Advisory Committee for
Pharmaceutical Science
April 13, 2004
PAT
Rapid Microbiology Methods
Update
Background
Rapid
Microbiology Methods (RMM) came under the umbrella of the PAT initiative during
an ACPS PAT subcommittee meeting in Oct 2002. Several presentations were made
regarding the advantages of using RMM for the pharmaceutical manufacturing
process. Discussion by the participants in the subcommittee meeting also
supported the inclusion of RMM as part of PAT.
Since
a key component of PAT is technical training for review and inspection
personnel, a rapid microbiology training session was organized. In July 2003
selected FDA personnel from CDER, ORA, CBER and CVM met in Rockville for a one
day training session on RMM. The training session started with an overview of available RMM technologies. A
detailed look at two RMM technologies was provided by the vendors of these test
methods. A pharmaceutical company presented their experiences with validation
of a RMM. Finally a discussion of RMM took place among the FDA personnel
present at the training session.
To
conform to the PAT regulatory model, a RMM review and inspection team,
consisting of personnel from ORA and CDER, was formed to deal with PAT RMM
submissions. The RMM team has already handled the regulatory approval process
for a RMM product release test. The RMM team met on several occasions prior to
the inspection to discuss the proposed RMM and the inspection process. Issues
of potential concern to the team members were discussed and decisions were made
as to the appropriate method(s) to deal with these issues. The inspection went
smoothly and no problems were found.