Control Strategy for Small Molecule Impurities in Antibody-Drug Conjugates
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Abstract
Antibody-drug conjugates (ADCs) are an emerging class of biopharmaceuticals. As such, there are no specific guidelines addressing impurity limits and qualification requirements. The current ICH guidelines on impurities, Q3A (Impurities in New Drug Substances), Q3B (Impurities in New Drug Products), and Q6B (Specifications: Test Procedures and Acceptance Criteria for Biotechnological/Biological Products) do not adequately address how to assess small molecule impurities in ADCs. The International Consortium for Innovation and Quality in Pharmaceutical Development (IQ) formed an impurities working group (IWG) to discuss this issue. This white paper presents a strategy for evaluating the impact of small molecule impurities in ADCs. This strategy suggests a science-based approach that can be applied to the design of control systems for ADC therapeutics. The key principles that form the basis for this strategy include the significant difference in molecular weights between small molecule impurities and the ADC, the conjugation potential of the small molecule impurities, and the typical dosing concentrations and dosing schedule. The result is that exposure to small impurities in ADCs is so low as to often pose little or no significant safety risk.
KEY WORDS
ADC control strategy small molecule impurity risk assessmentINTRODUCTION
The material in this manuscript was developed with the support of the International Consortium for Innovation and Quality in Pharmaceutical Development (IQ Consortium or IQ). The IQ is a not-for-profit organization composed of pharmaceutical and biotechnology companies with a mission of advancing science-based and scientifically driven standards and regulations for pharmaceutical and biotechnology products, worldwide. Today, IQ represents 42 pharmaceutical and biotechnology companies. Please visit www.iqconsortium.org for more information.
A cartoon representation of different conjugation chemistries for ADCs. The linker is attached between the drug and the mAb usually by a covalent bond through a cysteine or lysine
Convergent manufacturing scheme for ADCs
Like other drug substances (DS) and drug products (DP), impurities can arise during the synthesis, purification, and storage of the intermediates as well as the ADC DS and DP. Depending on their point of origin and molecular weight, impurities in ADCs can be classified as mAb-related or small molecule. The mAb-related impurities will not be addressed in this paper. Information provided in ICH Q6B2 details impurity and heterogeneity concerns for mAbs, and these will typically need to be addressed during the manufacture of the mAb intermediate. Some of these attributes, such as aggregates and charge variants, are also relevant to the DS and/or DP but are beyond the scope of this paper. Here we will concentrate on the impurities that are associated with the small molecule component of the ADC. These are impurities that originate during the manufacture of the linker, the drug, or the linker-drug, and the related small molecule impurities that arise during the manufacture or storage of the ADC DS and DP. These small molecule impurities typically have molecular weights of < 2000 Da (the molecular weight of a typical linker-drug) while the ADC itself will have a molecular weight of ~ 160,000 Da (typical for ADCs with a drug-to-antibody ratio (DAR) of 4). This difference in molecular weight means that any small molecule impurity present in the ADC, including those originating in the linker-drug intermediate, represents a much smaller proportion of the total administered dose of ADC than would be the case in a typical small molecule pharmaceutical. This difference should play a significant role in guiding decisions about risks associated with these impurities and the appropriate controls. Other factors that play a part in the assessment include the dose, schedule, duration of therapy, and therapeutic area in which the ADC is being applied. All these factors will be discussed as we propose an integrated approach to the development of a control strategy for small molecule impurities in ADCs.
