Safety Based Limits for the Control of Impurities in Drug Substances and Drug Products: A Review-Juniper Publishers
JUNIPER PUBLISHERS-OPEN ACCESS JOURNAL OF PHARMACY &
PHARMACEUTICAL SCIENCES
Introduction
Paracelsus, the medieval physician, who is often 
viewed as the father of modern toxicology, was the first person to 
appreciate that "the dose makes the poison". This essentially means that
 very toxic materials can be used therapeutically at very low 
concentrations and conversely even safe materials can be toxic if 
overdosed. This in turn led to Haber's law, which basically states that,
 the incidence and/or severity of any toxic effect is dependent on the 
total exposure to the toxic agent; that is, the exposure concentration 
(c) rate(or dose) multiplied by the duration time (t) of exposure (i.e. 
cxt). This law is often utilised in setting exposure limits for toxic 
components. The major caveat, is that establishing acceptable daily 
intakes (ADIs) for long-term exposures to a toxic substance when only 
data from short-term studies are available, does require the use of an 
uncertainty or safety factor.
For example, cancer risk estimates are typically 
based on the average lifetime daily dose (LDD), which in turn is derived
 from the total cumulative exposure, using Haber's law, i.e. cxt. Gaylor
 [1]
 proposed a modified Haber’s law to better extrapolate safe levels based
 on shorter term exposure intervals and this takes the form of:
            c3x t=c’3x t'
where c and t are the known safe exposure levels(c) 
based on the longer exposure duration (t) and c’ and t' are the 
projected safe concentration (c’) based on the pre-defined shorter 
exposure duration (t’). Haber’s law is equally germane to impurities as 
it is to medicinal products.
Impurities in New Drug Substances and New Drug Products (Ich Q3a/ Ich Q3b)
One of the first international guidance that used 
safety based limits for impurities was the international conference on 
harmonization (ICH) Q3A [2].
 This provided an overview of the typical impurities that were found in 
new drug substances and their controls. Impurities were evaluated based 
on both chemistry considerations, including "classification and 
identification of impurities, report generation, listing of impurities 
in specifications, and a brief discussion of analytical  procedures"; 
and safety considerations, including "specific guidance for qualifying 
those impurities that were not present, or were present at substantially
 lower levels, in batches of a new drug substance used in safety and 
clinical studies"
Impurities were further delineated into identified 
and unidentified classes, both of which were included as specification 
tests [3].
 This includes unidentified impurities that were known to be present at 
levels greater than pre-defined reporting, identification and 
qualification threshold (Table 1).
 Those unidentified impurities are often defined on the drug substance 
specification "by an appropriate qualitative analytical descriptive 
label (e.g., "unidentified A", "unidentified with relative retention of 
0.9")"

1. The amount of drug substance administered per day;
2. Reporting Threshold: A limit above (>) which an
 impurity should be reported. Reporting threshold is the same as 
reporting level in Q2B (4);
3. Higher reporting thresholds should be scientifically justified;
4. Lower thresholds can be appropriate if the impurity is unusually toxic;
 5 Identification Thresholds: A limit above (>) which an impurity should be identified;
 6 Qualification Thresholds: A limit above (>) which an impurity should be qualified
The reporting threshold was linked to the capability of the supporting analytical methodology [4].
 Identification threshold was the limit where the unknown impurity was 
required to be identified by appropriate analytical methodology. 
Whereas, the qualification threshold necessitated acquiring and 
evaluating pre-clinical safety data that "establishes the biological 
safety of an individual impurity or a given impurity profile at the 
level(s) specified".
Interestingly, although the derivation of the 
reporting threshold was linked to method capability, the derivation of 
the identification and qualification threshold limits were never fully 
delineated, apart from linkage with the maximum daily dose of the 
product. In addition, for those impurities "known to be unusually potent
 or to produce toxic or unexpected pharmacological effects, the 
quantitation/detection limit of the analytical procedures should be 
commensurate with the level at which the impurities should be 
controlled". Again, the implicit meaning of this statement was never 
fully articulated, but it was the genesis for the subsequent guidance on
 mutagenic impurities, initially termed genotoxic impurities [5].
