This guidance helps sponsors of investigational new drug applications (INDs) or applicants of new drug applications (NDAs), abbreviated new drug applications (ANDAs), biologic license applications (BLAs), and supplements validate bioanalytical methods used in human clinical pharmacology, bioavailability (BA), and bioequivalence (BE) studies that require pharmacokinetic, toxicokinetic, or biomarker concentration evaluation.2 This guidance can also inform the development of bioanalytical methods used for nonclinical studies that require toxicokinetic or biomarker concentration data. For studies related to the veterinary drug approval process such as investigational new animal drug applications (INADs), new animal drug applications (NADAs), and abbreviated new animal drug applications (ANADAs), this guidance may apply to blood and urine BA, BE, and pharmacokinetic studies.
The information in this guidance applies to bioanalytical procedures such as chromatographic assays (CCs) and ligand binding assays (LBAs) that quantitatively determine the levels of drugs, their metabolites, therapeutic proteins, and biomarkers in biological matrices such as blood, serum, plasma, urine, and tissue such as skin.
This final guidance incorporates public comments to the revised draft published in 2013 and provides recommendations for the development, validation, and in-study use of bioanalytical methods. The recommendations can be modified with justification, depending on the specific type of bioanalytical method. This guidance reflects advances in science and technology related to validating bioanalytical methods.
In general, FDA’s guidance documents do not establish legally enforceable responsibilities. Instead, guidances describe the Agency’s current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in Agency guidances means that something is suggested or recommended, but not required.
The 2001 guidance for industry on Bioanalytical Method Validation was originally based on the deliberations of two workshops described in publications entitled:
II。 背景
2001年生物分析方法驗證行業指南最初是基于出版物中描述的兩個研討會的討論,這兩個研討會的題目是:
? Analytical Methods Validation: Bioavailability, Bioequivalence, and Pharmacokinetic Studies
?分析方法驗證:生物利用度,生物等效性和藥代動力學研究
? Bioanalytical Methods Validation: A Revisit With a Decade of Progress
生物分析方法驗證:帶有十年進展的重訪
Additional workshops, summarized in the following publications, have informed subsequent revisions (e.g., the 2013 draft guidance for industry entitled Bioanalytical Method Validation):
以下出版物中總結的其他研討會已通知后續修訂(例如,2013年生物分析方法驗證行業指南草案):
? Quantitative Bioanalytical Methods Validation and Implementation: Best Practices for Chromatographic and Ligand Binding Assays
?定量生物分析方法驗證和實施:色譜和配體結合分析的最佳實踐
? The AAPS/FDA Workshop on Incurred Sample Reanalysis
?AAPS / FDA關于發生樣品再分析的研討會
? The AAPS Workshop on Crystal City V — Quantitative Bioanalytical Method Validation and Implementation: 2013 Revised FDA Guidance
?AAPS水晶城V研討會 -定量生物分析方法驗證和實施:2013年修訂的FDA指南
Validated analytical methods for the quantitative evaluation of analytes (i.e., drugs, including biologic products, and their metabolites) and biomarkers in a given biological matrix (e.g. blood, plasma, serum, or urine) are critical for the successful conduct of nonclinical, biopharmaceutics, and clinical pharmacology studies. These validated methods provide critical data to support the safety and effectiveness of drugs and biologic products. Validating the analytical method ensures that the data are reliable by addressing certain key questions, including:
? Does the method measure the intended analyte? For example, does anything interfere with the measurement, and is the method specific or selective for the analyte?
? What is the variability associated with these measurements? For example, what are the accuracy and precision of the method?
? What is the range in measurements that provide reliable data? For example, what is the sensitivity of the method (e.g., what is the lower limit of quantitation (LLOQ) of the method, and what is the upper limit of quantitation the method (ULOQ)?)
? How do sample collection, handling, and storage affect the reliability of the data from the bioanalytical method? For example, what steps need to be followed while collecting samples? Do the samples need to be frozen during shipping? What temperatures are required to store the samples, and how long can the samples be stored?
When changes are made to a validated method, the sponsor should conduct additional validation (i.e., partial or cross validation).
The fit-for-purpose (FFP) concept states that the level of validation should be appropriate for the intended purpose of the study. The key questions listed above should be evaluated relative to the stage of drug development. Pivotal studies submitted in an NDA, BLA, or ANDA that require regulatory decision making for approval, safety or labeling, such as BE or pharmacokinetic studies, should include bioanalytical methods that are fully validated. Exploratory methods that would not be used to support regulatory decision making (e.g., candidate selection) may not require such stringent validation. This FFP concept applies to drugs, their metabolites, and biomarkers.
