Overview of USP General Chapters <476> and <1086> Prescription/Non-Prescription Stakeholder Forum October 19, 2017

Similar documents
Organic Impurities in Drug Substances and Drug Products. Antonio Hernandez-Cardoso, M.Sc. Senior Scientific Liaison September 8, 2017

ANDA Submissions Refuse to Receive for Lack of Proper Justification of Impurity Limits Guidance for Industry

General Chapter/Section: <232> Elemental Impurities - Limits Expert Committee(s): General Chapters Chemical Analysis No.

The Complexity of Setting Compendial Specifications for Excipient Composition and Impurities

Residual Solvents: FDA/ Regulatory Perspective

Dr. Christian Zeine LGC Standards GmbH. Webinar Series 2013 July 2013

General Concepts in the European Pharmacopoeia. Anne-Sophie Bouin European Pharmacopoeia Department, EDQM, Council of Europe

EMEA WORKING PARTY ON HERBAL MEDICINAL PRODUCTS

EVALUATION AND RECOMMENDATION OF PHARMACOPOEIAL TEXTS FOR USE IN THE ICH REGIONS ON DISINTEGRATION TEST GENERAL CHAPTER Q4B ANNEX 5(R1)

Topics covered by the talk

General concepts in the Ph. Eur.: theory and rationale

USP Perspective on Atypical Actives November 29, 2017

in the ICH Regions Table of Content Annexes to Guideline and 3. Why is Q4B necessary? Q4B Annexes? for Human Use

COMMENTS. Submitted by The International Pharmaceutical Aerosol Consortium

USP NF General Chapter <905> Uniformity of Dosage Units

USP <232> and <233> Understanding Your Path to Compliance with the New Elemental Impurity Chapters. Steve Wall Agilent Technologies

COMMENTARY TO USP31 - NF26

Vol. 41(1) [Jan. Feb. 2015] (P) \\uspnetapp2\share\share\uspnf\printq\pager\xmlin\lyc_ _m99989.xml. Nov.

USP Dietary Supplements Standards Up-to-Date Roundtable Meeting Report. Huy Dinh, MS. Senior Scientific Liaison Dietary Supplements

232 ELEMENTAL IMPURITIES LIMITS

U.S. Requirements for Dietary Supplement Ingredients and USP <2232> Elemental Impurities Is Your Company Ready for Implementation?

AAM Fall Tech Conference November 6-8, 2017 Rockville, MD

AD HOC WORKING GROUP ON HERBAL MEDICINAL PRODUCTS

COMPENDIUM OF MONOGRAPHS NATURAL HEALTH PRODUCTS DIRECTORATE

USP Guideline for Submitting Requests for Revision to USP NF SUBMISSION GUIDELINE FOR NON-BOTANICAL DIETARY SUPPLEMENTS TABLE OF CONTENTS

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP)

Guideline on the use of the CTD format in the preparation of a registration application for traditional herbal medicinal products 1

H e r b a l M e dicines' Q U A L I T Y M ANUAL. I. Introduction

Guideline on the use of the CTD format in the preparation of a registration application for traditional herbal medicinal products 1

MEDICNES CONTROL AGENCY GUIDELINE FOR REGISTRATION OF HERBAL MEDICINAL PRODUCTS IN THE GAMBIA

INTERNATIONAL CONFERENCE ON HARMONISATION OF TECHNICAL REQUIREMENTS FOR REGISTRATION OF PHARMACEUTICALS FOR HUMAN USE

HOMEOPATHIC MEDICINAL PRODUCT WORKING GROUP (HMPWG) DRAFT (12/08) POINTS TO CONSIDER ON STABILITY TESTING OF HOMEOPATHIC MEDICINAL PRODUCTS

Agenda. The current state of Pharmaceutical Excipients in Japan -JPE, JP, DMF, GAB (GMP Auditing Board)- Pharmaceutical Excipients

Cross Contamination & the EU GMP Guide. Bryan J Wright July 2017

INTERNATIONAL CONFERENCE ON HARMONISATION OF TECHNICAL REQUIREMENTS FOR REGISTRATION OF PHARMACEUTICALS FOR HUMAN USE

INTERNATIONAL CONFERENCE ON HARMONISATION OF TECHNICAL REQUIREMENTS FOR REGISTRATION OF PHARMACEUTICALS FOR HUMAN USE

USP botanical quality standards: contributions in quality control & safe use of botanicals

WHITE PAPER ACCESS TO GOOD QUALITY DIETARY SUPPLEMENTS

Guideline on quality of herbal medicinal products 2 /traditional herbal medicinal products

Recognized Pharmacopoeia in Registration system

Guideline on quality of herbal medicinal products 1 /traditional herbal medicinal products

