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48 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
Nitrosamine Impurities in Drug Substances and
Drug Products
Dr. Tabrez Shaikh1*
, Dr. Amit Gosar2
, Dr. Hussain Sayyed3
1,2
Researcher, Indoco Research Centre, Analytical research & development, Navimumbai,
Maharashtra, India
1,3
Researcher, Sir Sayyed College, Department of Chemistry, Aurangabad, Maharashtra,
India
INFO
Corresponding Author:
E-mail Id: *tabrezs@indoco.com
DOI: 10.5281/zenodo.3629095
Cite as:
Dr. Tabrez Shaikh, Dr. Amit Gosar, &
Dr. Hussain Sayyed. (2020).
Nitrosamine Impurities in Drug
Substances and Drug Products.
Journal of Advances in Pharmacy
Practices (e-issn: 2582-4465), 2(1),
48–57.
http://doi.org/10.5281/zenodo.362909
5
ABSTRACT
Nitrosamine impurities are known to be mutagenic and
carcinogenic, very small exposure of these impurities
can lead to cancer. These impurities may be formed and
get incorporated into drug substance or drug product
through reagent, catalyst, solvent or raw materials used
in the process of manufacturing. The various regulatory
authority has published the press release or notice
regarding the control of these impurities with the
interim limit. Nitrosamine impurities can be avoided by
taking precaution in the manufacturing of drug
substance and drug products. Validated analytical
methods are to be used to identify and quantify these
impurities hence it needs highly sensitive instrument
which can detect these impurities to the trace level at
given interim limit. Liquid chromatography or Gas
chromatography, along with mass detector is majorly
used for their determination.
Keywords: Classification, drug substances, drug
product, impurities, nitrosamine and guidelines
INTRODUCTION
Food and drug administration (FDA) and
European Medicines Agency (EMA) in
July 2018 announced that a carcinogenic
impurities N-Nitrosodimethylamine
(NDMA) and N-Nitrosodiethylamine
(NDEA) are said to be present in generic
drug substances and drug product,
especially in angiotensin II receptor
blockers (ARBs) or ‘Sartans’class
medicines which are used to treat patients
with hypertension (high blood pressure)
and heart failure (Fig.1). This
announcement leads to voluntarily recall
hundreds of batches of these generic
versions by pharmaceutical distributor
worldwide [1-3]. Further, the FDA and
EMA investigation in year 2019 led to the
detection of these Nitrosamine impurities
in Pioglitazone used for the treatment of
diabetes and Ranitindine an H2
(histamine-2) blocker used for the
treatment of acidity of the stomach.
Presently, low level of NDMA impurity
found in Metformin also brought this drug
under FDA and EMA investigations.
ICH M7 (R1) classifies Nitrosamine
impurities as Class 1, which is known to
be mutagenic and carcinogenic, based on
49 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
both rodent carcinogenicity and
mutagenicity data. These Nitrosamine
impurities impact the genetic material by
means of mutations through chromosomal
breaks, rearrangements, covalent binding or
insertion into the DNA during replication.
These changes in the genetic materials caused
by the exposure to very low levels of
Nitrosamine impurities can lead to cancer [4-
6]. Thus, it is important to identify
Nitrosamine impurities in drugs at very low
levels to ensure safety to the public.
Figure 1: Structure of sartans drug.
SOURCES OF NITROSAMINE
IMPURITIES
Nitrosamine impurities can get
incorporated into the drug substance and
drug product basically through process
formation, direct introduction,
degradation or cross-contamination.
Manufacturing of drug substances
involves raw material, intermediates,
solvents, chemicals and reagents [7-9].
Through these stages, if this impurity is
formed or present it may get
incorporated and carried forwarded to
drug product as shown in (Fig.2).
Figure 2: Sources of Nitrosamine impurities.
50 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
1. Primary, secondary, tertiary amines or
quaternary ammonium salts along with
nitrosating agents such as Sodium
nitrite are considered to be precursors
for the generation of Nitrosamines
impurities. Similarly, carbamate,
amides and N-alkyl amides if
nitrosated may form Nitrosamine
impurities. The extent of Nitrosamine
impurity formation depends mainly on
the type of reagent, their structure and
the concentration of the nitrosating
agent. Secondary amines are
considered to be more reactive (Fig.3).
2. Recovered solvents and catalysts used
in the process may cause a risk for
Nitrosamine formation. As these
solvents or catalysts are treated with
sodium nitrite or nitric acid in order to
destroy residual azide which may lead
to the formation of Nitrosamine
impurities.
3. Contaminated starting material or raw
material supplied by the vendor may
introduce the Nitrosamine impurities in
drug substance or drug product.
4. Cross-contamination between different
manufacturing processes and products
on the same production line may lead
to contamination of Nitrosamine
impurities. A process where nitrosating
reagents are not used may still be
contaminated through the presence of
nitrite in the water used in the
manufacturing process.
5. Trace amount of these impurities may
be formed due to decomposition of
solvent or other materials used in the
synthesis of drug substances.
Similarly, by-products formed in the
drug synthesis process may get be
carried forward to the drug substances
as Nitrosamine impurities. Solvents
such as Dimethylformamide,
Dimethylacetamide (DMF) or
Diethylacetamide (DEA) may form
potential NDMA and NDEA
impurities (Fig.3).
6. Use of certain packaging materials for
finished product may for Nitrosamine
impurities. According to one
hypothesis the packing material lidding
foil containing nitrocellulose, printing
primer may react with amines in
printing ink to form Nitrosamines
impurities, which may get transferred
to the drug product.
Figure 3: Formation of Nitrosamine impurities.
Experts suggest that the NDMA impurity in
Valsartan could have come from sodium
nitrite, which is used to expel remaining
sodium azide reagent. Under the acidic
condition, nitrite ion forms nitrous acid,
which then could react with trace amounts of
dimethylamine, a degradation product of the
solvent Dimethylformamide (DMF). Fig. 3
51 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
shows the formation of impurities in drug
synthesis. Some of the secondary amine and
their corresponding Nitrosamine impurities
formed are tabulated below in Table-1.
Table 1: Amines and corresponding Nitrosamine impurities.
