INTERNATIONAL CONCIL FOR HARMONISATION OF TECHNICAL REQUIREMENTS FOR PHARMACEUTICALS FOR HUMAN USE ICH HARMONISED GUIDELINE Q3D(R1)

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INTERNATIONAL CONCIL FOR HARMONISATION OF TECHNICAL REQUIREMENTS FOR PHARMACEUTICALS FOR HUMAN USE ICH HARMONISED GUIDELINE GUIDELINE FOR ELEMENTAL IMPURITIES (R1) Draft version Endorsed on 18 May 2018 Currently under public consultation At Step 2 of the ICH Process, a consensus draft text or guideline, agreed by the appropriate ICH Expert Working Group, is transmitted by the ICH Assembly to the regulatory authorities of the ICH regions for internal and external consultation, according to national or regional procedures.

(R1) Document History Code History Date (R1) Endorsement by the Members of the ICH Assembly under Step 2 and release for public consultation (document dated 23 February 2018). Corrigendum to correct: the modifying factor in the text of the safety assessment for Selenium (changed to 2 instead of 10 consistent with Section 3.1); and two references for consistency in the safety assessments for Barium (deleted reference) and Vanadium (revised reference). 18 May 2018 16 December 2014 Approval by the Steering Committee under Step 4 and recommendation for adoption to the ICH regulatory bodies. Addition of line numbers to facilitate the provision of comments by stakeholders. Post sign-off minor editorial corrections including: removal of references to Appendix 5 (pgs i & 13); deletion of redundant text (pg 4); change of Option 2 to Option 2a (pg 10); insertion of omitted text under Safety Limiting Toxicity (pg 35); removal of duplicated redundant text (pg 41); replacing references to metals in text and metal in Table A.4.7 title with elementals and elements (pg 73); and deletion of header Table A.4.10 (pg 75). Post sign-off corrigendum in: Table 4.1 W and Al were removed from the list of included elemental impurities in Class 2B and 3 respectively. Table A.2.1 the Class for Ni was changed to read 3 instead of 2. Approval by the Steering Committee under Step 2b and release for public consultation. Approval by the Steering Committee under Step 2a. 12 November 2014 30 September 26 July 14 June 6 June 6 June

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 CADMIUM Summary of PDE for Cadmium Cadmium (Cd) Oral Parenteral Inhalation PDE (µg/day) 5.0 1.7 3.4 Introduction Cadmium (Cd) is a transition metal whose most abundant naturally-occurring isotope is non-radioactive. It is found in nature in mineral forms and is obtained for commercial uses principally from cadmium ore (ATSDR, 2012). Cadmium exists as a salt form in the +2 oxidation state only. Some cadmium salts such as cadmium chloride, cadmium sulfate and cadmium nitrate are water soluble; other insoluble salts can become more soluble by interaction with acids, light or oxygen. Cadmium, cadmium oxide, cadmium salts on borosilicate carrier are used as catalysts in organic synthesis. Silver cadmium alloy is used in the selective hydrogenation of carbonyl compounds. Safety Limiting Toxicity Cadmium has shown to be genotoxic, but not mutagenic and has been acknowledged as a human carcinogen (Group 1; IARC, 2012). Cadmium and cadmium compounds cause cancer of the lung. Also, positive associations have been observed between exposure to cadmium and cadmium compounds and cancer of the kidney and of the prostate. A sensitive endpoint for oral exposure to cadmium and cadmium salts is renal toxicity (Buchet et al. 1990). Skeletal and renal effects are observed at similar exposure levels and are a sensitive marker of cadmium exposure (ATSDR, 2012). Evidence from numerous epidemiologic studies assessing inhalation exposures to cadmium via both occupational and environmental routes has demonstrated an increased risk of developing cancer (primarily lung) that correlates with inhalation exposure to cadmium (IARC, 2012; NTP, 1995). ATSDR (2012) concluded that lung carcinogenesis due to occupational exposure was not unequivocal. Cadmium was clearly positive for lung tumours in rats; non-significant, non dose dependent in mice; and not observed in hamsters. An inhalation unit risk estimate of 0.0018/µg/m 3 has been derived by the US EPA (1992); however, a modifying factor approach may be used for non-mutagenic carcinogens. The US Department of Labor has a reported a Permitted Exposure Level of 5 µg/m 3 for cadmium (Cadmium OSHA, 2004). PDE Oral Exposure A sensitive endpoint for oral exposure to cadmium and cadmium salts is renal toxicity (Buchet et al, 1990). Skeletal and renal effects are observed at similar exposure levels and are a sensitive marker of cadmium exposure (ATSDR, 2012). A number of oral exposure studies of cadmium in rats and mice showed no evidence of carcinogenicity. Therefore, the renal toxicity endpoint was used to establish the oral PDE for cadmium, following the recommendations of ATSDR, an MRL of 0.1 µg/kg for chronic exposure is used to set the oral PDE. This is consistent with the WHO drinking water limit of 0.003 mg/l/day (WHO, 2011). PDE = 0.1 µg/kg/d x 50 kg = 5.0 µg/day No modifying factors were applied because they are incorporated into the derivation of the MRL. PDE Parenteral Exposure A 12-week study in rats given daily subcutaneous injections of 0.6 mg/kg Cd, 5 days per week showed renal damage at week 7 and later (Prozialeck et al, 2009). A single dose level was used in this study. The

