table continued
Supporting data
1. Updated excipient specifications.
2. Where a House analytical procedure is used and a pharmacopoeial/compendial
standard/monograph is claimed, results of an equivalency study between the
House and compendial methods.
3. Justification of the proposed excipient specifications (for example, demonstration
of the suitability of the monograph to control the excipient and potential impact
on the performance of the drug product).
4. A declaration that consistency of quality and of the production process of the
excipient is maintained.
260
Annex 3
Table continued
49. Change in supplier for an None 2, 3, 5–7 Moderate
excipient of non-biological
origin or of biological origin 1, 5, 6 3 Minor
(excluding plasma-derived
excipient)
50. Change in excipient 1 10 Minor
testing site
Note: Transfer of testing to a
different facility within a GMP-
compliant site is not considered
to be a reportable change but is
treated as a minor GMP change
and is reviewed during inspections.
Conditions
1. There is no change to the specification of the excipient or drug product outside
the approved limits.
2. The change does not concern a human plasma-derived excipient.
3. The human plasma-derived excipient from the new supplier is an approved
medicinal product and no manufacturing changes were made by the supplier of
the new excipient since its last approval in the country/jurisdiction of the NRA.
4. The excipient does not influence the structure/conformation of the active
ingredient.
5. The TSE risk source is covered by a TSE certificate of suitability and is of the same
or lower TSE risk as the previously approved material (7).
6. Any new excipient does not require the assessment of viral safety data.
Supporting data
1. Declaration from the manufacturer of the excipient that the excipient is entirely of
vegetable or synthetic origin.
2. Details of the source of the excipient (for example, animal species, country of
origin) and the steps undertaken during processing to minimize the risk of TSE
exposure (7).
3. Information demonstrating comparability in terms of physicochemical properties,
and the impurity profile of the proposed excipient compared to the approved
excipient.
4. Information on the manufacturing process and on the controls performed at
critical steps of the manufacturing process, and on the intermediate of the
proposed excipient.
5. Description of the batches and summary of results as quantitative data, in a
comparative tabular format, for at least three commercial-scale batches of the
proposed excipient.
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Table continued
6. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug product batches produced with the proposed changes and stored under
accelerated and/or stress conditions for a minimum of 3 months. Test results that
cover a minimum of 6 months in real-time/real-temperature conditions should
also be provided. A possibility of 3 months of real-time data could be acceptable if
properly justified (for example, it can be proven that the relevant effect, if present,
can already be observed within 3 months). Comparative pre-change test results
do not need to be generated concurrently; relevant historical results for batches
on the stability programme are acceptable. Additionally, the manufacturer should
commit to undertake real-time stability studies to confirm the full shelf-life/
hold-time of the drug product under its normal storage conditions and to report
to the NRA any failures in these ongoing long-term stability studies. Matrixing,
bracketing, the use of smaller-scale batches and/or the use of fewer than three
batches of drug product for stability testing may be acceptable where justified (6).
7. Information assessing the risk with respect to potential contamination with
adventitious agents (for example, impact on the viral clearance studies, or BSE/TSE
risk (7)), including viral safety documentation where necessary.
8. Complete manufacturing and clinical safety data to support the use of the
proposed human plasma-derived excipient.
9. A letter from the supplier certifying that no changes were made to the plasma-
derived excipient compared to the currently approved corresponding medicinal
product.
10. Evidence that the new company/facility is GMP-compliant.
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
b. Transfer of the quality None 1, 2 Moderate
control testing activities for
a pharmacopoeial assay to a 1 1, 2 Minor
new company not approved
in the current marketing
authorization or licence
Conditions
1. The transferred quality control test is not a potency assay or bioassay.
2. There are no changes to the test method.
3. The transfer is within a facility approved in the current marketing authorization for
the performance of other tests.
Supporting data
1. Information demonstrating technology transfer qualification for the non-
pharmacopoeial assays or verification for the pharmacopoeial assays.
2. Evidence that the new company/facility is GMP-compliant.
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Table continued
Conditions
1. The change is made exclusively to comply with a pharmacopoeial monograph.
2. There is no change in drug product specifications outside the approved ranges.
3. There is no deletion of tests or relaxation of acceptance criteria of the approved
specifications, except to comply with a pharmacopoeial standard/monograph.
4. There is no deletion or change to any analytical procedures, except to comply with
a pharmacopoeial standard/monograph.
Supporting data
1. Revised drug product labelling information, as applicable.
2. An updated copy of the proposed drug product specifications.
3. Where an in-house analytical procedure is used and a pharmacopoeial standard/
monograph is claimed, results of an equivalency study between the in-house and
pharmacopoeial methods.
4. Copies or summaries of validation reports if new analytical procedures are used.
5. Justification of specifications with data.
264
Annex 3
Table continued
2. An updated copy of the proposed drug product specifications.
3. Copies or summaries of analytical procedures if new analytical procedures are used.
4. Copies or summaries of validation reports if new analytical procedures are used to
monitor the new critical quality attribute at release.
5. Justification and supporting data for each proposed change to the control strategy.
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Table continued
6. Acceptance criteria for residual solvents are within recognized or approved
acceptance limits (for example, within ICH limits for a Class 3 residual solvent, or
pharmacopoeial requirements).
7. The change does not result from unexpected events arising during manufacture
(for example, new unqualified impurity, or impurity content outside the approved
limits).
8. The change is from a pharmacopoeial assay to another pharmacopoeial assay or
the marketing application holder has demonstrated an increased understanding
of the relationship between method parameters and method performance
defined by a systematic development approach including robustness studies.
Supporting data
1. An updated copy of the proposed drug product specification.
2. Copies or summaries of analytical procedures if new analytical procedures are used.
3. Validation/qualification results if new analytical procedures are used.
4. Comparative results demonstrating that the approved and proposed analytical
procedures are equivalent.
5. Justification for the change to the analytical procedure (for example,
demonstration of the suitability of the analytical procedure in monitoring the drug
product, including the degradation products) or for the change to the specification
(for example, demonstration of the suitability of the revised acceptance criterion to
control the drug product).
6. Justification for the deletion of the test (for example, demonstration of the
suitability of the revised specification in controlling the final product).
7. Documented evidence that consistency of quality and of the production process is
maintained.
Reference standards
WHO Technical Report Series, No. 1011, 2018
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
58. Change of the reference 3 1, 2 Minor
standard from in-house
(no relationship with
international standard)
to a pharmacopoeial or
international standard
59. Qualification of a new batch 1 2 Minor
of reference standard against
the approved reference
standard (including
qualification of a new batch
of a secondary reference
standard against the
approved primary standard)
60. Change to the reference None 3, 4 Moderate
standard qualification
protocol
61. Extension of the reference 2 5 Minor
standard shelf-life or re-test
period
Conditions
1. The qualification of a new standard is carried out in accordance with an approved
protocol.
2. The extension of the shelf-life of the reference standard is carried out in
accordance with an approved protocol.
3. The reference standard is used for a physicochemical test.
Supporting data
1. Revised product labelling to reflect the change in reference standard, as applicable.
2. Qualification data of the proposed reference standards or materials (for example,
source, characterization, certificate of analysis).
3. Justification of the change to the reference standard qualification protocol.
4. Updated reference standard qualification protocol.
5. Summary of stability testing and results or retest data to support the extension of
the reference standard shelf-life.
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Conditions
1. There is no change in the type of container closure or materials of construction.
2. There is no change in the shape or dimensions of the container closure.
3. The change is made only to improve the quality of the container and does not
modify the product contact material (for example, increased thickness of the glass
vial without changing interior dimensions).
4. The modified part is not in contact with the drug product.
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Annex 3
Table continued
Supporting data
1. Revised product labelling information, as appropriate.
2. For sterilized products, process validation results, unless otherwise justified.
3. Update dossier containing information on the proposed container closure system,
as appropriate (for example, description, materials of construction of primary
packaging components).
4. Results demonstrating protection against leakage, no leaching of undesirable
substance, compatibility with the product, and results from the toxicity and
biological reactivity tests.
5. Summary of release testing results as quantitative data, in a comparative tabular
format, for at least three consecutive commercial-scale batches of the pre-change
and post-change drug product. Comparative pre-change test results do not need
to be generated concurrently; relevant historical testing results are acceptable.
Bracketing for multiple-strength products, container sizes and/or fills may be
acceptable if scientifically justified.
6. Comparative pre-change and post-change test results for the manufacturer’s
characterized key stability-indicating attributes for at least three commercial-scale
drug product batches produced (unless otherwise justified) with the proposed
changes and stored under accelerated and/or stress conditions for a minimum
of 3 months. Test results that cover a minimum of 6 months in real-time/real-
temperature conditions should also be provided. A possibility of 3 months of real-
time data could be acceptable if properly justified (for example, it can be proven
that the relevant effect, if present, can already be observed within 3 months).
Comparative pre-change test results do not need to be generated concurrently;
relevant historical results for batches on the stability programme are acceptable.
Additionally, the manufacturer should commit to undertake real-time stability
studies to confirm the full shelf-life/hold-time of the drug product under its
normal storage conditions and to report to the NRA any failures in these ongoing
long-term stability studies. Matrixing, bracketing, the use of smaller-scale batches
and/or the use of fewer than three batches of drug product for stability testing
may be acceptable where justified (6).
7. Information demonstrating the suitability of the proposed container/closure
system with respect to its relevant properties (for example, results from last media
fills; results of interaction studies demonstrating preservation of protein integrity
and maintenance of sterility for sterile products; maintenance of sterility in
multidose containers; user testing).
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
e. Widening of an acceptance None 1, 2 Moderate
criterion
f. Narrowing of an acceptance 8 1 Minor
criterion
Conditions
1. The deleted test has been demonstrated to be redundant compared to the
remaining tests or is no longer a pharmacopoeial requirement.
2. The change to the specification does not affect the functional properties of
the container closure component and does not have a potential impact on the
performance of the drug product.
3. The change is not necessitated by recurring events arising during manufacture or
because of stability concerns.
4. There is no change to the acceptance criteria outside the approved limits.
5. The new analytical procedure is of the same type.
6. Results of method validation demonstrate that the new or modified analytical
procedure is at least equivalent to the approved analytical procedure.
7. The new or modified analytical procedure maintains or improves precision,
accuracy, specificity and sensitivity.
8. The change is within the range of approved acceptance criteria.
Supporting data
1. An updated copy of the proposed specification for the primary or functional
secondary container closure component.
2. Rationale for the change in specification for a primary container closure component.
3. Description of the analytical procedure and, if applicable, validation data.
Stability
Description of change Conditions to Supporting Reporting
be fulfilled data category
67. Change in the shelf-life of the drug product,
involving the following:
a. Extension (includes extension None 1–5 Moderate
of shelf-life of the drug
product as packaged for
sale, and hold-time after
opening and after dilution or
reconstitution)
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Table continued
Description of change Conditions to Supporting Reporting
be fulfilled data category
b. Reduction (includes None 1–5 Moderate
reduction as packaged for
sale, after opening, and after
dilution or reconstitution)
Conditions
None
Supporting data
1. Updated product labelling information, as appropriate.
2. Proposed storage conditions and shelf-life, as appropriate.
3. Updated post-approval stability protocol.
4. Justification of the change to the post-approval stability protocol or stability
commitment.
