Bureau Circular 5 S 1997
Bureau Circular 5 S 1997
Bureau Circular 5 S 1997
Department of Health
BUREAU OF FOOD AND DRUGS
Civic Drive, Filinvest
Alabang, Muntinlupa City
SUBJECT
The BFAD has adopted the 1997 Guidelines for the Registration of Pharmaceutical Products
and has revised the checklist of requirements according to the said guidelines. Copies of the 1997
Guidelines etc. and the Revised Checklist of Requirements are attached as Annex A and B
respectively.
Hence, effective April 1, 1997, all applications for products registration shall be contained in
the PSD application form (PSD Form No. 8) and together with the submitted requirements as listed in
the checklist, shall be pre-assessed and submitted at the Public Assistance, Information and
Compliance Section in accordance with the 1997 Guidelines for Registration of Pharmaceutical
Products.
Any application that will not comp pharmaceutically with the said guidelines shall be returned
to the applicant and may be re-submitted only after the completion of the requirements.
ANNEX B
1997 GUIDELINES FOR THE REGISTRATION OF
PHARMACEUTICAL PRODUCTS
I.
INTRODUCTION
These guidelines are formulated to guide the pharmaceutical companies in the preparation
and submission of drug registration applications and as an aid for the Bureau of Food and
Drugs - Product Services Division (BFAD-PSD) evaluators in assessing the acceptability of
such applications as well as the approval of registration of the product applied for.
A correctly accomplished application form and well-arranged with complete documentation
facilitate the work of the evaluators and can contribute to shorten the time required for the
evaluation of applications for registration. All pertinent documents and information regarding
the product shall be fully disclosed as these shall be used as bases in evaluating the
acceptability of the drug product for registration.
1.1.
DRUG REGISTRATION
The main function of the regulatory agency on pharmaceuticals is to ensure that all
drug products being made available to the general public are safe, efficacious and of
good quality.
Registration of drug products as required by RA 3720 as amended enables the BFAD
to assess the benefits of a product complying with the criteria of safety, efficacy and
good quality and to control or regulate its distribution.
All products which fall under the definition of drugs are required to be registered
following the procedure and requirements stated in this guidelines.
If all the criteria and requirements for registration have been met all applications
undergoing final evaluation are issued an approval of registration whose validity
period is as follows:
1. Initial registration of drugs for general use shall be issued either 2 years or 5
years validity based on the application of the company.
2. Drugs which fall under the new drug monitored release category shall be given 3
years registration validity.
3. Renewal registrations are valid for 5 years.
If any of the requirements are not met, a letter shall be sent to the
company denying the application. An application for reconsideration shall no longer
be allowed but the application may submit an application for initial registration for the
same product correcting all deficiencies.
1.2.
DRUG EVALUATION
The evaluation of drug product is primarily a process to determine its safety, efficacy
and quality.
Safety means that the drug product will not cause unfavorable reactions when used
according to its declared indication and that it does not have unexpected toxic
properties.
Efficacy pertains to a drug products ability to deliver the desired effect. It may be
expressed in terms of the extent of prevention or treatment of disease in man or the
manner in which it affects the structure or any function of the body of man or animals.
Quality as applied to a drug product requires that the product contains the quantity of
active ingredient(s) claimed on its label within the applicable limits of its specification.
It also means that the drug product can maintain its appearance, potency and
therapeutic availability until its claimed shelf-life/expiration.
All applications shall undergo a detailed evaluation of documents at the PSD and this
includes:
a. Complete formulation, facilities and methods of manufacture
b. Technical specifications, methods and results of quality control tests and analysis
conducted on all starting materials as well as on the in-process and finished
product
c. Complete data on stability testing and predicted shelf-life, container
description/specifications and recommended storage conditions
d. Labels or specimens of the proposed labels and other labeling materials such as
inserts, brochures, etc.
The application shall be accompanied by samples which shall be forwarded to the
Laboratory Services Division (LSD) for analysis which includes potency, identification
and other test requirements. The results of analysis on the samples shall be
forwarded to the PSD for final evaluation.
At any stage in the evaluation process an abeyance letter may be issued containing
questions and deficiencies regarding the product application.
2.
Tuesday
Wednesday
- a.m.
- p.m.
- a.m.
- p.m.
Application Letter
The Application/covering letter shall provide the following information
1. Name of the product
2. Dosage strength and dosage form
3. Name of the manufacturer, trader and distributor-importer/exporter, if
applicable
3.1.2
3.1.3
Agreement between
Importer/Exporter
Manufacturer
and
Trader
or
Distributor-
The licensed trader or distributor shall submit a copy of valid agreement with
a BFAD-licensed manufacturer or a foreign manufacturer containing the
following:
-
3.1.4
General Information
A detailed information regarding the product shall include the following:
- products proprietary or brand name
- official chemical name(s) and generic name(s) of active ingredient(s)
- molecular or chemical formula and structure
- amount of active ingredient per unit dose
- pharmaceutical form of the drug
- indication
- recommended dosage
- frequency of administration
- route and mode of administration
- contraindication
- warnings and precautions
3.1.5
3.1.6
or
Non-Active)
described
in
or
Non-Active)
not
described
in
3.1.8
3.1.9
3.1.10 Full description of the methods used, the facilities and controls in the
manufacture, processing and packaging of the finished product.
