The FDA Guidance for Industry, Container Closure Systems for Packaging Human Drugs and Biologics (1) addresses the review and evaluation of packaging requirements. According to this document, each New Drug Application (NDA) or Abbreviated New Drug Application (ANDA) should contain enough information to demonstrate that a proposed container closure system and its components are suitable for its intended use.
The type and extent of information required will depend on the dosage form and route of administration. Qualification and quality review is applied to packaging materials and to the actual dosage form. Packaging suitability is based on four attributes: protection, safety, compatibility and performance (function and/or drug delivery). For injectable dosage forms, the document outlines the tests required to show that interaction is not a problem. Associated components, such as those used only at the time a dosage is administered, self-adhesive labels and secondary packaging materials, are also included in the review process.
Inhalation and injection drug products have the highest requirements. There are product-specific draft guidelines for metered dose inhalers (MDI), dry powder inhalers (DPI), nasal sprays and inhalation solutions, suspensions and spray drug products. The identity and concentration of leachables in inhalation and nasal drug products must be monitored throughout the dosage form’s shelf life since the product consists of the dosage form and container closure system.
Numerous guidances (see Table I) mention the appropriate evaluation of packaging components. These guidances recommend that the safety and compatibility of the dosage form with the primary container closure system be established early in the development process. Specific focus is on the potential for drug-biologic interaction with the container or closure because of leaching or absorption.
|Table I: Numerous guidances mention the appropriate evaluation of packaging components.|
|Committee for Proprietary Medicinal Products (CPMP): Note for Guidance on Development Pharmaceutics (January 1998) (2)|
|CPMP: Development Pharmaceutics for Biotechnological and Biological Products, Annex to Note for Guidance on Development Pharmaceutics (October 1999) (3)|
|International Conference on Harmonization (ICH) Q6A: Test Procedures and Acceptance Criteria for New Drug Substances and New Drug Products: Chemical Substances (November 1999) (4)|
|ICH: The Common Technical Document for the Registration of Pharmaceuticals for Human Use, Quality (February 2003) (5)|
Industry-based working groups have been established to assess extractable concerns and other scientific issues. The Product Quality Research Institute (PQRI) was established to conduct research that generates scientific information to support the development of regulatory policy. PQRI is driven by its member organizations which include (but are not limited to) the American Association of Pharmaceutical Scientists (AAPS), the Pharmaceutical Research and Manufacturers Association, the Generic Pharmaceutical Association, the Parenteral Drug Association (PDA) and FDA’s Center for Drug Evaluation and Research. PQRI is a nonprofit foundation that serves as a vehicle for FDA, industry and academia to collaborate on key issues in pharmaceutical product quality through research and expert analysis. The PQRI Extractables and Leachables Working Group has developed and submitted to FDA a document entitled “Safety Thresholds and Best Practices for Leachables and Extractables Testing in Orally Inhaled and Nasal Drug Products.” A copy of the document is available here on the PQRI website.
A newly formed working group will focus on parenteral and ophthalmic dosage forms.
Another industry group, the International Pharmaceutical Aerosol Consortium on Regulation and Science, and the Inhalation Technology Focus Group of AAPS developed a points-to-consider document in reference to leachables and extractable testing as defined in the MDI and DPI draft guidance and the nasal spray and inhalation solution draft guidance. The concept recommends establishment of identification and qualification thresholds for extractable and leachables along with other suggested points clarification.
Primary container-closure systems, as well as other packaging components, have the potential to interact with the dosage form. Factors that must be considered in evaluating container closure systems are materials of construction of the container-closure system, surface treatments and/or processing aids, dosage form active ingredient and excipients, sterilization and/or other related processing, and storage conditions.
The presence of extractables is determined through artificial means. An extractable is a chemical species that can be released from a container or closure material of construction that has the potential for contaminating the dosage form. Under certain exaggerated solvent, temperature and time conditions, an extractable may be generated through an interaction with the closure system.
Extractable testing studies are recommended even if containers or closures meet compendial suitability tests. Extensive testing for extractables should be performed as part of the qualification of the container-closure components. Testing under stressed conditions should demonstrate that the extractable profile is acceptable for the specific dosage form and that levels observed will not be approached or exceeded during the shelf life of the drug product.
A leachable is a chemical species that has migrated from packaging or other components into the dosage form under normal conditions of use or during stability studies. Leachables are substances identified in a defined laboratory regimen by simulating use conditions. The industry is focused on potential problems associated with extraction of chemicals from packaging materials into drug product. Leachables are a subset of extractables.
Testing criteria include:
Leachables have the potential to interfere with drug product assays. For instance, leachables might have the same retention time as a drug in a high performance liquid chromatography (HPLC) assay. Leachables also may interfere with medical diagnostic tests, increase the impurity level of a drug product to an unacceptable range or increase the toxicity of a drug product. If leachables react with one or more drug product components, they could cause a precipitate or pH change.
Extractable screening during safety studies is an important part in choosing the appropriate container or closure for a dosage form. It can minimize the time and money needed for future suitability studies. Because test methods must be specific to the extractable, the laboratory performing the testing must use the correct techniques. Test methods must be specific to the drug product and placebo in order to evaluate interferences, linearity and other critical factors. In addition, evaluators must test the final packaging-drug combination for leachables during stability studies.