The analytical laboratory conducting toxicology studies for regulatory submissions should adhere to 21 CFR 58, Good Laboratory Practices (GLPs).9 The bioanalytical method for human BA, BE, and pharmacokinetic studies must meet the criteria specified in 21 CFR 320 Bioequivalence and Bioavailability Requirements (i.e., 21 CFR 320.29).
The following sections discuss the development, validation, and in-study use of bioanalytical methods and how best to document validation methods and results. Refer to the Glossary for the definitions of assay parameters and analytical terms used in this guidance.
III. BIOANALYTICAL METHOD DEVELOPMENT AND VALIDATION
A. Guiding Principles
The purpose of bioanalytical method development is to define the design, operating conditions, limitations, and suitability of the method for its intended purpose and to ensure that the method is optimized for validation.
Before the development of a bioanalytical method, the sponsor should understand the analyte of interest (e.g., determine the physicochemical properties of the drug, in vitro and in vivo metabolism, and protein binding) and consider aspects of any prior analytical methods that may be applicable.
The elements and acceptance criteria of method development and validation are summarized in Table 1. Table 2 describes how the sponsor should document the development and validation of the bioanalytical assay and where it should be stored or submitted.
Method development involves optimizing the procedures and conditions involved with extracting and detecting the analyte. Method development includes the optimization of the following bioanalytical parameters (which are discussed in greater detail in section III.B) to ensure that the method is suitable for validation:
? Reference standards ? Critical reagents ? Calibration curve ? Quality control samples (QCs) ? Selectivity and specificity ? Sensitivity ? Accuracy ? Precision ? Recovery ? Stability of the analyte in the matrix
Bioanalytical method development does not require extensive record keeping or notation. However, the sponsor should record the changes to procedures as well as any issues and their resolutions during development of the bioanalytical method to provide a rationale for any changes during the development of the method.
Bioanalytical method validation proves that the optimized method is suited to the analysis of the study samples. The sponsor should:
? Conduct a full validation of any new bioanalytical method for the analysis of a new drug entity, its metabolite(s), or biomarkers.
? Conduct a full validation for any revisions to an existing validated method that adds a metabolite or an additional analyte.
? Establish a detailed, written description (e.g., protocol, study plan, and/or standard operating procedure (SOP)) for the bioanalytical method before initiating validation. The description should identify procedures that control critical parameters in the method (e.g., environmental, matrix, procedural variables) from the time of collection of the samples to the time of analysis to minimize their effects on the measurement of the analyte in the matrix.
? Document and report (in the method validation report) all experiments used to make claims or draw conclusions about the validity of the method.
? Validate the measurement of each analyte in the biological matrix. The specific requirements and acceptance criteria for each bioanalytical parameter are listed in Table 1.
B. Bioanalytical Parameters of CCs and LBAs
The bioanalytical parameters applicable to CCs and LBAs are discussed below. Issues unique to either CCs or LBAs are specifically identified.
1. Reference Standards and Critical Reagents
The sponsor should appropriately characterize and document (e.g. determine the identity, purity, and stability) all reference standards and critical reagents, such as antibodies, labeled analytes, and matrices and store them under defined conditions.
a. Reference standards
The purity of reference standards used to prepare calibrators and QCs can affect the study data. Therefore, the sponsor should use authenticated analytical reference standards with known identities and purities to prepare solutions of known concentrations. The reference standard should be identical to the analyte; however, when this scenario is not possible, the sponsor can use an established chemical form (e.g., free base, free acid, or salt) of known purity.
The sponsor should provide the certificates of analyses (CoA), including the source, lot number, and expiration date (with the exception of United States Pharmacopeia (USP) standards) for commercially available reference standards. For internally or externally generated reference standards that do not have a CoA, the sponsor should provide evidence of the standard’s identity and purity in addition to the source and the lot number. When using expired reference standards, the sponsor should provide an updated CoA or re-establish the identity and purity of the standard. If the reference standard expires, the sponsor should not make stock solutions with this lot of standard unless the standard’s purity is re-established. For internal standards (ISs), the sponsor does not have to provide a CoA or evidence of purity if it demonstrates that the IS is suitable for the specific use (e.g., lack of interference with an analyte).
The sponsor should appropriately characterize and document (i.e., determine the identity, purity and stability) the critical reagents, including – but not limited to – any reference standards, antibodies, labeled analytes, and matrices.