A complete and detailed description of the manufacturing procedure including
all the facilities and equipment used in each stage of the manufacturing
process shall be given so that an assessment can be made of whatever the
processes employed in producing the pharmaceutical form might have
produced an adverse drug change in the constituents.
with
all
the
1. Application Letter
2. Certificate of Brand Name Clearance
3. Certificate of Agreement between Manufacturer and Trader or DistributorImporter/Exporter
4. Unit dose and batch formulation
5. Technical/Quality specifications of all raw materials
6. Certificate of Analysis of active ingredient
7. Technical/ Quality specifications of finished product
8. Certificate of Analysis of finished product
9. Full description of the methods used, the facilities and controls in the
manufacture, processing and packaging of the finished product
10. Details of the assay and other test procedures for the finished product
including data analysis
11. Detailed report of stability studies to justify claimed shelf-life
12. Labels or specimen of the proposed label and other labeling materials
such as inserts, brochures, etc.
13. Samples in market or commercial presentation
14. Duly authenticated Certificate of Free Sale from the country of origin
15. Duly authenticated government certificate attesting to the registration
status of the manufacturer
3.2.2
All communications with the BFAD regarding New Drugs and Investigational
New Drugs and matters arising from clinical investigation shall be coursed
through the Medical Director.
All labeling materials including inserts, brochures and other
labeling/promotion materials must be approved by the Medical Director.
3.2.3
3.2.4
Pre-clinical Data
Before initial human studies are permitted, the full spectrum of pharmacologic
properties of the new drug must be extensively investigated in animals.
Animal researches, are done to provide evidence that the drug has sufficient
efficacy and safety to warrant testing in man.
Pre-clinical studies shall include pharmacodynamics, pharmacokinetics, and
toxicity studies of the drug.
1. Pharmacodynamics
Pharmacodynamic studies are done for the following purposes:
1. to identify the primary action of the drug as distinguished from the
description of its resultant effects.
2. to delineate the details of the chemical interaction between drug and
cell or specific receptor site(s), and
3. to characterize the full sequence of drug action and effects.
a. Pharmacologic effects - properties relevant to the proposed
indication and other effects.
Pharmacodynamic data shall demonstate the primary
pharmacologic effect of the drug leading to its development for
the intended use(s) or indication(s). it shall also show the
particular tissue(s)/organ(s) affected by the drug and any other
effect it produces on the various systems of the body.
b. Mechanism of action including structure-activity relationship
(SAR)
Pharmacodynamic data shall also demonstrate the correlation of
the actions and effects of drugs with their chemical structures.
Structure-activity relationship is an integral link in the analysis of
drug actions since it is well known that the affinity of a drug for a
specific macromolecular component of the cell and its intrinsic
activity are intimately related to its chemical structure.
2. Pharmacokinetics
Pharmacokinetic data form the basis for prediction of therapeutic doses
and suitable dosage regimen.
These date shall demonstrate the following:
1. the rate and extent of absorption of the drug using the intended route
of administration;
2. the distribution patter including a determination of the tissues or
organs where the drug and its metabolites are concentrated
immediately after administration and the time course of their loss
from this sites;
3. the metabolic pathway of the drug or its biotransformation and the
biological activity of the metabolites;
4. the route of excretion of the drug and its principal metabolites and the
amount of unchanged substance and metabolites for each route of
excretion;
5. the drugs half-life or the rate that it is eliminated from the blood,
plasma or serum.
3. Toxicity data
Toxicity date shall include results of acute toxicity, subchronic and
chronic studies done on different species of animals.
1. Acute Toxicity
Acute toxicity data shall show the median lethal dose of a drug.
Ideally, the study shall be carried out in at least two (2) species of
animals, one (1) rodent and the other non-rodent, using 5 dose levels
with the appropriate number of test animals. Example: 10 rodents per
dose level with the drug given as a single dose and the animal
observed for seven (7) days or more (preferably 14 days). The route
of administration should that be anticipated for use in man, i.e., oral
(by gavage) if to be administered orally.
2. Subchronic Toxicity
Subchronic toxicity studies are carried out using repeated daily
exposure to the drug over a period of 21-90 days with the purpose of
studying the toxic effects on target organs, the reversibility of the
effects and the relationship of blood and tissue levels on the test
animals.
The following should be contained in the subchronic toxicity data:
1. a determination of the adverse effects from repeated exposures
to a chemical over a portion not exceeding 10% of the average
life span.
2. A determination of the cumulative toxicity and the development of
tolerance in target organ with continuous exposure.
3. A monitored hematologic, renal, hepatic and biochemical
changes.
4. A determination of the maximum tolerated dose or the dose with
no observed effects in animals.
The parameters used for objective evaluation of drug effects in animals
are as follows:
1. Physiologic changes such as body weight, food and water
consumption, grooming, bowel movement and urination,
temperature, heart rate and respiratory rate.
2. Hematologic such as Hemoglobin (Hb), Hematocrit (ct), White
Blood Clot (WBC), Differential count, platelet and reticulocyte
count
3. Biochemical such as liver enzymes, alkaline phosphatase, total
protein, albumin, globulin, BUN, creatinine, blood sugar, uric acid
and cholesterol.
4. Urinalysis
5. Neurological
6. Behavioral
7. Post-mortem analysis (anatomical and histopathological)
8. No observable effect level
3. Chronic Toxicity
Chronic toxicity studies constitute important steps in the analysis of a
chemical. The entire lifetime exposure of an individual or animal to
the environment or chemical is an on-going process which neither
acute nor subchronic toxicity study can provide. The effect on
animals when small doses of the drug are given over a long period of
time may not be the same as when large doses are given over a
short period.