Amines Corresponding Nitrosamine impurities
Dimethylamine N-nitrosodimethylamine (NDMA)
Diethylamine N-nitrosodiethylamine (NDEA)
Dipropylamine N-nitrosodipropylamine (NDPA)
Diisopropylamine N-nitrosodiisopropylamine (NDIPA)
Dibutylamine N-nitrosodibutylamine (NDBA)
Ethylmethylamine N-nitrosomethylethylamine (NMEA)
4-(methylamino)butanoic acid N-nitroso-N-methyl-4-aminobutyric acid (NMBA)
REGULATORY PERSPECTIVE
Food Drug Administration (FDA)
In June 2018, FDA was informed by one
of valsartan drug substances manufacture
about the presence of an impurity,
identified as N-Nitrosodimethylamine
(NDMA). Further investigation by the
FDA found out that other Nitrosamine
impurities, e.g., N-Nitrosodiethylamine
(NDEA) were also present at unacceptable
levels in drug substances from multiple
drug substances manufacturer of valsartan
and other drugs in the ARB class. As there
was no acceptable limit in the specification
for Nitrosamines, as an initial measure, the
FDA published “interim acceptable limits”
for these Nitrosamine impurities in ARB
drugs. Drug substances and drug product
exceeding these limit levels were
recommended to recall the drug product
from the market. The FDA advised that
drug product manufacturers, that they
should test the samples of each drug
product batch or drug substances lot used
for the drug product manufacture for the
US market to determine whether it has
contain a detectable amount of
Nitrosamine impurities. FDA has also
published validated methods to detect and
quantify NDMA and NDEA impurities in
all ARB drug substances and some drug
products [10].
European Medicines Agency (EMA)
EMA first initiated Nitrosamine impurities
investigation in July, 2018 and found out
that sartan-containing medicines are
contaminated with Nitrosamine impurities,
which leads to recall of several drug
products and come under review by the
European Union (EU), thus it set strict
new manufacturing requirements for these
medicines.
Earlier in January, 2019 the EMA
recommended that companies making
sartan medicines review their
manufacturing processes so that
Nitrosamine impurities cannot be formed.
Companies were given a transition period
to make necessary changes during which
strict temporary limits on levels of these
impurities were applied. After this period
companies will have to demonstrate that
their sartan products have a safe level for
these impurities before they can be used in
the EU. The EMA noted that in the vast
majority of sartan medicines, impurities
were either not found or were present at
very low levels. The EMAs Committee for
Medicinal Products for Human Use
(CHMP) will provide guidance on
avoiding the presence of Nitrosamine
impurities to marketing authorization
holders, which they should consider
alongside their knowledge of the
manufacturing processes of their products
[11].
Other Regulatory Agency
Therapeutic Goods Administration (TGA)
of Australia made advice in a public notice
that it has introduced requirements for
52 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
sponsors of 'sartan' blood pressure
medicines to take measures to avoid the
presence of Nitrosamine impurities in
medicines and implement rigorous testing
of their medicines to identify the presence
of any Nitrosamine impurities. The TGA
provides a two year transition period
(2019-2021) to allow sponsors to review
and if necessary make changes to their
manufacturing processes and to implement
adequate testing methods. During the
transition period sponsors must inform the
TGA if they identify the presence of
Nitrosamine compounds in their
medicines. Changes to manufacturing
processes and/or controls if needed should
be lodged as a 'category 3' request under
section 9D (3) of the Therapeutic Goods
Act 1989 (the Act). The TGA Laboratories
has adapted a publically available US-
FDA test method. Health Canada
continues to hold manufacturers
responsible for the safety and effectiveness
of drugs sold on the Canadian market and
has taken several actions to mitigate the
risk to Canadian. Health Canada continues
to work closely with international
regulatory partners including the FDA and
the EMA to share information and
coordinate efforts on inspections, risk
assessments and public communications.
Health Canada has provided a method that
has been developed to detect and quantify
the Nitrosamine impurities NDMA and
NDEA in angiotensin II receptor blockers
(ARBs) [12-13].
LIMITS AND ACCEPTABLE
INTAKE
Nitrosamine impurities are classified as
Class-1 impurities as per ICH guidelines
due to its known carcinogenicity and
mutagenicity. For the calculation of its
limit, the median toxic dose TD50 (Shows
toxicity in 50% cases) is used. The TD50
is the well-accepted by ICH M7 (R1) for
the calculation of the acceptable excess
risk to calculate acceptable intake (AI) for
mutagenic and carcinogenic impurities and
it is a well-recognized international
standard.
The TD50 value reported for NDMA is
0.096 mg/kg/day for the most sensitive
species rat [5].
The extrapolation to the excess risk level
for cancer is calculated by linear back
extrapolation to the dose theoretically
causing a 1:100,000 risk by dividing the
TD50 by 50,000 (50% or 0.5 x 100,000).
For NDMA this translates into a dose of
1.92 ng/kg/day. For a person with a
bodyweight of 50 kg, this would result in
an AI level of 96 ng/day (50 x 1.92 ng).
Similarly, for NDEA, it comes out to be
26.5 ng/day. Following ICH M7 (R1)
guideline, FDA has calculated limit for
NDMA and NDEA impurities in various
sartans drug as tabulated below in Table 2.
Through this procedure, the limit for
Nitrosamine impurities in any drug
substance or drug product can be
calculated. FDA and EMA have made
clear that these are interim limits [14-15].
Table 2: Limit for NDMA & NDEA in sartans drugs.
Active substance
(max daily dose)
NDMA NDEA
AI ng/day Limit (ppm) AI ng/day Limit (ppm)
Candesartan (32 mg)
96.0
3.000
26.5
0.820
Irbesartan (300 mg) 0.320 0.088
Losartan (150 mg) 0.640 0.177
Olmesartan (40 mg) 2.400 0.663
Valsartan (320 mg) 0.300 0.082
53 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
REVIEW OF THE
MANUFACTURING PROCESS
The European Medicines Agency (EMA)
has issued templates for marketing
authorization holders to use when filing
results of product testing for Nitrosamine
contamination. The following steps are
required by the manufacturer to control the
assessment of Nitrosamine in human
medicinal products [16].
Step I. Risk evaluation
The marketing authorisation holder along
with drug substance and drug product
manufacturer should perform a risk
evaluation of Nitrosamine as per ICH Q9
and ICH M7 guidelines within six months
(Notice publication 26 September, 2019).