Similar guidance was provided for impurities 
typically found in new drug products. These impurities are usually 
termed degradation products [6]. There was greater delineation of the thresholds in terms of dose (Table 2).
 However, it was never fully explained why the various thresholds, in 
terms of maximum daily dose, could not be aligned. Thus there is the 
confusing scenario that the reporting thresholds are above or below 1g; 
whereas, the identification thresholds are divided into four (>2g, 
>10mg- 2g, 1mg-10mg and <1mg); whilst the qualification thresholds
 were also divided into four, but were not aligned with the classes 
defined in the identification thresholds (>2g, >100mg-2g, 10mg- 
100mg and <10mg).

1 The amount of drug substance administered per day;
2 Thresholds for degradation products are expressed 
either as a percentage of the drug substance or as total daily intake 
(TDI) of the degradation product. Lower thresholds can be appropriate if
 the degradation product is unusually toxic;
3 Higher thresholds should be scientifically justified.
The other confusing aspect was that the maximum daily
 dose (mg/day) and the maximum strength of a product (mg) are often not 
the same value. Thus for instance, the anti-malarial drug quinine 
sulfate [7]
 has a maximum therapeutic dose from the product label of 648mg every 
8hours, i.e. 1944mg/day; whereas, the highest dose strength are 
324mg/capsule. The analysts testing and releasing quinine sulfate 
capsules will do so on the commercial product (324mg/capsule), not the 
maximum dose taken by the patient (1944mg/day). In addition, although 
reporting thresholds are always measured as percentage values and are 
easily aligned with the data output from the method used by the analyst;
 identification and qualification thresholds are measured in either 
percentage values or mg/day values (Table 3).

The other aspect of having safety based limits for 
impurities is that it does not reflect the duration of treatment use for
 that drug and results in the same limits being proposed irrespective of
 whether the drug is proscribed pro ne rata (PRN) or as required,
 e.g. for constipation, mild pain, etc., or through life time 
treatments, e.g. for treatment of high blood pressure, etc. ICH Q3A [2] and Q3B [6]
 were always intended to be only applicable to marketed products, but 
the regulatory expectations during clinical development often exceed 
what is actually required. For example, it isn't unusual to see the 
following expectations [8]: "For phase I expect structure (or identifier) and 
origin For phase II expect Limit of Detection and Quantification and 
actual impurity levels to be established (aligned with ICH Q3A, Q3B, 
etc)".
However, by phase II the final synthetic route and 
process of the drug substance are rarely identified or optimised, and 
the attrition rate of phase II drugs is still very high [9]. What the regulatory guidance enshrined in ICH M3 [10],
 actually states with respect to impurities is, "If specific studies are
 warranted to qualify an impurity or degradant, generally these studies 
are not warranted before phase 3 unless there are changes that result in
 a significant new impurity profile (e.g., a new synthetic pathway, a 
new degradant formed by interactions between the components of the 
formulation). In these latter cases, appropriate qualification studies 
can be warranted to support phase 2 or later stages of development"
Residual Solvent Impurities (ICH Q3C)
Although residual solvents are mentioned in ICH Q3A [2], a separate guideline, ICH Q3C [11],
 was developed to provide safety based guidance on the allowable limits 
of common residual solvents within pharmaceuticals. As there are "no 
therapeutic benefits from residual solvents, all residual solvents 
should be removed to the extent possible to meet product specifications,
 good manufacturing practices, or other quality based requirements". 
Additionally, ICH Q3C recommends the use of less toxic solvents. Thus, 
solvents that are known to be highly toxic (Class 1) should be avoided 
during the production of drug substances, excipients, and especially 
drug products, unless their usage can be justified using a risk-benefit 
assessment [12].
 In addition, some solvents with intermediate toxicity (Class 2) should 
also be limited from a patient safety perspective. Ideally, the least 
toxic solvents (Class 3) should always be used where practical. 