Current Regulatory Guidance
ICH Q3A(R2) Threshold Levels for Impurities. Qualification Threshold Is the Limit Above Which an Unknown Impurity Will Need to be Qualified
Dose | Reporting threshold (%) | Identification threshold | Qualification threshold |
---|---|---|---|
≤ 2 g/day | 0.05 | 0.1% or 1 mg/day (whichever is lower) | 0.15% or 1.0 mg/day (whichever is lower) |
> 2 g/day | 0.03 | 0.05% | 0.05 |
ICH Q3B(R2) Thresholds for Degradation Products in New Drug Products
Maximum daily dose | Threshold |
---|---|
Reporting thresholds | |
≤ 1 g | 0.1% |
> 1 g | 0.05% |
Identification thresholds | |
< 1 mg | 1.0% or 5 μg TDI, whichever is lower |
1–10 mg | 0.5% or 20 μg TDI, whichever is lower |
> 10–2 g | 0.2% or 2 mg TDI, whichever is lower |
> 2 g | 0.10% |
Qualification thresholds | |
< 10 mg | 1.0% or 50 μg TDI, whichever is lower |
10–100 mg | 0.5% or 200 μg TDI, whichever is lower |
> 100 mg–2 g | 0.2% or 3 mg TDI, whichever is lower |
> 2 g | 0.15% |
ICH Q3C5 details expectations for control of residual solvents. ICH Q3D6 provides guidance with respect to elemental impurities. These guidelines should be considered during the development of ADCs.
Acceptable Intakes for Genotoxic Compounds from ICH M7
Duration of treatment | Daily intake |
---|---|
≤ 1 month | 120 μg/day |
> 1–12 months | 20 μg/day |
> 1–10 years | 10 μg/day |
> 10 years | 1.5 μg/day |
ICH S98 explains how controlling impurities to levels that provide negligible risk is not an appropriate requirement for pharmaceuticals used to treat advanced cancer patients. For these situations, the risk-benefit assessment is different from that applied to drugs used in other indications. Since most ADCs are currently being developed for use in advanced cancer indications, ICH S9 should be applicable. Therefore, for most ADCs, deviation from the limits established in ICH Q3(A, B, C and D) and ICH M7 can be justified.
In cases where ADCs are to be developed for diseases that are not covered by ICH S9, adjustments to the strategies proposed below may be considered. The current ICH S9 Q&A draft document9 addresses these issues and interested readers are referred to that document for further details.
Assumptions in Establishing Control Limits for Small Molecule Impurities in ADCs
Control of Small Molecule Impurities in ADCs
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The ADCs are intended for use in treating cancer.
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The small molecule drug would be toxic to patients if present at high enough doses.
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The worst-case assumption, that all small molecule impurities containing structural elements of the drug will have a similar level of toxicity as the drug itself, will be used.
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Data is available to demonstrate that the small molecule drug does not need to be considered unusually potent as defined in ICH Q3A (the drug is not pharmacologically active or toxic at 1 mg/day patient exposure).
Impurity Control in the Linker-Drug Intermediate
In most cases, the majority of the small molecule impurities present in the DS and DP originate from the linker-drug intermediate, and this is true regardless of whether the impurities are conjugated to the mAb or not. In keeping with the modern pharmaceutical development principles, impurity control is generally best achieved near the point of introduction or at a step where the impurity can be removed. Thus, small molecule impurities in ADCs are generally best controlled during the manufacture of the linker-drug intermediate. These impurities include residual solvents, reagents and their by-products, elemental impurities, and impurities structurally related to the linker, drug, or linker-drug. Most of these impurities are not capable of conjugating to the antibody intermediate, so any residual impurity that is present in the linker-drug intermediate will normally be removed during the UF/DF purification steps commonly utilized during DS manufacture. In this way, meeting the residual solvent and elemental impurities limits in DS and DP, as defined by ICH Q3C and Q3D respectively, is relatively straight forward (5).10 Due to the efficiency of the typical UF/DF purification step, non-conjugatable impurities are expected to be present at levels below those associated with potential risk to patients. Therefore, limits on the levels of these impurities in the linker-drug intermediate should be based solely on a demonstration of process control. In practice, this means that the linker-drug intermediate may not need to meet the solvent and elemental impurity limit guidelines, and more flexibility may be appropriate in demonstrating overall control in the DS and DP. In this way, it should be possible to minimize the inclusion of tests for residual solvent, elemental impurities, and other non-conjugating impurities in the specification for linker-drug intermediates.
The impurities in the linker-drug that have the potential to conjugate to the mAb cannot be removed after conjugation because UF/DF, and other purification steps would typically not provide for separation from the other proteinaceous materials. Therefore, the final opportunity to control these impurities is at the stage of the linker-drug manufacture and release. Understanding how the quantity of these impurities in the intermediate relates to their levels in DS and DP is necessary for the determination of a sound control strategy.