The risk evaluation should be conducted in
a priority manner i.e. the highest
probability of contamination should be
evaluated first. Authorities must be
informed about the evaluation results. If a
risk of potential contamination has been
detected, the marketing authorisation
holder should proceed to go to step 2 as
below.
Step II. Confirmatory testing
After risk evaluation, confirmatory testing
activity should start immediately. A
product with high-risk must analytically be
tested first as soon as possible for
Nitrosamine impurities using validated
methods having appropriately sensitive.
Similarly, confirmatory testing of all the
concerned drug product should be
concluded at the latest within three years
of the publication of the notification or
otherwise justified. If Nitrosamine is
detected, the competent authorities are to
be informed immediately, irrespective of
the amount detected.
Step III. Changes to the marketing
authorisation
Changes to the marketing authorisation
such as a change in the manufacturing
process of a drug substance or drug
product specifications are to be applied in
a timely manner. If there is a risk to public
health the competent authorities must be
informed immediately. All steps must be
completed within three years in a
prioritised manner.
AVOIDING NITROSAMINE
CONTAMINATION
All amine along with nitrosating agents are
considered to be antecedent in the
generation of Nitrosamines impurities in
the drug substance or drug products. Thus,
the following precautions may lead to
minimize these impurities in human
medicinal products [17].
1) Nitrosamines impurities are formed
when nitrites or other nitrosating
agents react with the secondary or
tertiary amine or quaternary
ammonium salts are used within the
same or different steps of the
manufacturing process of drug
substances. Thus avoiding the use of
these reagents can prevent Nitrosamine
impurity formation.
2) Many of Nitrosamine impurities get
purged out with the solvent. If these
solvents are recovered and reused,
there may be a chance of
reintroduction of these impurities in
the drug synthesis process. Therefore,
use of recovered solvent should be
avoided in the manufacturing process.
Similarly, recovered catalyst may
contaminate the drug with Nitrosamine
impurities if reused.
3) Contaminated raw material,
intermediate and reagents used in drug
substance manufacturing are also the
potential source of Nitrosamine
impurities. The degradation product of
raw materials and intermediate on
storage in the presence of traces of
nitrites may lead to the formation of
Nitrosamine impurities. Hence, these
materials should be properly stored and
tested for Nitrosamine impurities.
4) Equipment used for the manufacturing
54 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
of drugs substances may be cross-
contaminated with Nitrosamine
impurities due to previous products.
Equipment should be properly cleaned
and checked for contamination.
5) The drug substances manufacturer
should test and check the carryover of
Nitrosamine impurities in various
intermediate stages and if it is present,
it should be controlled with the proper
limit.
6) The manufacturer should modify the
process to purge out amines, nitrites
and Nitrosamine impurities at various
stages. Control strategies should be
implemented to detect and control
Nitrosamine impurities in intermediate
or drug substances.
Overall, it can be concluded that
Nitrosamines in finished products can be
very effectively controlled by selecting the
synthesis path which minimizes the
formation of these impurities and also
observing implementing strict GMP
requirements such as cleaning of
equipments and control of the recovery
process for solvents may also lead to
remove and limit the Nitrosamine
impurities in drug substance and drug
product.
ANALYTICAL METHODS
The development of analytical methods to
determine Nitrosamines impurities is the
challenging task due to very low levels of
impurities present in the complex matrices.
The developed methods also need to be
validated to conform to GMP
requirements. Several methods have been
published by the FDA to cover NDMA
and NDEA in different 'sartans'. The EMA
has indicated the extension of measures to
include more Nitrosamines.
Other regulatory authorities (Canada,
Switzerland and Singapore) have adopted
their own measures and published
analytical methods. Most of the methods
used for testing of Nitrosamines in drug
substance and drug product utilize the
chromatographic techniques such as
reversed-phase liquid chromatography
(LC) or gas chromatography (GC)
combined with various detectors such as
mass spectrometry (MS), Ultraviolet
spectrophotometry (UV) or nitrogen
chemiluminescence (NCD) etc. [18-20].
European network of Official Medicines
Control Laboratories (OMCLs) has
developed methods for the testing of
specific Nitrosamines in sartans on the
basis of different analytical principles. The
Irish OMCL in the Public Analyst’s
Laboratory in Galway (PALG), the French
OMCL at the ANSM site in Montpellier,
the Chemisches and Veterinär-
Untersuchungsamt (CVUA) Karlsruhe as
well as the LGL Bayern established
analytical methods for quantification of
Nitrosamine on behalf of the network.
Additionally, the U.S. FDA, Health
Canada and Swissmedic have published
methods for the simultaneous
determination of Nitrosamine. Some of
these methods are tabulated below in
Table-3.
Table 3: Published analytical methods for testing Nitrosamine impurities.
Method Technique Ionisation Impurity Sample
FDA
GC-MS (DI) Triple quad NDMA, NDEA, Valsartan
(DS and DP)GC-HS-MS Quadrupole NDMA, NDEA
LC-MS/MS HR / Triple Quad NDMA Ranatidine (DS and DP)
PALG GC-HS-MS Single Quad NDMA Sartans (DS and DP)
ANSM HPLC-UV Not applicable NDMA, NDEA Sartans (DS and DP)
CVUA UPLC-MS/MS APCI NDMA, NDEA Sartans (DS and DP)
Health Canada GC-MS/MS EI NDMA, NDEA Sartans (DS and DP)
Swissmedic GC-MS EI NDMA, NDEA Sartans (DS and DP)
LGL
GC-HS-MS EI/CI NDMA, NDEA Sartans (DS)
LC-MS/MS Q-trap NDMA, NDEA Sartans (DS and DP)
55 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
These published testing methods serve as a
starting point for the development and
validation of analytical methods,
appropriate for other drug substance and
drug products. The FDA says that these
methods should be validated by the user if
the resulting data are used to support a
required quality assessment of the API or
drug product or if the results are used in a
regulatory submission.
Gas Chromatography
Gas chromatography along with mass
spectrometry (GC-MS) is the most
frequently employed technique for the
determination of Nitrosamines with lower
molecular weight. The majority of recent
publications employ GC-MS, GC–MS/MS
or GC-HS-MS technique due to its high
selectivity and low detection limit. The
FDA has developed and validated a
combined GC-HS-MS method for the
simultaneous evaluation of four
Nitrosamine impurities in Valsartan drug
substance and drug products, these
impurities are N-nitrosodimethylamine
(NDMA), N-nitrosodiethylamine (NDEA),
N-nitrosodiisopropylamine (NDIPA), and
N-nitrosoethylisopropylamine (NEIPA).
