Residue Chemistry Studies for Veterinary Drugs. Human Food Safety Assessment. Presentation Topic. Improving residue chemistry submissions

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Residue Chemistry Studies for Veterinary Drugs Julia A. Oriani, Ph.D. Food and Drug Administration Center for Veterinary Medicine Division of Human Food Safety Human Food Safety Assessment Risk = Hazard x Exposure Toxicology and Microbial Food Safety: identify and characterize the risk of potential adverse health effects Residue Chemistry assess the exposure and mitigate any identified hazard by controlling the exposure with assignment of tolerance and withdrawal period Microbial Food Safety Toxicology Residue Chemistry Presentation Topic Improving residue chemistry submissions Focus on tissue residue depletion study for withdrawal period calculation 1

Tissue Residue Depletion Study - Objective is to establish the withdrawal period Conduct a residue depletion study under field conditions Use the regulatory method to measure marker residues in edible tissues Determine how long it takes the marker residues to deplete to below the tolerance Before conducting depletion study! First establish: ADI marker residue tolerance target tissue validated analytical method (LOQ < tolerance) Definition of Residue: Any compound present in the edible tissues after treatment with the drug. Includes parent drug, metabolites, and any substance formed in or on food. The definition is broad enough to include resistant bacteria. 2

Edible Tissues: Muscle Liver Kidney Fat/Skin Milk Eggs Definitions of Tolerance and Withdrawal Period Tolerance legal safety limit for residues in edible tissues of food animals Withdrawal Period the amount of time between last treatment of the food animal and when residues have depleted to below the tolerance. Two Parts for Tissue Residue Depletion Study 1. In-Life Portion Market size animals dosed under field (or field-like) conditions - according to proposed label (highest dose, longest duration) - sample animals at timepoints after drug is withdrawn -GLP-like 2. Analytical Phase collect and analyze tissues for residue concentrations -GLPs 3

Tissue Residue Depletion Study Critical! GLP Compliance Statement Deviations from GLP Critical! Quality Assurance Statement Dates and Type of Inspection Critical! Protocol Amendments In-Life Portion Animal Information Study Animals Numbers Breed or species or strain Males/females Health Records Critical! Records of any prior drug treatments Age Critical! Weight - Were animals weighed close to the start of dosing period? - Appropriate weight for market size 4

In-Life Portion Housing/Feed Critical! Description of housing does it mimic commercial conditions? (individually or group housed, pen size, light/dark cycle, air flow, etc.) Feed composition and analyzed for contaminants Water analyzed for contaminants Environmental conditions (daily temperatures, etc) Critical! Acclimation Period - enough information to demonstrate that animals aren t stressed and are eating normally prior to test period 5

In-Life Portion Dosing Information Test Material certificate of analysis Route of Administration Medicated feed Drinking water Injectable product Intramammary infusion Added directly to holding tank (fish) In-Life Portion Dosing Information Critical! How was dose prepared? SOP follow? Description of how medicated feed was mixed, syringes were filled, or medicated water prepared 6

In-Life Portion Dosing Information Critical! Verify concentration in dosage form before dosing animals For medicated feeds, provide mixing records, demonstration of homogeneity, sampling records Analysis Critical! Provide documentation that animals were dosed correctly In-Life Portion Sample Collection Slaughter of animals at various timepoints after dosing period follows protocol Critical! Obtain residue data around the tolerance on linear portion of depletion curve. Critical! Values must be >LOQ to be used for the withdrawal calculation Method of slaughter SOPs Critical! Doesn t interfere with analysis of test material Tissues collected SOPs Critical! Correct sample size Critical! Document handling of tissue samples from collection through analysis End of In-Life Phase of Study 7

Analytical Phase Analytical lab facility Analysis of tissues for drug residues - SOPs Storage stability of drug in tissues Critical! Demonstrate stability if samples are stored longer than 1 week may be a separate study 8

Analytical Phase Critical! Demonstrate that method is performing successfully prior to analyzing test samples may be a separate study provide validation data Critical! Provide method performance data for analysis of test samples Provide standard curve preparation Provide representative chromatograms 9

Provide residue data for individual animals, means, and standard deviation Concentrations in rainbow trout muscle/skin exposed to 17.8 mg/ml for 60 minutes at 17 C. Withdrawal Time (hours) 0 0.5 1 Concentration (ppm) 61.4 41.0 47.0 38.6 54.8 50.4 32.4 20.6 28.1 34.7 16.9 26.0 19.7 11.0 14.9 14.0 11.5 20.8 Mean ± standard deviation 48.9±8.5 26.5±6.8 15.3±4.1 Residue concentrations <LOQ can t be used for withdrawal period calculation 100.0 Drug Concentration 10.0 Actual Residue Values 0.1 99 th Percentile with 95% Confidence Tolerance 1 2 3 4 Withdrawal Time (days) 5 6 10

ppm Depletion of flumequine from rainbow trout muscle and skin 16 14 12 10 Muscle 8 Skin 6 4 2 0 0 days 1 day 3 days 7 days 15 days Time (days) Depletion of malachite green from rainbow trout muscle and skin ppm 3 2.5 2 1.5 1 0.5 0 0.25 hours 0.5 hours Time (hours) 1 hour 13 hours 25 hours 73 hours 145 hours 241 hours 337 hours 505 hours Muscle Skin Depletion of tulathromycin residues (CP-600,300) from swine and cattle tissues 4.5 4 3.5 ppm 3 2.5 2 1.5 1.5 0 0 5 10 15 20 25 30 35 40 time (days) Swine Liver Swine Kidney Cattle Liver Cattle Kidney 11

Key Issues Were animals acclimated adequately? Dose accountability Was dosage form prepared properly? Did each animal receive the intended dose? Was chain of custody documented: collection of tissues, initial preparation of tissues, shipment to lab, storage of tissues until analysis? Key Issues (continued) Was method validated prior to analyzing test samples? Were method performance data provided for analysis of test samples? Were an adequate number of residue concentrations generated on terminal portion of depletion curve? julia.oriani@fda.hhs.gov 12