Assay validation is important when there are changes to the critical reagents, such as lot-to-lot changes or switches to another reagent. For example, if there are changes to the labeled analytes, detector reagents, or antibodies, the sponsor should:
? Evaluate binding and re-optimize assays
? Verify performance with a standard curve and QCs
? Evaluate cross-reactivities
2. Calibration Curve
During method development, the sponsor should choose the quantitation range of the assay and the concentrations of the calibration standards on the basis of the concentration range expected in a particular study. For LBAs, in addition to the calibration standards, anchor points outside the range of quantification can facilitate the fitting of the curve. Anchor points should not be used as part of the acceptance criteria for the run. For most LBAs, calibration (standard) curves are inherently nonlinear, and in general, more calibration standards are needed to define the fit over the calibration curve range for LBAs than for CCs. In addition, the response-error relationship for LBA standard curves is a variable function of the mean response (i.e., heteroscadisticity).
The sponsor should use the simplest model that adequately describes the concentration-response relationship, as well as an appropriate weighting scheme and regression equation. For LBAs, the concentration-response relationship is most often fitted to a four -or five-parameter logistic model, although other models can be assessed.
When the method is validated, the calibration curve should be continuous and reproducible. The sponsor should prepare the calibration standards in the same biological matrix as the samples in the intended study. Study samples may contain more than one analyte. The sponsor should generate a calibration curve for each analyte in the sample. When surrogate matrices are necessary, the sponsor should justify and validate the calibration curves.
The requirements for the calibration curve, including the LLOQ, ULOQ, as well as the acceptance criteria are listed in Table 1.
Quality controls are used to assess the precision and accuracy of an assay and the stability of the samples. Sponsors should prepare QCs in the same matrix as the study samples to be assayed with the validated method. Freshly prepared QCs are recommended for precision and accuracy analyses during method development, as stability data are generally not available at this time.
During method validation, QCs evaluate the performance of a method and the stability of an analyte. Performance QCs are included in validation runs to determine the precision and accuracy of the method (see section III.B). Stability QCs evaluate the stability of an analyte under various stress conditions (Refer to section III.B for the selection of QC concentrations).
The sponsor should prepare any calibration standards and QCs from separate stock solutions. However, if the sponsor can demonstrate the precision and accuracy in one validation run using calibrators and QCs prepared from separate stock solutions, then the sponsor can use calibrators and QCs prepared from the same stock solution in subsequent runs. The sponsor should make up calibrators and QCs in lots of blank matrix that is free of interference or matrix effects.
4. Selectivity and Specificity
During method development, the sponsor should verify that the substance being measured is the intended analyte to minimize or avoid interference. Selectivity of the method is routinely demonstrated by analyzing blank samples of the appropriate biological matrix (e.g., plasma) from multiple sources. Depending on the intended use of the assay, the impact of hemolyzed samples, lipemic samples, or samples from special populations can be included in the selectivity assessment. When using liquid chromatography/mass spectrometry (LC/MS) methods, the sponsor or applicant should determine the effects of the matrix on ion suppression, ion enhancement, or extraction efficiency. Internal standards should be assessed to avoid interference with the analyte. Potential interfering substances in a biological matrix include endogenous matrix components such as metabolites, decomposition products – and from the actual study – concomitant medications and other xenobiotics. If a stabilizer or enzyme inhibitor is used during sample collection, the sponsor should evaluate the potential for interference on the quantitation of the analyte. Sponsors should make a scientific judgment about the need to assess these (and any other) potential interferences during method development.
During validation, the sponsor should confirm that the assay is free of potential interfering substances including endogenous matrix components, metabolites, anticipated concomitant medications, etc. If the study sample contains more than one analyte and the analytes are intended to be quantified by different methods, the sponsor should test each method for interference from the other analyte.
The sponsor should analyze blank samples of the appropriate biological matrix (e.g. plasma) from at least six (for CCs) or ten (for LBAs) individual sources. The sponsor should ensure that there are no matrix effects throughout the application of the method. Refer to Table 1 for details of selectivity and specificity requirements and acceptance criteria.