This method meets all the requirements of
current regulations with sensitivity and
repeatability and exceed the expected
requirements of the control limits. GC-
TEA (Thermal energy analyser) also
provides high selectivity for Nitrosamines.
The high molecular weight Nitrosamines
are rather labile molecules and it is
impossible to determine by GC.
Liquid Chromatography
LC technique offers a faster alternative to
the traditional GC-MS methods. The use
of high-resolution accurate mass
spectrometry helps to obtain good
selectivity for the detection of both GC-
detectable and GC-undetectable
compounds along with thermally stable
and unstable Nitrosamines. The FDA has
observed that the GC-MS method for
testing ARBs of Nitrosamine impurities is
not suitable for testing ranitidine because
heating the sample generates NDMA. An
LC-HRMS method was subsequently
developed by the FDA to measure the
levels of NDMA in ranitidine drug
substance and drug product following ICH
Q2 (R1). The limit of detection (LOD) is
0.011ppm, limit of quantitation (LOQ) is
0.033 and the range of the method is 0.033
– 3.33ppm. In addition, several methods
using liquid chromatography-mass
spectrometry (LC-MS) or LC-MS/MS
have been reported in the scientific
literatures. However, only a few studies
have reported for NDMA analysis using
conventional high-performance liquid
chromatography (HPLC), especially in the
drugs. HPLC is the most popular technique
for quality control of APIs and products in
routine analysis and it is preferable if
NDMA impurity is simultaneously
detected with drug substances by a single
HPLC analysis. Thus, it is important to
develop a fast and simple analytical
method for NDMA in drugs by using
HPLC.
ANALYTICAL METHOD
DEVELOPMENT
The basic task for the development of an
analytical method for Nitrosamine
impurities is to develop the method which
can detect these impurities at very trace
levels and well below the TTC. Various
advanced and sophisticated techniques
should be employed for their detection.
The developed analytical method should
have less variability by conducting a series
of controlled experiments thus to make
quality and safe drug products. As global
regulatory, requirements have gone more
stringent and analytical methods for global
products must be able to meet all the
regulatory requirements. Method
development is a continuous process
where the goal is to consistently improve
the quality of the product [21].
56 Page 48-57 © MAT Journals. All Rights Reserved
Journal of Advances in Pharmacy Practices
e-ISSN: 2582-4465
Volume 2 Issue 1
ANALYTICAL METHOD
VALIDATION
A very general definition of validation is
establishing documented evidence which
provides a high degree of assurance that a
specific procedure, process, equipment,
activity or system will consistently
produce a product meeting its
predetermined specifications and quality
attributes. Validation is an important
feature after the development of any
analytical method because it is closely
related to the quality of the results. All
analytical methods, whether qualitative or
quantitative are required to be validated.
The degree of validation varies for the type
of method and its application. For several
years now method validation studies,
guidelines and procedures have focused
mainly on quantitative methods of
analysis. Validation is an imperative
activity in the process of impurities
profiling where the developed analytical
method used for the determination of
genotoxic impurities in drug substances is
validated in order to establish that the
method is suitable for its aimed purpose.
The analytical methods are validated with
specificity, linearity, precision, accuracy,
ruggedness, robustness and forced
degradation parameters in accordance with
ICH Harmonized Tripartite Guidelines
[22-23].
CONCLUSION
Highly mutagenic and carcinogenic
Nitrosamine impurities need to limit it to
the acceptable limit in drug substances and
drug products. Potential sources of
Nitrosamine impurities such as raw
material, reagent, catalyst, solvents and
cross-contamination used in manufacture
should be identified to control it in drug
substances. Medicine regulatory
authorities such as FDA, EMA, TGA and
Health Canada have published several
public notices to guide the manufacturer to
control and limit these impurities to
acceptable intake levels. Regulatory
authorities have also issued the templates
for marketing authorities to assess the
Nitrosamine impurities in human
medicinal products. Nitrosamine impurity
formation can be avoided by selecting
proper reagent, catalyst and solvents in the
manufacturing of drug substances. The
analytical method used for the
determination and quantification of
Nitrosamine impurities is by GC or LC
using mass spectroscopy. These methods
should be well developed and validated as
per ICH guidelines to determine these
impurities upto very low levels.
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EMA/189634/2019.
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take to avoid nitrosamines in human
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u, EMA/511347/2019.
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nitrosamines”, J. of pharma. and
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Method Development Strategy for
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22. Hussain, S., Gosar, A., & Shaikh, T.
