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1
Meet Regulatory the Team
01 02 03 04
Facilities and
About Protalix Characterization Manufacture
Equipments
01
Introduction
About Protalix
About Gaucher’s
Disease
About Elelyso
4
About Protalix
5
● Genetic disorder in which
Gaucher’s glucocerebroside accumulates in cells
Disease (Gaucher cells) and specific organs
7
Executive Summary
Regulatory CMC
01 02
Introduction Drug
Substance
About Gaucher’s
Manufacture
Disease
8
Drug Substance
9
3.2.S. DRUG SUBSTANCE
10
3.2.S. DRUG SUBSTANCE
● Taliglucerase alfa:
β-Glucocerebrosidase: β-D-glucosyl-N-acylsphingosine glucohydrolase, E.C. 3.2.1.45
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
11
3.2.S. DRUG SUBSTANCE
C2580H3918N680O727S17
https://www.drugbank.ca/drugs/DB08876
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf 12
:
https://www.tga.gov.au/sites/default/files/auspar-taliglucerase-alfa-rpc-141014-pi.pdf
13
Glycan Structures on Recombinant GCD enzyme Comparison of Glycans expressed in Mammalian cell line and Plant cell line
https://www.tga.gov.au/sites/default/files/aus https://link.springer.com/chapter/10.1007/10_2018_76
par-taliglucerase-alfa-rpc-141014-pi.pdf
14
3.2.S. DRUG SUBSTANCE
● Accession Number
DB08876 (DB06667)
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
https://www.tga.gov.au/sites/default/files/auspar-taliglucerase-alfa-rpc-141014-pi.pdf 15
3.2.S. DRUG SUBSTANCE
16
http://protalix.com/technology/procellex-platform/
https://www.elelyso.com/how-is-elelyso-mad
e 17
3.2.S. DRUG SUBSTANCE
18
https://www.ncbi.nlm.nih.gov/pubmed/26102075
https://www.ncbi.nlm.nih.gov/pubmed/21236330 19
Upstream Downstream Purification
Initial Production Step Final Steps
Process Process Process
Taliglucerase alfa is Expansion of the Extraction, The standard Filtered using a 0.2
purified from recombinant carrot Clarification and techniques for μm filter and filled
genetically modified cells and expression Purification of the protein purification into bottles with
carrot cells of taliglucerase alfa; taliglucerase alfa by chromatography HDPE screw
protein. on multiple columns closures, pre-
sterilized with
gamma irradiation
Taliglucerase alfa is
purified from
genetically modified
carrot cells
21
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
https://europepmc.org/article/med/25621170
https://plantcellbiology.masters.grkraj.org/html/Genetic_Engineering4D-Transformation-Plant_Cells.htm 22
INITIAL CELL LINE
PRODUCTION
https://www.ncbi.nlm.nih.gov/pubmed/25572939
23
Upstream Downstream Purification
Initial Production Step Final Steps
Process Process Process
Expansion of the
recombinant carrot
cells and expression
of taliglucerase alfa;
24
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
http://protalix.com/technology/procellex-platform/
25
CELL LINE
EXPANSION
https://www.ncbi.nlm.nih.gov/pubmed/24630271 26
OSMOTEK BAG BIOREACTOR
● Made up of a simple culture bag without any exterior
supporting vessel
27
https://www.ncbi.nlm.nih.gov/pubmed/21236330
Upstream Downstream Purification
Initial Production Step Final Steps
Process Process Process
28
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
http://protalix.com/technology/procellex-platform/
29
Polishing
Size Exclusion Chromatography;
05 Ion Exchange Chromatography
Harvesting Cells
Cell Separator - separates cells and media
Intermediate Purification
.