Recommended limits for all solvents may change as additional safety data
 become available. In addition, supporting safety data for new solvents 
may be added to the guidance.
Although tolerable daily intake (TDI) and acceptable 
daily intake (ADI) were both in common usage, ICH Q3C (12) introduced a 
new term, permitted daily exposure (PDE) to avoid confusion of differing
 values for ADI's for the same substance. In addition to avoidance of 
class 1 solvents, the concept of "as low as reasonably practicable" 
(ALARP) was introduced and is applied to class 2 solvents and often to 
class 3 solvents. Indeed, regulatory agencies will often use process 
capability arguments to drive down residual solvent levels below the 
safety based limits [13] derived from ICH Q3C.
Residual Elemental Impurities (ICH Q3D)
Residual elemental impurities were also mentioned in ICH Q3A [2],
 but again a separate guideline, ICH Q3D (14) was developed to provide 
safety based guidance on the allowable limits of residual elements 
within pharmaceuticals. As elemental impurities provide no therapeutic 
benefit to the patient, "their levels in the drug product should be 
controlled within acceptable limits" [14].
The ICH Q3D guideline is sub-divided into three 
parts: the derivation and assessment of toxicity data; the establishment
 of a PDE for each elemental impurity derived for three different routes
 of administration (oral, inhaled and parenteral); and application of a 
risk based approach to control elemental impurities (as per ICH Q9 
(12)). One difference from ICH Q3C [11]
 is that applicants are not expected to tighten the safety based limits 
based on process capability considerations, as long as the residual 
elemental impurities do not exceed the PDE values. However, in certain 
cases, levels below the PDE may be warranted when lower levels have been
 shown to positively impact on other critical quality attributes (CQAs) 
of the drug product; for example, element catalyzed drug degradation 
(this is particularly common with oxidative degradation mechanisms [15].
 In addition, for those elements with higher PDEs, lower limits may have
 to be assessed from a pharmaceutical quality perspective. Residual 
elements are classified into 5 different categories: class 1, 2a, 2b, 3 
and others (Table 4).

ICH Q3D [14]
 provides a platform for developing an ICH Q9 (12) aligned risk-based 
control strategy to limit elemental impurities within the drug product. 
Although, the guidance had highlighted the risk inherent from both drug 
substance and excipients, the reality based on a multi-product 
assessment is that the risk is low. Li et al. [16]
 tested 190 samples from 31 different excipients and 15 samples from 
eight different drug substances for residual elemental impurities. The 
results show relatively low levels of elemental impurities are present 
in the samples tested.
Residual mutagenic impurities (ICH M7)
ICH M7 [5]
 is focused on DNA reactive impurities that can potentially cause DNA 
damage, when present at low levels, and thus can potentially cause 
cancer in man. Importantly, other types of toxic impurities that are 
non-mutagenic will typically have a threshold mechanism and as such 
usually do not pose carcinogenic risk in man, at the levels typically 
seen for impurities.
A Threshold of Toxicological Concern (TTC) approach 
was introduced to describe an "acceptable intake for any unstudied 
chemical that poses a negligible risk of carcinogenicity or other toxic 
effects", this equates to a virtually safe dose (VSD). The methodologies
 that underpin the TTC are universally considered to be very 
conservative, as they use a simple linear extrapolation from the TD50 dose (i.e. dose giving a 50% tumor incidence) to a 1 in 106 likelihood of cancer occurrence.
A default TTC value of 1.5μg/day corresponding to a theoretical 10-5
 excess lifetime risk of cancer can therefore be justified for mutagenic
 impurities. Some high potency groups referred to as the "cohort of 
concern", e.g. aflatoxin-like-, N-nitroso-, and alkyl-azoxy compounds; 
were identified where the default TTC would still pose a significant 
carcinogenic risk. These high potency compounds were excluded from the 
TTC approach.
ICH M7 [5] bases acceptable intakes for mutagenic impurities on established risk assessment approaches (see ICH Q9 [12].