Impurity Dose Based on Level of Conjugatable Impurities in the Linker-Drug Intermediate
Impurity level in linker-drug | Maximum impurity level in DSa (wt/wt%) | ADC 5 mg dose | ADC 50 mg dose | ADC 500 mg dose | |||
---|---|---|---|---|---|---|---|
Maximum impurity level | Maximum daily impurity level | Maximum impurity level | Maximum daily impurity level | Maximum impurity level | Maximum daily impurity level | ||
3% | 1.5 μg/mg DS (0.15%) | 7.5 μg/dose | 0.36 μg/day | 75 μg/dose | 3.6 μg/day | 0.75 mg/dose | 36.0 μg/day |
1% | 0.5 μg/mg DS (0.05%) | 2.5 μg/dose | 0.1 μg/day | 25 μg/dose | 1.2 μg/day | 0.25 mg/dose | 12.0 μg/day |
0.5% | 0.25 μg/mg DS (0.025%) | 1.25 μg/dose | 0.06 μg/day | 12.5 μg/dose | 0.6 μg/day | 0.125 mg/dose | 6.0 μg/day |
0.1% | 0.05 μg/mg DS (0.005%) | 0.25 μg/dose | 0.01 μg/day | 2.5 μg/dose | 0.12 μg/day | 0.025 mg/dose | 1.2 μg/day |
ICH M7 provides guidance for assessing risks associated with genotoxic impurities in drug products. However, this guidance is not applicable to drug products that are targeted to cancer patients. While M7 is not applicable, we can look at the risk/benefit principles of this guidance to help in forming the control strategy. One of the key elements of this guideline is that, for drugs that are administered for limited periods of time, higher levels of genotoxic impurities can be tolerated (Table 3). Many oncology drugs are administered over a very short time so patient exposure to any impurity present is very limited. In the example above, the 3% impurity in the linker-payload would translate to a patient exposure lower than that outlined in ICH M7 in most cases.
Impurity Control in the DS
As mentioned above, non-conjugated impurities originating from the production of linker-drug intermediate are typically removed during the purification and isolation of DS. The conjugation of the linker drug to the mAb is the last chemical bond forming step in the ADC process. Most processes-related impurities originating at this step should also be removed during the purification steps. Because these processes related impurities originate at this last bond forming step, they could be present at a higher level than those impurities coming from the linker-drug. Thus, it will normally be more important to demonstrate their control. Conjugation process-related impurities typically include organic solvents, reagents and their by-products, processing aids, and, possibly, degradation products. The purification step’s ability to remove these impurities should be demonstrated during development and, much like impurities in other biologic products, would not necessarily need to be addressed in the drug substance specification. One class of non-conjugated impurities that is worth special attention is the linker-drug and its quenched derivatives or byproducts. This is typically encountered in ADC programs due to stoichiometric excess of intermediate used to ensure timely completion of the conjugation reactions. A properly designed UF/DF step should effectively clear these impurities as well, so that they will be well below the ICH Q3A limits and below any level of concern. This can generally be demonstrated during process development. In some situations, additional purification steps such as column chromatography may also be utilized, and these unit operations can provide additional levels of clearance for non-conjugated linker-drug impurities. This type of assessment can also be used to demonstrate that other impurities from the conjugation process, including organic solvents, reagents, reaction by-products, and elemental impurities, are effectively cleared and present little risk.
Decision tree for assessment of impurities in linker-drug intermediates
Stability of the ADC (as It Relates to Small Molecule Degradants)
A unique aspect of ADCs that must be considered is the propensity of the DS and DP to release free drug and degradation products that contain the drug. Again, it is the presence of the resulting unconjugated drug that is the highest concern due to the associated risk of toxicity. In general, the drug itself is the species with the highest toxicity risk, so treating all drug-related degradants as equivalent to the drug can be viewed as a worst-case assumption.
