Simplifying Complexity: How the Four-Field Matrix Reshapes Thinking
Judging Science & Prior Knowledge Beyond the Line
1. Judging Science & Prior Knowledge
Beyond the Line
Roohi B. Obaid
22 September 2022
2. Disclaimer
We discuss science, nothing more, nothing less
It is experience based learning expression received during
last 25 years while dealing hundreds of foreign & domestic
inspections, regulatory compliance & enforcements, dozen
of meetings with international experts (FDA, EU, Japan,
Canada, MHRA) etc. etc.
Thoughts represent the current thinking of
Centre for Quality Sciences
Obaid Ali & Roohi B. Obaid
8. New Drug
• Non Clinical Studies
• Clinical Studies
• Product Development
• Technology Transfer
• Process Validation
• Commercial Manufacturing
• Change Management
• Periodical Reviews
• Knowledge Management
• Life cycle
10. Relation between New & Generic Drug
New Generic
Bio-studies of generic are surrogate for all
clinical studies done by innovator
11. • Non Clinical Studies
• Clinical Studies ….. BioStudies
• Product Development
• Technology Transfer
• Process Validation
• Commercial Manufacturing
• Change Management
• Periodical Reviews
• Knowledge Management
• Life cycle
G
M
P
Zone
12. 1 2 3
Technology Transfer Process Validation Controlled Manufacturing
GMP Zone
13. A B C
Specifications Critical Processing Parameters Critical Quality Attributes
How …….
14. All products that were
recalled or withdrawn
anywhere, were released
after testing
Remember, quality cannot
be tested but it should be
built in the product
46. Cause
Effect
Cause and effect are
self-evident, don’t
need specialized
education, training
and experience to
know what causes
what.
47. Cause
Effect
Cause and effect are
self-evident, don’t
need specialized
education, training
and experience to
know what causes
what.
Simple System
48. Cause
Effect
Multivariate
Multiple causes & effects
Interactions and
multiple
interrelationships
This needs good
practices, process
validation, scientific
education, training and
experience.
49. Cause
Effect
Multivariate
Multiple causes & effects
Interactions and
multiple
interrelationships
This needs good
practices, process
validation, scientific
education, training and
experience.
Complicated System
50. Cause
Effect
Cause and effect are only
known after research
beside training &
experience.
A complex system has
property called
emergence which comes
up that is never
expected.
51. Cause
Effect
Cause and effect are only
known after research
beside training &
experience.
A complex system has
property called
emergence which comes
up that is never
expected.
Complex System
52. Cause
Effect
Unpredictable beyond
average. Exhibit extreme
sensitivity to initial or
starting conditions.
Starting conditions are
raw materials,
excipients, equipment,
people (education,
training and experience)
68. Data
Before entry
of generic in
market
24
Months data
10% visited emergency
or hospitalized/month
136177 patients
66 & above age
60% women &
40% men
73. Data extended
After 12
months entry
of generic in
market
36
Months data
Visited emergency or
hospitalized/month
18% for
Losratan
22% for
Valsartan
24% for
Candesartan
83. The test drug is compared with innovator &
its profile falls on the innovator scale in
between 80 to 125%
If
84. The test drug is compared with innovator &
its profile falls on the innovator scale in
between 80 to 125%
It is Generic
If
85. The test drug is compared with innovator &
its profile falls on the innovator scale in
between 80 to 125%
We expect same therapeutic effect as
established by the innovator in their clinical
studies done earlier
It is Generic
If
112. 01 Bioequivalence study &
03 validation batches may
not assure drug quality for
lifetime.
Different people with
different level of
knowledge, skill &
experience may not
manufacture equal drug.