Pharmacopeial Perspectives on Vitamin Analysis

US FDA Process Validation Guidance. Presented by Marc Fini 21 May, 2013

No comments were received for the following proposals:

Regulation of Genotoxic and Carcinogenic Impurities in

COMMISSION REGULATION (EU)

EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL. EudraLex The Rules Governing Medicinal Products in the European Union

E11(R1) Addendum to E11: Clinical Investigation of Medicinal Products in the Pediatric Population Step4

Type II variation. Public Assessment Report for the suspension of. Palfium 5 mg tablets. (dextromoramide) NL License RVG: 03170

Risk Assessment in Drug Development (or How much of compound X is safe? ) (EYP 2006) Colin Fish

Kazuhiko Mori Ministry of Health, Labour and Welfare

Guidance on Limits of Foreign Matter in Herbal Ingredients

THE NON PENICILLIN BETA LACTAM DRUG CROSS CONTAMINATION PREVENTION; USFDA PERSPECTIVE

Discussion by HMPC Drafting Group on Quality September Start of public consultation 15 February 2013

Good pharmacopoeial practices: Chapter on monographs on herbal medicines

Prof. Marina Heinonen University of Helsinki Member of the NDA Panel and EFSA s WG on Novel Foods

Discussion by HMPC Drafting Group on Quality February Start of public consultation 27 June 2012

The International Pharmacopoeia - Overview

contents of the currently official monograph. Please refer to the current edition of the USP NF for official text.

Official Journal of the European Union L 109/11

REGULATION concerning Marketing Authorisations for Natural Medicinal Products and Registration of Traditional Herbal Medicinal Products, No. 142/2011.

Discussion at the HMPC January March Draft agreed by Quality Working Party April Adoption by CHMP for release for consultation 26 May 2005

Pharmaceutical Manufacturer Perspective - GPhA

Formulation stability studies. 9.1 OBJECTIVE To monitor the stability of the developed herbal formulations using the limited and specific methods.

KEY DIFFERENCES BETWEEN THE NEW MEDICAL DEVICE AND THE OTC REGULATIONS IN EUROPE

Disclosure. Objectives. Objectives. Introduction. Introduction. Non-Sterile Compounding/Calculations

Analytical method validation. Presented by Debbie Parker 4 July, 2016

CODE OF STATUTES MEDICAL PRODUCTS AGENCY

European Medicines Agency Inspections

ICH M4E(R2): Revised Guideline on Common Technical Document -- Efficacy

Requirements to the Registration of Medicinal products in the Republic of Armenia

ANDA Labeling Question Based Review September 11, 2013 GPhA/FDA ANDA Labeling Workshop/USP User Forum

Indian Pharmacopoeia Commission

FOOD AND DRUGS AUTHORITY (FDA) GHANA

Fang-Chi Chang (M.D.,Ph.D.) Center for Drug Evaluation, Taiwan

Legal Requirements for the Control of Contaminants in Herbal Medicinal Products and Related Areas

Emanuela Turla Scientific Officer Nutrition Unit - EFSA

EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL. EudraLex The Rules Governing Medicinal Products in the European Union

This revision also necessitates a change in the table numbering in the test for Organic Impurities.

Guidance for Industry

OLIN CORPORATION SALES SPECIFICATION

The EU PIP - a step in Pediatric Drug Development. Thomas Severin Bonn,

The State Pharmacopoeia of the Russian Federation

USP Chewable Gels Monographs

Use of Bridging Justifications to Support the Safety of Excipients in Generic Drug Products

Food additives. FAO guidelines on the structure and content of the document called "Chemical and Technical Assessment (CTA)" Rome, February 2003

Module 34: Legal aspects, ADI and GRAS status of food additives

(Legislative acts) REGULATIONS

The European Union CD 1999/83/EEC on well-established use

QUALITY OF HERBAL MEDICINAL PRODUCTS: PRESENT REQUIREMENTS

EUROPEAN COMMISSION HEALTH AND FOOD SAFETY DIRECTORATE-GENERAL VOLUME 2C. Guidelines. Medicinal products for human use

VICH GL58 Stability Testing of New Veterinary Drug Substances and Medicinal Products in Climatic Zones III and IV

The role of JECFA for CCFA

A Modern Approach to Excipient Quality Assurance

HOMEOPATHIC MEDICINAL PRODUCT WORKING GROUP (HMPWG)

