Building Phase-Appropriate Quality from Preclinical to Commercial with Jackie Klecker
Episode
35 min
Read time
2 min
Topics
Relationships, Design & UX, Software Development
AI-Generated Summary
Key Takeaways
- ✓Phase-Appropriate Validation: Sponsors frequently over-request at preclinical stage — fully validated analytical methods are unnecessary and expensive before product understanding matures. Conversely, under-preparing by skipping design space testing creates downstream failures. CDMOs should provide sponsors a written phase roadmap specifying exactly when validations, bill of materials, and QMS requirements must be completed — for example, full analytical method validation before Phase 3.
- ✓FMEA as Product Lifecycle Encyclopedia: A Failure Mode and Effects Analysis should be initiated at preclinical and updated continuously through commercial production. Scope it by functional area — separate FMEAs for bulk drug substance, filling, and packaging — with a cross-functional team no larger than a minivan's capacity. Update occurrence rankings as controls are added, and incorporate complaint data and CAPA findings to keep it current.
- ✓EU vs. FDA Regulatory Gaps: EU submissions require completed Process Performance Qualification data before approval, whereas FDA accepts submitted protocols. EU Annex 13 also demands more complete analytical method validation at earlier phases and more extensive hold study data than FDA. Sponsors targeting European markets should pull forward stability studies and PPQ completion timelines to avoid resubmission delays.
- ✓Structured Knowledge Transfer at Program Start: Both sponsor and CDMO should document known product sensitivities — light exposure, oxygen sensitivity, pH specifications — alongside explicit gaps in knowledge before work begins. Sponsors often use only one API lot at preclinical, creating material variability blind spots. A formal written knowledge transfer document covering critical process parameters and material attributes reduces risk of late-stage surprises.
- ✓Quality Agreement as Conflict Prevention Tool: A detailed, documented quality agreement between sponsor and CDMO should define complaint response timelines, document approval authority, and review turnaround expectations before the program starts. Replacing ad-hoc email chains with regularly scheduled standing meetings — weekly, biweekly, or monthly — prevents documentation bottlenecks and eliminates tone misinterpretation that can damage working relationships.
What It Covers
Jackie Klecker, EVP and Head of Quality at Lifecore Biomedical, a 60-year-old fully integrated CDMO with 20 commercial SKUs, outlines how sponsors and CDMOs can build phase-appropriate quality systems from preclinical through commercial launch, avoiding costly delays through structured documentation, risk tools, and aligned communication.
Key Questions Answered
- •Phase-Appropriate Validation: Sponsors frequently over-request at preclinical stage — fully validated analytical methods are unnecessary and expensive before product understanding matures. Conversely, under-preparing by skipping design space testing creates downstream failures. CDMOs should provide sponsors a written phase roadmap specifying exactly when validations, bill of materials, and QMS requirements must be completed — for example, full analytical method validation before Phase 3.
- •FMEA as Product Lifecycle Encyclopedia: A Failure Mode and Effects Analysis should be initiated at preclinical and updated continuously through commercial production. Scope it by functional area — separate FMEAs for bulk drug substance, filling, and packaging — with a cross-functional team no larger than a minivan's capacity. Update occurrence rankings as controls are added, and incorporate complaint data and CAPA findings to keep it current.
- •EU vs. FDA Regulatory Gaps: EU submissions require completed Process Performance Qualification data before approval, whereas FDA accepts submitted protocols. EU Annex 13 also demands more complete analytical method validation at earlier phases and more extensive hold study data than FDA. Sponsors targeting European markets should pull forward stability studies and PPQ completion timelines to avoid resubmission delays.
- •Structured Knowledge Transfer at Program Start: Both sponsor and CDMO should document known product sensitivities — light exposure, oxygen sensitivity, pH specifications — alongside explicit gaps in knowledge before work begins. Sponsors often use only one API lot at preclinical, creating material variability blind spots. A formal written knowledge transfer document covering critical process parameters and material attributes reduces risk of late-stage surprises.
- •Quality Agreement as Conflict Prevention Tool: A detailed, documented quality agreement between sponsor and CDMO should define complaint response timelines, document approval authority, and review turnaround expectations before the program starts. Replacing ad-hoc email chains with regularly scheduled standing meetings — weekly, biweekly, or monthly — prevents documentation bottlenecks and eliminates tone misinterpretation that can damage working relationships.
Notable Moment
Klecker notes that skipping EU-required hold time studies to accelerate timelines backfires severely — regulators reject the submission outright, forcing sponsors to restart stability work from scratch. The resulting delay far exceeds any time saved by skipping the studies initially.
Episode Transcript
Hello, everyone. Welcome to the Life Science Rundown, the podcast where we discuss current, regulatory complexities facing life science industry and explore innovative ways to overcome those challenges. I am your host, Nicholas Catman, president and CEO of the FDA Group. Before we get started, here is a quick word about who we are. The FDA Group is a consulting firm that helps life science companies in the areas of regulatory submissions, audit projects, log inspection, staff augmentation, and remediation. So if you ever find yourself a need, just head over to the fdagroup.com to check us out and get in touch. So today, I am speaking with Jackie Clicker. Hey, Jackie. How are you? Hi, Nicholas. Fine. How are you? Doing excellent. Thank you so much for joining me today. I'm really excited to get into today's discussion. Before we before we touch on the, the topic, would you kindly introduce yourself? I will. Thank you. I'm Jackie Clecker. I'm the executive vice president and head of quality and head of development services here at Lifecore Biomedical. Lifecore has been around sixty years now, and we are a fully integrated CDMO. We do really specialty formulation, aseptic filling into vials, syringes, cartridges. We also do med device and pharmaceutical drug products along with some biologics. We have about 20 commercial SKUs, FDA, and Europe right now. That's our CDMO side, and we also produce a sodium hyaluronate API, which is our product and used throughout the world. Okay. Awesome. Thank you so much. So we will be talking about how scaling from preclinical to clinical and then to the commercial, it can be a daunting task. And we wanna understand how can sponsors ensure that they're asking the right questions to build robust processes while incorporating phase appropriate approaches, especially when getting it right saves time, resources, and money. So, to start, like I mentioned, you know, scaling that product from preclinical to commercial, it can really seem like a monumental task. From your experience, what are, what are the most common missteps companies make during this transition? It's a good question. What I've seen is some of the the sponsors would come in with their preclinical solutions and they would be requesting us to validate analytical methods fully, for example. That's very expensive endeavor and not necessarily needed at preclinical as the sponsor continues to understand their product. So that's an example of the sponsor asking for too much information. I've also seen the other side of it where the sponsor will come in and really doesn't understand the design space of the solution they're providing to us. So it it's they haven't really done the design testing. There isn't the understanding of what are the material variability attributes or even, you know, if there's a specification for pH, is is that the right spec? Should it be different? Will it be more stable if it's different? So those type of things. And and we're looking at it …
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