For LBAs, it is important to investigate any interference originating from structurally or physiologically similar analytes (i.e., exogenous interference) or matrix effects (i.e., endogenous interference). Investigating exogenous interference involves determining the cross-reactivity of molecules that could potentially interfere with the binding interaction, including molecules structurally related to the drug, any metabolites, concomitant medications (and their significant metabolites), or endogenous matrix components. The sponsor should evaluate each factor individually and in combination with the analyte of interest to determine its ability to cause interference. Matrix effects evaluation involves comparing calibration curves in multiple sources of the biological matrix against a calibration curve in the matrix for parallelism (serial dilution of incurred samples) and nonspecific binding. The sponsor should eliminate or minimize any significant interference. If such attempts are unsuccessful, the sponsor could consider the development of an orthogonal method to eliminate or minimize the interference.
Carryover between samples can occur in analytical methods. The sponsor should eliminate any carryover during method development. If carryover cannot be eliminated, the sponsor should assess the impact of any carryover during method validation on the accuracy of the study sample concentrations.
5. Sensitivity
The LLOQ defines the method sensitivity and should be determined during method development. The method should be developed and validated such that it will be able to meet the requirements necessary for the intended study samples. The LLOQ evaluation can be done separately or as part of the precision and accuracy assessment for the calibration range. The specific requirements to validate sensitivity are listed in Table 1.
6. Accuracy, Precision, and Recovery
Evaluating the accuracy and precision across the quantitation range during method development is essential to determine whether the method is ready for validation and involves analyzing replicate QCs at multiple concentrations across the assay range. Specifically, the sponsor should evaluate the performance at the LLOQ, low, mid and high QCs (and the ULOQ for LBAs) to determine if the method is suitable to analyze study samples.
Method validation experiments for estimating accuracy and precision should include a minimum of three (for CCs) and six (for LBAs) independent runs (i.e., accuracy and precision (A & P) runs; see Table 1) conducted over several days. Each A & P run should include a calibration curve and multiple QC concentrations that are analyzed in replicates. The sponsor should determine the accuracy and precision of the method based on the performance of the QC in the A & P runs. The specific validation requirements for accuracy and precision and A & P runs are listed in Table 1. The sponsor should use freshly prepared calibrators and QCs in all A & P runs. Use of freshly prepared QCs in all A & P runs is preferred; however, if this is not possible, the sponsor should use freshly prepared QCs in one or more A & P runs.
The sponsor should optimize the recovery of the analyte to ensure that the extraction is efficient and reproducible. Recovery need not be 100 percent, but the extent of the recovery of an analyte and of the ISs should be consistent and reproducible. The sponsor should perform recovery experiments by comparing the analytical results of extracted samples with corresponding extracts of blanks spiked with the analyte post-extraction (i.e., to represent 100 percent recovery). Recovery evaluation is not necessary for LBAs unless sample extraction is involved. Recovery experiments should be performed as described in Table 1.
During method development, the sponsor should determine the chemical stability of the analyte in a given matrix, including the effects of sample collection, handling, and storage of the analyte. The sponsor should assess autosampler, benchtop, processed or extracted samples, freeze-thaw, stock solution, and long-term stability of the analyte. The sponsor should assess the stability in the same matrix as that intended for in-study samples; however, when the matrix is rare, the sponsor can explore the use of suitable surrogate matrices.
For drugs administered as fixed combinations, or part of a specific drug regimen, the stability of the analyte should be assessed in the presence of the other drug. The sponsor should also consider the stability of the analyte in the presence of other co-medications that are known to be regularly administered to patients for the indication of the drug under development.
Depending on the analyte as well as the sample collection and assay conditions, evaluating the stability of the analyte in whole blood during method development can be useful. For example, a drug can be unstable in whole blood or adsorb to cellular components during collection.
During validation, stability evaluations should cover the expected sample conditions before receipt at the analytical site (e.g., at the clinical site, during shipment, and at all other secondary sites) as well as during receipt and analysis at the analytical site. Validation of drug stability in a biological fluid is a function of the storage conditions, the physicochemical properties of the drug, the matrix, and the container system. The stability of an analyte in a particular matrix and container system is relevant only to that matrix and container system and should not be extrapolated to other matrices and container systems.
If the storage conditions changed or the sample analysis occurred outside of the validated storage condition , the stability should be re-established under these new conditions. Stability testing of the analyte in whole blood should be revalidated if necessary (e.g., if the analytes are unstable during blood collection). The specific requirements and acceptance criteria for stability are listed in Table 1.
Matrix-related stability experiments should compare stability QCs against freshly prepared calibration curves and freshly prepared QCs. Although the use of freshly prepared calibrators and QCs is the preferred approach, in some cases, (e.g., for macromolecules), it may be necessary to freeze them overnight. In such cases, the sponsor should provide valid justification and demonstrate the freeze-thaw stability.