If the ADC dose were 50 mg every 21 days, then the maximum possible level of free drug would be 1.25 mg/dose or 60 μg/day. A more reasonable amount of degradation at the end of shelf life of 10% loss of drug would result in a daily exposure of only 6 μg/day. Table 4 illustrates how the level varies as a function of ADC dose. Applying worst-case scenarios such as this along with an understanding of the toxicity of the drug, one can assess the level of risk that degradation presents. In this example, if doses of 1.25 mg of drug every 3 weeks or 60 μg daily of drug were well tolerated in animals, then drug release would not be considered a significant safety concern. On the other hand, the loss of drug is expected to significantly decrease the activity of the ADC, so from the standpoint of product potency, this level of drug loss would be concerning. Regardless of the results of the assessment above, compliance with ICH Q3A and Q3B would normally remain an expectation.
Examples of Worst Case DP Degradant (Drug) Exposure, Based on Eq. 3
5 mg dose | 50 mg dose | 500 mg dose | |||
---|---|---|---|---|---|
Free Drug (max) | Daily drug exposure (max) | Free Drug (max) | Daily drug exposure (max) | Free Drug (max) | Daily drug exposure (max) |
125 μg | 6 μg/day | 1.25 mg | 60 μg/day | 12.5 mg | 600 μg/day |
Decision tree for assessment of small molecule degradants in ADC DS and DP
CONCLUSION
ADCs present challenges that are not typically encountered with small molecule drugs or traditional biologic products. Small molecule impurities, whether conjugated to the protein or not, must be addressed. Due to the low molecular weight of the linker and drug compared to the high molecular weight of the ADC, patient exposure to these small molecule impurities is comparatively low. For these drug products, the small molecule impurities can be assessed using a risk-based approach that is consistent with ICH Q3A and Q3B guidelines. The control of conjugated small molecule impurities is best achieved at the stage of manufacturing the linker-drug rather than the DS or DP. Following this approach, it can be demonstrated that adopting ICH Q3A limits at the stage of linker-drug intermediates is generally not necessary. Non-conjugated small molecule impurities including free drug are generally cleared effectively by typical manufacturing processes. The purification steps assure compliance with ICH Q3A for non-conjugated impurities. If linker-drug stability after conjugation is demonstrated, then ICH Q3B compliance is assured, and removal of tests for small molecule impurities from release and stability specifications can be justified.
Footnotes
- 1.
In this manuscript, the term “drug” is used to describe the pharmacologically active small molecule that is conjugated to a monoclonal antibody via a linker. Other names for this species have included payload, cytotoxin, toxin, and warhead. The term “linker-drug” refers to a single molecular entity that contains both the linker and the drug. Other names that have been used for this species include drug-linke and linker/payload.
- 2.
ICH Q6B: Specifications: Test Procedures and Acceptance Criteria for Biotechnological/Biological Products
- 3.
ICH Q3A: Impurities in New Drug Substances
- 4.
ICH Q3B: Impurities in New Drug Products
- 5.
ICH Q3C: Impurities: Guidance for Residual Solvents
- 6.
ICH Q3D: Guidelines for Elemental Impurities
- 7.
ICH M7: Genotoxic Impurities: Assessment and Control of DNA Reactive (Mutagenic) Impurities in Pharmaceuticals to limit Potential Carcinogenic Risk
- 8.
ICH S9: Nonclinical Evaluation for Anticancer Pharmaceuticals
- 9.
S9 Implementation Working Group ICH S9 Guideline: Nonclinical Evaluation for Anticancer Pharmaceuticals Questions and Answers
- 10.
The concentration of small molecule impurities (Csm) decreases during diafiltration. The amount of small molecules purged from the system through a UF/DF step can be calculated based on the following equation:
Csm = Csm0e−N(1 − R)
where Csm0 is the initial contaminant concentration and N is the number of diafiltration volumes. For a contaminate with a retention of 0 (which should be true for small molecules well below the membrane cutoff), 6.9 diafiltration volumes will purge 99.9% of these impurities from the DS
Notes
Acknowledgements
The authors would like to thank Andrew Teasdale (AstraZeneca) and Ron Ogilvie (Pfizer) for discussions and edits that greatly improved the quality of this manuscript.
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