Prescreening procedures should begin with a basic evaluation of container-closure options. The protocol can involve multiple temperatures and conditions for acceleration. It should be designed to identify the appropriate container-closure candidate for inclusion in stability programs. Identification of extractables can be achieved through analytical testing, such as liquid chromatography–mass spectrometry (LC–MS), gas chromatography–mass spectrometry (GC–MS), inductively coupled plasma (ICP) and infrared (IR). Suppliers of these systems may be able to provide some information on testing procedures. The testing laboratory can then develop methods and complete validation of them.
Using rubber closures as an example, the laboratory would identify a potential extractables list for the rubber formulation. This list would include chemicals that can leach into the product from the base closure formulation. These extractables have a direct relationship to the ingredients of the rubber closure. If the laboratory has prior experience with certain potential extractables, previously used methods are chosen for the study. Otherwise, the laboratory will engage in methods development and conduct an assessment to determine the potential for analytical interference, the limits of quantification, and typical percentage of recovery of spiked extractables in nondegraded and degraded product and placebo.
If there is significant interference during method feasibility testing, such as HPLC column deterioration evidenced by peak fronting, peak splitting, retention time shortening and poor recovery after multiple injections for extractables, the laboratory determines that these extractables cannot be detected by that particular method. If issues with column performance are noted, dilution of drug product with an organic solvent and cleanup injections between sample injections may be investigated, and analysis of these extractables by other methods with a new sample preparation technique may be attempted.
Typically, methods development would be required to address leachables. Sometimes methods development studies are expanded to improve sample preparation before analysis with a particular instrument. In one case of certain extractables analyzed by HPLC, it has been determined through several organic solvent investigations that client samples require dilution with an equal volume of tetrahydrofuran (THF) to enhance the solubility of the extractables. Samples must then be centrifuged at a preset time and speed to allow presence of a clear THF top layer. The laboratory then analyzes this layer and allows for proper detection of compounds at required concentrations. It has also been determined that the cleanup step between sample injections must be made with acetonitrile to maintain column performance. For some extractables, new sample preparation techniques are investigated.
Once appropriate methods are developed and verified through multiple sample preparation repetitions and varying factors, formal procedural methods are written in detail for method validation.
Methods validations for detection of leachables in placebo and dosage form are based and recommended on industry practice and International Conference for Harmonization (ICH) Guidelines. A validation plan for each identified test method is developed and approved by the client. Each plan includes detailed standards and sample preparation techniques, system suitability, validation criteria and pass-fail specifications.
Once the appropriate test methods are validated, samples are analyzed for leachables. Then testing of development and stability lots is performed under accelerated and long-term conditions. If leachables are found, toxicological evaluation should be conducted and routine testing or testing of the annual stability lot may be necessary. Typically, three lots of each dosage strength will be tested at predetermined conditions. The extractables testing may be incorporated into the master stability study protocol. This “next phase” testing allows for monitoring of leachables during long-term storage conditions and will assess any negative or positive impacts that may occur with the primary packaging components.
West, a supplier of primary packaging components for the drug, biologic and medical device industries, has developed an extractables-leachables testing program for elastomeric closures. West evaluates and quantifies the interaction between the dosage form and container-closure components. Testing includes analytical techniques such as HPLC, GC, ICP, ion chromatography, and other methodologies to identify potential extractables and leachables from rubber, plastic, glass or labeling components. In addition, analysts perform elastomeric closure compendial tests, USP 661 container testing for plastics, package-drug prescreening, various seal integrity testing and testing per ICH Stability Programs.
They can also conduct specialized elastomeric closure-plunger tests such as quantification of silicone oil on a closure surface or breakloose and extrusion of a syringe system.
At the 2007 PDA’s Extractables/Leachables Forum, West unveiled VeriSure™, a program to simplify the testing process for extractables and leachables. VeriSure is an analysis and verification testing service that identifies extractables and assures they are controlled before the product is sent to the purchaser. Once West has evaluated the properties of these closure system components, they are shipped with a Certificate of Analysis that identifies the extractables, the specifications and the quantity of the extractables for each lot of components. This enables the customers to speed the design of leachables testing for primary packaging components by eliminating the need for costly, time-consuming extractables testing and assures component control, which is critical to the Quality by Design philosophy within the pharmaceutical and biotech industries.
FDA’s May 1999 Container Closure Guidance has accelerated the requirements for extractable and leachable testing of container-closure packaging components.
Since that date, additional recommendations have been made by industry groups to clarify how these issues should be addressed.
Obtaining this information may require testing methods not previously completed within the manufacturers’ environment. Further, additional testing will require time and money that must be built into the qualification and stability studies of the container-closure system early in the product development cycle.
Container-closure prescreening assures suitability for use with the dosage form and establishes appropriate methodology to test leachables using validated methods. New programs such as VeriSure can also mitigate pharmaceutical manufacturers’ risks while accelerating their development timeline to aid in a successful product launch.
VeriSure™ is a trademark of West Pharmaceutical Services, Inc. in the United States and other jurisdictions.
Frances L. DeGrazio is vice-president of marketing and strategic business development at West Pharmaceutical Services, Inc., 101 Gordon Drive, Lionville, PA 19341.