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Pacing the Journey: A Framework to Commercial Readiness
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by Jey Bouc, Ph.D., and Keerthana Subramanian
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As gene therapy manufacturing continues to mature, the focus is shifting. Most gene therapy developers begin this work running a sprint, racing to reach first-in-human data as quickly as possible. But as programs advance toward commercialization, the discipline required starts to look less like a sprint and more like a marathon. Early development once focused primarily on
demonstrating that a vector could be produced reproducibly and at sufficient yield. Today, as programs advance toward pivotal studies and commercialization, the challenge shifts to a thorough, steady journey. Regulatory agencies no longer ask whether a product can be manufactured. They ask whether the process and product are truly understood in a way that supports consistency and safety. Process characterization (PC) provides the scientific foundation needed to build the data set that enables developers to identify
critical process parameters, establish robust manufacturing control strategies and demonstrate process understanding as programs advance toward commercialization. Like training for a marathon, PC is not about a single explosive effort; it’s the sustained, disciplined work, mile after mile, that builds the endurance a program needs to go the distance to commercial launch. It transforms a process that operates reliably in the hands of its developers into one that can be justified, reproduced, and trusted by health authority reviewers. When executed well, PC reduces downstream risk
by strengthening validation strategies, supporting PPQ readiness, and enabling a smoother path to commercial launch. When treated as both a regulatory requirement and a scientific exercise, it can become a foundational source for information requests during BLA or MAA review. Within the development lifecycle, process characterization serves as the critical link between process development and commercial process validation: It is where the empirical, exploratory work of early development is formalized into a defensible control strategy, grounded in statistical evidence rather than institutional knowledge. This is precisely why PC draws such close regulatory scrutiny. Regulatory bodies collectively expect that critical process parameters (CPPs), proven acceptable ranges (PARs), and the resulting control strategy are not asserted, but demonstrated. At Forge, our
approach to process characterization aligns with the Alliance for Regenerative Medicine's (ARM) Project A-Gene framework, which emphasizes a connected scientific narrative rather than a collection of independent studies. Every stage builds upon the previous one, beginning with structured risk assessments, progressing through qualification of representative scale-down models, into Design of Experiments (DoE), and ultimately supporting process validation and commercial readiness. Together, these elements support regulatory
expectations while building the scientific basis for a robust and scalable manufacturing process. | | Process Characterization Begins with Understanding Risks | Starting
characterization early on is what separates programs that pace themselves for the marathon ahead from those left sprinting to catch up later. Before a single DoE run is executed, the question must be answered: what are the greatest risks to product quality? This is the role of the Parameter Risk Assessment (PRA) and process Failure Mode and Effects Analysis (pFMEA). These tools provide a structured framework for holistically evaluating process parameters including setpoints, hold times, and material attributes across each unit
operation, and systematically ranking their potential impact on critical quality attributes (CQAs), which are the measurable property or characteristics that must be controlled to ensure product quality2. In gene therapy products, relevant CQAs may include attributes such as purity, potency, and infectivity. The quality of a risk assessment depends on the breadth of expertise involved in its development. A scientifically sound and defensible risk ranking
requires cross-functional input from Process Development, Analytical Development, Manufacturing Science and Technology (MSAT), Validation, Quality and Regulatory teams. Each team brings a distinct perspective to the assessment of process risk. For developers working with a CDMO, this is also the moment to bring that partner to the table, as a marathon is best paced with the full team assembled before race day, not recruited mid-course. A parameter that may appear low risk from a process performance perspective may present greater risk when evaluated through the lens of
analytical robustness or clinical impact. Importantly, risk assessment is not a one-time milestone completed early in development. It should be treated as a living document that evolves alongside the program, incorporating new process knowledge, characterization data, and manufacturing experience as the product advances toward commercialization. | | Qualifying the Scale-Down Model | Once the right questions are identified, they must be evaluated using a model that reliably represents commercial manufacturing. This is where scale-down model (SDM) qualification becomes essential. Think of the SDM as the practice course: it must mirror race-day conditions (i.e., commercial-scale manufacturing) closely enough that a strong training run predicts a strong result on the day that matters. Regulatory expectations require characterization data generated at laboratory or pilot scale to be representative of commercial-scale manufacturing. Common qualification approaches include statistical equivalence testing (e.g., TOST),
comparability assessments, and multivariate analyses evaluating multiple quality attributes simultaneously. To ensure SDM qualification proceeds smoothly, several considerations should be addressed upfront. These include confirming the availability and suitability of representative commercial-scale batches for comparison, accounting for expected batch-to-batch variability, and defining
scientifically justified acceptance criteria and data inclusion/exclusion criteria before execution of the qualification study. The qualification strategy should also establish in advance which process parameters and CQAs will be compared, the statistical approach for assessing scale-dependent differences, and the rationale for determining equivalence between the SDM and commercial-scale processes. Establishing these elements prospectively helps distinguish true scale-dependent effects from normal process
variability and provides a clear, defensible framework for qualification. When supported by representative data and predefined criteria, a qualified SDM can then be confidently leveraged for characterization of multiple unit operations. | | Designing Experiments that Build Process Understanding | With confidence that the scale-down model is representative of manufacturing, the next challenge is designing experiments that generate meaningful process understanding rather than simply confirm existing assumptions. This is where DoE provides a critical advantage over one-factor-at-a-time (OFAT) approaches. While OFAT studies can demonstrate how an individual
parameter behaves in isolation, they are unable to capture interactions between parameters, which are often where the greatest risks to product quality exist. DoE establishes PARs, characterizes parameter interactions, and establishes a control strategy reflecting how the process behaves across the full operating space. |
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