What are the main regulations related to sterility testing of cell therapy products?
In the UK, we operate under European Pharmacopoeia – Chapter 2.6.1 Sterility. Where the requirements of this monograph cannot be satisfied due to certain characteristics of the preparation, European Pharmacopoeia – Chapter 2.6.27 Microbiological Examination of cell-based Preparations – can be followed. This monograph helps to deal with product issues regarding a short shelf life, small sample volume, and microbial detection due to the sample composition. Laboratories in the UK may also work towards US Pharmacopoeia Chapter <71> where required.
What are the top three considerations for cell therapy manufacturers when looking to select rapid testing methods?
The first consideration would be to know your product and its unique requirements, then complete a user requirement specification (URS) for your test methodology based on these. What is the desired turnaround time or time to result? What is the shelf life of your product and how rapid does the test have to be? Are there any components within your sample material which preclude it from testing by certain methods? What is the available volume size of the material to be tested? What is the throughput volume of your testing method and will automation be beneficial if the number of samples to be tested in a given
period reaches an unmanageable level? How will any automation equipment be validated? Do you require a qualitative
or quantitative measurement? Second, assess if the method of choice has been demonstrated to be equivalent or non-inferior to the compendial method. Can your rapid testing method detect standard reference strains as well as your particular facility isolates and slow-growing microorganisms? Third, how will data be handled? Do you require digitalisation in your lab for the
management of data and data integrity or will results be record via a paper-based system? For digital systems, are these
21 CFR Part 11-compliant? Do you require your digital system to be integrated with a laboratory investigation management
system (LIMS) or an electronic batch manufacturing record (eBMR)? How will you be trending your results and does the
software have this capability?
What approach should companies take when looking to validate alternative methods?
I would advise following current ICH Q2 guidelines for an approach to validation of an alternative method with specificity and accuracy paramount and testing performed in parallel against the compendial method, using a panel of isolates to include those found in the manufacturing facility, slow growing microorganisms, and compendial stains. Limit of detection and robustness should also be included to assess the range of detection of the method and the maximum stand-time following addition of the sample material to the test media.
What is the main benefit of rapid microbial ID or ultra-fast microbial speciation of cell therapy products?
Rapid microbial ID techniques such as the MALDI-TOF system used by SMIC QC laboratories, have the main benefit of being able to generate a result with minutes. However, preparation of subcultures from parent colonies and test samples can still take 24 to 48 hours in total, for bacterial and fungal speciation, respectively. Microbial speciation that utilises PCR removes the need for subculture of colonies, therefore testing can be performed immediately following initial detection. Any decrease in time to micro results can only result in quicker release of drug product to patient.
How is automation and digitalisation shaping the future of microbiological QC for cell therapies?
Automation brings increased standardisation by removing operator involvement and thereby reducing variability of operations; increases productivity by freeing operators to work on other tasks during runtime; and reduces waste due to operator error. The introduction of flexibility of configuration to automated systems can now avoid the previous issues where a
system designed for high throughput, when used for low throughput, could result in waste of reagents and consumables. Automated systems are frequently accompanied by associated software with data analysis and trending capabilities and can be integrated with LIMS systems which themselves can facilitate test requests, scheduling, and results and sample management.
LIMS systems can improve on data integrity by removing the need for manual verification of data entry when linked to an analytical instrument.
What are the main considerations when employing digital systems in QC?
In my experience, one of the first considerations when employing a digital system is to recognise that your current paper-based workflow might not necessarily need to be replicated wholesale and consideration should be given to examining the functionality of the system and applying the best use of this to improve processes and maintain data integrity. Knowing where data will be stored and how this will be backed up is crucial to data integrity and facility for this should be considered. Both cloud-based systems and a local area network (LAN) have their advantages and disadvantages regarding security and access control. Ensure that your digital system includes audit trail function for traceability and saves data in an uneditable format to prevent loss or manipulation of original information.
References
1. Yue J, Chen C, Jing X et al. Development of next-generation sequencing-based sterility test. bioRxiv; 2020.
2. Dubczak J, Reid N, Tsuchiya M. Evaluation of limulus amebocyte lysate and recombinant endotoxin alternative assays for an assessment of endotoxin detection specificity. EJPS. 2021; 159:105716.
3. Maloney T, Phelan R, Simmons N. Saving the horseshoe crab: A synthetic alternative to horseshoe crab blood for endotoxin detection. PLOS Biology. 2018; 16(10).