5. Results of stability testing under real-time/real-temperature conditions covering
the proposed shelf-life generated on at least three commercial-scale batches
unless otherwise justified.
of an analytical procedure, or
change in storage temperature
b. Addition of test(s) into the 1 1, 2, 4, 5 Minor
post-approval stability protocol
c. Deletion of time point(s) from 2 4, 5 Minor
the post-approval stability
protocol within the approved
shelf-life
d. Replacement of sterility None 1, 2, 4, 5 Moderate
testing by the container/
closure system integrity 3 4, 5 Minor
testing
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Annex 3
Table continued
Conditions
1. The addition of the test(s) is not due to stability concerns or to the identification of
new impurities.
2. Deletion of time point(s) is done according to relevant guidelines (for example, (6)).
3. The method used to demonstrate the integrity of the container/closure system
has already been approved as part of a previous application related to the drug
product.
Supporting data
1. Copies or summaries of analytical procedures if new analytical procedures are used.
2. Validation results if new analytical procedures are used.
3. Proposed storage conditions and or shelf-life, as appropriate.
4. Updated post-approval stability protocol, including justification for the change,
and stability commitment.
5. Comparative results demonstrating that the approved and proposed analytical
procedures are equivalent.
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Table continued
Supporting data
1. Revised product labelling information, as applicable.
2. Proposed storage conditions and shelf-life.
3. Updated post-approval stability protocol and stability commitment.
4. Justification of the change in the labelled storage conditions/cautionary statement.
5. Results of stability testing under appropriate stability conditions covering the
proposed shelf-life, generated on one commercial-scale batch unless otherwise
justified.
6. Results of stability testing under appropriate conditions covering the proposed
shelf-life, generated on at least three commercial-scale batches unless otherwise
justified.
References
1. The common technical document for the registration of pharmaceuticals for human use:
quality – M4Q(R1) (Step 4 version). Geneva: International Conference on Harmonisation of
Technical Requirements for Registration of Pharmaceuticals for Human Use; 2002 (http://www.ich.
org/fileadmin/Public_Web_Site/ICH_Products/CTD/M4_R1_Quality/M4Q__R1_.pdf, accessed 12
December 2017).
2. CTD Quality (M4Q) guideline. M4Q Implementation Working Group: Questions & Answers (R1) –
M4Q Q&As (R1). Geneva: International Conference on Harmonization of Technical Requirements
for Registration of Pharmaceuticals for Human Use; 2003 (http://www.ich.org/fileadmin/
Public_Web_Site/ICH_Products/CTD/M4_R1_Quality/M4_Quality_Questions_Answers_R1.pdf,
accessed 12 December 2017).
3. WHO good manufacturing practices for biological products. In: WHO Expert Committee on
Biological Standardization: sixty-sixth report. Geneva: World Health Organization; 2016:
Annex 2 (WHO Technical Report Series, No. 999; http://www.who.int/biologicals/areas/vaccines/
Annex_2_WHO_Good_manufacturing_practices_for_biological_products.pdf?ua=1, accessed
12 December 2017).
WHO Technical Report Series, No. 1011, 2018
4. Guidelines on the quality, safety and efficacy of biotherapeutic protein products prepared by
recombinant DNA technology. In: WHO Expert Committee on Biological Standardization: sixty-
fourth report. Geneva: World Health Organization; 2014: Annex 4 (WHO Technical Report Series,
No. 987; http://www.who.int/biologicals/biotherapeutics/TRS_987_Annex4.pdf?ua=1, accessed
12 December 2017).
5. Comparability of biotechnological/biological products subject to changes in their manufacturing
process. ICH Guideline Q5E. Geneva: International Conference on Harmonisation of Technical
Requirements for Registration of Pharmaceuticals for Human Use; 2004 (http://www.ich.org/
fileadmin/Public_Web_Site/ICH_Products/Guidelines/Quality/Q5E/Step4/Q5E_Guideline.pdf,
accessed 12 December 2017).
6. Stability testing of biotechnological/biological products. ICH Guideline Q5C. Geneva: International
Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for
Human Use; 1995 (https://www.ich.org/fileadmin/Public_Web_Site/ICH_Products/Guidelines/
Quality/Q5C/Step4/Q5C_Guideline.pdf, accessed 12 December 2017).
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Appendix 4
Safety, efficacy and product labelling information changes
The examples of safety and efficacy changes, product labelling information
changes and administrative product labelling information changes in this
appendix are provided for clarification. However, such changes are not limited to
those included in this appendix. They may also result in changes to the product
labelling information for health-care providers and patients, and to inner and
outer labels.
Because the amount of safety and efficacy data needed to support
a change may vary according to the impact of the change, risk–benefit
considerations and product-specific characteristics there is no “one size fits all”
approach. This appendix therefore provides a list of examples of changes in the
various categories rather than a detailed table linking each change with the
required data needed to support that change (as is provided in Appendices 2
and 3 for quality changes). Marketing authorization holders or applicants are
encouraged to contact the NRA for guidance on the data needed to support
major changes if deemed necessary.
1
Some NRAs consider that these changes may require a new application for a marketing authorization
or licence.
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Annex 4
Technical Specifications Series (TSS) for WHO
Prequalification – Diagnostic Assessment
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Acknowledgements 283
List of contributors 283
Abbreviations 284
A Introduction 284
B How to apply these specifications 285
C Other guidance documents 286
D Performance principles for WHO prequalification 286
D.1 Intended use 286
D.2 Diversity of specimen types, users and testing environments and impact on
required studies 287
D.3 Applicability of supporting evidence to an IVD under review 287
E Table of Requirements 289
Part 1 Establishing analytical performance characteristics 291
Part 2 Establishing clinical performance characteristics (professional use and/or
self-testing) 305
Part 3 Qualification of usability (self-testing) 307
References 312
WHO Technical Report Series, No. 1011, 2018
282
Annex 4
Acknowledgements
The document Technical Specifications Series 1 (TSS–1) for WHO Prequalification
– Diagnostic Assessment: Human immunodeficiency virus (HIV) rapid diagnostic
tests for professional use and/or self-testing was developed with support from the
Bill & Melinda Gates Foundation and UNITAID. The first draft was prepared
in collaboration with Dr M Lanigan, Geneva, Switzerland and Ms R Meurant,
WHO, Geneva, Switzerland, with input and expertise from Dr H Scheiblauer,
Paul-Ehrlich-Institut, Langen, Germany; Ms D Healy, Ms H Ardura, Dr R
Baggaley, Dr C Case, Dr C Figueroa, Dr M Nübling; and Ms A Sands, WHO,
Geneva, Switzerland. This document was produced under the coordination
and supervision of Ms R Meurant and Ms I Prat, Prequalification Team, WHO,
Geneva, Switzerland.
List of contributors
First-round comments were received from the following: Ms S Best, National
Serology Reference Laboratory, Victoria, Australia; Dr T Crucitti, Institute of
Tropical Medicine, Antwerp, Belgium; Dr J Duncan, London, the United Kingdom;
Dr F Gruszka, E-Meddia, Paris, France; Dr C Hill, CA, United States of America
(USA); Mr G James, Institute for Clinical Pathology and Medical Research, New
South Wales, Australia; Dr L Kestens, Institute of Tropical Medicine, Antwerp,
Belgium; Ms D Lepine, Medical Devices Bureau, Health Canada, Ottawa, Canada;
Dr A Reissinger, Paul-Ehrlich-Institut, Langen, Germany; and Dr M Nübling and
Ms M Perez Gonzalez, WHO, Geneva, Switzerland.
The draft technical specifications document was then posted on the WHO
Prequalification website for public consultation on 15 September 2016. Various
stakeholders, including manufacturers submitting to WHO prequalification
of in vitro diagnostic medical devices (IVDs), IVD manufacturing industry
associations, various national and international regulatory bodies, and IVD
standards organizations, were informed of the consultation in order to solicit
feedback. A two-month response period was provided.
Second-round public comments were then received from the following:
Dr P Akolkar, Center for Biologics Evaluation and Research, United States Food
and Drug Administration, MD, USA; Ms S Best, National Serology Reference
Laboratory, Victoria, Australia; Dr J Duncan, London, the United Kingdom;
Epicentre and Médecins sans Frontières International Office, Paris, France; Dr C
Kosack, Dr A Page and Ms E Tran, Geneva, Switzerland; Dr R Galli, bioLytical™
Laboratories Inc., Vancouver, Canada; Ms D Lepine, Medical Devices Bureau,
Health Canada, Ottawa, Canada; Dr M Nübling, WHO, Geneva, Switzerland;
OraSure Technologies Inc., PA, the USA; Dr H Scheiblauer, Paul-Ehrlich-Institut,
Langen, Germany; UNITAID/PSI HIV Self-Testing Africa (STAR) project
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Abbreviations
Ag antigen
CE Conformité Européenne (European Conformity)
CRF circulating recombinant form
HIV human immunodeficiency virus
IVD in vitro diagnostic medical device
RDT rapid diagnostic test
A Introduction
The purpose of this document is to provide technical guidance to in vitro
diagnostic medical device (IVD) manufacturers that intend to seek WHO
prequalification of rapid diagnostic tests (RDTs) for the detection of human
immunodeficiency virus (HIV).
The minimum performance requirements for WHO prequalification
WHO Technical Report Series, No. 1011, 2018
are summarized in this document, and apply equally to RDTs intended solely
for HIV detection and to those tests where HIV detection is one component
of a multi-detection assay (for example, an HIV/syphilis dual-detection RDT).
This document applies to RDTs intended to be used as an aid to diagnosis of
HIV infection. The current version of this document does not address IVDs
that discriminate between the detection of HIV-1 and HIV-2 infection, IVDs
intended as confirmatory tests, or the requirements for accompanying quality
control materials.
For the purpose of this document, the use of certain verbal forms is
as follows:
■■ “shall” indicates that the manufacturer is required to comply with
the technical specifications;
284
Annex 4
and Parts 1 and 2 of this document have already been satisfied, the additional
claim for self-testing shall be supported by studies outlined in Part 3.
These requirements are summarized below in Table 1.
Table 1
Summary of requirements for submission for WHO prequalification based on the
intended use of the IVD
■■ the testing population for which the functions are intended (for
example, detection of susceptible individuals) and the intended
operational setting (for example, for use in near-patient testing); and
■■ clinical indication (for example, aid to diagnosis of HIV infection).
1
Medical technologists, medical laboratory technicians or similar, who have received a formal professional
or paraprofessional certificate or tertiary education degree.
2
Any person who performs functions related to health-care delivery and has been trained to deliver specific
services but has received no formal professional or paraprofessional certification or tertiary education
degree.
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■■ collection procedures;
■■ reading times, etc.
It is a manufacturer’s responsibility to verify through testing (as
summarized in Parts 1 and 2 of this document) that any changes made do not
have an adverse impact on critical safety and performance characteristics of an
IVD. Usability studies are undertaken to optimize the presentation of an IVD and
the understanding of self-testing users. The minimum reporting requirements
summarized in Part 3 of this document are not intended to be an exhaustive list
or to indicate a particular order in which studies should be undertaken.