Chronic toxicity studies are done to determine the no observed
adverse effect level (NOEL) and to set the acceptable daily intake
(ADI) tolerance and threshold limits. The parameters to be observed
are the same as in subchronic studies.
4. Special Toxicity Data
Special toxicity studies in animals are conducted to
1. determine the safety of the drug or its preparation through acute,
sub-acute and allerginicity tests using appropriate species of
animals.
4. Biovailability
Bioavailability studies are conducted to determine the rate and extent
to which the active substance or therapeutic moiety is absorbed from
a pharmaceutical form and becomes available at the site of action.
3. Name(s) of investigator(s) and their curriculum vitae
The name(s) and address(es) of the investigator(s) and
subinvestigation(s) (e.g. research fellows, resident physicians) who will
be assisting the investigator(s) in the conduct of the investigation should
be submitted.
A curriculum vitae or other statement of qualifications of the
investigator(s) showing the education, training and experience that
qualifies the investigator as an expert in the clinical investigation of a
drug should also be submitted.
The investigator shall be well qualified by
experience to conduct investigational studies of
is affiliated with a recognized medical school
institution recognized for its excellence or is
qualified.
The training and experience needed will vary, depending upon the kind of
drug and the nature of the investigation. In Phase I, the investigator must
be able to evaluate human toxicology and pharmacology. In Phase II, the
clinicians should be familiar with the conditions to be treated the drugs
used in these conditions and the methods of their evaluation. In Phase III,
in addition to experienced clinical investigators, physicians not regarded
as specialists in any particular field of medicine may serve as
investigators, properly guided by a competent clinical investigator who
will collate all the data and be responsible for the final result of the body.
At this stage a large number of patients may be treated by different
physicians so that a broad background of experience may be secured.
4. Name(s) of center/institution wherein the clinical investigation was
undertaken
The institution/center must be accredited by the regulatory agency and
must have an independent ethical and technical review boards. The
facilities and laboratories must meet the requirements for the phase of
clinical trial that will be undertaken in such institution/center.
Phase I clinical trials require facilities and human resource capabilities of
the highest degree. These requirements are usually met only by
institutions/center in well developed countries. Phase II and III may be
undertaken in academic institutions and tertiary hospitals with trained
clinical pharmacologists, specialists and paramedical personnel.
The capabilities and standard of these institutions/centers must have
been certified by the appropriate government agency as meeting the high
standard of Good Laboratory Practice (GLP) and Good Clinical Practice
(GCP)
The Medical Director of such institution/center or hospital must certify that
such clinical trial is being allowed to be conducted in such institution or
hospital.
5. Protocol for Local Clinical Trial
Local clinical trials are conducted to determine the safety, efficacy and
suitability of the recommended dosage and therapeutic dose regimen to
the local patient population. These trials can only be conducted after the
protocol for a local clinical trial is approved by an accredited independent
institutional review board and a temporary permit to market the drug
locally is granted.
The protocol for the local trial shall include the following:
1. Study Title
2. Names of Investigator(s) including supervising investigator, principal
investigator, co-investigator(s).
3. Funding/Sponsoring Agency
4. Summary of the Proposed Study
5. Introduction including an identification of what is being studied, an
explanation of why the study is valid or the scientific rationale.
6. Objective(s) of the study indicating the general objective and specific
objective(s).
7. Study Design e.g. descriptive study, case control, cohort, randomized
concurrent trial.
8. Methods including a description of the study subjects, sample size,
description of the study procedure, and a description of outcome
measurements.
9. Data analysis including the criteria for substantive and statistical
success, definition of drop-outs, withdrawals, treatment failure,
details of statistical strategy to be used, and a specification of data
handling, collation and computer use.
10. Ethical Consideration including
a. Good outweighing harm
b. Free informed consent
c. Freedom to withdraw from the study at any time
d. Confidentiality
11. Indemnification Policy which is compensation statement indicating
availability payment for treatment or free treatment hospitalization in
case of an adverse drug experience.
12. Time schedule or duration of clinical trial.
13. Duties and responsibilities of research personnel.
a. The investigator must conduct the studies in conformance with
the Declaration of Helsinki or the laws and regulations of the
country in which the research is conducted, whichever represent
the greater protection of the individual.
b. The investigator must keep careful records of his study and
retain them for at least two years after the new drug application is
approved. The records must be available promptly to the drug
sponsor (usually the drug manufacturer) and to the drug
regulatory agency. Progress reports must be sent to the sponsor
at intervals not exceeding one year.
c. The investigator must send emergency reports to the sponsor
and the regulatory agency when dangerous adverse effects are
observed.
NEW
INDICATION(S)
OR
NEW
ROUTE
OF
3.3.2
Pharmacokinetic data
Pharmacokinetic studies should be conducted to determine the most
suitable dosage regimen for the new indication or the new route of
administration.
It is important to conduct pharmacokinetic studies relating to the new
route of administration since the metabolic pathways of a drug substance
and the biological activity of its metabolites may vary depending on the
route it is administered.
3.3.3
Phase III clinical trial for the new indication(s) or the new route of
administration
Phase III clinical studies should be aimed at determining the safety and
efficacy or the drug product for its new indication or new route of
administration.
For studies on a new indication, Phase III clinical trial should be
conducted in patient population for which the new indication is intended.
3.3.4
Local clinical trials are conducted to determine the safety, efficacy and
the most appropriate dosage or dosage regimen for the new indication in
local patient population.