41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 LOAEL of this study is 0.6 mg/kg based on decreased body weight, increased urine volume and urinary biomarkers seen at this dose level. This study was used to set the parenteral PDE. In a separate single dose study where rats were administered 0, 1, 2, 4, 8, 16 or 32 µmol/kg cadmium chloride by the subcutaneous route, sarcomas were noted at the injection site at the two highest doses at the end of the 72 week observation period (Waalkes et al, 1999). It is uncertain whether the granulomas at the sites of injection over time trap an unspecified amount of the administered cadmium dose at the injection site. This phenomenon may decrease the actual parenteral cadmium dose, compared with the calculated parenteral cadmium dose. Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), and correcting for continuous dosing from 5 days to 7 days per week (factor of 5/7), the parenteral PDE is calculated as: PDE = 0.6 mg/kg x 5/7 x 50 kg / 5 x 10 x 5 x 5 x 10 = 1.7 µg/day A factor of 5 was chosen for F4 because cadmium is carcinogenic by the inhalation route and granulomas were observed by the subcutaneous route. These findings are of uncertain relevance. A factor of 10 was chosen for F5 because a LOAEL was used to set the PDE. PDE Inhalation Exposure The United States Department of Labor Occupational Safety and Health Administration has developed a Permitted Exposure Level of 5 µg/m 3 for cadmium. Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the inhalation PDE is calculated as: For continuous dosing = 5 µg/ m 3 x 8 hr/d x 5 d/wk = 1.19 µg/m 3 = 0.00119 µg/l 24 hr/d x 7 d/wk 1000 L/m 3 Daily dose = 0.00119 µg/l x 28800 L = 0.685 µg/kg 50 kg PDE = 0.685 µg/kg x 50 kg / 1 x 10 x 1 x 1 x 1 = 3.43 µg/day A modifying factor for F4 of 1 was chosen based on the potential for toxicity to be mitigated by the possible species specificity of tumorigenesis, uncertain human occupational tumorigenesis, ambient exposure levels not expected to be a health hazard, and workplace exposure levels expected to be safe. A larger factor F4 was not considered necessary as the PDE is based on a PEL. REFERENCES ATSDR. Toxicological profile of cadmium. Agency for Toxic Substances and Disease Registry, Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2012. Buchet JP, Lauwerys R, Roels H, Bernard A, Bruaux P, Claeys F et al. Renal effects of cadmium body burden of the general population. Lancet 1990;336:699-702. Cadmium: OSHA 3136-06R, 2004. (available at https://www.osha.gov/publications/osha3136.pdf; accessed October 10, 2017)

82 83 84 85 86 87 88 89 90 91 92 93 94 95 IARC. Arsenic, metals, fibres, and dusts: a review of human carcinogens. Monographs on the Evaluation of Carcinogenic Risks to Humans. International Agency for Research on Cancer, World Health Organization, Lyon. 2012;100C. NTP. Technical report on toxicity studies of cadmium oxide (CAS No. 1306-19-0) administered by inhalation to F344/N Rats and B6C3F 1 mice. National Toxicology Program, Public Health Service, U.S. Department of Health and Human Services. 1995. Prozialeck WC, Edwards JR, Vaidya VS, Bonventre JV. Preclinical evaluation of novel urinary biomarkers of cadmium nephrotoxicity. Toxicol Appl Pharmacol 2009;238:301-305. US EPA. Cadmium. Integrated Risk Information System (IRIS). 1992. Waalkes MP, Anver M, Diwan BA. Carcinogenic effects of cadmium in the Noble (NBL/Cr) rat: induction of pituitary, testicular, and injection site tumors and intraepithelial proliferative lesions of the dorsolateral prostate. Toxicol Sci 1999;52:154-161. WHO. Cadmium in drinking-water. Background document for development of WHO Guidelines for drinking-water quality. World Health Organization. 2011;WHO/SDE/WSH/03.04/80/Rev/1.