Qvents Template |
Excipient Risk Assessment |
Excipient
Name |
|
Material
Code |
|
Excipient Manufacturer |
|
Assessment
Document Number |
|
Material
Origin (Animal / Vegetable / Mineral / Synthesis /Others |
|
|
|
1. Excipient
Source Risk Assessment |
|||
S.NO |
Source risk element |
Risk Category (Low / Medium / High) |
Rationale |
1.
|
TSE
(transmissible spongiform encephalopathy) and BSE (transmissible
spongiform encephalopathy) risk |
|
|
2.
|
Potential for viral contamination |
|
|
3.
|
Potential
for microbiological or endotoxin/pyrogen contamination; |
|
|
4.
|
Potential
for any impurity originating from the raw materials, e.g. aflatoxins or
pesticides |
|
|
5.
|
Potential
for any impurity generated as part of the process and carried over, e.g.
residual solvents and catalysts; |
|
|
6. |
Sterility assurance for excipients claimed to be sterile |
|
|
7. |
Potential for any impurities carried over from other processes,
in absence of dedicated equipment and/or facilities; |
|
|
8. |
Risk of Nitrosating agents /
Nitrosamines from excipient |
|
|
9. |
Stability of excipient; |
|
|
10. |
Risk of storage and transport temperature, cold chain
requirements |
|
|
11. |
Supply chain complexity; |
|
|
12. |
Packaging integrity risk, adulteration, manipulation risk |
|
|
13. |
Manufacturer reliability, track record past performance record
on quality and /or performance issues |
|
|
Risk categorization criteria |
|
1. |
Contamination Risk TSE/ BSE Low:
Not of animal origin, Milk related products like Lactose Medium:
Animal origin, but not from bovine / other animals involving
animal tissues vulnerable for TSE / BSE impact High: Excipient material of bovine animal /other animal origin
involving high-risk tissues, such as the brain and spinal cord |
2. |
Contamination Risk Viral Safety Low: Non Animal or Human Sources Medium: Animal source material
but not involving cell lines/ organs or tissues of human or animal origin,
have effective controls to remove or inactivate potential viral contaminants
like heat treatment, pasteurization, high or low pH treatment, solvent
treatment etc. High: Products derived from invitro culture of cell lines or invivo culture of cell lines or organs or tissues of
human or animal origin, products derived from blood or urine or biological
fluids of human or animal origin |
3. |
Potential for Microbiological or Endotoxin / Pyrogen
contamination Low: Material is not of Animal or Vegetable origin; Material from
Synthetic or Mineral origin with appropriate GMP practices for excipient
manufacturing. Material do not provide a nutrient source for microbial
growth. Medium:
Material is not of Animal or Vegetable origin. Material from
Synthetic origin but can be a nutrient source for microbial growth. High: Material of Animal or Vegetable origin, Material provide a
nutrient source for microbial growth, High water activity |
4. |
Potential for carry over of impurities like Aflatoxins, Pesticide
residues from raw materials Low:
Excipients of mineral or synthetic origin, animal origin High: Excipients of vegetable origin, no risk assessment or controls
for aflatoxins, pesticide residues in raw materials |
5. |
Potential for carry over of impurities from excipient
manufacturing process – Residual solvents, Catalysts, Elemental impurities Low: Manufacturing process do not involve solvents, catalysts Medium: Manufacturing process involve
solvents and / or catalysts, risk assessment available for process impurity
carry over, specification controls in place for potential impurities High:
No risk assessment and / or specification control of process impurities |
6. |
Sterility assurance Low: Excipient is for non-sterile, non-parenteral drug products High:
Excipient is for sterile drug products |
7. |
Potential for carry
over impurities from other processes / products Low: Dedicated facility, dedicated equipment for the product Medium: Multiproduct facility, adequate risk assessment, GMP cleaning
practices, cleaning validation High: Multi product facility, procedural controls on cleaning,
cleaning verification, cleaning validation are poor or absent |
8. |
Nitrosating agents / Nitrosamines risk Low: Animal origin, Mineral origin with no solvents and
reagents with risk of nitrosamines in the process, no process water involved
in manufacture. Process use highly purified water with no chloramine or ozone
in water treatment Medium: Synthetic origin, process has nitrosation
reaction or secondary amines or solvents and reagents which can contribute to
amine residues (DMF, NMP, Quaternary ammonium salts like TBAH), potable water
used in process and water treatment involving Chloramine, Ozone, Multi
product facility with other products having nitrosation
reactions, reagents or secondary amines High: Excipient process has nitrosation
reaction / reagents and amines / amine contributing reagents in same or
different steps |
9. |
Excipient stability / degradation risk Low:
Stable excipient, shelf life and storage conditions are
supported by stability data High: Excipient not known to be highly stable, formal stability data
or studies are absent |
10. |
Storage / Transport condition/
Cold Chain risk Low: No specific storage / transport temperature conditions for
excipient High: Excipient requiring controlled temperature or cold chain
transport |
11. |
Supply Chain complexity Low: Purchased directly from manufacturer, purchased from region
with controls on counterfeiting and security (US, Europe, Canada, Australia),
not repackaged by intermediaries, transported from manufacturer through
qualified carriers, tamperproof containers Medium: Minimum intermediaries in supply chain but reliable, contracts
and agreements in place with intermediaries High:
Complex supply chain with several intermediaries, region of security concerns
and manipulations, no tamper proof seals |
12. |
Packaging Integrity risk Low: Low supply chain
complexity, tamper proof packing and seal High: High supply chain complexity, poor tamper proof
pack, seal integrity |
13. |
Manufacturer Reliability Low: Established manufacturer with reliable track record, no
complaints, no past quality defects or performance rejections (last 3 or more
years) Medium:
Minimal experience with Manufacturer, minor quality or
performance issues in past supplies High: No experience with manufacturer, history of excipient
variability, history of quality failures and complaints |
2. Drug product matrix for
Excipient function risk assessment |
|||||||||||||
Drug Product Attributes |
Excipient functional risk in
the product |
||||||||||||
Drug Product |
Product Code |
Function of the Excipient |
Dosage Form |
Sterile or Non Sterile |
%ge of excipient
in Product |
Daily Patient Intake of Excipient |
Dosage form risk |
Daily Intake risk |
Functional risk |
BA / BE risk |
Composition risk |
Product CQA risk |
Sterility risk |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3. Consolidated Excipient
function risk assessment |
|||
S.NO |
Functional risk element |
Risk Category* (Low / Medium / High) (Mark highest among all products) |
Rationale |
1.
