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Checklist Plug-and-play starting point Cell & Gene Therapy

Checklist: Comparability and CMC Flexibility Data Package Integrity Review

A plug-and-play checklist that reviews the data integrity of the justification package behind a comparability conclusion or a CMC flexibility position, reduced PPQ batches, prior knowledge, alternative methods, evolving specifications, scored pass/fail/NA with references and a filled specimen.

Document type: Checklist

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use checklist for reviewing the data integrity of the justification behind a comparability conclusion or a CMC flexibility position, not the scientific merit of the position itself. FDA’s CMC flexibilities framework for cell and gene therapy products allows phase appropriate CGMP expectations, risk based comparability scope, use of prior knowledge, a scientifically justified PPQ batch count, alternative analytical methods, and a lifecycle approach to specifications. None of that reduces what has to be true of the data behind the decision: it still has to be complete, attributable, and reconstructable, because when the dataset is smaller or the method is new, there is less redundant evidence to fall back on if the justification itself cannot be checked. Replace every <<FILL: ...>> placeholder, mark each item Pass / Fail / NA with evidence, and route the completed checklist through QA. A filled specimen follows. Verify each cited regulation and guidance against the current source before you rely on it.

Checklist header

FieldEntry
Checklist number<<FILL: ID>>
Program / product<<FILL>>
Flexibility or comparability position under review<<FILL: e.g. single representative PPQ lot, alternative potency method>>
Completed by / date<<FILL>>
QA reviewed by / date<<FILL>>

How to score

Mark each item Pass (control in place and evidenced), Fail (gap), or NA (with a reason). Any Fail on a position that supports a BLA filing or an approved commercial specification is a finding to close before the position is relied on further.

Section A: Governing document

#ItemP/F/NAEvidence / noteReference
A1The flexibility position is supported by a named, approved, version controlled document, not an email thread, meeting minutes, or a briefing slide<<FILL>><<FILL>>FDA 2018 DI Q&A
A2The document was approved before, or independent of, seeing the data it was meant to justify (for a risk assessment or scope decision), not adjusted after the fact<<FILL>><<FILL>>ICH Q9
A3Authorship and approval are attributable to named individuals with dates<<FILL>><<FILL>>ALCOA Attributable

Section B: Reduced PPQ batch / representative lot justification

#ItemP/F/NAEvidence / noteReference
B1The rationale for the batch count, including any use of a single representative lot, is documented and traceable to process understanding, not asserted without support<<FILL>><<FILL>>FDA CMC Flexibilities guidance (final, May 2026)
B2Raw data behind every engineering run or development batch cited to support representativeness is retrievable, not summarized only<<FILL>><<FILL>>ALCOA Original
B3The representative lot’s own data (raw data, audit trail, disposition) is complete and was reviewed under the same rigor as a conventional PPQ batch<<FILL>><<FILL>>21 CFR 211.192

Section C: Risk based comparability scope

#ItemP/F/NAEvidence / noteReference
C1An approved change to CQA risk assessment exists and set the comparability scope before testing began<<FILL>><<FILL>>ICH Q5E; ICH Q9
C2Every lot in the comparability scope, including any that trended differently, is retained in the dataset and reported<<FILL>><<FILL>>FDA 2018 DI Q&A
C3Any lot excluded from the comparability dataset has a documented, approved scientific justification<<FILL>><<FILL>>FDA OOS guidance (Rev. 1, May 2022), by analogy

Section D: Prior knowledge and platform data

#ItemP/F/NAEvidence / noteReference
D1Every prior knowledge or platform data citation has a traceable, attributable source, not a restated conclusion with no path back to raw data<<FILL>><<FILL>>ALCOA Original, Attributable
D2Where platform data comes from a different product or program, the basis for applying it here is documented, not assumed<<FILL>><<FILL>>FDA CMC Flexibilities guidance

Section E: Alternative analytical methods

#ItemP/F/NAEvidence / noteReference
E1Method equivalence or bridging data exists comparing the alternative method to the method it replaces<<FILL>><<FILL>>ICH Q2(R2)
E2Bridging data was generated and reviewed under the same audit trail and second person review standard as a release test<<FILL>><<FILL>>FDA 2018 DI Q&A

Section F: Stability and lifecycle specification setting

#ItemP/F/NAEvidence / noteReference
F1Stability data from clinical lots supporting a commercial expiration dating period is complete for every included lot, with any exclusion documented and justified<<FILL>><<FILL>>FDA CMC Flexibilities guidance
F2Every specification change has a dated rationale tied to the manufacturing data available at the time of the change<<FILL>><<FILL>>ICH Q12

References

FDA, Chemistry, Manufacturing, and Controls Flexibilities for Developing Human Cellular and Gene Therapy Products for a Biologics License Application (final Level 2 guidance, May 2026). 21 CFR Part 601 (licensing); 21 CFR 211.192, 211.194. ICH Q5E (comparability); ICH Q9 (quality risk management); ICH Q12 (lifecycle management); ICH Q2(R2) (analytical procedure validation). FDA Data Integrity and Compliance With Drug CGMP Q&A (final, Dec 2018).

Confirm each reference against the current source before issue.


Filled specimen

Illustrative extract for a single representative PPQ lot position supporting a defined release strategy.

#ItemP/F/NAEvidence / note
A1Named, approved, version controlled documentPassRisk Assessment RA-2026-041, approved, version 2.0
A2Approved before seeing the data it justifiesPassRA-2026-041 approved prior to PPQ execution per change control CC-2026-118
B1Batch count rationale traceable to process understandingPassRA-2026-041 section 4 cites platform history and two engineering runs (ENG-2026-004, ENG-2026-007)
B2Raw data behind cited runs retrievableFailEngineering run raw data archived under a decommissioned system; retrieval pending IT request, logged as exception EX-2026-019
C2All comparability lots retained, including outliersPassComparability report CR-2026-030 includes lot PUR-2026-0184, which trended low on one attribute, with a documented investigation
E1Bridging data for alternative methodPassBridging report BRG-2026-012, 12 samples, both methods, statistically equivalent

The Fail on B2 is exactly the kind of finding this checklist is built to surface before an inspector finds it: a scientifically sound representative lot position with a real gap in the retrievability of its own supporting raw data. It was logged as an exception and routed for remediation rather than left in the file.

Common inspection findings this checklist prevents

  • A reduced testing or single lot position supported only by a narrative in a briefing document, with no underlying approved risk assessment.
  • Prior knowledge cited by conclusion only, with no retrievable dataset behind the claim.
  • A comparability or stability lot quietly excluded with no documented justification, caught only when someone reconciles the lot list against actual manufacturing records.
  • An alternative method adopted for its efficiency without retained bridging data connecting it back to the method it replaced.

How to adapt this checklist

  1. Complete one checklist per flexibility position or comparability conclusion, not one checklist for an entire program; each position needs its own traceable evidence chain.
  2. Add or remove sections to match which flexibilities your program actually uses.
  3. Route any Fail through your deviation or CAPA process before the position is relied on in a filing or a release decision.
  4. Confirm every regulation and guidance reference against the current published version before issue.
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