 As such, acceptable risk during the early development phase is 
established at a higher theoretically calculated risk level of 
approximately one additional cancer incidence per million, i.e. 1 in 106
 risk levels. For later stages in development (Phase III) and for 
commercial products, the risk level is reduced to one in one hundred 
thousand, i.e. 1 in 105 risk levels. It is worth 
highlighting, that these risk levels represent a small theoretical 
increase in risk when compared to the overall lifetime incidence of 
developing cancer in man, which is greater than 1 in 3.
The initial risk assessment is undertaken on the drug
 substance synthetic pathway to identify real or potential impurities 
that may be reactive and thereby mutagenic in nature. In parallel, the 
formulation and manufacturing process are also assessed for the 
formation of any reactive degradants (both real and potential), that 
could be realistically expected to form during long term, real-time 
storage conditions. In silico structure- based assessments, i.e. Derek 
Nexus, Sarah Nexus, etc., are used for predicting mutagenicity based 
upon QSAR (quantitative structure activity relationships) approaches. 
These findings are then reviewed by toxicology experts to provide any 
additional understanding as to the relevance of these predictions (both 
positive and negative), and in the case of contradictory outcomes to 
understand those differences. Based on this assessment, impurities are 
categorised into five different classes in order of decreasing 
regulatory concern (Table 5).

1. For class 1 compounds, i.e. those which are known 
mutagenic carcinogens, an AI (acceptable intake) or a PDE (permitted 
daily exposure)approach has been introduced (ICH M7(R1) (17)). These 
limits are based on either (i) linear extrapolations from TD50 (AI) or 
(ii) threshold-based PDEs. There are 10 compounds covered by the AI 
approach and a further 3 covered by the PDE approach.
2. LTL (less than lifetime limits)
3. TTC (Threshold of Toxicological Concern)
It is anticipated that monitoring and control 
strategies (including analytical methods) will be less developed during 
earlier clinical phases, where overall development experience is of 
necessity limited, compared to later clinical phases and commercial 
manufacture. ICH M7 [17]
 proposesa control strategy using four control options for mutagenic 
impurities, of these only one includes control of the mutagenic impurity
 on the API specification (option 1). Options 2 and 3 define some levels
 of in-process control; whereas, option 4 is centred on process 
understanding alone, typically termed "Purge Arguments" [18].
It is should be emphasised that these established 
cancer risk assessments are based on lifetime exposures, i.e. 75 years. 
Thus, Less-Than-Lifetime (LTL) exposure based limits can be derived both
 during development and commercial use. LTLs can have higher acceptable 
intakes of mutagenic impurities and still maintain comparable risk 
levels, which is obviously an application of Haber's law. Therefore, the
 carcinogenic effect is predicated on both duration of exposure and 
dose. Thus for example, "if the compound specific acceptable intake is 
15 |ig/day for lifetime exposure, the less than lifetime limits (Table 6)
 can be increased to a daily intake of 100 |ig (>1-10 years treatment
 duration), 200 |ig (>1-12 months) or 1200|ig (<1month)" [5].
 This LTL approach may also be appropriate "in diseases with reduced 
life expectancy, limited therapeutic alternatives or chronic diseases 
with late onset" [19].

It is worth emphasising that exceeding the default 
TTC or LTL limits is not necessarily linked with an increased cancer 
risk in man, given the extremely conservative suppositions employed in 
the evolution and derivation of the TTC or LTL values. For instance, 
higher exposure to a potential mutagenic impurity, e.g. formaldehyde, 
may be reasonable when exposure can be significantly greater from other 
sources, e.g. endogenous metabolism, food, etc. The most likely increase
 in cancer incidence is actually much less than 1 in 100,000. In 
addition, in cases where a mutagenic compound is a non-carcinogen in a 
rodent bioassay, there would be no predicted increase in cancer risk. 
