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Support for FDA Regulations on Genotoxic

            Impurities in Pharmaceuticals


            Genotoxicity is the property of a compound that can have   At the end of 2008, the FDA issued a draft guidance,
            irreversible effects on the structure and functionality of the   "Genotoxic and Carcinogenic Impurities in Drug Substances
            DNA in cells and cause DNA loss, DNA replication errors,   and Products: Recommended Approaches." These
            mutations, and chromosomal abnormalities. Addressing the   guidelines establish and apply the Threshold of
            issue of genotoxicity is one of the most important   Toxicological Concern (TTC) to genotoxic impurities in the
            safety-related issues during the development of new   pharmaceutical ingredients. The TTC indicates the
            pharmaceuticals.                                    acceptable daily intake that presents no genetic risk to
            The International Conference on Harmonization (ICH)   humans below this threshold. It is effectively an estimated
            guidelines indicated threshold values for general   safety value such that the risk of developing cancer
            impurities. However, the guidelines do not prescribe   throughout the person’s life does not exceed one in a
            numeric values for the genotoxicity of impurities, but   million. It defines the acceptable daily intake as 1.5 μg
            rather note comments such as "However, analytical   max., assuming that the person takes the drug over 12
            procedures should be developed for those potential   months. (Table 1)
            impurities that are expected to be unusually potent,
            producing toxic or pharmacological effects at a level not   For example, for a daily dose of 30 mg, the acceptable
            more than (≤) the identification threshold." or "Lower   daily intake concentration of the impurity is given by:
            thresholds can be appropriate if the impurity is unusually   Concentration Limit (ppm) = TTC (μg/day)/Dose (g/day) =
            toxic."                                             1.5 (μg/day)/0.03 (g/day) = 50 x 10-6 (= 50 ppm).
                                                                Compared to the impurity value in the previous ICH
                                                                guidelines, this demands higher detection sensitivity for
                                                                the analysis of ultra-trace impurities.

                             Table 1 Permitted Values for Genotoxic and Mutagenic Impurities Under the FDA Draft Guidelines

                                                  Clinical trial period and exposure permitted value

               Administration   Shorter than   14 days to   1 month to     3 to          6 to       Longer than
                  period         14 days      1 month       3 months     6 months      12 months     12 months
              Threshold values
                                   120           60            20           10             5            1.5
                   (μg)
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