3.4 PRODUCTS WITH ADDITIONAL DOSAGE OR DOSAGE STRENGTH
3.4.1
3.4.2
Pre-clinical studies
1. Toxicology data for increased dosage to ensure that the addition in
the amount of active ingredient will not diminish the desirable effects
of the drug.
3.4.3
3.4.4
comply
with
the
following
a)
b)
c)
d)
e)
f)
g)
Application letter
Copy of latest Certificate of Product Registration
Unit dose and batch formulation
Certificate of Analysis of active raw material
Technical specifications of finished product
Certificate of Analysis of finished product
Details of the assay and other test procedures for finished product
including data analysis
h) Detailed report of stability studies to justify claimed shelf-life
i) Sufficient samples in market or commercial presentation for laboratory
analysis and representative sample for PSD
j) Actual unattached generic labeling materials; label, box, insert, blister/foil
strip
k) Requirements for sterile products
2. Notification of the change in formulation including a justification for such
change.
3. Bioavailability of Bioequivalence data, as needed.
3.7 PRODUCTS FOR MONITORED RELEASE PRIOR TO APPROVAL FOR
GENERAL USE
Newly Introduced Drugs (NID) (with history of 5 years registered use 5000 patient
exposure in other countries), will be required to complete clinical pharmacological
studies and pass through a 3-year Initial Registration (Monitored Release) before
becoming eligible for application and approval for General Use.
The model protocol for monitored release is as follows:
An Uncontrolled Clinical Study reported the therapeutic effects and adverse
reaction for 1000 patients per year or 3000 patients over 3 years, provided
however that if the drug product is for a very limited therapeutic indication the
1000 patients/year requirement will be waived and only 10% of total patients is
given the drug will be required to be monitored and reported to BFAD by the
Pharmaceutical Company.
Application letter
Copy of latest Certificate of Product Registration
Unit dose and batch formulation
Certificate of Analysis of active raw material
Technical specifications of finished product
Certificate of Analysis of finished product
Details of the assay and other test procedures for finished product
including data analysis
Detailed report of stability studies to justify claimed shelf-life (3 batches)
Sufficient samples in market/commercial presentation for laboratory
analysis and representative sample for PSD
Actual unattached generic labeling materials; label, box, insert, blister/foil
strip
Requirements for sterile products
4.2.2
4.3 Payment of surcharge shall not make the product under the renewal process
eligible for conditional registration.
5. FIXED-DOSE COMBINATION DRUG PRODUCTS
Definition:
Fixed Dose Combination Drug Products (FDCs) are pharmaceutical preparations
containing two or more pharmacologically-active ingredients in a single formulation or
dosage form.
Scope of these Guidelines: (A.O. 96 series 1990)
All products classified as FDCs are covered by these guidelines. These are three
categories of products included:
5.1 Currently registered products already recognized and identified by BFAD as FDCs.
5.2 Currently registered product which may later be classified as FDCs
5.3 Products with pending or for future initial registration under the category of FDCs.
All these categories of FDCs are covered but the specific applicability will be defined
below.
Safety, Efficacy and Quality Criteria
The drug regulatory criteria of safety, efficacy and quality shall be applied to the specific
class of FDCs using the following rules:
1. The FDC drug product must comply with the appropriate requirements of A.O. 67 s.
1989 on registration of drug products.
2. The drug establishment seeking to register the FDC drug products should comply
with the appropriate requirements of A.O. 56 s. 1989 on the registrations of drug
establishments.
3. In addition to the above, the FDC drug product in its final dosage form must be
proven to adhere to all the following criteria:
(a)
(b)
(c)
(d)
PRIORITY I
PRIORITY III
1. Anti-infectives
2. Anti-asthmatics
3. Cough/Cold remedies
1. Gastro-intestinal preparations
2. OB/Gyne preparations
3. Musculoskeletal preparations
4. Urinary tract preparations
5. Vitamins-minerals
6. Eye-Ear preparations
7. Dermatologicals
8. Dermatologicals
9. Others
PRIORITY II
1. Anti-TB
2. Cardio-vascular preparations
3. Endocrine/metabolics
4. Drugs acting on central nervous
System
5.4 Fixed Dose Combination Drug Products listed in the latest edition of the
Philippine National Drug Formulary and complying with A.O. 67 s. 1989 shall be
accepted for registration without satisfying the requirements stated in Section
4.2 of A.O. 96 s. 1990.
6. PRODUCTS WITH CHANGE OF MANUFACTURER (M.C. No. 12 s 1991)
6.1 When a drug establishment changes manufacturer for its product(s) to one that has
better technical capabilities as evidenced by a record showing no deficiencies or only
minor deficiency (not substantively affecting product quality) in either GMP or its
whole product lines, a conditional certificate of product registration (CPR) may be
granted following the registration procedure defined under BFAD Circular No. 12 s.
1991.
6.2 Compliance with the following requirements under Established Drug as follows:
1.
2.
3.
4.
5.
6.
7.
Application letter
Original Certificate of Product Registration
Unit dose and batch formulation
Certificate of Analysis of active raw material
Technical specifications of finished product
Certificate of Analysis of finished product
Details of the assay and other test procedures for finished product
including data analysis
8. Sufficient samples in market/commercial presentation for laboratory
analysis and representative sample for PSD
9. Actual unattached generic labeling materials; label, box, insert,
blister/foil strip
10. Requirements for sterile products
6.3 The conditional CPR shall be effective for a period of one (1) year subject to the
results of the BFD Laboratory tests and stability studies for the product conducted by
the new manufacturer.
