Dr. Saranjit Singh

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    Dr Saranjit SinghNational Institute of Pharmaceutical Education and Research

    SAS Nagar 160 062 India

    [email protected]

    Setting Impurity

    Standards for APIsand Dosage Forms:

    An IP Perspective

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    Indian Pharmacopoeia

    Available Edition: 1996Supplements: 2000, 2002 and 2005

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    Control of Impurities in

    IP 1996 and Supplements

    Tests for Related Substances

    Specific Tests for the Named Impurities General Tests for Unnamed Impurities

    Total Impurity limits

    Test Design and Expression of Limitsfor Known and Unknown Impurities

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    IP 1996

    Total number of monographs 1253

    Monographs with HPLC assay

    methods

    139

    Monographs with Test forRelated Substances

    448

    TLC methods 391

    HPLC methods 57

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    A Typical Example - TLC Method

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    Established: 9 December 2004

    Indian PharmacopoeiaCommission

    IPC

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    To bring new editions and supplementsof Indian Pharmacopoeia at regularintervals

    To accelerate the process ofpreparation, certification and

    distribution of IP reference substances

    To develop understanding withInternational Pharmacopoeial agencies

    Mandate ofIPC

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    To promote the highest standardsfor drugs for use in humans andanimals within practical limits of

    the technologies available formanufacture and analysis

    Vision Statement ofIPC(Adopted 8 July 2006)

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    ..practical limits oftechnologies available formanufacture and analysis?

    Why mention of:

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    Indian industry is fragmented

    into: Indian multinationals Large Companies Medium sized Small scale

    In total 5500 enterprises, withdifferences in technological capabilityfor manufacture and analysis

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    Regulatory laboratory set-up is

    also fragmented:

    Central Laboratories

    State Laboratories

    Approved Private Test Laboratories

    Presently differ in technological capability

    for analysis, though Central/StateLaboratories are being upgraded with samebrands of state-of-art sophisticated analyticalinstruments under Capacity Building Project

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    Other local compulsions

    Large population of the country ~1.2 billion

    Very low gross national income ~$620

    (US $41,400)

    390 millionlive on less than $1 a day

    Population below poverty line:25-29%

    80% of the health care payments borneby individuals

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    So important for the Government toensure continued supply of medicinesat an affordable cost

    Drug Name Price inIndia

    Price inPakistan

    Price inIndonesia

    Price inUS

    Ciprofoxacin500 mg (10s)

    29.00 423.86 393.00 2352.35

    Norfloxacin400mg (10s)

    20.70 168.71 130.63 1843.66

    Diclofenac50 mg (10s)

    3.50 84.71 59.75 674.77

    Source: OPPI website, 45 INR = 1$

    Price comparison of some well known drugs in INR

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    In this scenario

    The drug quality standards need to be

    rational, practical and simple

    The products sold in the countrypresently comply to standards laid

    down in Indian Pharmacopoeia1996, the monographs of which meetthe above requirements

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    The perspectives ofIPC

    on impurities inpharmaceuticals in futureeditions of compendia

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    To give special attention to the

    methods of manufacture used bythe indigenous industry in selectingthe pharmacopoeial tests for

    monitoring the toxicimpurities ofthe concerned drug.

    An objective ofIPC(Adopted 8 July 2006)

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    Basic decisions ofIPCon ImpuritiesMinimum change in existing monographs

    For new monographs, impurity control directed

    to be a part of Related Substances test

    Both TLC and HPLC methods acceptable

    Stringent limit, if an impurity is toxic and/or

    named impurity is to be controlled (e.g., N,N-dimethylalinine in cloxacillin sodium,

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    IPC to take care that Related Substances

    test in new monographs received fromindustry has no barrier element

    In all situations, the test must be

    possible in Government and PrivateLaboratories

    Other perspectives ofIPC

    on Impurities

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    The use of chromatographicmethods has been greatly extended

    to cope with the need for morespecificity in assays and in particular,in assessing the nature and extent of

    impurities in ingredients andproducts

    IP 2007: INTRODUCTION

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    IP 1996 versus 2007

    1996 2007Total number of

    monographs

    1253 1253 -13 +257= 1497

    Monographs with HPLCassay methods

    139 139+

    Monographs with test of

    Related Substances

    448 448+~100

    TLC methods 391 ~390

    HPLC methods 57 57+~100

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    IP 2007General Chapter on Impurities

    5.5 ImpuritiesThis chapter provides guidance on the control of impurities indrug substances and formulated preparations. It applies mainlyto totally synthetic organic medicinal substances and those

    substances obtained by synthetic modification of a naturally-produced precursor; it is not necessarily relevant to otherorganic substances e.g. those of plant or animal origin,biological and biotechnological products, inorganic substances

    and pharmaceutical excipients. It provides an approach to thesetting of limits for impurities in articles for which the individualmonographs do not provide either a test or specific limits.