Sterility Assurance and Risk Management: A CDER Microbiologist s Perspective

Co-processed Excipient Guide

COMPLETION OF THE CTD IN APPLICATION FOR A COMPLEMENTARY MEDICINE

Work plan for the joint CHMP/ CVMP Quality Working Party (QWP) for 2018

AGREEMENT ON COMMON PRINCIPLES AND RULES OF CIRCULATION OF MEDICINAL PRODUCTS WITHIN THE EURASIAN ECONOMIC UNION. (Moscow, 23 December 2014)

Transcription:

Overview of USP General Chapters <476> and <1086> Prescription/Non-Prescription Stakeholder Forum October 19, 2017

Introduction Periodic review of existing general chapters Typically an approximately 5 year cycle Evaluate currency of information Review changes in regulations or Health Authority expectations Identify any potential gaps in standards Chapters already present in USP providing guidance for impurities <197> Spectrophotometric Identification Tests <231> Heavy Metals <232> Elemental Impurities-Limits <233> Elemental Impurities-Procedures <466> Ordinary Impurities <1086> Impurities in Drug Substances and Drug Products Gap identified in standard: Potential new chapter <476> Control of Organic Impurities in Drug Substances and Drug Products (developed and concepts introduced in PF) Periodic review of <1086> as well as questions received post-publication suggested a need for revision. A focused survey to stakeholders confirmed the support to harmonized the impurities policy with ICH Q3A/B

Chapters development: <476> and <1086> Link to advanced copies of <476> and <1086> : http://www.uspnf.com/notices/gc-476-1086

Revised <476> and New <1086> Promotes a Science based approach Current regulatory guidance documents and sound scientific principles may be used to control the level of impurities. A threshold-based approach described in ICH Q3A/B is used for the reporting/identification/qualification of impurities. Higher thresholds may be applied if scientifically justified. Lower thresholds may be appropriate for highly toxic impurity. Considerations for Highly Toxic Impurities (e.g. Genotoxic) included For impurities known or suspected to be highly toxic (e.g., genotoxic), the quantitation/detection limit of the analytical procedures should be commensurate with the acceptance criteria. Highly toxic (e.g., genotoxic) impurities or degradation products shall be addressed using applicable guidelines (e.g. ICH M7) 4

New General Chapter <476> Control of Organic Impurities in Drug Substances and Drug Products - Update

Objectives <476> and <1086> to be published in PF 43(6) Address public comments received from previous publication in PF. As part of a permanent ongoing process. Aligned requirements in <476> with proposed revisions to <1086> Impurities in Drug Substances and Drug Products that were proposed as part of the monograph modernization initiative. Aligned the proposed USP standard with current scientific and regulatory best practices and expectations for the appropriate control of organic impurities in drug substances and drug products. Intended to provide a science-based approach for the control of impurities in relevant monographs to ensure product quality and safety Intent is to have drug substance and drug product include a cross reference to this chapter in the organic impurities section, where appropriate on a case-by-case basis, during the monograph modernization initiative.

Strategic changes/concepts included in <476> Significant revisions were included based on extensive review with internal and external groups and prior public comments from PF 41(3) Included internal USP alignment with Chemical Medicines EC, OTC EC, USP lab staff and Biologics Collaborative Group Input from Stakeholders groups and FDA have been incorporated Discussion of specific limits moved from <1086> to <476> Recommended limits aligned with ICH Q3A & B have been included in <476> References to specific handling of potential genotoxic impurities are included in <476> Justification of levels aligned with ICH M7

Revisions of General Chapter <1086> Impurities in Drug Substances and Drug Products and final proposed General Chapter <476> Control of Organic Impurities in Drug Substances and Drug Products

<476> Scope This chapter covers drug substances and drug products marketed in United States based on approval by the FDA either via NDA, ANDA or OTC Does not cover veterinary, peptides, biological or biotechnological, oligonucleotides, fermentation products or semisynthetic, polymorphic forms, radiopharmaceuticals, herbal and crude products of animal or plant origin Introduces the following limits: Reporting Threshold Disregard Limit (some monographs have this designated with the phrase do not report for levels below this limit) Identification Threshold Any Unspecified Impurity or Unspecified Degradation Product Qualification Threshold Specified Impurity or Specified Degradation Product 9

<476> Thresholds for Drug Substances Table 1. ICH Recommended Thresholds for Impurities in Drug Substances Impurity Thresholds Maximum daily dose 2 g 2 g Reporting 0.05% O,03% Identification 0.10% (1.0mg) a 0.05% Qualification 0.15% (1.0 mg) a 0.05% a The total daily intake in parentheses applies if it is lower than the calculated value Organic impurities in drug substances arising from the manufacturing process and or storage should be controlled (from process impurities) A rationale for the inclusion or exclusion of impurities in the specification (at release and through shelf life) should be presented Higher threshold may be applied if scientifically justified Lower threshold may be applied if the impurity is unusually toxic For OTC drug products, total daily intake is based upon the manufacturer's recommended labeled dosage per day. 10