7. PRODUCTS WITH IMPROVEMENT OF IMMEDIATE CONTAINER OR PACKAGING
(M.C. No. 16 s1991)
7.1 Encouraging technical improvement of validly registered drug products, a conditional
initial registration may be granted to products whose only change is an improvement
in the immediate container or packaging. For this purpose, the procedure under the
Memorandum Circular No. 16 s. 1991 shall be observed.
7.2 Compliance with the following requirements under Established Drug
1. Application letter
2. Copy of latest Certificate of Product Registration
3. Unit dose and batch formulation
4. Certificate of Analysis of active raw material
5. Technical specifications of finished product
6. Certificate of Analysis of finished product
7. Details of the assay and other test procedures for finished product
including data analysis
8. Sufficient samples in market/commercial presentation for laboratory
analysis and representative sample for PSD
9. Actual unattached generic labeling materials; label, box, insert,
blister/foil strip
10. Requirements for sterile products
7.3 If the establishment opts to retain the registered products with the old packaging
specifications, a new registration number will be assigned to the same product with
the new packaging specifications; however if the establishment applies to use the
same DR number of the old product for the new, the product with the old packaging
specifications shall be considered automatically phased out after the Conditional
CPR for the new product is approved. In this case, the original CPR with the old
packaging specification shall be submitted.
7.4 The Conditional CPR shall be valid for a period of one (1) year from the date of
issue. It shall be subject to the satisfactory result of laboratory tests and of stability
studies.
8. REGISTRATION OF BRANDED VERSION OF REGISTERED UNBRANDED GENERIC
DRUG PRODUCT AND GENERIC VERSION OF REGISTERED BRANDED DRUG
PRODUCT (AS PER M.C. No. 10-A S 1992)
8.1 Requirements for Branded version
A manufacturer, trader or distributor-Importer who has a registered unbranded
generic drug product may apply for registration of the branded version of the said
product provided that if the registration of that generic product was processed through
the Special Lane (M.C. No. 5 s. 1990) under product category B, the registration of
the branded version will become effective only one (1) year from the date of
application for the branded version but not less than one (1) year after the date the
generic version was approved. (Product category B under MC No. 5 s. 1990 is a
special privilege for generic (unbranded) drug product, hence this rule).
The applicant shall submit together with his application the following:
a) A copy of the Certificate of Brand Name Clearance
b) If the company opts to retain the unbranded version, a copy of the Certificate of
Product Registration of the generic drug product, if the company will no longer
market the generic version, the current original Certificate of Product Registration.
c) A prototype of the proposed complete commercial form and presentation of the
branded version of the product including labels and inserts.
d) Unit dose and Batch Formulation
e) Technical/Quality Specification of the finished product
8.2 Requirements for Generic version
A manufacturer, trader or distributor-importer who has a registered branded drug
product, may apply for registration of the unbranded generic version of the same.
The applicant shall submit together with his application the following:
a) If the company opts to retain the branded version a copy of the Certificate of
Product Registration of the branded version; if the company will no longer market
the branded version, the current original Certificate of Product Registration.
b) A prototype of the proposed complete commercial forms and presentation of the
unbranded generic version of the product.
c) Unit dose and batch formulation
d) Technical/Quality specifications of finished product
9. The foregoing guidelines shall not preclude the BFAD form requiring any specific
technical data whenever question of safety, efficacy and quality arises during the
evaluation.
These 1997 Guidelines shall be amended or modified after consultation with the
pharmaceutical sectors to update the same with technological advancement in
pharmaceutical products.
Date approved:
January 30, 1997
Date of Effectivity
April 1, 1997
General
Assay
Degradation products
Physical products
Preservative efficacy
Dissolution rate
High humidity studies
Presentation of Results
Prediction of Shelf-Life from Stability Data
Product Modifications
Prospective Extensions of Shelf-Life for Individual Batches
Shelf-life Extensions According to an Approved Protocol
Appendices
1. Acceptable Temperature Storage Conditions Which May Appear on Labels
2. Common Deficiencies in Stability Data and Trial Design
3. Glossary of Terms
Preamble
These notes provide guidance as to the design, conduct and reporting of stability studies. These
guidelines primarily cover:
-
Materials of biological origin. The principles described in this document also generally apply to stability
studies on materials of biological origin, such as hormones, allergens, modified animal tissues,
vaccines and the products of genetic engineering or other newer biological techniques. However
some specific guidelines may not be appropriate for biologicals, in particular:
References to chemical assay techniques, such as the preference stated in 3.3 for
chromatographic methods for decomposition products, may not always be appropriate for
biologicals.
It may not always be possible to establish degradation pathways and identify
decomposition products formed in significant amounts (see 2.1 and 3.3)
The degradation of biologicals is not usually amenable to kinetic analysis and
extrapolation from accelerated testing (see 5)
Stability data for biologicals will be evaluated on a case by case basis, having regard to the nature of
the product and the methods of analysis (physical, chemical biological) which are appropriate for that
product.
I. General Principles
The objectives of a stability study is to determine the period of time during which a pharmaceutical
product meets appropriate standards when stored under defined conditions. As a minimum, the
product must be shown to comply with relevant specifications for the whole of its shelf-life.
The following statement, which appears in the 1993 edition of the British Pharmacopoeia, reflects a
principle which should be familiar to any pharmaceutical manufacturer:
A manufacturer must recognize that a product or material may be challenged at any time during its
claimed period of use by the methods of the Pharmacopoeia and that it must then comply with the
pharmacopoeia requirements. These requirements allow for acceptable levels of change that may
occur during storage and distribution and reject articles showing unacceptable levels of change.
