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[RegAffairs]Re: Holding Time and Kinetic Mean Temperature

Re Stability issues related to shipping
1. ICHQ1A [R2] section 2.2.7 requires stability under storage and 
time conditions sufficient to cover storage, shipment and use-so this 
is the regulatory basis for the requirement

2. The best way to do this is during the development phase and 
include it as a separate section in the development report as 
required by ICH Q8

3. As to details, current ICH just has general requirements for one 
off testing during the development phase. For guidance purposes 
however I would refer you to an older document-The FDA Guidance for 
Industry 1998-Stability testing of drug substances and drug products. 
Although this has been replaced by ICH what was excellent was that it 
gave specific requirements for different dosage forms and it gives 
details of thermal cycling [sometimes mistakenly called freeze and 
thaw]

I quote from the guidance-----
A study of the effects of temperature variations particularly if 
appropriate for the shipping and storage conditions of certain drug 
products should be considered...........As part of the stress 
testing.\the phackaged drug product should be cycled through 
temperature conditions that simulate the changes likely to be 
encountered......

Suggestions regarding thermal cycling is given.

4. My experience is that thermal cycling-three cycles normally, is 
much more revealing than any accelerated testing-obviously Arrhenius 
is inapplicable .

5. The testing is always related to physical changes in the product 
rather than simple chemical assay---so for example for tablets it is 
things like hardness, friability, disintegration and particularly 
dissolution that would require testing.

Regarding the response of the regulatory authorities-as usual it 
depends on the authority-and on the individual. My experience is that 
if it is included in the development report in a reasonable way there 
should be no problems. If it was ignored completely, then some 
reviewers in countries who dont experience dramatic temperature 
changes will probably not pick it up.


I trust that provides everything you require


Dr. Malcolm Ross
Generapharm-Training and Consultancy
Basel, Switzerland
m.ross@generapharm.eu


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