    An impurity is defined as any component of a drug substancefor pharmaceutical use or of a drug product that is not the

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    Acceptance criteria for impurities in drugsubstances:

    Each identifiedspecified

    impurity

    Not more than 0.5 per cent

    Each unidentified impurity Not more than 0.3 per cent

    Total impurities Not more than 1.0 per cent

    Provided it has been determined that the impurities are nottoxic. Higher limits may be set if scientifically justified.

    General Chapter

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    Although a primary objective of thePharmacopoeia is to guarantee the

    identity, strength, purity and quality ofofficial articles, it is not possible toinclude in each monograph a test for

    every impurity or contaminant or evenan adulterant that might be present

    Viewpoints in the General Chapter

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    The exclusion of a limit for impurities in amonograph does not absolve the manufacturer ofproviding assurance to the user on the safety of a

    drug.

    It is incumbent on the manufacturer to follow goodmanufacturing practices (GMP) and to ensure thelimitation of impurities based on knowledge of theproperties of the chemical entity and the likelihoodof related substances being associated with theend product during production and subsequentstorage.

    Viewpoints in the General Chapter(cont..)

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    So, an overall perspective ofIPC

    CONTROL OF IMPURITIES is more strongerregulatory and GMP issue, than compendial

    So only reasonable control in IP, except forthose related substances that are known or

    even doubted to adversely influence safetyof the product

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    WhatIPCaspires for

    Information on impurities associated with

    side effects or toxic reactions, including

    genotoxicity, so that specific named tests

    can be added in existing or new monographs

    of Indian Pharmacopoeia

    Simple tests for these impurities

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    Current Dynamics

    of

    Indian

    Pharmaceutical

    Industry

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    Top Indian Companies Way Ahead

    Export oriented Indian companies, which haveworld class facilities, completely comply to

    stringent International regulatory

    expectations on impurities

    Some of the Indian companies have more

    than 600 HPLC systems, change 100 columns

    per day, and are equipped with mostsophisticated instruments, like LC-MS, LC-

    NMR, etc., which are being used for impurity

    profiling and structure characterization

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    An Example of Maturity of Indian Industry

    FDAnews Drug Daily Bulletin

    Nov. 16, 2007 | Vol. 4 No. 226

    Generic Firm Commences Gabapentin Recall Due to

    Excessive Impurities

    Ranbaxy Pharmaceuticals initiated a voluntary Class III recall of73 million gabapentin

    tabletsbecause the allowed level of impurities in the tablets exceeded their specification limits,

    according to FDA documents.

    Gabapentin is the active ingredient in Pfizers antiseizure drug Neurontin, which is off patent.

    The affected dosage strengths include the 600- and 800-mg tablets. Ranbaxys abbreviated newdrug application (ANDA) for the tablet formulation is for those two strengths and the firm holds

    approval for a capsule formulation as well.

    The company could not comment on whether the recall will create a shortage of its tablets.

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    A Few Distinct Advantages

    The drive of export-oriented Indian Pharmacompanies, to meet stringent quality and impurity

    control expectations of International agencies,

    has lead not only to creation of excellent facilities

    and trained manpower, it has been indirectlyresponsible for improvement of quality of

    pharmaceuticals sold within the country, as the

    same companies hold 70% share in the local

    market

    This is happening without intervention of

    local pharmacopoeial and regulatory

    agencies

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    The Benefit of Indian System

    as a Whole

    The Indian system encourages the big

    players, but it also protects mediumand small scale enterprises, which are

    very much needed in the chain of

    supply of drugs to large population ofthe country with marked differences in

    paying capacities

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    Summing up

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    For a country with >1.2 billion people

    The priority is

    AVAILABILITYof

    GOOD QUALITY DRUGS

    atAN AFFORDABLE COST

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    Our belief is

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    GOOD QUALITY

    of drugs and products can be well

    assured by recently adoptedapproach ofIPCon impurities

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    Somehow

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    We atIPCare not fully convincedon the trend in USP, EP, BP, etc. onsearching impurities in each and every

    product, even old and well established, atICH thresholds, which we consider is

    guided more by protectionist approach

    of big players in Pharmaceutical industry

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    A glimpse of emerging

    standards.

    E Ph i 5 0 2005

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    European Pharmacopoeia 5.0, 2005

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    EP 5.0(2005)(Ph Eur monograph 0906)

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    Moreover, a moot point.

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    If there is no emphasis on

    impurities in kilogram(s)and liters of food taken byan individual in a day

    Then how come it is aso serious issue for fewmilligrams of drug(s)

    consumed in a tiny pilldaily?

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    So overall,

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    1. There is a need to ponderwhether the forensic analysisof pharmaceuticals is all thatnecessary

    2. Something, which is real toxicand difficult for our bodies to

    handle, must be controlled butnot every type of minutiae

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    3. The compendia require innovative

    thinking, wherein impurities areclassified drug-wise as toxic andsafe, with emphasis only on those

    that might be harmful

    4. Compendia must pursue policy of

    exclusion rather than inclusion,unlike the trend being pursuedcurrently

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