Frequently a manufacturer will need to apply more stringent test limits at the time of release of a batch
of the product or material in order to ensure compliance. (BP 1993, p xxii)
Thus the difference between release and expire specifications must take into account the results of
stability testing.
The maximum permitted shelf life is normally five years.
2. Stability Trial Design
2.1 Active raw material. An assessment of the stability of the active raw material (see Glossary of
Terms) is required for new drugs and is useful in support of shelf lives for new formulations of
existing drugs. such information provides a useful guide to the problems which may be
encountered during stability studies on finished products.
Studies should establish the inherent stability characteristics of the molecule, in particular the
degradation pathways, the identity of degradation products formed in significant amounts and
the suitability of proposed analytical procedures for quantitation of both the drug substance
and degradation products. The nature of the studies will depend on the drug substance but is
likely to include the effect of elevated temperature, susceptibility to moisture and oxidation,
and the effect of light. The effect of pH may be important when the finished product is an
aqueous solution or suspension, in the latter case by means of effects on the fraction of drug
actually dissolved, however small.
The kinetics of degradation of the active raw material cannot be assumed to apply to
reactions which occur in the finished product, and care should be exercised in extrapolating
on the basis of such data.
2.2 Finished product
2.2.1
The formulation must be the same as that proposed for registration in the
Philippines. Stability data on related formulations may be submitted as supporting
evidence provided the differences between the formulation employed in the stability
trial and that proposed for registration are clearly stated. A shelf life will not normally
be allocated for the purposes of registration if there are no data on the formulation to
be registered.
All manufacturing processes must have been carried out on the batches used in the
stability trial, e.g. filtration, packaging, sterilization.
2.2.2.
2.2.3.
2.2.4.
2.2.5.
The cycling effect of night and day temperatures and humidity can be important for
example where the drug is present partly in suspension and partly in solution. Cycling
conditions may be simulated in environmental cabinets. The data are useful in
confirming the stability of the product under conditions of stress. However at is
difficult to derive accurate predictions for the shelf life of a product from this
information and it is not a formal requirement.
2.2.6.
The possibility of leaching of substances from containers into the product should be
considered for:
- injectables and ophthalmics supplied in non-glass containers or with
plastic or with plastic or rubber stoppers,
- plastic components of metered dose aerosols, and
- any other product where this could occur and may be a hazard.
2.2.8 In-use stability data should be generated where relevant, for example:
-
The stability of the in-use form of the product should be established for the period of
time and under the conditions for which storage is recommended.
Published papers may be submitted as evidence of in-use stability provided (1) they
can be shown to be relevant to the formulation proposed for registration, and (2) they
include sufficient detail to allow independent evaluation.
Where it is claimed (on the label or in product information) that the product may be
diluted with a range of solutions, the most common example being parenteral drugs
diluted in large volume intravenous infusions. Stability data should establish
compatibility with each recommended diluent at the extremes of the recommended
dilution ratios for the permitted duration of storage.
Tests on reconstituted and/or diluted solutions should normally include pH,
clarity/particulate matter, assay and, if assay sensitivity allows, degradation products.
Note however that, regardless of chemical stability, the product information for
reconstitutable and dilutable injectables should normally include the direction. To
reduce
microbiological
hazard
use
as
soon
as
practicable
after
reconstitution/preparation. If storage is necessary, hold at 2-8C for not more than 24
hours, or words to that effect. If there are valid reasons why the reconstituted and/or
diluted solution may be kept for longer periods then data should be generated to
establish the effectiveness of the preservative for the duration of the recommended
storage period.
2.2.9 Where a precipitate may form during normal storage, for example in an intravenous
injection where the drug may precipitate because of borderline solubility, directions
for redissolution must be included in product information and should be supported by
appropriate stability data.
2.2.10 Studies of container/closure interaction with the product should be considered where
this is a risk, for example injectable liquids should be stored both upright and inverted
to determine whether contact with the closure affects stability.
3. Appropriate Tests
3.1 General
3.1.1
Where test methods are identical to those in the routine quality control specifications,
this should be explicitly stated and not left to the evaluator to assume.
Alternative test methods maybe used in stability studies, but they should be fully
described and validated. Dissolution procedures other than those in finished product
specifications are discouraged.
3.1.2
If changes are made to the assay or other test method during a stability study, it may
be difficult to compare results before and after the change. On the other hand, if the
change is being made because of a deficiency in the first method, it may be
warranted. In such a case, data should be generated comparing the two methods in
terms of accuracy, precision, specificity and other relevant characteristics. Both
procedures should be conducted at several stations to find how the results compare.
Change to dissolution test methodology during stability studies are discouraged.
3.2 Assay. Details should be provided of all analytical methods used in the stability studies
together with validation data including:
- accuracy and precision in the range of the concentrations to be
measured
- shape of the calibration curve over the same range (linearity is preferred)
specificity, i.e. freedom from interference by degradation products, other
likely impurities and excipients.
It is not sufficient to determine that the drug content remains within the limits of the
specifications; the study design and assay parameters should be such as to allow any trend
over time to be observed.
As well as assay of drug, it may be necessary to assay other components, e.g. antimicrobial
preservatives. In multidose parenterals, and in some cases the content of antioxidant.
It should be noted that loss of drug may be due to factors other than degradation, such as
absorption on to or absorption into the container wall, volatilization, etc.