(2018). Impurity profiling in
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23. Chang Chau Chan, Lee Y.C, Harman
Lam, Xui Ming Zhang (2004),
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978-0-471-25953-4

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Nitrosamine impurities in drug substances and drug products-format

  • 1. 48 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 Nitrosamine Impurities in Drug Substances and Drug Products Dr. Tabrez Shaikh1* , Dr. Amit Gosar2 , Dr. Hussain Sayyed3 1,2 Researcher, Indoco Research Centre, Analytical research & development, Navimumbai, Maharashtra, India 1,3 Researcher, Sir Sayyed College, Department of Chemistry, Aurangabad, Maharashtra, India INFO Corresponding Author: E-mail Id: *tabrezs@indoco.com DOI: 10.5281/zenodo.3629095 Cite as: Dr. Tabrez Shaikh, Dr. Amit Gosar, & Dr. Hussain Sayyed. (2020). Nitrosamine Impurities in Drug Substances and Drug Products. Journal of Advances in Pharmacy Practices (e-issn: 2582-4465), 2(1), 48–57. http://doi.org/10.5281/zenodo.362909 5 ABSTRACT Nitrosamine impurities are known to be mutagenic and carcinogenic, very small exposure of these impurities can lead to cancer. These impurities may be formed and get incorporated into drug substance or drug product through reagent, catalyst, solvent or raw materials used in the process of manufacturing. The various regulatory authority has published the press release or notice regarding the control of these impurities with the interim limit. Nitrosamine impurities can be avoided by taking precaution in the manufacturing of drug substance and drug products. Validated analytical methods are to be used to identify and quantify these impurities hence it needs highly sensitive instrument which can detect these impurities to the trace level at given interim limit. Liquid chromatography or Gas chromatography, along with mass detector is majorly used for their determination. Keywords: Classification, drug substances, drug product, impurities, nitrosamine and guidelines INTRODUCTION Food and drug administration (FDA) and European Medicines Agency (EMA) in July 2018 announced that a carcinogenic impurities N-Nitrosodimethylamine (NDMA) and N-Nitrosodiethylamine (NDEA) are said to be present in generic drug substances and drug product, especially in angiotensin II receptor blockers (ARBs) or ‘Sartans’class medicines which are used to treat patients with hypertension (high blood pressure) and heart failure (Fig.1). This announcement leads to voluntarily recall hundreds of batches of these generic versions by pharmaceutical distributor worldwide [1-3]. Further, the FDA and EMA investigation in year 2019 led to the detection of these Nitrosamine impurities in Pioglitazone used for the treatment of diabetes and Ranitindine an H2 (histamine-2) blocker used for the treatment of acidity of the stomach. Presently, low level of NDMA impurity found in Metformin also brought this drug under FDA and EMA investigations. ICH M7 (R1) classifies Nitrosamine impurities as Class 1, which is known to be mutagenic and carcinogenic, based on
  • 2. 49 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 both rodent carcinogenicity and mutagenicity data. These Nitrosamine impurities impact the genetic material by means of mutations through chromosomal breaks, rearrangements, covalent binding or insertion into the DNA during replication. These changes in the genetic materials caused by the exposure to very low levels of Nitrosamine impurities can lead to cancer [4- 6]. Thus, it is important to identify Nitrosamine impurities in drugs at very low levels to ensure safety to the public. Figure 1: Structure of sartans drug. SOURCES OF NITROSAMINE IMPURITIES Nitrosamine impurities can get incorporated into the drug substance and drug product basically through process formation, direct introduction, degradation or cross-contamination. Manufacturing of drug substances involves raw material, intermediates, solvents, chemicals and reagents [7-9]. Through these stages, if this impurity is formed or present it may get incorporated and carried forwarded to drug product as shown in (Fig.2). Figure 2: Sources of Nitrosamine impurities.
  • 3. 50 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 1. Primary, secondary, tertiary amines or quaternary ammonium salts along with nitrosating agents such as Sodium nitrite are considered to be precursors for the generation of Nitrosamines impurities. Similarly, carbamate, amides and N-alkyl amides if nitrosated may form Nitrosamine impurities. The extent of Nitrosamine impurity formation depends mainly on the type of reagent, their structure and the concentration of the nitrosating agent. Secondary amines are considered to be more reactive (Fig.3). 2. Recovered solvents and catalysts used in the process may cause a risk for Nitrosamine formation. As these solvents or catalysts are treated with sodium nitrite or nitric acid in order to destroy residual azide which may lead to the formation of Nitrosamine impurities. 3. Contaminated starting material or raw material supplied by the vendor may introduce the Nitrosamine impurities in drug substance or drug product. 4. Cross-contamination between different manufacturing processes and products on the same production line may lead to contamination of Nitrosamine impurities. A process where nitrosating reagents are not used may still be contaminated through the presence of nitrite in the water used in the manufacturing process. 5. Trace amount of these impurities may be formed due to decomposition of solvent or other materials used in the synthesis of drug substances. Similarly, by-products formed in the drug synthesis process may get be carried forward to the drug substances as Nitrosamine impurities. Solvents such as Dimethylformamide, Dimethylacetamide (DMF) or Diethylacetamide (DEA) may form potential NDMA and NDEA impurities (Fig.3). 6. Use of certain packaging materials for finished product may for Nitrosamine impurities. According to one hypothesis the packing material lidding foil containing nitrocellulose, printing primer may react with amines in printing ink to form Nitrosamines impurities, which may get transferred to the drug product. Figure 3: Formation of Nitrosamine impurities. Experts suggest that the NDMA impurity in Valsartan could have come from sodium nitrite, which is used to expel remaining sodium azide reagent. Under the acidic condition, nitrite ion forms nitrous acid, which then could react with trace amounts of dimethylamine, a degradation product of the solvent Dimethylformamide (DMF). Fig. 3
