CMC regulatory consulting: from IND to commercial supply

CMC consulting is the chemistry, manufacturing and controls work behind a regulatory submission: the control strategy, the specifications, the stability program, the manufacturing process description and the documents in Module 3 of the Common Technical Document. QLogixCMC plans that work for small molecules, biologics, sterile injectables, mRNA, cell immunotherapies and gene therapies, writes and reviews the documents from IND and IMPD through NDA, BLA and MAA, and supports the site through agency questions, post-approval changes and technology transfers.

What we deliver

  • CMC development strategy and the plan of studies for each phase
  • Module 3 (CTD) authoring and review for IND, IMPD, NDA, BLA and MAA submissions
  • Control strategy, critical quality attributes and critical process parameters
  • Specifications, analytical method validation plans and stability protocols to ICH Q1A(R2)
  • Process description, process validation strategy and comparability protocols
  • Post-approval changes: classification, reporting category and supporting data
  • Technology transfer packages and receiving-site readiness
  • Preparation for pre-IND, end-of-phase and pre-approval meetings

How the work runs

We begin with a CMC gap assessment of the development history, the data on hand and the target submission, and produce a plan that says which studies, documents and decisions are on the critical path. Writing starts from the data and the batch records, not from a template, so the narrative in Module 3 matches the evidence behind it.

Every document is reviewed against the ICH guideline it answers to and the agency's questions on similar products. For technology transfers, we run the gap analysis between sending and receiving sites, write the transfer protocol, and stay with the receiving site through the first batches.

What makes it hold up under review

  • Control strategy built on ICH Q8, Q9(R1), Q10 and Q11 principles, with the risk assessments on file
  • Specifications justified to ICH Q6A and Q6B from the batch data and the clinical exposure
  • Stability data presented to ICH Q1A(R2) and Q1E, with shelf-life proposals the data supports
  • Post-approval changes classified under ICH Q12 and the applicable FDA and EMA guidance
  • Every statement in the submission traceable to a report, a batch record or a validated method

Questions about CMC and regulatory

What does a CMC consultant do?

A CMC consultant plans and documents how a drug substance and a drug product are made, tested and controlled so that a regulatory submission can be approved and the product can be made consistently. At QLogixCMC that means the CMC development strategy, the control strategy, specifications and stability, the Module 3 sections of the CTD, agency meeting preparation, post-approval changes and technology transfers, drafted with the sponsor's team and decided by its qualified people.

When should a biotech bring in CMC consulting?

Before the first IND or IMPD, when the CMC package is being built; before an end-of-phase meeting, when the control strategy and the validation plan are set; in the year before an NDA, BLA or MAA, when Module 3 is written and the pre-approval inspection is prepared; and whenever a technology transfer, a post-approval change or an agency question needs CMC expertise the team does not have. QLogixCMC starts each with a CMC gap assessment.

Which products do you cover?

QLogixCMC works on small molecules, biologics, sterile injectables, mRNA and other nucleic acid products, cell immunotherapies such as CAR-T, gene therapies and drug-device combination products, for both drug substance and drug product. The team is assembled for the product: a biologics submission gets consultants who have run biologics processes, and an advanced therapy gets people who have released vector, cell and mRNA batches.

Do you support mRNA, cell therapy and gene therapy CMC?

Yes. For mRNA, QLogixCMC covers the plasmid DNA template, in vitro transcription, lipid nanoparticle formulation, the identity, integrity, purity and potency specifications and the stability program. For cell immunotherapies, the apheresis starting material, the vector, the manufacturing process, release testing with a potency assay, chain of identity and custody, and the vein-to-vein timeline. For gene therapies, the plasmid and vector production, capsid and genome characterization, specifications and comparability through process changes. Submissions follow the FDA CBER and EMA ATMP guidance that applies.

Can you write Module 3 from our data?

Yes. QLogixCMC authors Module 3 sections from your development reports, batch records, analytical data and stability tables, and reviews sections your team has written. Each statement is traced to the document that supports it, so the submission can be defended in an agency question.

Do you support post-approval changes?

Yes. QLogixCMC classifies the change under ICH Q12 and the FDA or EMA guidance that applies, defines the supporting studies, writes the variation or supplement, and tracks the commitments to closure.

How do you work with our regulatory affairs team?

As part of it. QLogixCMC drafts, reviews and advises; your regulatory lead owns the strategy and every document that goes to an agency. Where you have no regulatory function yet, we can act as the CMC regulatory lead until you hire one.

Talk it through with someone who has run a plant

Bring your backlog, your submission timeline or the Form 483. We will tell you plainly what we would do first, what it would take, and what we would leave alone.

In the first meeting we cover

  • What is on your mind: a backlog, a submission, a validation program, an inspection date or a system that is not working
  • What we would assess first, and what we would leave alone
  • Whether an engineer on your site, a fixed-scope assessment or a defined deliverable is the right way to start