3.3 Degradation products. Determination of trends in formation of major degradation products
provides, in conjunction with the assay for content of drug substance, a better basis for
assigning a shelf life to a product that assay results for the drug substance alone. Therefore,
as far as possible, degradation products should be quantified or, if this is not possible,
semiquantified.
Results for content of degradation products should be provided even if the assay method is
specific for the drug. Where results are below the limit of detection of the test method, these
should be expressed as -below x%, where x% is the detection limit of the test(s) used.
Results should be given for total and all individual impurities detected, even where the identify
of the impurity is unknown. Where the identity of the impurity is unknown, results may have to
be semiquantitative.
Chromatographic techniques are preferred for the separation and detection of degradation
products, but validated alternatives methods of quantification may be acceptable. The
chromatographic system employed should be capable of separating and detecting
compounds which are likely to be present as impurities or which may arise via established
degradation pathways. It may be necessary to provide data from two or more systems to
confirm the adequacy of resolution.
Information should be provided on the means by which the methods used in the stability study
for estimating degradation products were selected.
Degradation products, present at 0.55 of the active content or greater should normally be
identified.
3.4 Physical properties. In addition to assay for content of active ingredients and degradation
products, it is also necessary to monitor the physical properties of the product during storage.
The physical tests will vary with the formation in question but important attributes of various
dosage forms may include the following:
3.4.1
3.4.2
3.4.3
3.4.4
3.4.5
3.4.6
3.4.7
3.5 Preservative efficacy. Because chemical assays do not necessarily indicate antimicrobial
efficacy, if a product is required to contain an antimicrobial preservative, for example eye
drops or multidose injections, it will usually be necessary to conduct a microbial challenge test
at the end of the shelf life in addition to chemical assay of the preservative during the study.
3.6 Dissolution rate. The behavior of dissolution rate over time should be examined for all solid
oral dosage forms and other compressed products (suppositories, implants, etc.) even where
the drug is water soluble. Dissolution data should normally be generated on at least six
individual units at each test station (e.g. 1 month, 3 months, 6 months etc) and should be
reported as both individual and mean data. Test conditions should normally be those used in
routine quality control or, if dissolution is not a part of routine quality control, any reasonable,
validated method.
It may be necessary to generate dissolution profiles (percent of nominal content dissolved at
a number of time points at appropriate intervals to almost complete dissolution) for certain
products, for example:
-
3.7 High Humidity Studies. The use of plastic containers for the packaging of pharmaceuticals
raises questions concerning the stability of the contents when stored under conditions of high
humidity. High relative humidity can affect chemical stability (for example some antibiotics are
readily hydrolysed) and physical stability (for example, altered dissolution rate).
Date should be generated to establish the effect of high humidity on solid dosage forms
packaged in containers which are likely to be permeable to moisture. This includes containers
made from polyvinyl chloride or low density polyethylene but does not include those made
from glass or high density polyethylene. If a sponsor believes that high humidity data are not
needed for a product which is packed in a plastic material, this view should be supported by,
for example, information on the composition, thickness, density and/or moisture
transmissibility of the packaging materials.
Temperature and relative humidity data available from the Bureau of Meteorology have
established that a number of centres in Philippines experience a combination of high humidity
and high temperature during the summer months.
Satisfactory stability results when the product is stored at 25C and 80% RH or 30C and 75%
RH for 3 months are normally sufficient to establish the adequacy of the packaging to protect
the product from moisture for a period of up to 2 years. Data which show stability for a period
of 6 months are normally sufficient to support shelf lives in excess of 2 years.
These short term high humidity data provide support for stability data accumulated at the
maximum recommended storage temperature at lower relative humidity, but do not obviate
the need for studies for the duration of the shelf life.
4. Presentation of Results
4.1 Results obtained at the commencement and at nominated time intervals throughout the trial
(for example 0, 3, 6, 9, 12, 18, 24 months, or 0, 1, 2 and 3 months for high humidity studies)
should be provided. This will allow any trends to be detected and will enhance the predictive
value of the trial.
Data which do not include initial results (that is at the start of the trial) are of limited value.
4.2 If more than one assay result is available for any particular time interval, all results should be
quoted rather than, or in addition to, an average figure. Where bioassays are employed to
study antibiotics, the accompanying fiducial limits of error (p=0.95) of each assay should be
provided.
4.3 Assay results obtained during the study should be recorded either as absolute values (such
as number of mg of drug per capsule) or as a percentage of the nominal (labeled) content.
4.4 Care should be taken that individual dose unit variations, such as between individual tablets
or between individual vials of freeze-dried powder, are allowed for in stability studies. For
freeze-dried vials, this may be achieved by assaying the content of active per unit weight of
powder. For tablets and capsules, an average content may be obtained by conducting the
assay on pooled samples (normally 20 tablets or capsules), or by averaging individual dose
unit results.
4.5 Wherever possible, quantitative results should be quoted rather than a statement that the
product complies with a particular specification.
4.6 All results obtained should be discussed and explanation given where necessary, for example
anomalous or unusual results, change in assay method, change in appearance.
4.7 A brief outline of the sampling procedure followed in the stability trial should be provided.
The following general rule-of-thumb is used by the evaluators when assessing data from elevated
temperature studies:
If no trends are noted after storage for a period of (x) months at an elevated temperature (at least
10C above the maximum storage temperature proposed for the product) then an interim shelf life
of a maximum of 2(x) months may be permitted, where 2(x) does not exceed 3 years.