<476> Thresholds for Drug Products Table 2. ICH Recommended Thresholds for Impurities in Drug Products Maximum daily dose <1 mg 1 to 10 mg Degradation Product Thresholds 10 mg >10 to 100 mg >100 mg to 1 g >1 to 2 g a Whichever is lower, calculated value or Total Daily Intake (TDI) >2 g Reporting 0.1% 0.1% 0.1% 0.1% 0.1% 0.05% 0.05% Identification 1.0% or 5 µg 0.5% or 20 µg 0.5% or 20 µg 0.2% or 2 mg 0.2% or 2 mg 0.2% or 2 mg 0.10% Qualification 1.0% or 50 µg 1.0% or 50 µg 0.5% or 200 µg 0.5% or 200 µg 0.2% or 3 mg 0.2% or 3 mg 0.15% Organic impurities in drug products arising from the manufacturing process and/or storage of the drug product should be controlled. Manufacturers should provide rationale and supporting data to justify the acceptance criteria 11

<1086> Decision Tree Decision tree provides guidance for impurities in drug substances and drug products 12

Manufacturers responsibilities in <1086> and <476> Manufacturer s Responsibilities in General Chapter <1086>: If a new impurity is detected above the appropriate identification threshold or when the level of a specified related compound increases as compared to its characteristic impurity profile, the manufacturer is responsible for evaluating the impact on the safety and efficacy of the drug substance or drug product. For marketed products, the manufacturers are responsible for controlling organic impurities in accordance with current regulatory standards. Manufacturer s Responsibilities in General Chapter <476>: If an individual monograph is inadequate to control does not include a procedure for quantifying an impurity or acceptance criterion for an observed impurity, the manufacturer is responsible for developing and validating appropriate analytical procedures and establishing appropriate acceptance criteria. Manufacturers shall validate or verify, as appropriate analytical procedures must demonstrate their suitability for the detection and quantitation of impurities in the drug substances and drug products Manufacturers shall develop acceptance criteria for impurities justified by appropriate safety considerations and consistent with current applicable regulatory guidances. 13

<476> Acceptance Criteria The acceptance criteria for drug substances and drug products include the following, where applicable: Each specified identified impurity Each specified unidentified impurity Any unspecified impurity with an acceptance criterion of NMT the identification threshold Total impurities 14

Next steps Pursue inclusion of specific organic tests rather than referencing <466> Ordinary Impurities Use the OTC Initiative to address many challenges Examples: proposed <321> Drug Product Assay Tests-Organic Chemical Medicines and <327> Drug Product Impurities Tests to establish procedures for known impurities by categories/families of OTC products published in PF 41(1) Evaluating a new proposal to introduce cross references to <476> in monographs, on a case by case basis, as appropriate Possible tool to control any individual unspecified impurity Approach would be similar to the European Pharmacopeia Review and consolidate public comments from publication in 43(6) Expert Committee to prepare recommendations for revisions to the General Notices for consideration by the Expert Council 5.60. Impurities and Foreign Substances 5.60.10. Other Impurities in USP and NF Articles

Backup information

Related General Notices - to be revised 5.60. Impurities and Foreign Substances Tests for the presence of impurities and foreign substances are provided to limit such substances to amounts that are unobjectionable under conditions in which the article is customarily employed (see also Impurities in Drug Substances and Drug Products 1086 ). Nonmonograph tests and acceptance criteria suitable for detecting and controlling impurities that may result from a change in the processing methods or that may be introduced from external sources should be employed in addition to the tests provided in the individual monograph, where the presence of the impurity is inconsistent with applicable good manufacturing practices or good pharmaceutical practices.

Related General Notices - to be revised 5.60.10. Other Impurities in USP and NF Articles If a USP or NF monograph includes an assay or organic impurity test based on chromatography, other than a test for residual solvents, and that monograph procedure does not detect an impurity present in the substance, the amount and identity of the impurity, where both are known, shall be stated in the labeling (certificate of analysis) of the official substance, under the heading Other Impurity(ies). The presence of any unlabeled other impurity in an official substance is a variance from the standard if the content is 0.1% or greater. The sum of all Other Impurities combined with the monograph-detected impurities may not exceed 2.0% (see Ordinary Impurities 466 ), unless otherwise stated in the monograph. The following categories of drug substances are excluded from Other Impurities requirements: Fermentation products and semi-synthetics derived therefrom, Radiopharmaceuticals, Biologics, Biotechnology-derived products, Peptides, Herbals, and Crude products of animal or plant origin. Any substance known to be toxic shall not be listed under Other Impurities.