  • 4. 51 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 shows the formation of impurities in drug synthesis. Some of the secondary amine and their corresponding Nitrosamine impurities formed are tabulated below in Table-1. Table 1: Amines and corresponding Nitrosamine impurities. Amines Corresponding Nitrosamine impurities Dimethylamine N-nitrosodimethylamine (NDMA) Diethylamine N-nitrosodiethylamine (NDEA) Dipropylamine N-nitrosodipropylamine (NDPA) Diisopropylamine N-nitrosodiisopropylamine (NDIPA) Dibutylamine N-nitrosodibutylamine (NDBA) Ethylmethylamine N-nitrosomethylethylamine (NMEA) 4-(methylamino)butanoic acid N-nitroso-N-methyl-4-aminobutyric acid (NMBA) REGULATORY PERSPECTIVE Food Drug Administration (FDA) In June 2018, FDA was informed by one of valsartan drug substances manufacture about the presence of an impurity, identified as N-Nitrosodimethylamine (NDMA). Further investigation by the FDA found out that other Nitrosamine impurities, e.g., N-Nitrosodiethylamine (NDEA) were also present at unacceptable levels in drug substances from multiple drug substances manufacturer of valsartan and other drugs in the ARB class. As there was no acceptable limit in the specification for Nitrosamines, as an initial measure, the FDA published “interim acceptable limits” for these Nitrosamine impurities in ARB drugs. Drug substances and drug product exceeding these limit levels were recommended to recall the drug product from the market. The FDA advised that drug product manufacturers, that they should test the samples of each drug product batch or drug substances lot used for the drug product manufacture for the US market to determine whether it has contain a detectable amount of Nitrosamine impurities. FDA has also published validated methods to detect and quantify NDMA and NDEA impurities in all ARB drug substances and some drug products [10]. European Medicines Agency (EMA) EMA first initiated Nitrosamine impurities investigation in July, 2018 and found out that sartan-containing medicines are contaminated with Nitrosamine impurities, which leads to recall of several drug products and come under review by the European Union (EU), thus it set strict new manufacturing requirements for these medicines. Earlier in January, 2019 the EMA recommended that companies making sartan medicines review their manufacturing processes so that Nitrosamine impurities cannot be formed. Companies were given a transition period to make necessary changes during which strict temporary limits on levels of these impurities were applied. After this period companies will have to demonstrate that their sartan products have a safe level for these impurities before they can be used in the EU. The EMA noted that in the vast majority of sartan medicines, impurities were either not found or were present at very low levels. The EMAs Committee for Medicinal Products for Human Use (CHMP) will provide guidance on avoiding the presence of Nitrosamine impurities to marketing authorization holders, which they should consider alongside their knowledge of the manufacturing processes of their products [11]. Other Regulatory Agency Therapeutic Goods Administration (TGA) of Australia made advice in a public notice that it has introduced requirements for
  • 5. 52 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 sponsors of 'sartan' blood pressure medicines to take measures to avoid the presence of Nitrosamine impurities in medicines and implement rigorous testing of their medicines to identify the presence of any Nitrosamine impurities. The TGA provides a two year transition period (2019-2021) to allow sponsors to review and if necessary make changes to their manufacturing processes and to implement adequate testing methods. During the transition period sponsors must inform the TGA if they identify the presence of Nitrosamine compounds in their medicines. Changes to manufacturing processes and/or controls if needed should be lodged as a 'category 3' request under section 9D (3) of the Therapeutic Goods Act 1989 (the Act). The TGA Laboratories has adapted a publically available US- FDA test method. Health Canada continues to hold manufacturers responsible for the safety and effectiveness of drugs sold on the Canadian market and has taken several actions to mitigate the risk to Canadian. Health Canada continues to work closely with international regulatory partners including the FDA and the EMA to share information and coordinate efforts on inspections, risk assessments and public communications. Health Canada has provided a method that has been developed to detect and quantify the Nitrosamine impurities NDMA and NDEA in angiotensin II receptor blockers (ARBs) [12-13]. LIMITS AND ACCEPTABLE INTAKE Nitrosamine impurities are classified as Class-1 impurities as per ICH guidelines due to its known carcinogenicity and mutagenicity. For the calculation of its limit, the median toxic dose TD50 (Shows toxicity in 50% cases) is used. The TD50 is the well-accepted by ICH M7 (R1) for the calculation of the acceptable excess risk to calculate acceptable intake (AI) for mutagenic and carcinogenic impurities and it is a well-recognized international standard. The TD50 value reported for NDMA is 0.096 mg/kg/day for the most sensitive species rat [5]. The extrapolation to the excess risk level for cancer is calculated by linear back extrapolation to the dose theoretically causing a 1:100,000 risk by dividing the TD50 by 50,000 (50% or 0.5 x 100,000). For NDMA this translates into a dose of 1.92 ng/kg/day. For a person with a bodyweight of 50 kg, this would result in an AI level of 96 ng/day (50 x 1.92 ng). Similarly, for NDEA, it comes out to be 26.5 ng/day. Following ICH M7 (R1) guideline, FDA has calculated limit for NDMA and NDEA impurities in various sartans drug as tabulated below in Table 2. Through this procedure, the limit for Nitrosamine impurities in any drug substance or drug product can be calculated. FDA and EMA have made clear that these are interim limits [14-15]. Table 2: Limit for NDMA & NDEA in sartans drugs. Active substance (max daily dose) NDMA NDEA AI ng/day Limit (ppm) AI ng/day Limit (ppm) Candesartan (32 mg) 96.0 3.000 26.5 0.820 Irbesartan (300 mg) 0.320 0.088 Losartan (150 mg) 0.640 0.177 Olmesartan (40 mg) 2.400 0.663 Valsartan (320 mg) 0.300 0.082
  • 6. 53 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 REVIEW OF THE MANUFACTURING PROCESS The European Medicines Agency (EMA) has issued templates for marketing authorization holders to use when filing results of product testing for Nitrosamine contamination. The following steps are required by the manufacturer to control the assessment of Nitrosamine in human medicinal products [16]. Step I. Risk evaluation The marketing authorisation holder along with drug substance and drug product manufacturer should perform a risk evaluation of Nitrosamine as per ICH Q9 and ICH M7 guidelines within six months (Notice publication 26 September, 2019). The risk evaluation should be conducted in a priority manner i.e. the highest probability of contamination should be evaluated first. Authorities must be informed about the evaluation results. If a risk of potential contamination has been detected, the marketing authorisation holder should proceed to go to step 2 as below. Step II. Confirmatory testing After risk evaluation, confirmatory testing activity should start immediately. A product with high-risk must analytically be tested first as soon as possible for Nitrosamine impurities using validated methods having appropriately sensitive. Similarly, confirmatory testing of all the concerned drug product should be concluded at the latest within three years of the publication of the notification or otherwise justified. If Nitrosamine is detected, the competent authorities are to be informed immediately, irrespective of the amount detected. Step III. Changes to the marketing authorisation Changes to the marketing authorisation such as a change in the manufacturing process of a drug substance or drug product specifications are to be applied in a timely manner. If there is a risk to public health the competent authorities must be informed immediately. All steps must be completed within three years in a prioritised manner. AVOIDING NITROSAMINE CONTAMINATION All amine along with nitrosating agents are considered to be antecedent in the generation of Nitrosamines impurities in the drug substance or drug products. Thus, the following precautions may lead to minimize these impurities in human medicinal products [17]. 1) Nitrosamines impurities are formed when nitrites or other nitrosating agents react with the secondary or tertiary amine or quaternary ammonium salts are used within the same or different steps of the manufacturing process of drug substances. Thus avoiding the use of these reagents can prevent Nitrosamine impurity formation. 2) Many of Nitrosamine impurities get purged out with the solvent. If these solvents are recovered and reused, there may be a chance of reintroduction of these impurities in the drug synthesis process. Therefore, use of recovered solvent should be avoided in the manufacturing process. Similarly, recovered catalyst may contaminate the drug with Nitrosamine impurities if reused. 3) Contaminated raw material, intermediate and reagents used in drug substance manufacturing are also the potential source of Nitrosamine impurities. The degradation product of raw materials and intermediate on storage in the presence of traces of nitrites may lead to the formation of Nitrosamine impurities. Hence, these materials should be properly stored and tested for Nitrosamine impurities. 4) Equipment used for the manufacturing