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Annex 4
E Table of Requirements
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Table continued
Part 2 Establishing clinical performance characteristics (professional use
and/or self-testing)
2.1 Diagnostic sensitivity and specificity
2.1.1 Diagnostic sensitivity
2.1.2 Diagnostic specificity
Part 3 Qualification of usability (self-testing)
3.1 Qualification of usability (self-testing)
3.1.1 Labelling comprehension study
3.1.2 Results interpretation study
3.1.3 Observed untrained user study
WHO Technical Report Series, No. 1011, 2018
290
Part 1 Establishing analytical performance characteristics
Aspect Testing requirements Notes on testing requirements Source
documents
1.1 Specimen type
1.1.1 For each claimed specimen type, 1. The relationship between IVD performance in claimed Technical Guidance
Demonstration testing in at least: specimen types and reference materials used for Series for WHO
of equivalence • 25 HIV-positive specimens analytical studies shall be established. The design of Prequalification
between • 25 HIV-negative specimens. subsequent studies shall then take that relationship – Diagnostic
specimen types into account. Assessment (1)
2. If there is no equivalence between claimed specimen European
types then the impact that this will have on each Commission (2)
subsequent performance claim shall be fully
1.1.2 At least 25 HIV-positive and 25 understood and described. Where a significant
Demonstration HIV-negative specimens for each difference in performance exists between specimen
of equivalence claimed anticoagulant. types, equivalence may need to be investigated as
of claimed The equivalence of specimen part of a larger clinical study (see Part 2 below).
anticoagulants types shall be determined for all Example: an IVD intended for testing whole blood for
claimed analytes (for example, which seroconversion sensitivity is estimated using
HIV‑1 antibody, HIV-2 antibody, panels of serum/plasma specimens.
p24 Ag, as appropriate) (see • The relationship between seroconversion sensitivity
Note 3). in serum/plasma to that of the same characteristic
in whole blood shall be understood.
• This might be achieved by comparing titres
between end-point dilution series of matched
specimen types (whole blood versus serum/plasma)
from a set of positive patients.
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3. In some cases it may be acceptable to use diluted
or spiked specimens. This approach is acceptable in
early development work, but all reasonable attempts
should be made to use natural specimens. Justification
should be provided if diluted or spiked specimens are
used in the submitted studies.
4. Positive specimens (undiluted) shall be chosen so that
the majority of them are near the IVD cut-off.
5. Paired specimens should be used (for example, if
claiming equivalence of four anticoagulants then each
subject should provide four samples – one in each
anticoagulant).
1.2 Specimen collection, storage and transport
1.2.1 Real-time studies taking into 1. Evidence shall be provided which validates the Technical Guidance
WHO Expert Committee on Biological Standardization Sixty-eighth report
Specimen account: maximum allowable time between specimen Series for WHO
stability • storage conditions (duration collection and its addition to the IVD in the setting Prequalification
at different temperatures, where testing takes place. – Diagnostic
temperature limits, freeze/ Assessment (3)
thaw cycles);
• transport conditions, where
applicable;
• intended use (see Note 1);
• specimen collection and/or
transfer devices intended to
be used with the IVD.
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1.3 Precision of measurement
1.3.1 Both repeatability (within- 1. For example, within- or between-run, -lot, -day, -site, CLSI EP05-A3 (4)
Repeatability, condition – see Note 1) and etc. ISO 13612:2002 (5)
reproducibility reproducibility (between- 2. Precision shall be determined for each pathogen and/ CLSI EP12-A2 (6)
condition – see Note 1) shall or analyte for which detection is claimed (for example,
be estimated using panels of at HIV-1 antibody, HIV-2 antibody, HIV-1 p24 Ag, as
least: appropriate).
• 1 negative specimen; 3. The testing panel should be composed of natural
• 1 low-reactivity positive (that is, undiluted) specimens. Where this is not
specimen (near assay cut-off ); feasible, the stock specimens that are to be diluted
• 1 medium-reactivity positive should represent a range of stages of infection
specimen. (antibody maturation) in order to take into account
Each panel member shall be the limitations of mimicking low IVD reactivity with a
tested: high-avidity specimen.
• in 5 replicates; 4. IVDs which include whole blood as a specimen type
• using 3 different lots; shall include evidence of precision in (at a minimum)
• over 5 days (not necessarily spiked whole blood specimens (negative whole blood
consecutive) with one run spiked with highly reactive plasma/serum specimens
per day (alternating morning/ to produce an appropriate range of reactivities in the
afternoon); IVD).
• at each of 3 different testing 5. Where possible, the testing panel should be the same
sites. for all operators, lots and sites.
6. Lots shall comprise different batches of critical
components.
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The effect of operator-to- 7. Results shall be statistically analyzed to identify
operator variation on IVD and isolate the sources and extent of any variance.
performance should be In addition, the percentage of correctly identified,
included as part of the precision incorrectly identified and invalid results shall be
studies (see also Note 8). Testing tabulated for each specimen and be separately
should be done: stratified according to site, lot, etc. This type of analysis
• by personnel representative is especially important for rapid tests that may not have
of intended users; any numerical values.
• unassisted; 8. The effect of operator-to-operator variation on IVD
• using only those materials performance may also be considered as a human factor
provided with the IVD (for when designing robustness (flex) studies (see section
example, instructions for use, 1.11.1 below) and may be addressed as part of clinical
labels and other instructional studies in representative populations (see Part 2).
materials). 9. Users should be selected based on a pre-determined
and contextually appropriate level of education,
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Performance studies shall 3. Some of these aspects could be evaluated within the
be conducted at each of 3 flex studies (see section 1.11.1 below).
temperatures (at the mid-point
and two extremes of the claimed
operating range); the effect of
humidity on reading times shall
also be investigated.
1.6 Analytical sensitivity
1.6.1 A minimum of 25 commercial 1. Specimens should have been collected at short European
Seroconversion or well-characterized intervals to cover the seroconversion period and Commission (2)
seroconversion panels shall be should also cover the whole window period. Health Products
tested: 2. Early seroconversion: and Food Branch,
• test at least 40 early – p24 Ag and/or HIV RNA-positive; Health Canada (7)
seroconversion specimens – not recognized by all Conformité Européenne (CE)- CLSI EP12-A2 (6)
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1.8 Analytical specificity
1.8.1 Potentially The potential for false 1. The risk assessment conducted for an IVD shall identify Health Products
interfering results (false negatives and substances where the potential for interference and Food Branch,
substances false positives) arising from can reasonably be expected for the analyte being Health Canada (7)
interference from at least the detected (for example, HIV-1/2 antibodies and/or European
substances/conditions listed HIV‑1 p24 Ag). Commission (2)
below in sections 1.8.1.1 and 2. Where either the scientific literature and/or risk
1.8.1.2 (see Note 1) shall be CLSI EP07-A2 (10)
analysis identifies the potential for false results in
determined using: co-infected individuals (for example, decreased
• a minimum of 100 specimens sensitivity or specificity), further investigation shall be
(either naturally occurring or undertaken using both HIV-negative and HIV-positive
spiked to a low reactivity); specimens.
• each substance/condition 3. In addition to the substances listed here, IVDs that are
represented, where possible, used to test oral fluid shall take into account the effect
by at least 3–5 specimens from of oral infections, such as Candida, as well as tobacco,
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1.8.1.2 • relevant medicines, including:
Exogenous antiparasitic, antimalarial,
antiretroviral and anti-
tuberculosis medications;
• common over-the-counter
anti-inflammatory medications
(aspirin, paracetamol and
ibuprofen);
• ethanol and caffeine.
1.8.2 The potential for false-positive 1. The types of interferences tested for shall be risk
Cross-reactivity results arising from cross- based, taking into consideration the operational
reactivity (see Note 1) shall be setting as well as the intended users for the analyte
determined for a minimum of being detected (for example, HIV-1/2 antibodies and/
100 specimens, including, where or HIV-1 p24 Ag).
possible, at least 3–5 specimens 2. Any observed interference shall be investigated and
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2. In some jurisdictions there is a requirement for the
use of a “National Testing Panel” for lot release and
IVD validation. Such a national requirement does
not remove the need for evidence of traceability to a
validated reference material as described here.
1.10 Stability
Replicate testing shall be 1. The testing panel shall include all claimed analytes ISO 23640:2011 (11)
undertaken using a panel (for and include whole blood specimens and/or oral CLSI EP25-A (12)
each claimed pathogen/analyte) fluid specimens, as appropriate, in accordance with
Technical Guidance
consisting of at least: intended use (for example to verify proper flow and
Series for WHO
• 1 non-reactive specimen; absence of background interference, and to account
Prequalification
• 2 low-reactivity specimens, for other variables).
– Diagnostic
near assay cut-off (see Note 2); 2. Where detection of multiple genotypes and/or Assessment (13)
• 1 medium-reactivity specimen. subtypes is claimed, equivalent performance (for
ASTM D4169 - 14
WHO Expert Committee on Biological Standardization Sixty-eighth report
Wherever possible, specimens example, sensitivity and specificity) shall have been
(14)
chosen for the testing panel demonstrated; otherwise evidence of stability in these
shall reflect the main specimen genotypes/subtypes will need to be provided.
types intended for use with 3. Ideally, the stability testing panel shall be composed
the IVD (for example, capillary of natural (that is, undiluted) specimens. Where this
whole blood and/or oral fluid, is not feasible, stock specimens to be diluted should
as appropriate). represent a range of stages of infection (antibody
maturation) so as to take into account the limitations
of mimicking low IVD reactivity with a high-avidity
specimen.
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1.10.1 Real-time, minimum of 3 lots of 4. Lots shall comprise different batches of critical
Shelf-life final design product and: components.
(including • transport stressed (simulated) 5. Determination of shipping stability shall be performed
transport before real-time studies are using simulated extreme stress conditions, ensuring
stability) undertaken; that application of those conditions is consistent and
• IVD in final packaging controlled.
subjected to drop-shock 6. Claims for stability shall be based on the second-last
testing. successful data point from the least-stable lot – with
1.10.2 • minimum of 1 lot, using (where lots are different) a statistical analysis showing
In-use stability panel(s) compiled as above; that the bulk of lots will be expected to meet the
• testing of all labile claimed life. For example, for testing conducted at 3, 6,
components (for example, 9, 12 and 15 months where stability was observed at
buffers vials, sealed cartridges, 15 months, then the maximum stability claim shall be
etc. – see Note 8). 12 months.
7. Accelerated studies do not replace the need for real-
time studies.
8. In-use stability of labile components shall be
determined using components in their final
configuration.
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1.11 Flex studies
1.11.1 The influence of the following 1. Refer to WHO document PQDx_018 “Instructions WHO
Flex studies factors on expected positive for compilation of a product dossier” for other flex Prequalification
and negative results shall be studies that may be relevant, taking into consideration – Diagnostic
considered: the broad range of operational and environmental Assessment (8)
• specimen and/or reagent conditions consistent with intended use.
volume; 2. The factors listed opposite should be investigated
• buffer pH (measure of in ways that not only reflect but also exceed likely
robustness – for example, as operating conditions in low- and middle-income
affected by evaporation of the countries, so that the limitations of the device can be
buffer); understood. For example, in addition to investigating
• reading time (that is, the deviations of temperature within those claimed in the
interval between when the instructions for use, temperature ranges should be
first and last readings can be investigated that exceed those of claimed operating
taken); conditions and which cause test failure (incorrect/
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2.1.2 Testing of: 5. Consideration shall be given to the influence of
Diagnostic • at least 1000 HIV antibody/ antiretroviral medications present in a specimen on
specificity antigen negative specimens. the serostatus of such specimens, and to how this
might affect specimen selection.
6. Lots (locked-down design) shall comprise different
batches of critical components.
7. Where possible, all tests that produce a discrepant
result (between the assay under evaluation and the
reference results) shall be repeated using the same
lot, and then on all available lots and the variability
noted. Performance characteristics shall be reported
using initial results only. The results of further
testing of specimens with discrepant results shall be
reported separately as additional information on IVD
performance.