Based on all the above considerations, any exposure to an impurity that 
is later identified as a mutagen is not necessarily associated with an 
increased cancer risk for patients already exposed to the impurity. A 
risk assessment would determine whether any further actions would be 
taken
In principle, ICH M7 does not apply to advanced 
cancer therapeutic indications (covered by ICH S9 (20)), where the drug 
is itself genotoxic. ICH M7 does not apply to established excipients, 
flavouring agents and certain biological products, including herbal 
medicines. Existing commercial products are also exempted, apart from 
where there are new safety data (including new mutagenic data) for 
existing impurities; significantly, structural alerts alone do not 
trigger regulatory concern. However, ICH M7 does cover changes to 
marketed products, including new marketing applications and postapproval
 submissions.
Impurities in oncology products (ICH S9)
ICH S9 [20]
 was developed to provide guidance for nonclinical studies for the 
development of anticancer pharmaceuticals used in clinical trials for 
the treatment of patients with advanced disease and limited therapeutic 
options. During the development of oncology products, supporting 
clinical studies often involve cancer patients whose prognosis is poor 
and projected lifetime is short (<2 years).
As such, the guideline objectives are to facilitate 
and accelerate the development of these anticancer pharmaceuticals 
whilst protecting patients from unnecessary adverse effects. In 
addition, ethical use of animals, in accordance with the 3R principles 
(reduce/refine/replace) are paramount. Importantly, the principles 
described in other ICH guidelines need to be considered in the 
development of oncology products; whereas, those specific situations 
where requirements for nonclinical testing may diverge from other 
guidance are described in ICH S9.
Additionally, the dose levels used in these clinical oncology studies are often at the top end of the tolerable range [21]
 and often result in adverse effect dose levels. Hence, "the type, 
timing and flexibility called for in the design of nonclinical studies 
of anticancer pharmaceuticals can differ" significantly from nononcology
 pharmaceuticals. Historically, limits for impurities (see ICH Q3A [2] and Q3B [6]
 have been based on a negligible risk to the patient. In oncology 
products this consideration, whilst important, is not as important as 
patient wellbeing and exceeding the ICH Q3A [2]/Q3B [6] limits for impurities may be applicable and an appropriate justification should be included in the marketing application.
This explanation should include an overview of the 
disease being treated, including patient prognosis, the nature of the 
drug itself (pharmacology, genotoxicity and carcinogenicity, etc.), the 
total duration of treatment, and the impact of any reduction in impurity
 levels on manufacturability. Furthermore, the qualification of these 
impurities may include reflections on the concentration tested in 
supporting nonclinical studies compared to the levels seen in clinical 
batches. In addition, TTC, LTL and AI/PDE limits for mutagenic 
impurities (see ICH M7 [5])
 are inappropriate for oncology products and justifications can be used 
to set higher limits. Interestingly, the guidance does not specifically 
say that the applicant can default to ICH Q3A [2]/ Q3B [6] limits, although this is often inferred. Impurities that are also metabolites can be considered to be suitably qualified.
Interestingly, regulators have been very unwilling to extend the philosophy of ICH S9 [20] beyond oncology products, for instance into rare diseases [22], where lifetime expectancy can be similarly short, i.e. <2 years and where patient expectations are equally high.
New Reflections on Impurities
Harvey et al. [23]
 used a variety of chemical databases to demonstrate that the 1mg/day 
impurity level for an unqualified impurity of unknown toxicity, proposed
 by ICH Q3A [2] (Table 1)
 is indeed a robust prediction of a virtually safe dose (VSD) for 
non-mutagenic impurities. Then using the modified Haber's law, where C=1
 mg and t=75 years (i.e., 27375 days) and t is 6 months or 182 days they
 determined a VSD for this shorter exposure interval of 5 mg/day (i.e. 5
 times higher than existing ICH Q3A limit). However, for very potent 
drugs with effective doses of <1mg, a 5mg/day limit for a related 
impurity isn't realistic from either a safety or quality perspective. 
Therefore, the authors also introduced a percentage cut off based on 5x 
the ICH Q3A qualification threshold of 0.15%; i.e. 0.7%. Thus the 
proposed limits for drug substances are 5mg or 0.7%, whichever is lower.