01 04 Ion Exchange Chromatography
Hydrophobic Interaction Chromatography
Affinity Chromatography
02 03 Clarification, Pre-
Cell Disruption purification and Capturing
Crude Pressing-Homogenizer Ion Exchange Chromatography/
. Hydrophobic Interaction Chromatography
https://www.ncbi.nlm.nih.gov/pubmed/21236330 30
Upstream Downstream Purification
Initial Production Step Final Steps
Process Process Process
32
3.2.S. DRUG SUBSTANCE
Two
Critical
Process
Parameters
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf 34
3.2.S. DRUG SUBSTANCE
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf 35
3.2.S. DRUG SUBSTANCE
36
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
3.2.S. DRUG SUBSTANCE
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf 37
3.2.S. DRUG SUBSTANCE
3.2.S.4.1 CONTROL OF DRUG SUBSTANCE (Specifications)
Property Method
Purity RP-HPLC, host cell protein by ELISA, automated electrophoresis,Capillary Isoelectric Focusing
Specific Activity Enzymatic activity and taliglucerase alfa assessment determination by RP-HPLC absorption at 280 nm
Residual DNA and Free sulfhydryl content Ellman’s reaction for thiol determination)
38
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
3.2.S. DRUG SUBSTANCE
Detection limit
41
https://www.fda.gov/files/drugs/published/Analytical-Procedures-and-Methods-Validation-for-Drugs-and-Biologics.pdf
3.2.S. DRUG SUBSTANCE
128 batches.
128
Batches were analyzed
42
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
3.2.S. DRUG SUBSTANCE
Reviewing
43
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
3.2.S. DRUG SUBSTANCE
Elelyso
44
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
3.2.S. DRUG SUBSTANCE
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf 45
3.2.S. DRUG SUBSTANCE
Reconstituted
taliglucerase alfa
finished product diluted
into infusion bags is
considered stable for at
least 18 hours at 2-8°C
The post-approval stability protocol and the stability commitment have been provided and are considered
satisfactory. In accordance with EU GMP guidelines, any confirmed out-of-specification result of significant
negative trend should be reported to the rapporteur and EMA.
https://www.ema.europa.eu/en/documents/assessment-report/elelyso-epar-public-assessment-report_en.pdf
48
Executive Summary
Regulatory CMC
01 02 03
About Gaucher’s
Manufacture Analytical
Disease
49
Drug Product
50
3.2.P.1 DRUG PRODUCT
51
3.2.P.1 DRUG PRODUCT
Quantity(mg)/
Ingredient 200mL Vial Function Quality
Drug Substance
Taliglucerase alfa 212 active ingredient Manufacturer's specification
Excipients
Mannitol 206.7 tonicity-adjusting agent USP
Polysorbate 80 0.56 stabilizer USP
Sodium citrate* 30.4 buffering agent USP
Citric acid** - pH adjustment USP
Water for Injection*** N/A diluent prior to lyophilization USP
Composition of Elelyso
*Introduce during manufacturing of Drug Substance
**To adjust pH to 6; amount depends on pH of ingredient 52
***Removed from finished product during lyophilization
3.2.P.1 DRUG PRODUCT
3.2.P.2.2 DRUG PRODUCT (Formulation Development, Overages, Physicochemical
and Biological Properties)
Physicochemical and
Formulation Development: Overages: Biological Properties:
53
3.2.P.1 DRUG PRODUCT
3.2.P.2.3 MANUFACTURING PROCESS DEVELOPMENT
Thawing of Drug 05
Fill and Finish
Substance
01 04
Sterile Filtration
Separation
02 03
Purification
54
3.2.P.1 DRUG PRODUCT
3.2.P.2.4 CONTAINER CLOSURE SYSTEM
Protects from light Protect from solvent leakage protects sterile products
55
3.2.P.1 DRUG PRODUCT
Purification Filling
56
3.2.P.1 DRUG PRODUCT
3.2.P.2.6 COMPATIBILITY
3.2.P.3.1 MANUFACTURERS
57
3.2.P.1 DRUG PRODUCT
3.2.P.2.6 COMPATIBILITY
As of March 12, 2020:
In the absence of compatibility studies, ELELYSO should not be mixed with other
medicinal products, except those mentioned in the DOSAGE AND ADMINISTRATION
section.