WHO Expert Committee on Biological Standardization Sixty-eighth report
ADDITIONAL POINTS:
■■ For each type of study summarized below, the study group shall
comprise untrained subjects whose age, gender, level of education,
literacy and additional supplementary skills may challenge the
usability of the IVD by its intended users, including in unfavourable
operational settings (for example, poor lighting).
■■ These assessment activities will determine the changes needed to
optimize the IVD for use by self-testers. Changes may range from
minor (simplification of instructions for use) to major. The impact
of any change on safety and performance shall be determined.
■■ Results from any one of the stages summarized below may indicate
that assay redesign is necessary. This may in turn result in a need to
revalidate the IVD or to perform additional specific performance
studies and to update the risk analysis.
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3.1 Qualification of usability (self-testing)
3.1.1 Questionnaire-based testing 1. Instructions for use and labelling shall be clear and European
Labelling of subjects representative of easy to understand; use of pictorial instructional Commission (2)
comprehension intended users, to assess the material is encouraged. ISO 18113-1:2009
study ability of such users to correctly (19)
comprehend key messages from
ISO 15197:2013 (20)
packaging and labelling with
regard to: IEC 62366-1:2015
(21)
• proper self-selection (whether
or not users understand if MHRA (22)
it is appropriate for them to Poffenberger, K (23)
undertake testing); FDA (24)
• understanding key warnings,
European
limitations and/or restrictions;
Parliament and
• proper test procedure;
European Council
• test result interpretation.
WHO Expert Committee on Biological Standardization Sixty-eighth report
(25)
Questionnaire shall be
Center for Devices
administered to at least 200
and Radiological
subjects, representative of
Health, FDA (26)
intended users, in order to
demonstrate comprehension of WHO (27)
key messages. USAID and WHO
(28)
Center for Devices
and Radiological
Health, FDA (29)
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3.1.2 A minimum of 400 subjects to 1. The study group may include subjects recruited as
Results interpret the results of contrived part of the labelling comprehension study.
interpretation IVDs (for example, static/pre-
study made tests) to assess their
ability to correctly interpret
pre-determined test results.
Contrived tests shall be made
to demonstrate the following
potential test results:
• non-reactive
• range of invalid results
• reactive
• weak reactive.
Study group to consist of at
least 200 self-testers from
2 high-prevalence (> 5%)
and geographically diverse
populations, and at least
200 self-testers from a low-
prevalence (< 5%) population
to demonstrate correct
interpretation of simulated
test results.
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3.1.3 Testing by at least 900 self- 1. A separate venous whole blood specimen shall be
Observed testing subjects comprising collected prior to testing to establish the reference
untrained user at least 200 self-testers in results for HIV-1 status (and HIV-2 where detection is
study each of 2 high-prevalence claimed). The testing algorithm used to determine the
(> 5%) geographically diverse reference results shall include use of a state-of-the-
populations, and at least art fourth-generation immunoassay, with all initially
500 self-testers from a low- reactive specimens reflexed for full characterization of
prevalence (< 5%) population. HIV status.
• Each subject to self-collect 2. For WHO purposes, the term “professional use”
test specimen and perform encompasses a diversity of skills, training and
test according to only those experience, and does not necessarily imply “highest
materials provided with the standard of skills, training and experience”. It may be
IVD (for example, instructions a useful step in the evaluation of usability to compare
for use, labels and other the performance of self-testers with that of health-
instructional materials). care workers, lay providers and laboratory technicians.
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References
1. Technical Guidance Series (TGS) for WHO Prequalification – Diagnostic Assessment. Principles
of performance studies. TGS–3. Geneva: World Health Organization; 2017 (http://apps.who.int/
iris/bitstream/10665/258985/1/WHO-EMP-RHT-PQT-TGS3-2017.03-eng.pdf?ua=1, accessed 22
December 2017).
2. Commission Decision of 3 February 2009 amending Decision 2002/364/EC on common technical
specifications for in vitro-diagnostic medical devices (2009/108/EC). OJ. 2009;L 39:34–49 (http://
eur-lex.europa.eu/legal-content/EN/ALL/?uri=uriserv:OJ.L_.2009.039.01.0034.01.ENG, accessed
22 December 2017).
3. Technical Guidance Series (TGS) for WHO prequalification of in vitro diagnostic medical devices.
Standards applicable to the WHO Prequalification of in vitro diagnostic medical devices.
TGS–1. Geneva: World Health Organization; 2017 (http://www.who.int/diagnostics_laboratory/
guidance/170808_tgs1_standards_2.0.pdf?ua=1, accessed 22 December 2017).
4. Evaluation of precision of quantitative measurement procedures; approved Guideline EP05-A3.
Third edition. Wayne (PA): Clinical and Laboratory Standards Institute; 2014.
5. EN 13612:2002. Performance evaluation of in vitro diagnostic medical devices. Brussels: European
Committee for Standardization; 2002.
6. User protocol for evaluation of qualitative test performance; approved Guideline EP12-A2.
Second edition. Wayne (PA): Clinical and Laboratory Standards Institute; 2008.
7. Guidance for manufacturers of human immunodeficiency virus (HIV) test kits intended to be
used in the laboratory. Ottawa: Health Canada; 2011 (http://hc-sc.gc.ca/dhp-mps/md-im/applic-
demande/guide-ld/md_gd_hiv_im_ld_vih-eng.php, accessed 2 January 2018).
Note: the above guidance does not apply to HIV test kits which are used for patient management, or
HIV test kits intended to be used outside the laboratory, that is, at the point of care and/or for home
use. Separate guidance titled “Draft Guidance Document – HIV Simple/Rapid Test Kits” is available
for manufacturers of near-patient HIV test kits upon request from Health Canada’s Medical Devices
Bureau, Health Canada; email: [email protected]
8. Instructions for compilation of a product dossier. Prequalification of In Vitro Diagnostics
Programme. Geneva: World Health Organization; 2014 (PQDx_018 v3, 27 August 2014; http://
www.who.int/entity/diagnostics_laboratory/evaluations/141015_pqdx_018_dossier_instructions_
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14. Standard practice for performance testing of shipping containers and systems. ASTM D4169 - 14.
West Conshohocken (PA): ASTM International; 2014.
15. Blood Products Advisory Committee. 86th Meeting, 10 March 2006. Silver Spring (MA): United
States Food and Drug Administration; 2006 (https://www.fda.gov/ohrms/dockets/ac/06/
transcripts/2006-4206t2.pdf, accessed 2 January 2018).
16. Blood Products Advisory Committee. 85th Meeting, 3 November 2005. Silver Spring (MA):
United States Food and Drug Administration; 2005 (https://www.fda.gov/ohrms/dockets/ac/05/
transcripts/2005-4190t1.htm, accessed 2 January 2018).
17. Blood Products Advisory Committee. Open Session, 17 November 2009. Silver Spring (MA):
United States Food and Drug Administration; 2009 (https://wayback.archive-it.org/7993/2017011
3022625/http://www.fda.gov/downloads/AdvisoryCommittees/CommitteesMeetingMaterials/
BloodVaccinesandOtherBiologics/BloodProductsAdvisoryCommittee/UCM193386.pdf, accessed
2 January 2018).
18. Blood Products Advisory Committee. 102nd Meeting, 15 May 2012. Silver Spring (MA): United
States Food and Drug Administration; 2012 (https://wayback.archive-it.org/7993/2017011301
4805/http://www.fda.gov/downloads/AdvisoryCommittees/CommitteesMeetingMaterials/
BloodVaccinesandOtherBiologics/BloodProductsAdvisoryCommittee/UCM309516.pdf, accessed
2 January 2018).
19. ISO 18113-1:2009. In vitro diagnostic medical devices – information supplied by the
manufacturer (labelling) – Part 1: Terms, definitions and general requirements. Geneva:
International Organization for Standardization; 2009.
20. ISO 15197:2003. In vitro diagnostic test systems – requirements for blood-glucose monitoring
systems for self-testing in managing diabetes mellitus. Geneva: International Organization for
Standardization; 2003.
21. IEC 62366-1:2015. Medical devices – Part 1: Application of usability engineering to medical
devices. Geneva: International Electrotechnical Commission; 2015.
22. Guidance for notified bodies on the regulation of IVDs for self-testing. London: Medicines and
Healthcare products Regulatory Agency; 2012 (https://www.gov.uk/government/publications/
regulation-of-ivds-for-self-testing, accessed 2 January 2018).
23. Poffenberger K. Update: rapid HIV test approval requirements and standards [Slides]. Silver
Spring (MD): United States Food and Drug Administration; 2000 (http://www.fda.gov/ohrms/
dockets/ac/00/slides/3649s2.htm, accessed 2 January 2018).
24. OraQuick® In-Home HIV Test. Summary of safety and effectiveness. FDA BP120001. Silver Spring
(MA): United States Food and Drug Administration; 2012 (http://www.fda.gov/downloads/
BiologicsBloodVaccines/BloodBloodProducts/ApprovedProducts/PremarketApprovalsPMAs/
UCM312534.pdf, accessed 2 January 2018).
25. Directive 98/79/EC of the European Parliament and of the Council of 27 October 1998 on in
vitro diagnostic medical devices. OJ. 2012;L 331:1 of 7.12.1998 (http://data.europa.eu/eli/
dir/1998/79/2012-01-11, accessed 2 January 2018).
26. Recommendations: clinical laboratory improvement amendments of 1988 (CLIA) waiver
applications for manufacturers of in vitro diagnostic devices. Silver Spring (MD): United States
Food and Drug Administration; 2008 (http://www.fda.gov/MedicalDevices/DeviceRegulation
andGuidance/GuidanceDocuments/ucm079632.htm, accessed 2 January 2018).
27. Consolidated guidelines on HIV testing services. Geneva: World Health Organization; 2015
(http://who.int/hiv/pub/guidelines/hiv-testing-services/en/, accessed 2 January 2018).
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28. How to use a rapid diagnostic test (RDT). A guide for training at a village and clinic level.
Modified for training in the use of the Generic Pf-Pan Test for falciparum and non-falciparum
malaria). Bethesda (MD) and Geneva: The USAID Quality Assurance Project (QAP), University
Research Co., LLC, and the World Health Organization; 2009 (http://www.wpro.who.int/malaria/
NR/rdonlyres/23DD7DCB-48C4-4CFF-BD45-332F0BE3DCC7/0/generic_PfPan_training_manual_
web.pdf, accessed 2 January 2018).
29. Applying human factors and usability engineering to medical devices. Guidance for industry
and Food and Drug Administration staff. Silver Spring (MD): United States Food and Drug
Administration; 2011 (http://www.fda.gov/downloads/MedicalDevices/.../UCM259760.pdf,
accessed 2 January 2018).
