Globalization of the pharmaceutical supply chain has increased the challenges to FDA to ensure that drug products and ingredients are not contaminated, counterfeited, or mislabeled (1, 2). To help in this effort, the agency has developed rapid screening methods for pharmaceutical products and ingredients that can be deployed on portable instruments by field laboratories and inspectors for the screening of dietary supplements, pharmaceutical ingredients, and finished products on site (e.g., at border crossings, import centers, foreign manufacturing sites). Examples include detection of toxic and catalytic metals by X-ray fluorescence, detection of weight-loss drugs in dietary supplements by ion mobility spectroscopy, detection of diethylene glycol and ethylene glycol in glycerin, sorbitol or propylene glycol by Raman or near-infrared (NIR) spectroscopy (3–7). The deployment of such instruments will allow FDA inspectors to screen a large number of ingredients and products at the site of importation, in domestic commerce, or even at foreign drug manufacturing sites, and to determine which are suspect and should be detained, sampled, and sent to laboratories for confirmatory testing by traditional methods such as US Pharmacopeial testing. FDA is concerned about diversion into the legitimate supply chain of excipients that are unsuitable for use, as well as the possibility of tampering with an excipient during transit.
During the past year, FDA's Division of Pharmaceutical Analysis (DPA) has developed a deeper understanding of the value and limitations of library-based Raman and NIR spectral-correlation methods for rapid spectroscopic screening of pharmaceutical ingredients (8–10). The division has developed procedures for transferring spectral libraries across instruments from different vendors and platforms (e.g., laboratory, portable, and handheld).
DPA would now like to build an excipient library to be deployed on NIR and Raman portable instruments and used at points of entry or storage. To ensure a robust library, DPA is partnering with the International Pharmaceutical Excipients Council (IPEC) to reach out to manufacturers and distributors of common excipients to provide authentic samples to the agency to help build these libraries. This article provides details on how to participate, and some anticipated questions and answers.Benefits of participation
Development and deployment of an excipient library to monitor for possible contamination, adulteration, tampering, and diversion into the qualified pharmaceutical supply chain will improve safety of the drug supply, and thus, patient safety. Additional benefits include the following:
Creation of this library will provide added assurance that a given excipient is of the expected quality. Consumers will have increased confidence in the quality of drug products based on this increased surveillance of the excipient supply chain.
Details of participation
Materials (i.e, excipient samples) would be shared with DPA in St. Louis using a Material Transfer Agreement (MTA). This agreement would allow DPA to accept material from vendors and distributors and protect intellectual property. A copy of the MTA and contact information can be obtained on the FDA's Office of Testing and Research website under Hot Topics, at http://www.fda.gov/AboutFDA/CentersOffices/CDER/ucm136930.htm.
Manufacturers are asked to provide multiple lots (at least three) of approximately 2 g each of excipients with a Certificate of Analysis for the lot. In the case where manufacturers do not supply directly to the US pharmaceutical industry, distributors may submit the excipient samples. Material should be representative of the potential spectral variability that might be expected in their product. Variables that might affect spectral variability would include the following:
Samples should conform to market standards and/or standards filed with the agency. DPA is ready to begin receiving excipient samples for this project.