On 29 September 2004, the FDA published the document
Guidance for Industry
PAT – A Framework for Innovative Pharmaceutical Development,
Manufacturing, and Quality Assurance
This PAT Guidance replaces the former Draft Guidance of August 2003. In
comparison with the draft, the final version has almost the same
structure. The only exception is that more stress has been put on the
chapter on "Process Understanding", which represents the main
concern of PAT. Before, it had just been a subtopic of "Principles
and Tools". Here and there, the text of the new guideline has been shortened
a bit. Some sections have been interchanged.
As far as we can see, no significant changes have been made in
comparison with the draft version! If you would like to see the
differences, you have to have a very close look at the documents.
One of the differences is that the guidance is now also applicable to
specified biologic products that fall within the area of responsibility of CDER.
The four 'PAT Tools' listed in the guidance are now described a bit
more concise as:
- Multivariate tools for design, data acquisition and analysis
- Process analysers
- Process control tools
- Continuous improvement and knowledge management tools
Their description has remained nearly unchanged. The striking thing is
that the concrete methods mentioned in the draft, like NIR spectroscopy or
acoustics, have been left out. This might have been done in order to
underline the generality of the statements. Surprisingly enough, also the
reference to the GAMP Guideline
(GAMP Guide for Validation of Automated Systems) has been omitted both
from the text and from the literature section. Instead, the ASTM Technical
Committee E55 has been included.
As the main source of information on the topic 'PAT', the guideline now
indicates the link to
FDA's PAT web page.