  • 7. 54 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 of drugs substances may be cross- contaminated with Nitrosamine impurities due to previous products. Equipment should be properly cleaned and checked for contamination. 5) The drug substances manufacturer should test and check the carryover of Nitrosamine impurities in various intermediate stages and if it is present, it should be controlled with the proper limit. 6) The manufacturer should modify the process to purge out amines, nitrites and Nitrosamine impurities at various stages. Control strategies should be implemented to detect and control Nitrosamine impurities in intermediate or drug substances. Overall, it can be concluded that Nitrosamines in finished products can be very effectively controlled by selecting the synthesis path which minimizes the formation of these impurities and also observing implementing strict GMP requirements such as cleaning of equipments and control of the recovery process for solvents may also lead to remove and limit the Nitrosamine impurities in drug substance and drug product. ANALYTICAL METHODS The development of analytical methods to determine Nitrosamines impurities is the challenging task due to very low levels of impurities present in the complex matrices. The developed methods also need to be validated to conform to GMP requirements. Several methods have been published by the FDA to cover NDMA and NDEA in different 'sartans'. The EMA has indicated the extension of measures to include more Nitrosamines. Other regulatory authorities (Canada, Switzerland and Singapore) have adopted their own measures and published analytical methods. Most of the methods used for testing of Nitrosamines in drug substance and drug product utilize the chromatographic techniques such as reversed-phase liquid chromatography (LC) or gas chromatography (GC) combined with various detectors such as mass spectrometry (MS), Ultraviolet spectrophotometry (UV) or nitrogen chemiluminescence (NCD) etc. [18-20]. European network of Official Medicines Control Laboratories (OMCLs) has developed methods for the testing of specific Nitrosamines in sartans on the basis of different analytical principles. The Irish OMCL in the Public Analyst’s Laboratory in Galway (PALG), the French OMCL at the ANSM site in Montpellier, the Chemisches and Veterinär- Untersuchungsamt (CVUA) Karlsruhe as well as the LGL Bayern established analytical methods for quantification of Nitrosamine on behalf of the network. Additionally, the U.S. FDA, Health Canada and Swissmedic have published methods for the simultaneous determination of Nitrosamine. Some of these methods are tabulated below in Table-3. Table 3: Published analytical methods for testing Nitrosamine impurities. Method Technique Ionisation Impurity Sample FDA GC-MS (DI) Triple quad NDMA, NDEA, Valsartan (DS and DP)GC-HS-MS Quadrupole NDMA, NDEA LC-MS/MS HR / Triple Quad NDMA Ranatidine (DS and DP) PALG GC-HS-MS Single Quad NDMA Sartans (DS and DP) ANSM HPLC-UV Not applicable NDMA, NDEA Sartans (DS and DP) CVUA UPLC-MS/MS APCI NDMA, NDEA Sartans (DS and DP) Health Canada GC-MS/MS EI NDMA, NDEA Sartans (DS and DP) Swissmedic GC-MS EI NDMA, NDEA Sartans (DS and DP) LGL GC-HS-MS EI/CI NDMA, NDEA Sartans (DS) LC-MS/MS Q-trap NDMA, NDEA Sartans (DS and DP)
  • 8. 55 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 These published testing methods serve as a starting point for the development and validation of analytical methods, appropriate for other drug substance and drug products. The FDA says that these methods should be validated by the user if the resulting data are used to support a required quality assessment of the API or drug product or if the results are used in a regulatory submission. Gas Chromatography Gas chromatography along with mass spectrometry (GC-MS) is the most frequently employed technique for the determination of Nitrosamines with lower molecular weight. The majority of recent publications employ GC-MS, GC–MS/MS or GC-HS-MS technique due to its high selectivity and low detection limit. The FDA has developed and validated a combined GC-HS-MS method for the simultaneous evaluation of four Nitrosamine impurities in Valsartan drug substance and drug products, these impurities are N-nitrosodimethylamine (NDMA), N-nitrosodiethylamine (NDEA), N-nitrosodiisopropylamine (NDIPA), and N-nitrosoethylisopropylamine (NEIPA). This method meets all the requirements of current regulations with sensitivity and repeatability and exceed the expected requirements of the control limits. GC- TEA (Thermal energy analyser) also provides high selectivity for Nitrosamines. The high molecular weight Nitrosamines are rather labile molecules and it is impossible to determine by GC. Liquid Chromatography LC technique offers a faster alternative to the traditional GC-MS methods. The use of high-resolution accurate mass spectrometry helps to obtain good selectivity for the detection of both GC- detectable and GC-undetectable compounds along with thermally stable and unstable Nitrosamines. The FDA has observed that the GC-MS method for testing ARBs of Nitrosamine impurities is not suitable for testing ranitidine because heating the sample generates NDMA. An LC-HRMS method was subsequently developed by the FDA to measure the levels of NDMA in ranitidine drug substance and drug product following ICH Q2 (R1). The limit of detection (LOD) is 0.011ppm, limit of quantitation (LOQ) is 0.033 and the range of the method is 0.033 – 3.33ppm. In addition, several methods using liquid chromatography-mass spectrometry (LC-MS) or LC-MS/MS have been reported in the scientific literatures. However, only a few studies have reported for NDMA analysis using conventional high-performance liquid chromatography (HPLC), especially in the drugs. HPLC is the most popular technique for quality control of APIs and products in routine analysis and it is preferable if NDMA impurity is simultaneously detected with drug substances by a single HPLC analysis. Thus, it is important to develop a fast and simple analytical method for NDMA in drugs by using HPLC. ANALYTICAL METHOD DEVELOPMENT The basic task for the development of an analytical method for Nitrosamine impurities is to develop the method which can detect these impurities at very trace levels and well below the TTC. Various advanced and sophisticated techniques should be employed for their detection. The developed analytical method should have less variability by conducting a series of controlled experiments thus to make quality and safe drug products. As global regulatory, requirements have gone more stringent and analytical methods for global products must be able to meet all the regulatory requirements. Method development is a continuous process where the goal is to consistently improve the quality of the product [21].