|
Dosage
form risk on patient safety due to type of dosage form |
|
|
2.
|
Risk due to daily intake of excipient on patient safety |
|
|
3.
|
Functional risk due to functionality of the
excipient in the drug product / process |
|
|
4.
|
Risk due to excipient related factors affecting
bioavailability and processability for the drug product |
|
|
5.
|
Risk or impact on drug product quality / performance
due to change / variability in excipient sources / batches |
|
|
6.
|
Risk due to percentage of excipient in the drug
product formulation with respect to contamination carry over, product
attributes |
|
|
7.
|
Risk or impact of excipient on critical quality
attributes (CQAs) of the drug product (due to variability, changes in
excipient) |
|
|
8.
|
Drug product sterility risk due to excipient |
|
|
9.
|
Risk of Composite excipients |
|
|
Excipient function risk
categorization criteria |
|
1.
|
Dosage Form Risk Low: Topical applications and other similar applications Medium: Solid oral dosage forms, liquid oral dosage forms, ingestion
route High: Sterile, Injectables, Parenteral preparations, Ophthalmic
preparations, Products intended to application on open wounds |
2.
|
Daily Intake Risk Low:
Maximum daily dose of excipient does not exceed known maximum dose of the
excipient in any drug product, Acceptable Daily Intake (ADI) by JEFCA (Joint
FAO/WHO Expert Committee on Food Additives), For Topical products, Cosmetic
Ingredient Reviews (CIR) database, USFDA-IID (Inactive Ingredient Database) High:
Maximum daily intake exceeds known maximum dose of excipient material |
3.
|
Functional Risk Low:
Diluent, Coloring agent, Flavor, Sweetening agent, Emollient, Tonicity agent Medium: Thickener, Coating agent, Former, Compression aid, Lubricant,
Glidant, Anticaking agent, Humectant, Suspending / dispersing agent, Buffer,
Adhesive, Penetrant, Disintegrant, Binder, Capsule shell, Plasticizers, pH
modifiers, Chelating and/ or complexing agents, Antioxidants, Suppository
base, Suspending and /or viscosity-increasing agent, Stiffening agent,
Propellant High:
Antimicrobial preservative, Vehicle, Release modifier, Wetting / solubilizing
agent, Process / cleaning water |
4.
|
Function of excipient
in the formulation with respect to bioavailability, processability Low: Factors affecting processability, no significant impact on bio
availability High: Factors affecting bioavailability |
5.
|
Functional
variability and control by specifications Low: Functional attributes or characteristics which affect
functionality is well captures in the Excipient specifications and
controlled, risk of drug product performance variability is low due to
variability in excipient High: Functional attributes of excipient in drug product are not
controlled by excipient specifications (Key Functionality attributes: Bioavailability, Dissolution, Disintegration, Modified release) |
6.
|
Proportion of the
excipient in the medicinal product composition (impact of contaminants) Low: Proportion <5% Medium: Proportion 5-25% High: Proportion >25% |
7.
|
Potential impact on the CQA (critical quality attributes) of the
medicinal product (due to variability, changes in excipients) Low:
If there is nil / minimal impact on CQAs High:
If there can be an impact on CQAs CQAs:
Dissolution, Solubility, Content Uniformity, Impurities, Assay, Stability of
Medicinal product |
8.
|
Sterility assurance Low: Excipient is for non-sterile, non parenteral
drug products High: Excipient is for sterile drug products |
9.
|
Risk of Composite
excipient Low: Excipient is not a composite excipient Medium: Composite or coprocessed excipient,
but all components of the composite excipient are from same type of source High: Composite excipient with components from different
type of source |