This allows applicants to adopt the existing ICH Q3A 
guideline which were developed for commercial products and apply them to
 development products, in much the same way that the ICH M7 guidelines 
allows LTL limits for mutagenic impurities, for early clinical 
development. For drug products, similar LTL limits for non-mutagenic 
impurities can be derived based on a modification of Haber’s law. The 
additional constraint of a percentage limit of 0.7% need not be applied 
to drug products as the more potent the drug substance becomes, the 
lower the dose required. The authors therefore suggested a limit of 5 mg
 or 2%, whichever is lower, for exposure intervals of <6 months, for 
general drug substance impurities, i.e. non-mutagenic.
In addition to absolute amounts of unknown 
impurities, the other key focus is those impurities with unusually high 
and/ or specific toxicities. Whilst it is recognised that mutagenic 
impurities constitute the greatest threat to patient safety and they 
have been addressed via ICH M7; there are other classes of non-mutagenic
 impurities that will still give cause for concern. The three principal 
classes of toxic impurities are
(i) polyhalogenated, dibenzodioxins, dibenzofurans 
and biphenyls that are non-mutagenic carcinogens, which have specific 
regulatory framework with respect to acceptable exposure levels [24],
(ii) organophosphates or carbamates that are neurotoxins and have their own threshold of concern [25]
 and (iii) β- lactam like impurities that have the potential to cause 
anaphylaxis and which currently do not have any threshold of concern [23].
It is worth highlighting that
(a) These impurities are extremely rare and do not reflect the typical structure of impurities generated by medicinal research [26,27] and
(b) That these structural motifs (if present) would be highlighted and addressed as part of the ICH M7 risk assessment [5] , as "the findings from any mutagenic risk assessment are also reviewed by toxicology experts"
Conclusion
Safety based impurity limits are a core consideration
 of all of the existing ICH Q3 guidance documents. However, there has 
been an evolution in the approach toward impurities since the 
publication of the initial guidance [2,6]. Whereas, ICH Q3A [2] and Q3B [6]
 provide general guidance on impurities in drug substances and drug 
products, respectively and mainly focus on absolute levels of 
impurities, i.e. percentage based limits; later guidance focused on 
individual impurity classes; i.e. residual solvents [11], residual elemental impurities [14] and mutagenic impurities [5]
 and had a greater focus on daily exposure limits. In the latter cases, 
this led to the introduction of various impurity specific limits, such 
as PDEs, Als, TTCs and staged TTCs, all aimed at defining a virtually 
safe dose (VSD). This in turn led to the introduction of LTL limits for 
mutagenic impurities.
LTLs are based on an application of Haber's law which
 states that concentration and exposure times are both critical for 
assessing likely safety risk to patients. Surprisingly, LTLs have not 
been applied to the other specific classes of impurities or indeed 
general impurities. In order to address this deficiency, Harvey et al. [23] have assessed the underpinning data behind the current "1mg or 1%, whichever is lower" limit in ICH Q3A [2] /Q3B [6],
 and they found this to be based on robust science and they proposed an 
ancillary LTL for general impurities of 5 mg or 0.7%, whichever is 
lower, for clinical studies with durations of less than 6 months.
Logically, the toxicity of the parent drug substance 
also affects how we deal with impurities, even very toxic impurities. 
Thus, there is limited, if any, additional impact on patient safety for 
impurities where the parent drug substance is mutagenic, carcinogenic or
 cytotoxic. Accordingly it was recognised that for oncology products, 
impurity levels (even mutagenic impurities) could be controlled at 
higher levels. This "higher level" wasn’t defined but is based on an 
overview of the disease being treated, including patient prognosis, and 
the nature of the drug itself. Additionally, from a risk based 
perspective and an understanding of Haber's law, an overt focus on 
impurity control makes little sense if the life expectancy of the 
affected patient is short, i.e. less than 2 years [20].
 Interestingly, there has been little regulatory appetite for widening 
this entirely pragmatic approach to impurity control to other 
therapeutic areas, where life expectancy is equally short, i.e. rare 
diseases [22].
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