  • 9. 56 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 ANALYTICAL METHOD VALIDATION A very general definition of validation is establishing documented evidence which provides a high degree of assurance that a specific procedure, process, equipment, activity or system will consistently produce a product meeting its predetermined specifications and quality attributes. Validation is an important feature after the development of any analytical method because it is closely related to the quality of the results. All analytical methods, whether qualitative or quantitative are required to be validated. The degree of validation varies for the type of method and its application. For several years now method validation studies, guidelines and procedures have focused mainly on quantitative methods of analysis. Validation is an imperative activity in the process of impurities profiling where the developed analytical method used for the determination of genotoxic impurities in drug substances is validated in order to establish that the method is suitable for its aimed purpose. The analytical methods are validated with specificity, linearity, precision, accuracy, ruggedness, robustness and forced degradation parameters in accordance with ICH Harmonized Tripartite Guidelines [22-23]. CONCLUSION Highly mutagenic and carcinogenic Nitrosamine impurities need to limit it to the acceptable limit in drug substances and drug products. Potential sources of Nitrosamine impurities such as raw material, reagent, catalyst, solvents and cross-contamination used in manufacture should be identified to control it in drug substances. Medicine regulatory authorities such as FDA, EMA, TGA and Health Canada have published several public notices to guide the manufacturer to control and limit these impurities to acceptable intake levels. Regulatory authorities have also issued the templates for marketing authorities to assess the Nitrosamine impurities in human medicinal products. Nitrosamine impurity formation can be avoided by selecting proper reagent, catalyst and solvents in the manufacturing of drug substances. The analytical method used for the determination and quantification of Nitrosamine impurities is by GC or LC using mass spectroscopy. These methods should be well developed and validated as per ICH guidelines to determine these impurities upto very low levels. REFERENCES 1. Antonis Manolis (April 26, 2019), “Carcinogenic Impurities in Generic Sartans: An Issue of Authorities’ Control or a Problem with Generics”, Rhythmos; Volume 14, Issue 2, pp.23- 26. DOI: 10.1021/cen-09708. 2. FDA Press Release (July, 2018), “FDA announces voluntary recall of several medicines containing valsartan following detection of an impurity,” APHA. 3. EMA Press Release (September 21, 2018), “Valsartan: Review of Impurities Extended to Other Sartan Medicines,” EMA, Available at https://www.ema.europa.eu. 4. Jennifer L. Caulfield (1997), “The chemistry of nitric oxide-induced deamination and cross-linking of DNA”, (Doctoral dissertation), Massachusetts Institute of Technology, pp. 1-153. 5. R. Nilsson (July, 2011), “The molecular basis for induction of human cancers by tobacco specific nitrosamines”, Regulatory Toxicology and Pharmacology, Volume 60, Issue 2, pp. 268-80. Available at https://doi.org/10.1016/j.yrtph.2011.02 .014. 6. Lijinsky W. Andrews AW. (October, 1983), “The superiority of hamster liver microsomal fraction for activating nitrosamines to mutagens in Salmonella typhimurium”, Mutation Research/Fundamental and Molecular Mechanisms of Mutagenesis. Volume
  • 10. 57 Page 48-57 © MAT Journals. All Rights Reserved Journal of Advances in Pharmacy Practices e-ISSN: 2582-4465 Volume 2 Issue 1 111, Issue 2, pp.135-144. DOI: 10.1016/0027-5107(83)90058-1. 7. Aloka Srinivasan (2019), “Proactive Evaluation of Possible Genotoxic Impurities during the Early Stages of Drug Development”, http://www.pharmtech.com. 8. G. Subba Rao (1980), “N- Nitrosarnines from drugs and nitrite: potential source of chemical carcinogens in humans”, Pharmacy International, Volume 1, pp. 187-190. 9. “Information on nitrosamines for marketing authorization holders”, European Medicines Agency, pp. 1-10, EMA/CHMP/428592/2019 Rev. 2. 10. U. S. Food and Drug Administration update (Jan 25, 2019), “Statement on the FDA’s ongoing investigation into valsartan and ARB class impurities and the agency’s steps to address the root causes of the safety issues”, https://www.fda.gov. 11. European Medicines Agency (Dec 2019), Questions and answers on “Information on nitrosamines for marketing authorization holders”, EMA/CHMP/428592/2019 Rev. 2 https://www.ema.europa.eu. 12. Therapeutic Goods Administration (TGA) (2019), “N-nitroso compounds in 'sartan' blood pressure medicines”, Available at https://www.tga.gov.au/node/881814. 13. Health Canada (2019), “Impurities found in certain angiotensin II receptor blocker (ARB) products, also known as sartans”. 14. U. S. Food and Drug Administration (February, 2019), “FDA update table of interim limits for nitrosamine impurities in ARBs”, from https://www.fda.gov. 15. European Medicines Agency (2019), “Temporary interim limits for NMBA, DIPNA and EIPNA impurities in sartan blood pressure medicines”, EMA/351053/2019 rev. 1. 16. European Medicines Agency (2019), “Information on nitrosamines for marketing authorization holders”, https://www.ema.europa.eu, EMA/189634/2019. 17. European Medicines Agency (2019), “EMA advises companies on steps to take to avoid nitrosamines in human medicines”, https://www.ema.europa.e u, EMA/511347/2019. 18. Agnes Shanley, FDA Press Release (August, 2018), “FDA Announces Preliminary GC/MS Headspace Method”. 19. EDQM Press Release, “OMCLs Release Three Methods for Determination of NDMA in Sartans,” https://www.ema.europa.eu. 20. Parr MK, Joseph JF (2019), “NDMA impurity in valsartan and other pharmaceutical products: Analytical methods for the determination of N- nitrosamines”, J. of pharma. and biomedical analysis. Volume 164, pp.536-49, Available at https://doi.org/10.1016/j.jpba.2018.11. 010. 21. Mingjiang Sun, David Q. Liu, Alireza S. Kord (2010), “A Systematic Method Development Strategy for Determination of Pharmaceutical Genotoxic Impurities”, Organic Process Research & Development. Volume 14, Issue 4, pp.977-985, Available at https://doi.org/10.1021/op100089p. 22. Hussain, S., Gosar, A., & Shaikh, T. (2018). Impurity profiling in pharmaceuticals: a review. World J Pharm Res, Volume 7, Issue 9, pp. 305-320. 23. Chang Chau Chan, Lee Y.C, Harman Lam, Xui Ming Zhang (2004), “Analytical method validation and instrument performance verification”, John Wiley and Sons. Pp. 320, ISBN: 978-0-471-25953-4