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Technical Guidance Series (TGS) for WHO Prequalification –
Diagnostic Assessment
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Preface
WHO Prequalification – Diagnostic Assessment:
Technical Guidance Series
316
Annex 5
317
WHO Expert Committee on Biological Standardization Sixty-eighth report
Acknowledgements 320
List of contributors 320
1 Abbreviations 321
2 Definitions 322
3 Introduction 327
3.1 Key concepts 327
3.2 Rationale of stability studies 327
3.3 Purpose of this document 327
3.4 Standards 327
3.5 Limitations of this guidance 328
4 Considerations when applying for WHO prequalification 328
4.1 Manufacturer responsibility 329
4.2 Suitability for use in WHO Member States 329
4.3 Meeting customer requirements 329
5 Basic principles for stability testing 329
5.1 Critical characteristics or metrics of the IVD 329
5.2 Finalized product presentation 330
5.3 Environmental conditions 330
5.4 Minimum number of lots 331
5.5 Assessment of liquid components 331
5.6 Specimens for the stability testing panel 332
5.7 Validation of stability testing panel 332
5.8 Panel member selection and value assignment criteria 333
5.9 Time points 334
5.10 “Zero time” values and variance 335
6 Shelf-life studies 336
6.1 Requirements for determination of shelf-life 336
7 Component stability studies 337
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Acknowledgements
The document Technical Guidance Series 2 (TGS–2) for WHO Prequalification –
Diagnostic Assessment: Establishing stability of in vitro diagnostic medical devices
was developed with support from the Bill & Melinda Gates Foundation and
UNITAID. The document was prepared in collaboration with Dr RJS Duncan,
London, the United Kingdom; Ms S Best, Dr S Braniff and Dr M Lanigan,
National Serology Reference Laboratory, VIC, Australia; and Ms D Healy and
Ms R Meurant, WHO, Geneva, Switzerland, with input and expertise from Dr S
Hojvat, MD, United States of America (USA); Dr L Kestens, Institute of Tropical
Medicine, Antwerp, Belgium; and Ms D Lepine, Medical Devices Bureau, Health
Canada, Ottawa, Canada. This document was produced under the coordination
and supervision of Ms R Meurant and Ms I Prat, Prequalification Team, WHO,
Geneva, Switzerland.
List of contributors
First-round comments were received from the following: Dr JC Badciong,
Abbott Laboratories, Chicago, the USA; Mr K De Vore, Bio-Rad Laboratories,
France; Dr A Halim, Celldex Therapeutics, Hampton, NJ, the USA; Dr S Hojvat,
MD, the USA; Dr L Kestens, Institute of Tropical Medicine, Antwerp, Belgium;
Ms D Lepine, Medical Devices Bureau, Health Canada, Ottawa, Canada; Ms L
Ochs, Clinical and Laboratory Standards Institute (CLSI), Wayne, PA, the USA
and members of the CLSI Consensus Committee, ISO T212 WG3 committee;
Dr G Pennello, United States Food and Drug Administration, Silver Spring,
MD, the USA; Mr J Pierson-Perry, Siemens Healthcare Diagnostics, Erlangen,
Germany; Dr E Russek-Cohen, United States Food and Drug Administration,
Silver Spring, MD, the USA; Professor M Stevens Hardy, Medical Laboratory
& Technology Consultants, LLC, Washington, DC, the USA; Mr C Zang,
WHO Technical Report Series, No. 1011, 2018
National Institutes for Food and Drug Control, Beijing, China; and the Japanese
Committee for Clinical Laboratory Standards, Tokyo, Japan.
The draft technical guidance document was posted on the WHO
Prequalification website for public consultation on 14 December 2015. Various
stakeholders, including manufacturers submitting to WHO prequalification
of IVDs, IVD manufacturing industry associations, various national and
international regulatory bodies, and IVD standards organizations, were informed
of the consultation in order to solicit feedback. A two-month response period
was provided.
Second-round public comments were received from the following: Ms A
Asahina, Alere Medical Co., Ltd, Chiba, Japan; Dr J Budd, Beckman Coulter Inc.,
Chaska, the USA; Dr C Candia Ibarra, Ministerio de Salud Pública y Bienestar
Social, Asunción, Paraguay; Dr NA Carrington, Roche Diagnostics, Indianapolis,
320
Annex 5
IN, the USA; Dr M Dreher, mdc medical device certification GmbH, Stuttgart,
Germany; Dr I Fijalkowska, United States Food and Drug Administration,
Silver Spring, MD, the USA; Ms J Goss, Sysmex Partec GmbH, Goerlitz,
Germany; Dr C Hill, Encinitas, CA, the USA; Dr L Kestens, Institute of Tropical
Medicine, Antwerp, Belgium; Dr M Kondratovich, United States Food and Drug
Administration, Silver Spring, MD, the USA; Dr M Leportier, Beckman Coulter,
Marseille, France; Ms K Máté‚ European Diagnostic Manufacturers Association,
Brussels, Belgium; Mr F Nyberg, Asia Pacific Medical Technology Association,
Singapore; Dr S Ortigoza, Ministerio de Salud Pública y Bienestar Social,
Asunciòn, Paraguay; Dr GP Payne, BD Diagnostics Point of Care, San Diego,
CA, the USA; Mr J Pierson-Perry, Siemens Healthcare Diagnostics, Erlangen,
Germany; Ms L Seixas, ALADDIV, Brasília, Brazil; Dr W-W Tsai and Ms P-W Tu,
Asian Harmonisation Working Party TC WG2, China, Hong Kong SAR; Dr NT
Wetherall, DAIDS/NIAID, Bethesda, MD, the USA; and Dr L Xu, Theranos, Inc.,
Palo Alto, CA, the USA.
Following incorporation of the second-round public comments, a
revised draft was published on the WHO Biologicals website for a final round
of public consultation between 18 June and 18 September 2017. The comments
received were incorporated to produce the document WHO/BS/2017.2304.
The document was adopted by the WHO Expert Committee on Biological
Standardization as a WHO written standard on 20 October 2017.
1 Abbreviations
ASTM ASTM International
CE Conformité Européenne (European Conformity)
CLSI Clinical and Laboratory Standards Institute
EIA enzyme immunoassay
HBsAg hepatitis B surface antigen
HBV, HCV hepatitis B virus, hepatitis C virus
IFU instructions for use
IgG, IgM immunoglobulin G, immunoglobulin M
ISO International Organization for Standardization
IVD in vitro diagnostic medical device
NAT nucleic acid test
NIBSC National Institute for Biological Standards and Control
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2 Definitions
The definitions given below apply to the terms used in this document. They
may have different meaning(s) in other contexts. Common English dictionary
definitions apply to non-defined concepts, such as device, constituent, equipment,
evaluation, part, product, reaction, signal, substance, etc.
Accelerated stability evaluation: Study designed to increase the rate of chemical
and/or physical degradation, or change, of an IVD reagent by using stress
environmental conditions to predict shelf-life.
WHO Technical Report Series, No. 1011, 2018
the routine conditions of use (for example, on-board stability, reconstitution and
open-vial/bottle stability). A single product may have several different types of
in-use stability claim, each reflecting different aspects of its usage. For example,
an IVD reagent may have one in-use stability claim for unopened storage on
board its associated instrument system and another stability claim once it is
opened and put into active use. Another type of in-use life is the calibration
interval of an IVD reagent (2).
In vitro diagnostic medical device (IVD): A medical device, whether used alone
or in combination, intended by the manufacturer for the in vitro examination
of specimens derived from the human body solely or principally to provide
information for diagnostic, monitoring or compatibility purposes.
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WHO note: This document uses the terms IVD and IVD reagent interchangeably.
Life-cycle: All phases in the life of a medical device, from the initial conception
to final decommissioning and disposal (12).
Note: Conditions that can affect the stability of an IVD reagent include
temperature, transport conditions, vibration, light and humidity (1).
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3 Introduction
3.1 Key concepts
Stability is the ability of an IVD reagent to maintain its performance
characteristics over a defined time interval (12). The purpose of most stability
studies is to establish or verify the time interval, and the storage conditions that
can maintain stable IVD performance characteristics.
3.4 Standards
WHO recommends the following standards for use in establishing stability
claims: International Organization for Standardization (ISO) 23640:2011 (1);
Clinical and Laboratory Standards Institute (CLSI) EP25-A (2) and ASTM
International D4169 - 14 (14). It is recommended that manufacturers be familiar
with these standards and consider them when designing and planning their
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stability studies. For other relevant standards see TGS–1: Standards applicable to
the WHO Prequalification of in vitro diagnostic medical devices 1.
1
Available at: http://www.who.int/diagnostics_laboratory/guidance/170808_tgs1_standards_2.0.pdf?ua=1
2
WHO documents PQDx_049 Product dossier checklist and PQDx_018 Instructions for compilation of a
product dossier are available on the WHO Prequalification – Diagnostic Assessment website: http://www.
who.int/diagnostics_laboratory/evaluations/en/
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Examples:
1. A hepatitis C virus (HCV) assay containing the critical constituents
related to detection of NS3 or core proteins must have the stability of
all such constituents proven for the shelf-life of the IVD.
2. For an assay designed to detect both immunoglobulin G (IgG) and
immunoglobulin M (IgM) by use of protein A and protein L, the
stability of both protein A and protein L must be proven in the IVD.
3. For an IVD to quantitate CD4, all the constituent antibodies used
(for example, anti-CD3 and anti-CD4) must be shown to be stable in
the IVD.
4. For an IVD claimed to detect particular seroconversion specimens
or genotypes, or to have specified precision at particular analyte
concentrations, or a particular specificity, each of these claims at risk
or that change over time must be proven over the stated shelf-life (see
TGS–4: Guidance on test method validation for in vitro diagnostic
medical devices (16).
Other critical characteristics (also called critical metrics) identified in
the risk assessments may include physical measurement (for example, volume,
pH, flow rate, legibility and adhesion). These characteristics must be shown to
meet their specifications for the shelf-life of the IVD but are outside the scope of
this document.
example, different buffer volumes used for different kit sizes) must be used during
stability testing. Where some presentations are not tested, the manufacturer
should document the rationale, justifying why all presentations have not
been tested.
of the container) may be expected to affect the stability of the products contained
(for example, liquid component). This is sometimes referred to as “inverted
container stability”. The product orientation may need to be moved occasionally
during the stability study to ensure that there is direct contact between the liquid
contents and all parts of the container. This aspect requires particular attention
during in-use stability studies of components that are diluted or reconstituted
from a freeze-dried state before use.
3
A panel is a collection of well-characterized specimens and other materials that are used to monitor
aspects of IVD and component function during stability studies, for in-process control, for some aspects
of design validation and at release to sale. The same materials might be used for each of these purposes
but be assigned different acceptance criteria for the different functions.
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The benefits of a simple study design are that a small number of testing
intervals and fewer resources are required. However, such a simple design
represents a high-risk approach that has the potential to waste time and resources
if the IVD does not meet the acceptance criteria with an appropriate margin of
statistical confidence at the end of testing. If the acceptance criteria would have
been met at another intermediate time point then that might have been acceptable
as an assigned shelf-life.
A more effective and well-established approach routinely used is to
test at a number of additional predetermined intermediate time point intervals
(between 1 and 2 above). Typically, testing is carried out at relatively short
intervals (every 10 or 14 days) for the first 3 months, and then at monthly
WHO Technical Report Series, No. 1011, 2018
intervals until at least one month beyond the design input-specified shelf-life.
This protocol provides information on whether the IVD ages more rapidly in the
period just after manufacture than later on in the shelf-life, and usually provides
sufficient data to enable the assignment of a confidence interval to the shelf-life.
The manufacturer could identify the most practical intermediate test
points from a risk evaluation of a specific IVD and include them in the stability
study plan/protocol. Such planning will also help manufacturers to estimate the
resources required to implement the testing.
Testing of all panel members is not expected at each of the test/time
points. However, testing with all stability testing panel members is expected at
the initial, the second to last and the last test/time point for all of the study types.
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The manufacturer should consider and document the rationale for the selection
of intermediate test points, and choose panel members to be tested at these
intermediate test points (for example, representative members, specimens that
are close to the medical decision points and those at the extremes of the assay
range tested).
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6 Shelf-life studies
6.1 Requirements for determination of shelf-life
The stated shelf-life of an IVD must normally be based on real-time experimental
results. Accelerated stability studies are usually not sufficient to support a claimed
shelf-life, although they may be used in situations where experience already exists
with similar products (see (1) section 4.1) or when the stability of very similar
products is already known (see (2) section 7.3.1).
