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A new generation of equipment will help generate products with less cost and effort, while being made more efficiently.
January 29, 2015
By: Emil W. Ciurczak
Independent Pharmaceuticals Professional
Whenever the U.S. Environmental Protection Agency (EPA) sets limits on trace contaminants, it is based on currently available technology. For example, when plasma emission spectroscopy became commercially available, the EPA was able to set far lower limits for heavy metals in food and water. Unfortunately, the U.S. FDA did not have science behind all of its Congressional oversight. The Food Additives Amendment of 1958 to the Pure Food and Drug Act, known as the Delaney amendment was intended to proscribe any proven cancer-causing additive form food and drugs sold in the U.S. Starting in 1959, the amendment was invoked for food colors, etc. as well as any chemical in drug products. It was later expanded to cover by-products and trace materials in a dosage form. Eventually, the law was interpreted to mean “zero” levels were allowed to be present, even though we can never prove the total absence of anything, merely the material was below our levels of detection. When I first started at Sandoz, we had a product in clinical trials. I noticed that one of the starting materials for the API resembled benzidine (4, 4’-diaminobiphenyl), a known carcinogen. I asked for and received an Ames test for potential carcinogens or mutagens; it came back as a mutagen. When I asked how we tested for its presence, I was told gas chromatography. Fine, only the limit for our test—mirroring the USP standard for unknown substances—was 0.1% or 1000 ppm. Despite the fact that the Delaney Amendment says “zero”, I knew we could do better. After a few weeks, I developed an ion exchange method with a LOD of <1ppm. Upon testing all the lots in clinic trials, we found between 10 and 50 ppm of the mutagen; the lots were pulled, of course. Since the synthesis and clean-up could not do better than 10ppm residual, the product was scrapped. What is the point of this story? Simply that we are still being asked to make measurements or control processes, often without the tools being available or so expensive as to not make a product worthwhile. Another example occurred in the early 1980s when the EMEA, now the EMA, or the European Medicines Agency, suggested that all incoming raw materials should be tested for identity; every container of every lot was to be opened, sampled, and its ID verified. Since the EP or USP tests were chemical and, sometimes a UV and/or IR spectrum, the tests could be quite involved and time-consuming. Well, in Europe the bulk of raw materials were delivered by rail car while, in the U.S., by trucks. That meant that, for our parent company in Basel, Switzerland, 200 kilograms of aspirin would require, at most, four containers; for us, in the U.S., it could mean at least 20 fiber drums. A shipment of lactose could easily contain 200-250 bags, and so on. Since we had just undergone a massive expansion of the QC department, my suggestion to add a second shift to perform the USP tests was met, to make it family-friendly, with a touch of hostility. I was told to find another way. Fortunately, there was a coming-together of several technical factors:
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