Background:
👉Since 2018, several drug products including ARBs, ranitidine, nizatidine, and metformin have been found to contain unacceptable levels of nitrosamines.
👉In June 2018, FDA was informed of the presence of an impurity identified as Nnitrosodimethylamine (NDMA) in the ARB valsartan.
👉In September 2019, FDA learned that some common heartburn products (ranitidine, commonly known as Zantac, and nizatidine, commonly known as Axid) contained unacceptable levels of NDMA.
👉In December 2019, FDA became aware that some metformin diabetes medicines in other countries were reported to have NDMA.
👉The term nitrosamine describes a class of compounds having the chemical structure of a nitroso group bonded to an amine (R1N(-R2)-N=O)
Possible ways or sources of Nitrosamine Impurities:
✅General Conditions That Lead to Nitrosamine Formation:
1) Formation of nitrosamines is possible in the presence of secondary, tertiary, or quaternary amines and nitrite salts under acidic reaction conditions.
2) Nitrites used as reagents in one step can carry over into subsequent steps, despite purification operations, and react with amines to generate nitrosamine impurities.
3) Secondary and tertiary Amines may be present in a manufacturing process for a variety of reasons.
4) Amide solvents, which are susceptible to degradation under certain reaction conditions, are another source of secondary amines. For example, under high reaction temperatures for an extended reaction period, N,N-dimethylformamide can degrade into dimethylamine, which can react with nitrous acid to form NDMA.
This list of the aforementioned sources is not exhaustive, as amine reagents can be used to mediate a wide range of synthetic transformations. Manufacturers should evaluate other reagents containing amine functional groups for potential risk of nitrosamine formation.
✅Contamination in Vendor-Sourced Raw Materials:
Nitrosamine impurities can be introduced when vendor-sourced materials, including starting materials and raw materials, are contaminated, The Agency has observed the following contaminations due to this root cause:
1) Nitrosamine contamination has occurred when fresh solvents (ortho-xylene, toluene, and methylene chloride) were contaminated during shipment from vendors (e.g., during transfer between storage vessels).
2) Presence of Sodium nitrite is a known impurity in some starting materials.
3) Presence of Nitrate-containing raw materials, such as potassium nitrate, may contain nitrite impurities.
4) Starting materials or outsourced intermediates may be at risk through cross-contamination (if they are manufactured at sites where nitrosamine impurities are produced in other processes).
✅ Recovered Solvents, Catalysts, and Reagents as Sources of Contamination:
1) API Manufacturing involves synthetic process which produces nitrosamines or contains precursor amines.
2) It was reported that ortho-xylene and toluene were contaminated during recovery due to inadequate cleaning and to use of shared storage equipment between different customers.
3) Inadequate and unvalidated cleaning procedures can also lead to crosscontamination.
✅ Lack of Process Optimization and Control:
Nitrosamine impurities is lack of optimization of the manufacturing process for APIs when reaction conditions such as temperature, pH, or the sequence of adding reagents, intermediates, or solvents are inappropriate or poorly controlled.
These limits are applicable only if a drug product contains a single nitrosamine. If more than one of the nitrosamine impurities identified in Table 1 is detected and the total quantity of nitrosamine impurities exceeds 26.5 ng/day (The Acceptable Intake (AI) for the most potent nitrosamines) based on the maximum daily dose (MDD), the manufacturer should contact the Agency for evaluation.
🔖For drug products with an MDD (Maximum Daily Dose) of less than 880 mg/day, a recommended limit for total nitrosamines of 0.03 ppm is not more than 26.5 ng/day and is considered acceptable.
🔖For drug products with an MDD above 880 mg/day the limit for total nitrosamines should be adjusted so as not to exceed the recommended limit of 26.5 ng/day.
Products should use methods with LOQs at or below 0.03 ppm. If more than one nitrosamine listed in Table 1 is detected, then the analytical method should be validated for LOQs below 0.03 ppm to accurately quantify a total nitrosamine level of not more than 26.5 ng/day. For example, if the MDD is 1200 mg, the LOQ should be below 0.02 ppm.
Recommendations:
Because nitrosamines are probable or possible human carcinogens, FDA recommends that manufacturers consider the potential causes of nitrosamine formation described in this guidance as well as any other pathways observed and evaluate the risk for nitrosamine contamination or formation in their APIs and drug products. Manufacturers should prioritize evaluation of APIs and drug products based on factors such as maximum daily dose, duration of treatment, therapeutic indication, and number of patients treated. As new information becomes available and FDA’s understanding of nitrosamines in drugs evolves.
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