CCK Discussion Forum on Impurity Emergence: A Wake Up Call for Drug Safety & Quality - 13 Oct 2019 at ICCBS, University of Karachi. Session largely participated by qualified and experienced pharmaceutical professionals having diversified educational background and experience.
3. Acknowledgment and thanks to
Anthony Fake, Theo Dekker, Rutendo Kawana & Lynda
Paleshnuik of World Health Organization
4. Most Common Abbreviations Used
• API – Active Pharmaceutical Ingredient
• FPP – Finished Pharmaceutical Product
• LOD – Loss on Drying
• PDE – Permitted daily exposure
• TDI – Total daily intake
• TTC – Threshold of Toxicological Concern
5. Focus
• Impurities and brief explanation – already given
• What are potential impurities
• What impurities actually occur
• When to specify impurities
• Setting Impurities limits
9. What potential impurities might be present,
based upon all available information.
This step is often poorly performed by
applicants.
There is a tendency to skip this step in
discussions and just adopt pharmacopoeial
specifications if a monograph exists.
What are the
potential impurities?
10. What potential impurities might be present,
based upon all available information.
This step is often poorly performed by
applicants.
There is a tendency to skip this step in
discussions and just adopt pharmacopoeial
specifications if a monograph exists.
What are the
potential impurities?
11. What potential impurities might be present,
based upon all available information.
This step is often poorly performed by
applicants.
There is a tendency to skip this step in
discussions and just adopt pharmacopoeial
specifications if a monograph exists.
What are the
potential impurities?
20. It is essential to have a detailed knowledge of the
Preparation of the API & the Controls placed upon the
API
Starting
Materials
Reaction
Inter-
mediates
Reagents Solvents
28. Impurities introduced
during manufacture
API degradation
products
API reaction by-
products
Determining most of the potential impurities does not require
a great deal of chemistry knowledge. Impurities can be
divided into:
29. These can be determined
from the detailed
manufacturing process
description
They are the solvents,
reagents, catalysts, residue
starting material, reaction
intermediates used in
manufacture
What impurities are introduced during manufacture?
30. These can be
determined from the
results of stress
studies.
Significant degradation
products should be
identified and treated
as potential impurities.
What are the possible degradation impurities?
36. API SM
Step 1
Step 3
Final API
Step 2
Chance
Chance of an impurity occurring
Step impurity is introduced
Enantiomers
37. Investigation of batch
analysis and long-
term stability data is
required.
Impurities present at
levels greater than the
ICH reporting
threshold should be
reported by the
manufacturer.
38. Potential impurities can be excluded
by either testing the final API or FPP,
or a relevant proceeding molecule.
Some pharmacopoeial impurities
may not be present if a different
manner of preparation,
(reagents, synthesis) is used.
39. For degradants, look to long-term
stability data.
The presence of an impurity under
accelerated conditions does not mean it
will appear under long-term conditions
40. If you are looking for an impurity using
a test method that can not detect the
impurity then you are wasting your
time.
Demonstrated specificity and
appropriate LOD/LOQs are important,
especially for genotoxins.
Analytical
methods
41. It is important for the manufacturer to
detail the methods used.
This is often not clear in submitted
dossiers if different test methods have
been used at different times.
Analytical
methods
44. Any impurity routinely observed in
batch data or long-term stability
trials should be controlled by the
impurity specifications
Organic
Impurities
45. Impurities observed below the ICH
identification threshold need not be
individually specified in the
specifications. They can be
controlled under the limit for any
unspecified impurity
Organic
Impurities
46. Impurities above the ICH
identification threshold need to be
identified and individually specified
in the specifications
Organic
Impurities
47. If a genotoxin is formed or is likely to be
formed during manufacture or storage then a
limit for this impurity should be included in
specifications
GENOTOXINS
48. If batch data (6 pilot or 3
production) demonstrate that levels
of the impurity are at or below 30%
of the allowable limit then non-
routine testing may be adopted. It
should still be specified
49.
50. For instance, if
methylsulphonic acid
and methanol were used
in the last step, but
methane
methylsulphonate was
not detected then it may
be appropriate to test
once annually.
51. For instance, if
methylsulphonic acid
and methanol were used
in the last step, but
methane
methylsulphonate was
not detected then it may
be appropriate to test
once annually.
If methylsulphonic acid
and methanol were used
in the first of three steps,
but methane
methylsulphonate was
not detected then it may
be appropriate to specify
the test is to be applied
when there is a change
in manufacture.
53. The limits must be qualified as
safe.
The limits should realistically
reflect batch and stability data.
54. Through toxicological trials.
By comparison to levels found in an innovator or prequalified FPP.
By comparison to a limit previously approved in a prequalified FPP. This
is a last resort.
If the impurity is greater than the ICH qualification
threshold then it should be qualified:
55. If the impurity is greater than the ICH
qualification threshold then it should be
qualified:
56. By comparison to a limit specified in the Ph.Int., Ph.Eur.,
or USP for a specific impurity. It could even be in a
monograph for another substance. A statement in a
monograph of "any other impurity NMT 0.5%" can not be
used as justification for an impurity limit, as it is not
specific
If the impurity is greater than the ICH
qualification threshold then it should be
qualified:
57. The limit for any
unspecified impurity
should be at the ICH
identification threshold.
The limit for total
impurity content should
reflect batch data.
61. Any component of the
medicinal product which
is not the chemical entity
defined as the active
substance or an excipient
of the product
Impurity
62. Any component of the
medicinal product which
is not the chemical entity
defined as the active
substance or an excipient
of the product
Impurity
An impurity for which
structural
characterisation has been
achieved
Identified Impurity
63. Any component of the
medicinal product which
is not the chemical entity
defined as the active
substance or an excipient
of the product
Impurity
An impurity defined
only by qualitative
properties e.g. Rt
Unidentified
Degradation Product
An impurity for which
structural
characterisation has been
achieved
Identified Impurity
66. If a manufacturer controls impurity
content in accordance with a pharmacopoeial monograph,
Can we accept the specifications?
Yes/No
67. Unfortunately NO
Monographs are developed based upon how the API was prepared
historically.
If a manufacturer controls impurity
content in accordance with a pharmacopoeial monograph,
Can we accept the specifications?
68. Remember
A particular manufacturing method may lead to unexpected
impurities, due to a different route of synthesis, different reagents,
etc.
If a manufacturer controls impurity
content in accordance with a pharmacopoeial monograph,
Can we accept the specifications?
71. Preparation and potency determination/specification of primary and
secondary (working) standards, with CoAs
Analytical methods with validation
Impurities to be characterised and limits set
Synthesis/ degradation according to Q3A(R) Residual solvents according to Q3C
Requires justification for proposed specifications
72. Impurities
Moisture content (or LOD: moisture + residual solvents)
Identification (at least one specific, e.g. IR spectrum)
Appearance/description
Typical set of specifications
73. Residual solvent(s)
Inorganic impurities, including
catalysts
Related organic substances (synthesis
degradation)
specified unspecified
total organic
impurities
Impurities
Additional parameters
important for specific API
such as particle size,
polymorphic form,
microbial limits
Assay
74. • The current monograph always applicable
• Additional critical specifications that are not included in
monograph e.g.
– Particle size & polymorphic form
– Synthesis related impurities resulting from specific
process which may be additional to monograph
– Residual solvents (specific to process)
CEP normally states tests additional to the monograph
– e.g. residual solvents & impurities