Note: If at the time of dossier submission for WHO prequalification the
real-time study outcome is not available, accelerated studies might be considered.
The manufacturer must justify why the accelerated study is acceptable as
supportive evidence until real-time experimental results become available.
In these cases, the results of real-time stability studies will be requested as a
condition of WHO prequalification. The shelf-life of the IVD could be extended
upon WHO review of real-time data.
where products will first be transported to the end user and then stored under
the recommended conditions before use, possibly until almost the end of their
labelled shelf-life.
It may be routine practice to store IVDs for an extended period after
manufacture before shipping. In this case, the IVDs would be kept first for a
defined period of time under recommended storage conditions, then taken
through the transport stress condition sequences, and finally put back into the
recommended storage conditions for the duration of the study (2).
Example:
It is frequently seen in dossiers submitted for WHO prequalification that a
positive run control will produce a signal of > 2.0 optical density (OD) in
a freshly manufactured lot, and the IFU will state that an OD > 0.8 for the
same control qualifies a run. Thus the IVD may have lost more than half its
activity and still appear functional, even though some critical specimens are
shown in the dossier to have very weak signals on freshly made IVDs. This
is not considered appropriate unless data can be provided that demonstrate
that the critical specimens will still be detected at the end of shelf-life and
with a control material signal of 0.8 OD.
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Example:
A static challenge of 45 °C for 3 days may represent conditions seen during
the actual transportation of an IVD – however, a more stringent challenge
of cyclical high and low temperatures (including freezing) for a longer
period of time, and followed or preceded by exposure to vibration might
better cover a “worst-case scenario” of shipment, storage and subsequent
transportation to the end user.
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vacuum, impact and inversion; along with the size, weight and composition of
the packaging. This should be regarded as part of stability testing.
example, “use at 15–40 °C”) evidence must be provided to prove the stability
over that range with all the specimen types claimed (for example, serum, whole
blood and oral fluid), unless a documented rationale is provided. It is considered
best practice for the manufacturer to claim a stability range that includes an
appropriate safety margin (for example, test range 2–35 °C, claimed 4–30 °C) to
ensure that that the claimed stability range is acceptable. However, where claimed
in-use stability is restricted to a limited range (for example, “use at 35–37 °C”) it
is acceptable for in-use stability studies to be conducted at a single temperature
within this range, subject to evidence from documented robustness studies or
risk assessments.
It is good practice to perform the in-use stability testing at both the
start and end of the shelf-life of the IVD (or with components at the start and
end of their shelf-lives if any of the components have a longer shelf-life than
the complete IVD) and after simulated transport challenge (see section 8). This
will confirm that the IVD will have the claimed in-use life throughout its whole
shelf-life.
All studies should support precisely defined periods of in-use stability
claims.
Example:
An RDT test cassette may be labelled “Use immediately on opening”.
However, it is still necessary to determine the interval (one hour, one day,
etc.) over which IVD performance remains stable after the component
is opened.
Examples:
1. A reagent may have a stated period of stability once it has been placed
on board an instrument and another period of stability once it is in
active use (that is, during actual use/testing).
2. Multiple-use reagents (for example, buffers) may repeatedly be exposed
to high temperatures during the day while in use and exposed to lower
temperatures when not in use and stored in the refrigerator. The actual
use of the multiple-use reagent – squeezing of bottles, exposure of the
lid and tip to working surfaces and hands, and exposure to dust and
light – may also affect stability. Stability studies and associated risk
assessments should take all of these factors into account.
special attention must be paid to the potential for variability (see also section
12.3). However, the sources of variation will depend on the particular process,
product and component, and should be identified during product development
risk analyses.
Use of different batches of critical components ensures that the stability
evidence obtained is more likely to be representative of long-term manufacture.
Any variability found can be taken into consideration when assessing the
outcome of the studies against the design input requirements and when making
claims. This minimizes user problems and hence complaints.
■■ manufacturing specifications
■■ release-to-market QA criteria
■■ packaging and labelling (see section 10.4)
■■ validated manufacturing scale on qualified manufacturing
equipment.
Note 1: For WHO prequalification, it is important that the stability
studies have been conducted using the IVD intended to be prequalified, and
not surrogates and/or closely related products. Changes perceived as small (for
example, change in production scale, bulk container materials, supplier of a
critical biological or vial stopper) can have unexpected effects on stability and
other performance characteristics. After such changes, a new documented risk
assessment and, if necessary, a stability plan and study, is needed. Manufacturers
should have change-control procedures in place compliant with ISO 13485 (15).
Note 2: Stability studies undertaken in the R&D phase of the product
life-cycle provide an important understanding of how to design the product
so that it will meet the final stability requirements identified in the input
documentation. However, these studies are usually not sufficient for submission
to WHO prequalification assessment since they may not reflect the final design
and manufacture of the IVD.
10.2.1 Exceptions
If any of the above criteria are not met (for example if “pilot lots” or small-scale
lots are used, or if the method of use described in the IFU is not finalized), strong
evidence must be provided that the materials that were evaluated will perform
exactly the same as the final commercial product.
Note: In some exceptional circumstances, where it is not possible to sample
from actual production lots, samples from pre-production or development lots
might be used. If this is the case, manufacturers should justify why production
lots were not used, and provide robust evidence that the lots chosen are expected
to behave identically to the production lots. Data concerning lot-to-lot variability
must still be submitted. Although WHO will consider the available evidence
on its merits, this preliminary information must be followed by stability claims
conducted on fully qualified production lots.
obtained during R&D (see section 10.1). However, the minimum will never be
less than three lots for shelf-life verification.
WHO note: It is not acceptable to sample IVDs from a single production
lot but to label them so that they appear to have been taken from three separately
manufactured production lots. This is true for all performance evaluation and
regulatory submission purposes. WHO prequalification investigates batch
records during on-site inspections. Non-compliance with this requirement may
result in a critical non-conformity grading.
relatively fresh components and components which have progressed into their
assigned shelf-life will be used when selecting the different production lots for
use in studies to establish the product shelf-life (1, 2).
11.1 Responsibilities
The study plan should outline the responsibilities and applicable training for all
staff involved in the study. The responsibilities for implementing the study plan
must be assigned to appropriately qualified and trained staff. Responsibilities to be
allocated include study set up, testing, monitoring, validation of equipment and/or
processes, sample selection, risk assessment and corresponding documentation.
In addition, the manufacturer must nominate a person responsible for
investigating failures and a person responsible for conducting risk assessments
if the IVD fails to meet the requirements of the design inputs.
11.4 Documentation
The plan should make reference to the preparation of a study report that will
be used to summarize the interim, and ultimately final, study findings and
conclusions. The study plan, the testing protocol, the study report and all
WHO Technical Report Series, No. 1011, 2018
OD then the IVD will meet a particular claim. Given the results of the stability
study using that panel member and showing the variability within and between
lots of the IVD, the probability of future similar production of the IVD meeting
claims at the assigned life can be estimated. The derivation of valid criteria and
the probability of maintenance of all claims can be estimated by appropriate
statistical methods.
There is a wealth of information available on the statistical methods used
in the R&D of IVDs, from both ISO (20–22) and CLSI (2, 23–26). Although
most of these methods apply to quantitative assays, information on statistical
methods for qualitative assays is also available (27).
The fundamental considerations for stability testing are the number of
replicates required at each time point and the number of different production
lots required which together will produce an “acceptable overall probability
estimate” of the likelihood of future production lots meeting claims (and hence
user input requirements) at the end of the shelf-life.
However, consideration must also be given to what represents “an
acceptable overall probability limit”. “Acceptability” is a decision critical to
quality and must be decided upon in advance based on the input requirements
(for example, 80% confidence that 95% of lots will meet the claims). This is a
tolerance interval as described in ISO 16269-6:2014 (22). The consideration can
then be phrased as: “How many replicates and how many different production
lots can then be derived from the tolerance interval required?”
It is strongly recommended that manufacturers seek advice from a
professional statistician once the quality-critical requirements have been defined
and before beginning any experimental work.
The statistical methods to be used must be documented in the plans
and protocols of any stability study and consideration given to the treatment of
unexpected and atypical results. In general, all results must be used unless there
is a documented physical reason that the result can be ignored – for example,
known operator error, too little volume, incorrect timing or use of an unqualified
instrument (one lacking maintenance or calibration). Any ignored results must
nevertheless be recorded and included in the report of the stability study.
To avoid confusion, the details of actual storage and use procedures are required
in the testing report.
be defined according to the panel criteria for both qualitative and quantitative
test methods. Results from failed (invalid) test runs must not be used in the
determination of the stability claim. However, the invalid results should be
recorded and included in the report of the stability testing.
to the study plan, testing protocol and input requirements. It should make clear
references to other supporting documentation (for example, result worksheets).
of filter pad material does not dislodge when packages are jostled and
bumped in transit).
4. Based on an HIV RDT that has been fully validated for the detection
of HIV-1 antibodies, a new IVD is developed which includes detection
of antibodies to Treponema pallidum (TP). Detection of TP-specific
antibodies occurs on a completely separate membrane (and associated
architecture) to that of HIV-antibody detection. Additional handling
steps may have an impact on the stability of the HIV-1 antibodies
and retesting may be required. It may be necessary to review evidence
of stability during transportation to ensure that new components are
not affected by transit (for example, where a new packaging concept
is used).
–– If a new machine is used for striping of the HIV-1/TP IVD,
validation of the new machine (installation qualification,
operational qualification and performance qualification) would
be required to show that the stability studies are still valid.
–– If the IVD is designed in a way that HIV and TP detection occurs
either on the same membrane and/or using most of the same
architecture (and assuming that sample buffers are identical
between IVDs) it is likely that this new IVD would need to be
fully validated.
14 References
1. ISO 23640:2011. In vitro diagnostic medical devices – evaluation of stability of in vitro diagnostic
reagents. Geneva: International Organization for Standardization; 2011.
2. Evaluation of stability of in vitro diagnostic reagents; approved Guideline EP25-A. Wayne (PA):
Clinical and Laboratory Standards Institute; 2009.
3. Specifications: test procedures and acceptance criteria for biotechnological/biological products.
Q6B (Step 4). ICH Harmonised Tripartite Guideline. Geneva: International Conference on
Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use;
1999.
4. ISO 17511:2003. In vitro diagnostic medical devices – measurement of quantities in biological
samples – metrological traceability of values assigned to calibrators and control materials.
Geneva: International Organization for Standardization; 2003.
5. ISO 18113-1:2009. In vitro diagnostic medical devices – information supplied by the
manufacturer (labelling) – Part 1: Terms, definitions and general requirements. Geneva:
International Organization for Standardization; 2009.
6. Directive 98/8/EC of the European Parliament and of the Council of 16 February 1998
concerning the placing of biocidal products on the market). OJ. 1998;L 123:1–63 of 24.4.98
(http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1998:123:0001:0063:en:PDF,
accessed 20 December 2017).
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19. Pharmacopoeia of the People’s Republic of China English edition. Beijing: State Pharmacopoeia
Commission of the People’s Republic of China; 2000.
20. ISO 5725-1,2,3,4,6:1994 and ISO 5725-5:1998 Accuracy (trueness and precision) of measurement
methods and results – Parts 1–6. Geneva: International Organization for Standardization; 1994
and 1998.