58
3.2.P.1 DRUG PRODUCT
3.2.P.3.1 MANUFACTURERS
60
3.2.P.1 DRUG PRODUCT
61
3.2.P.1 DRUG PRODUCT
2 x
Purification Process
62
3.2.P.1 DRUG PRODUCT
63
3.2.P.1 DRUG PRODUCT
3.2.P.5.1 SPECIFICATIONS
64
3.2.P.1 DRUG PRODUCT
3.2.P.4.1 CONTROL OF EXCIPIENTS (Specifications)
Included within the 200 unit(s) vial of the finished product, there are four excipients:
Quantity(mg)/
Ingredient 200mL Vial Function Quality
Excipients
Mannitol 206.7 tonicity-adjusting agent USP
Polysorbate 80 0.56 stabilizer USP
Sodium citrate* 30.4 buffering agent USP
Citric acid** - pH adjustment USP
Water for Injection*** N/A diluent prior to lyophilization USP
65
3.2.P.1 DRUG PRODUCT
3.2.P.4.2 CONTROL OF EXCIPIENTS (Analytical Procedures)
● Infrared spectroscopy
● Ultraviolet spectroscopy
● Thin-layer chromatography
66
3.2.P.1 DRUG PRODUCT
1. Gas Chromatography
2. Liquid Chromatography
67
3.2.P.1 DRUG PRODUCT
The excipient is close to 100% purity, it is often necessary to widen the acceptance criteria
to “NLT 98.0% and NMT 102.0%”, which is typical for chromatographic procedures.- USP-
NF
Both Infrared spectroscopy ultraviolet spectroscopy should yield that all four known
excipients fall into the 98- 102 % purity range which is acceptable as outline in the USP-
NF.
68
3.2.P.1 DRUG PRODUCT
69
3.2.P.1 DRUG PRODUCT
3.2.P.4.6 CONTROL OF EXCIPIENTS (Novel Excipients)
70
3.2.P.1 DRUG PRODUCT
3.2.P.5.1 SPECIFICATIONS
Quantity(mg)/
Ingredient 200mL Vial Characterization Quality
Excipients
Mannitol 206.7 odorless white crystalline powder USP
Polysorbate 80 0.56 viscous, water-soluble yellow liquid USP
Sodium citrate* 30.4 white, crystalline powder USP
odorless and colorless crystals with an acidic
Citric acid** - taste USP
71
3.2.P.1 DRUG PRODUCT
The specific assays in which Protalix used for its analytical procedures were:
72
3.2.P.1 DRUG PRODUCT
73
3.2.P.1 DRUG PRODUCT
The applicant has provided acceptable data for the transfer of eight release and stability
assays.
For the cellular uptake assay limited data in relation to the transfer of this assay to the facility
at Pfizer Ireland Pharmaceuticals, Grange Castle was provided, however this was deemed
acceptable, A revised specification range should be introduced after release testing with the
improved assay of at least 30 batches of drug substance and 15 batches of the finished
product manufactured using the commercial process.
74
3.2.P.1 DRUG PRODUCT
Due to the nature of non-viral threat from mammalian cells with the plant-cell based
ProCellEx platform, all assessments of available information for ELELYSO batch analysis are
thought to be conducted on a periodic basis (Skip Testing) for the 128 batch analyzation as
outlined in ICH Q6A.
75
3.2.P.1 DRUG PRODUCT
The purity of the active substance is estimated by a combination of methods. The choice of
analytical procedures is focused on the separation of the taliglucerase alfa product from product
related substances (variants and impurities) and from process related impurities.
The quantitative composition of the lyophilized drug product is as follows: a 200 unit vial is
composed of taliglucerase alfa (212 units, which allows for a withdrawal of 200 units), mannitol
(206.7 mg), sodium citrate (30.4 mg) and Polysorbate 80 (0.56 mg). Citric acid anhydrous to
adjust pH.
76
3.2.P.1 DRUG PRODUCT
Process validation was performed at the commercial manufacturing site for the taliglucerase
alfa active substance process, Protalix (Carmiel, Israel), according to process validation
protocols.
Assays, including electrophoresis, RP-HPLC, capillary IEF, and Size Exclusion
Chromatography are performed to assure the purity of taliglucerase alfa and characterize the
product-related impurities. Process-related Impurities such as Host Cell Protein and Host Cell
DNA are controlled at release, while clearance of other potential process-related impurities has
been demonstrated.
