Early CMC decisions for Phase 1 clinical supply are foundational. Certain errors made at this stage, such as failing to prove cell bank clonality, are irreversible and can jeopardize the entire development program, similar to a faulty foundation in a house.
An FDA analysis of Complete Response Letters (CRLs) since 2020 revealed that 70% of drug approval rejections were due to CMC issues. This data underscores that manufacturing and control strategies are a primary gatekeeper for regulatory approval, not just clinical trial results.
For early-stage biotech companies, saving money by limiting initial drug substance characterization is a false economy. A comprehensive, state-of-the-art characterization before Phase 1 is essential to de-risk the program by identifying molecular issues before they become catastrophic problems in late-stage development.
Instead of immediately scaling up the manufacturing process between clinical Phase 1 and 2, it is strategically better to produce more batches using the established Phase 1 process. This approach builds critical knowledge about process parameters and CQAs through repetition and increased clinical exposure.