21. ISO 3534-1,2:2006 and ISO 3534-3:2013. Statistics – vocabulary and symbols – Parts 1–3. Geneva:
International Organization for Standardization; 2006 and 2013.
22. ISO 16269-4:2010, ISO 16269-6:2014, ISO 16269-7:2001 and ISO 16269-8:2004. Statistical
interpretation of data – Parts 4 and 6–8. Geneva: International Organization for Standardization;
2010, 2014, 2001 and 2004.
23. Evaluation of the linearity of quantitative measurement procedures: a statistical approach;
approved Guideline EP06-A. Wayne (PA): Clinical and Laboratory Standards Institute; 2003.
24. Interference testing in clinical chemistry; approved Guideline EP07-A2. Second edition. Wayne
(PA): Clinical and Laboratory Standards Institute; 2005.
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25. Evaluation of detection capability for clinical laboratory measurement procedures; approved
Guideline EP17-A2. Second edition. Wayne (PA): Clinical and Laboratory Standards Institute; 2012.
26. Evaluation of precision of quantitative measurement procedures; approved Guideline EP05-A3.
Third edition. Wayne (PA): Clinical and Laboratory Standards Institute; 2014.
27. Valcárcel M, Cárdenas S, Barceló D, Buydens L, Heydorn K, Karlberg B et al. Metrology of qualitative
chemical analysis. Brussels: Directorate-General for Research and Innovation (European
Commission); 2002 (http://bookshop.europa.eu/en/metrology-of-qualitative-chemical-analysis-
pbKINA20605/, accessed 22 December 2017).
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Appendix 1
Examples of stability protocols
This appendix uses the example of a wholly fictitious IVD to illustrate the kinds
of experimental design that would be required to adequately determine:
1. the stability of whole kits during transport followed by the stability of whole
kits during shelf-life; and
2. the in-use stability of whole kits including reagents.
The information provided in these examples should be used as a guide
to possible approaches for generating evidence of a standard sufficient to satisfy
the expectations of WHO prequalification. Further examples can be found in
the WHO Prequalification: Sample Product Dossiers available on the WHO
Prequalification website 1.
WHO expects that a transportation challenge would precede the real-
time determination of shelf-life and in-use studies.
The fictitious IVD used in the examples below is an RDT for the detection of
antibodies to HIV-1, HIV-2 and Treponema pallidum (TP) in serum, plasma
and whole blood, and is referred to as the HIV/TP RDT.
The IVD kit components are: a test cassette sealed in a foil pouch (with
desiccant) and a bottle of specimen buffer/diluent for use.
WHO Technical Report Series, No. 1011, 2018
1
http://www.who.int/diagnostics_laboratory/guidance/sample_product_dossier/en/
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Preparation
Acquire sufficient numbers of the IVD kits from three independent production
lots using a predetermined sampling protocol (for example, random, first X
number of kits in first box, every 100th kit, etc.). Allow at least 10% overage for
unexpected requirements and re-testing.
Note 1: To provide security against unforeseen events, duplicate tests
should be performed as a minimum. However, testing in triplicate will
provide more statistical confidence in the observed test result.
The IVD kits chosen for testing must be in their final packaging including all
labelling (see section 10.4).
The IVD kits are stored so that the reagents are in contact with all
elements of the packaging (for example, the bottles in the IVD kits are stored
horizontally, lying flat on their sides, allowing liquids to remain in contact with
the bottle closures).
Acquire sufficient volume of each panel member for the duration of the
testing schedule (see testing schedule below).
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The protocol for these studies specifies the number of IVD kits to be
picked, the statistical sampling plan to be used and the required panel members
and their volumes.
Documentation
In Worksheet XYZ00001 record the following:
■■ the lot numbers from which the IVD kits were sampled;
■■ the number of IVD kits sampled from each lot; and
■■ details (including manufacturing/lot information) for each of the
IVD kit components that will be tested as part of this protocol (test
cassette and specimen buffer).
The IVD kits will be divided into two groups. One group will be stored at
40 ± 5 °C, the other at 8 ± 2 °C. IVD kits from each group will then be subjected
to the following conditions:
WHO Technical Report Series, No. 1011, 2018
Condition 1: Temperature and humidity sequence; all IVD kits will be taken
through a temperature and humidity sequence consisting of:
Followed by
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Note 4: The protocol should call for testing of at least five individual IVD
kits after each stress condition, using the stability panel members giving
the most informative results. This approach will enable verification that
the IVD kits are sufficiently stable to progress to the next condition –
though this should already be known from preliminary experiments and
R&D work.
Condition 2: Transport stress conditions – shaking; each IVD kit will be placed
on a shaking table at X revolutions per minute (rpm) for X hours/days at
42 ± 5 °C as defined by ASTM D4169 section 12.2
After the simulated shipping challenge, each IVD kit will be returned to
its corresponding storage temperature (40 ± 5 °C or 8 ± 2 °C).
2
See: Standard practice for performance testing of shipping containers and systems. ASTM D4169 - 14. West
Conshohocken (PA): ASTM International; 2014.
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Acceptance criteria
Each panel member should show a band intensity result that matches its
expected result at each tested time point. The expected result must be validated
so that if the IVD fails to meet the claims (for example, fails to detect critical
specimens, has unacceptable performance at medical decision concentrations
or has unacceptable specificity) the panel member would also fail to meet its
specified result.
The stability after transportation of the IVD kit will be taken as the time
point before the last time point to have met the acceptance criteria – for example,
if the IVD is stable to 13 months, the stability after transportation will be deemed
to be 12 months.
The stability after transportation should be identical to the claimed shelf-
life of the IVD kit – that is, the extremes of possible conditions to which the
IVD kit is likely to be subjected during transport must not affect the shelf-life of
the IVD.
Calculation of results
Detailed statistical instruction must be obtained from a professional statistician
with an understanding of the expectations of the stability study plan and outcome.
Professional statistical input is particularly recommended when calculating
confidence limits for discrete data such as readings from a graduated scale.
Each of the following applies at each time point:
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The variance of the results for all replicates within and between all the lots
must be calculated for each panel member. From the overall variance between
lots, the confidence with which future lots of the IVD kit will detect the panel
member at that time point after manufacture and transport can be calculated. If
the confidence that the panel member will meet its specification is less than some
pre-defined value (normally 95%), it must be deemed to have failed at that time
point and the shelf-life of the IVD kit should be restricted accordingly.
If regression analysis is used to define the time point at which a panel
member would not meet its criterion, then lot-to-lot variability must be included
when setting the confidence limits around the regression line. However, real-
time data must extend beyond the claimed shelf-life so that the intercept of the
regression confidence limit and the expected value must be at a time period
longer than the claim. It is usually more appropriate to calculate as discussed
in the previous paragraph, particularly if the regression cannot be proven to
be linear.
Acquire sufficient numbers of IVD kits from one production lot using a
predetermined sampling protocol (for example, random, first X number of kits
in the first box, every 100th kit, etc.).
Acquire sufficient volume of each panel member for the duration of the
testing schedule. Establish a method for randomizing the panel for testing.
In Worksheet XYZ00001 record the following:
■■ the lot numbers from which the IVD kits were sampled;
■■ the number of IVD kits sampled from each lot; and
■■ details (including manufacturing/lot information) for each of the
IVD kit components that will be tested as part of this protocol (test
cassette and specimen buffer).
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Preparation
Two lots of specimen buffer are to be tested. One lot of the component must be
freshly made, while the other should be towards the end of the assigned shelf-life
of the IVD kit.
The component is to be tested in its final packaging.
The IVD kits are stored so that the reagents are in contact with all
elements of the packaging (for example, the bottles in the IVD kits are stored
horizontally, lying flat on their sides, allowing liquids to remain in contact with
the bottle closures).
Half of each lot will be stored at 30 ± 5 °C, the other half at 15 ± 5 °C. At
the start of testing, each bottle will be brought to room temperature (20 ± 2 °C),
opened, used for testing and then recapped and returned to the stated storage
temperature.
Note: It is important that the components under test are opened and
used under circumstances likely to occur in users’ laboratories (that is,
not in rooms with HEPA-filtered air) thus mimicking, as far as possible,
genuine use.
Testing schedule
At each subsequent scheduled time point the allotted number of bottles will be
brought to room temperature and used to test each panel member in triplicate.
Testing will be conducted at 0, 1, 2, 3, 4 weeks, etc., up to the end of the claimed
in-use life.
Documentation
In Worksheet XYZ00001 record the following:
■■ the lot number of the IVD kit used to conduct the test;
■■ the operator(s) name(s);
■■ the dates of testing;
■■ the temperature at which the IVD kits are stored;
■■ the ambient temperature during testing;
■■ identifying details for each member of the panel being tested;
■■ each test result as a band intensity – band intensity should be scored
using the calibrated scale described in Protocol ZXY00001 (for
example, 0; faint/trace; +1; +2; +3;…+10);
■■ each test result as an interpretation according to the IFU;
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■■ any aberrations or deviations from the protocol, the reason for the
deviation and any remedial action undertaken.
Acceptance criteria
Each panel member should show a band intensity result that matches its expected
result at each tested time point. The in-use stability of the sample buffer will be
taken as the time point before the last time point to have met the acceptance
criteria – for example, if the IVD kit is observed to be stable to 5 weeks, the in-use
stability will be deemed to be 4 weeks.
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Appendix 2
Suggested specimens for stability testing panels
Examples in this section
Not all of the specimens in the examples that follow will be necessary for all IVDs,
and nor is the list exhaustive. Panels must be composed according to strict risk-
management principles and all decisions must be documented and traceable.
The minimum set of specimens recommended for inclusion in a testing
panel for different types of products are outlined below.
Specimens Remarks
Specimens to demonstrate Traceability is required to one of the WHO
maintenance of sensitivity international standards 1 if available – for example,
and/or limit of detection, and/ the Third WHO International Standard for HIV1-RNA
or accuracy, and precision for NAT-based assays (National Institute for Biological
Standards and Control (NIBSC) code 10/152); or the
Fourth WHO International Standard for hepatitis C
virus RNA for NAT-based assays (NIBSC code 06/102).
More than one genotype may be required to
validate these claims: see the First WHO International
Reference Panel for hepatitis B virus genotypes for
NAT-based assays (Paul-Ehrlich-Institut (PEI) code
5086/08).
This may be required on each of the claimed
specimen types.
1
The catalogue of WHO International Reference Preparations is available at: http://www.who.int/
bloodproducts/catalogue/en/
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Table continued
Specimens Remarks
Specimens to demonstrate Sufficient negative specimens should be included
specificity and validity of to ensure that the claims will be met at end of
runs shelf‑life.
Specimens (or reagents) to If more than one part of the genome is to be
demonstrate stability of each detected, both systems must be shown to
of the critical components of be stable.
the IVD If both DNA and RNA are measured the complete
system must be shown to be stable.
Parameters
The panel used in stability work must be able to demonstrate the following:
■■ stability of all the antibodies used in the IVD (frequently anti-CD4
and anti-CD3 antibodies; any other critical components must also
be covered);
■■ accuracy and trueness of measurement maintained at the critical
level (at least five specimens required);
WHO Technical Report Series, No. 1011, 2018
■■ claimed linearity over the required range of CD4 count (at least five
specimens required); and
■■ measure drift.
Specimens
Artificial specimens (such as stabilized blood specimens) can be used if a risk
assessment based on R&D work indicates that they are effective. Fresh specimens
are usually required. Measurements should be compared to an approved
reference system.
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Examples of approaches
Aged or in-use lots may be compared with a reference – for example, a new lot.