77
3.2.P.1 DRUG PRODUCT
ICH guidances (e.g., Q3A(R) Impurities in New Drug Substances, Q3C Impurities: Residual
Solvents, and Q6A Specifications: Test Procedures and Acceptance Criteria for New Drug
Substances and New Drug Products: Chemical Substances)
78
3.2.P.1 DRUG PRODUCT
79
3.2.P.1 DRUG PRODUCT
Lyophilized vial: Store ELELYSO at 2° - 8 °C and protect vials from light. Reconstituted and
diluted solution for infusion: After reconstitution, promptly dilute vial. The reconstituted solution
may be stored for up to 12 hours at room temperature OR for up to 24 hours at 2 to 8°C,
protected from light. The diluted solution may be stored for up to 24 hours at 2 to 8°C, protected
from light. The medicinal product should be used immediately. If not used immediately, in-use
storage times and conditions prior to use are the responsibility of the user.
The quantitative composition of the lyophilized drug product is as follows: a 200 unit vial is
composed of taliglucerase alfa (212 units, which allows for a withdrawal of 200 units), mannitol
(206.7 mg), sodium citrate (30.4 mg) and Polysorbate 80 (0.56 mg). Citric acid anhydrous to
adjust pH.
80
3.2.P.1 DRUG PRODUCT
81
3.2.P.1 DRUG PRODUCT
If not used immediately, Taliglucerase alfa finished product powder for solution for injection is
stable when stored at 5 ± 3°C for the shelf life of 24 months. The applicant provided the results
of the primary stability studies after 24 months storage, including data for eleven batches of
which three were full scale validation batches.
Only up to 9 month of stability data was available at long term condition (5 ± 3°C) for the full
scale batches but the stability data of the primary stability batches (up to 36 months) were
considered to be supportive to the proposed shelf-life
82
3.2.P.1 DRUG PRODUCT
Stability data which was available showcased that the finalized product supplied evidence that
ELELYSO would have a shelf life of 24 months when stored at 5 ± 3°C.
Based on the evaluation of two batches of pooled reconstituted finished product diluted with
saline solution in infusion bags, reconstituted taliglucerase alfa finished product diluted into
infusion bags is considered stable for at least 18 hours at 2-8°C.
83
3.2.P.1 DRUG PRODUCT
From the stability studies, 18 of the 26 adults who completed the 9 month clinical trial
extension, as an open-label extension trial with an additional 27 months. Patients maintained
stability within the clinical parameters of:
● Spleen volume
● Liver Volume
● Platelet count
● Hemoglobin
10 of the 18 patients completed the 27 month extension of Elelyso with 7 of these patients
seeing a reduction in spleen and liver volume for a total of 36 months
84
Executive Summary
Regulatory CMC
01 02 03 04
Facilities and
About Protalix Characterization Manufacture
Equipments
85
Appendices
86
3.2.A APPENDICES
87
3.2.A APPENDICES
88
3.2.A APPENDICES
89
3.2.A APPENDICES
90
3.2.A APPENDICES
91
3.2.A APPENDICES
92
3.2.A APPENDICES
● No chemical consumption
● Low operating costs
● 24/7 operation
93
3.2.A APPENDICES
With the use of a plant cell line, viral contamination is a non-factor when considering the safety
evaluation with respect to users of ELELYSO.
Also for consideration, plant viruses are again considered a non-factor as no plant virus has
been link to infect mammalian cells.
94
3.2.A APPENDICES
95
3.2.A APPENDICES
3.2.R Regional
All ELELYSO product is manufacturing within Protalix’s only plant which is located in
Carmeil, Israel.
96
3.2.A APPENDICES
Being that Protalix has noted that all materials they recieve for the manufacturing process are
sourced from one supplier, which has been validated through the FDA. Regional information on
materials has not been provided.
97
3.2.A APPENDICES
The quantitative composition of the lyophilized drug product is as follows: a 200 unit vial is
composed of taliglucerase alfa (212 units, which allows for a withdrawal of 200 units), mannitol
(206.7 mg), sodium citrate (30.4 mg) and Polysorbate 80 (0.56 mg). Citric acid anhydrous to
adjust pH. ELELYSO is supplied in Type 1 glass vials packaged in single vial cartons
98
Executive Summary
Regulatory CMC
01 02 03 04
Facilities and
About Protalix Characterization Manufacture
Equipments
100
https://onlinelibrary.wiley.com/doi/epdf/10.1002/biot.201300548
Post Approval Change
Data Justification
101
Post Approval Change
Economic Rationale
102
Post Approval Change
Change Risk Assessment
103
Post Approval Change
Sections of CTD Affected
104
QUESTIONS?
105