Shelf lives of longer than 3 years should be supported by data on production batches stored at
the maximum recommended temperature for the duration of the proposed shelf life.
Stability trials involving at least three production batches stored at the maximum recommended
temperature should in any case be continued for the full period to validate the predicted shelf life.
Interim shelf lives may be extended through submission of additional data accumulated in the
later stages of the trial. Manufacturers should not however that the shelf life may not be extended
until the data have been evaluated be BFAD and a new shelf life agreed.
6. Product Modifications
Manufacturers may not implement changes to pharmaceutical data without prior approval by
BFAD. Applications to make changes should provide details of the proposed change and relevant
pharmaceutical data to the PSD. Whether or not stability data are required will be a matter of
judgment in each case.
These are examples of changes which would normally require supporting stability data:
-
The following are examples of changes which would not normally require justification in terms of
additional stability data provided that adequate stability data are available for the existing product
(note however that data other than stability data may be required):
- tightening of existing specifications for the drug product consistent with existing stability data,
for example narrowing of assay limits for a drug,
- change of site of manufacture of the active raw material or finished products with no other
change to pharmaceutical data,
- an additional pack size for tablets stored in a blister pack with no change of packaging
materials.
The following general comments may assist sponsors in the accumulation of stability data in
particular circumstances.
6.1 Change in Formulation. A proposed to change to a completely new formulation would be
regarded as an application to register a new product and would require
6.2 Change in Packaging. The major consideration in evaluating a proposal for a change in
packaging is the relative protection afforded the product by the new and old packs. If the new
pack is shown to be more protective, e.g. an amber screw-capped glass bottled compared
with a clear PVC bottle, it is likely that no data would be required. Where the pack is less
protective or where some interaction with the container is possible, additional stability data will
be required.
For parenteral or opththalmic solutions in new plastic packs, information on leaching is
important. Appendix XIX of the BP 1993 and <661) of the USP XXIII (1995) provide an outline
of some of the factors to be considered and test methods. Where the new pack has a greater
permeability to moisture, the effects of high humidity on solid dosage forms or the extent of
possible fluid loss from liquid preparations should be considered.
7. Prospective Extensions of Shelf-Life for Individual Batches
Under certain circumstances BFAD may approve a limited extension of shelf life for individual
batches approaching there expiry date in the absence of the stability data that may normally
be necessary. The prerequisites are as follows:
7.1 the existing shelf life should be at least 2 years
7.2 stability data should be available to BFAD which validate the existing shelf life and show
no deterioration of the product during this product
7.3 a recent (less than 2 months old) dated certificate of analysis should be supplied for the
batch showing compliance with specifications, together with the results obtained at batch
release
7.4 the company should provide an assurance that it has commenced or intends to
commence a stability study to validate a permanent extension of the shelf life
8. Shelf-life Extensions According to an Approved Protocol
Shelf lives may be extended in accordance with a stability test protocol which was approved
explicitly for this purpose. Such protocols may be submitted with the application for registration or
subsequent to registration. All of the following conditions apply:
8.1 BFAD must have explicitly approved the protocol for the purpose of self-assessable shelf life
extensions.
8.2 All pharmaceutical aspects of the product, including its immediate container and closure and
labeled storage conditions, are identical to those approved at the time a stability test protocol
was approved, except for changed made in accordance with other parts of this document.
8.3 At least two production batches of the product have been tested in accordance with the
approved stability test protocol.
8.4 The total shelf life is not longer than the time for which stability data meeting the approved
protocol are available on two production batches, and in any case is not longer than 5 years.
8.5 If BFAD requests copies of the additional stability data, these will be supplied within one
month of the request.
8.6 Any stability test protocol proposed for this purpose should include:
8.6.1 A statement of the proposed tests and test methods.
8.6.2 A matrix indicating the time stations at which each of the tests will be conducted.
8.6.3 Acceptable limits for results for each test
Note that:
-
BFAD may impose conditions on the implementation of an approved test protocol, such
as a maximum total shelf life of less than 5 years and
To provide a suitable safety margin, the acceptable limits for results should be somewhat
tighter than expiry specifications. If results are outside these tighter limits but within expiry
specifications, the sponsor has the option of submitting the data for evaluation with an
argument as to why the shelf life should be extended.
the method of synthesis or biosynthesis, proof of structure and purification of the active raw
material
the formulation, method of manufacture and stability of the finished product
specifications (including test methods) of the active raw material, excipients and finished
product
labelling, including shelf life, storage conditions and recommendation for processing prior to
use (e.g. reconstitution of a powder for injection)
bioavailability as applicable
Pilot Production Batch: A quantity of product which is identical in formulation and equivalent in
terms of manufacturing equipment and manufacturing method to a production batch, except for scale.
Semiquantitation: ballpark assays and therefore less desirable than true quantitation. Two
techniques are common:
1. for unknown impurities, a result is assigned on the basis of comparison with known
concentrations of the drug substance, e.g. by colour depth on a TLC plate. This technique is not
preferred as (1) the assumption of similar physicochemical properties for the degradation product
and the drug substance may be incorrect, and (2) even if the assumption is correct, the technique
is only approximate. It is generally used only in cases where the degradation product has not
been identified and is present in only trace amounts.
2. where the degradation product has been identified but is present in very small quantities, a result
is assigned on the basis of comparison with known concentrations of the authentic degradation
product.
In both cases, results are expressed as, for example, less than 0.055 or between 0.01 and
0.055. Expression of results as trace amounts is discouraged as there should normally be some
estimate of the limit of detection.
Stability Guidelines References