Precision studies can be performed as described elsewhere.2
Specimens Remarks
IgM first seroconversion Possible approaches to obtain samples:
specimens and IgG first • Study the early data from commercial
seroconversion specimens seroconversion panels where the
seroconversion was frequently monitored
by IgM and IgG blots.
• Study the responses to second and third
generation assays or protein A and protein L
assays (this approach is less useful).
All other parts of the HIV
proteome included – for example,
reverse transcriptase (RT)
Late stage specimens – usually This might serve to monitor any kit run
a high-dilution set near the control.
sample-to-cut-off ratio Note: HIV serology is not particularly genotype
dependent. It is usually not necessary to
include controls for genotype detection
unless risk assessment or experiment shows
that it is required for a particular IVD.
HIV-2, diluted to near the sample- Seroconversion specimens are very rare.
to-cut-off ratio
HIV-1 (O), if claimed
Difficult specimens to monitor 100 negatives at release subject to risk analysis
specificity and invalidity rate and statistical analysis of the allowable
(relative to the claimed) false-reactive rate and
invalidity rate.
2
Evaluation of precision of quantitative measurement procedures; approved Guideline EP05-A3. Third
edition. Wayne (PA): Clinical and Laboratory Standards Institute; 2014.
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Specimens Remarks
Specimens to detect HIV See the above section 3. Specimens to
monitor tests for HIV antibodies.
Specimens to detect all the critical Note: Each of these epitopes plays a role in
epitopes in the IVD – for example, detecting syphilis in different stages of the
TpN47, TpN17 and TpN15 infection. It is necessary to have a panel
member to monitor each epitope system
present (and possibly each stage of infection)
even if poly-fusion proteins are used. This
can be avoided if the manufacturer can
demonstrate that each epitope system is
equally stable.
Specimens able to show that the Note: It would not be sufficient for WHO
invalidity and specificity rates prequalification to extrapolate to the stability
do not fall outside the claims, of HIV-2/TP detection by testing only HIV-1-
particularly if whole blood is a positive specimens.
claimed specimen type
Specimens Remarks
NS3 first seroconversion specimens
and core first seroconversion
specimens
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Table continued
Specimens Remarks
Difficult specimens to monitor 100 negative specimens subject to risk
specificity and invalidity rate analysis and statistical analysis of the
allowable (relative to the claimed) false-
reactive rate and invalidity rate.
Specimens Remarks
Specimens to define sensitivity Traceability is required to one of the WHO
relative to the claim international standards 1 – for example,
the Third WHO International Standard for
hepatitis B virus surface antigen (genotype B4;
HBsAg subtypes ayw1/adw2); NIBSC code
12/226) for one or more specimens and
probably also to the ad and ay standards
available from a commercial supplier.
Commercially available seroconversion
specimens are almost all of the adw2 subtype
– different from the Third WHO International
Standard – so claims of critical threshold
specimen detection must be proven by
specimens in the panel.
Specimens to monitor the These will almost certainly be traceable to the
maintenance of the claims for a First WHO International Reference Panel for
variety of serotypes/genotypes hepatitis B virus genotype for HBsAg assays
and mutant forms (PEI code 6100/09).
Specimens to control against
prozone/high dose hook effect if
found or if theoretically an issue
If detection of HBsAg in the
presence of anti-HBsAg is claimed
(current best practice) proof
of maintenance of the claim
is required
3
The catalogue of WHO International Reference Preparations is available at: http://www.who.int/
bloodproducts/catalogue/en/
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Table continued
Specimens Remarks
Specimens to monitor the critical If the monoclonal antibodies used have a
components of the IVD particular function or bias, such as against
the ayr or adr subtypes (not controlled by the
standards) or are used to detect mutant forms
of the antigen, then each must be monitored
to ensure viability at end of shelf-life. These
may be the same specimens as mentioned in
the previous paragraphs.
If there are critical dissociation chemicals or
red-cell capture or rupture agents used then
these must also be monitored.
Difficult specimens to monitor 100 negative specimens subject to risk
specificity and invalidity rate analysis and statistical analysis of the
allowable (relative to the claimed) false-
reactive rate and invalidity rate.
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Appendix 3
Summary table of standards relevant to stability studies
Recommendation Comment Standard
Studies must be compliant The minimum expected standards. CLSI EP25-A
with CLSI EP25-A and ISO ISO 23640:2011
23640:2011
Studies must be fully Risk assessment must be specific to CLSI EP25-A
documented with the analyte, type of physical device (many sections)
risk evaluations, plans and assay format, and previous ISO 23640:2011
and protocols prior to manufacturing experiences, not (section 2)
initiation generic nor by rote. ISO 14971:2007
Studies and risk This is particularly important for
management must transport stress where extreme
take into consideration conditions must be evaluated.
the conditions likely to
be encountered in the
geographical and health-
care settings in which the
IVD is intended to be used
IVDs must be subjected This is particularly important to CLSI EP25-A
to simulation of transport WHOPQ as transport will always (section 4.2.3)
stress before being used be involved before use of an IVD, ISO 23640:2011
to establish any form of and transport conditions cannot be (section 5.2)
stability guaranteed nor predicted.
Transport simulation must It is most unlikely that actual transport CLSI EP25-A
cover the extremes of will involve all extreme conditions (section 4.2.3)
environmental conditions that might occur during the
ascertained during risk marketing life of the IVD, or that the
evaluations conditions during actual transport
can be adequately documented.
IVDs used in any stability If IVDs are not made to final validated Good
studies must be made to and documented manufacturing manufacturing
finalized manufacturing scales, stringent proof must be practice (GMP)
specifications, to final presented that the scale change will CLSI EP25-A
scale and in the packaging not affect any parameters of the IVD,
(including labelling) in nor any of the manufacturer’s claims.
which the IVDs will be Pre-production lots can only be used
made available for stability work if these conditions
are met.
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Table continued
Recommendation Comment Standard
If several presentations If, for example, two pack sizes are CLSI EP25-A
of the IVD are to be to be provided then each pack size
presented, all aspects of must be evaluated completely, even
stability must be shown though the contents are identical
for each except for vial size.
Sufficient numbers of “Independent lots” means lots CLSI EP25-A
independent lots of the with different production (or (section 4.4)
IVD must be evaluated manufacturing, purification, etc.)
to enable each form of runs of critical reagents (for example,
stability to be evaluated biological reagents prepared in
in terms of inter-lot different syntheses, growths or
variability purifications or other risk-defined
critical reagents from different
manufactured lots or from different
suppliers if applicable).
CLSI EP25-A and ISO 23640:2011
specify minimum numbers of lots
to be used but give no guidance to
recommended numbers beyond
documented risk evaluation.
If critical components of It must be documented that stored CLSI EP25-A
the IVD are assigned lives materials (for example, freeze-thawed (section 4.4)
independently of the life biological reagents) operate as
of the IVD, the various expected during the whole of the
forms of stability of the assigned shelf-life.
IVD must be proven
with those reagents
at different stages of
WHO Technical Report Series, No. 1011, 2018
their lives
Each form of stability If any lot-to-lot variability is found, the
must be defined manufacturer must provide evidence
statistically with respect that subsequent lots will not have
to any inter-independent worse stability than that claimed.
lot variability, not just
assigned to the minimum
stability found among the
lots that happened to be
evaluated experimentally
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Table continued
Recommendation Comment Standard
If any control material If the analytic function of the IVD is
with a claim to prove the out of specification from any cause,
functionality of the IVD including stability failure, the control
is provided to users that material must be demonstrated to
claim must be justified be able to alert the user to that fact.
in stability studies in
addition to any other
studies
Use of accelerated Accelerated stability is acceptable CLSI EP25-A
stability, even to provide in providing interim life if the (section 7.3 &
interim life assignments, parameters of the Arrhenius Appendix B)
must be justified equation, or any other method ISO 23640:2011
scientifically used, are adequately proven and (section 5.3.1;
documented. notes 1 & 2)
WHO/EMP/RHT/PQT/TGS2/2017.02
The Technical Guidance Series (TGS) for WHO Prequalification – Diagnostic
Assessment is intended to assist manufacturers in meeting WHO prequalification
requirements for their IVD. For further information on this guidance and other
TGS documents email: [email protected]
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Annex 6
Biological substances: WHO International Standards,
Reference Reagents and Reference Panels
The provision of global measurement standards is a core normative WHO
activity. WHO reference materials are widely used by manufacturers, regulatory
authorities and academic researchers in the development and evaluation of
biological products. The timely development of new reference materials is crucial
in harnessing the benefits of scientific advances in new biologicals and in vitro
diagnosis. At the same time, management of the existing inventory of reference
preparations requires an active and carefully planned programme of work to
replace established materials before existing stocks are exhausted.
The considerations and guiding principles used to assign priorities
and develop the programme of work in this area have previously been set out
as WHO Recommendations.1 In order to facilitate and improve transparency
in the priority-setting process, a simple tool was developed as Appendix 1 of
these WHO Recommendations. This tool describes the key considerations taken
into account when assigning priorities, and allows stakeholders to review and
comment on any new proposals being considered for endorsement by the WHO
Expert Committee on Biological Standardization.
A list of current WHO International Standards, Reference Reagents and
Reference Panels for biological substances is available at: http://www.who.int/
biologicals.
At its meeting in October 2017, the WHO Expert Committee on
Biological Standardization made the changes shown below to the previous list.
1
Recommendations for the preparation, characterization and establishment of international and other
biological reference standards (revised 2004). In: WHO Expert Committee on Biological Standardization:
fifty-fifth report. Geneva: World Health Organization; 2006: Annex 2 (WHO Technical Report Series, No. 932;
http://www.who.int/immunization_standards/vaccine_reference_preparations/TRS932Annex%202_
Inter%20_biol%20ef%20standards%20rev2004.pdf?ua=1, accessed 27 March 2018).
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WHO Expert Committee on Biological Standardization Sixty-eighth report
Additions 2
Preparation Activity Status
Biotherapeutics other than blood products
Parathyroid hormone 0.914 mg/ampoule Second WHO
1-34 (recombinant, 9140 IU/ampoule International Standard
human)
Rituximab In vitro biological activities: First WHO International
1000 IU/ampoule (CDC activity) Standard
1000 IU/ampoule (ADCC activity)
1000 IU/ampoule (cell-binding
activity)
1000 IU/ampoule (apoptotic
activity)
Infliximab 500 IU/ampoule (TNF- First WHO International
neutralizing activity) Standard
500 IU/ampoule (binding activity)
50 µg/ampoule for use in
therapeutic drug monitoring
Blood products and related substances
Activated blood 10.5 IU/ampoule Second WHO
coagulation factor IX International Standard
(human)
Blood coagulation FXII:C = 0.86 IU/ampoule First WHO International
factor XII (plasma, FXII:Ag = 0.80 IU/ampoule Standard
human)
(via assignment of
additional analytes to
WHO Technical Report Series, No. 1011, 2018
2
Unless otherwise indicated, all materials are held and distributed by the National Institute for Biological
Standards and Control, Potters Bar, Herts, EN6 3QG, the United Kingdom. Materials identified by an * in the
above list are held and distributed by the Paul-Ehrlich-Institut, 63225 Langen, Germany.
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380
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This report presents the recommendations of a WHO Expert
Committee commissioned to coordinate activities leading to the
1011
adoption of international recommendations for the production W H O Te c h n i c a l R e p o r t S e r i e s
and control of vaccines and other biological substances, and the
establishment of international biological reference materials. 1011
Following a brief introduction, the report summarizes a number