This document provides clarification on questions regarding the implementation and requirements of the ASEAN Guideline on Stability Study of Drug Product. It addresses general issues such as applicability to APIs and established products, as well as issues related to study design elements including photostability testing, batch selection, specification testing parameters, testing frequency, storage conditions, container closure systems, and evaluation. Clarification is provided on topics such as the definition of permeable/impermeable packaging, need for statistical analysis, and requirements for data from less stressful conditions.
This document provides clarification on questions regarding the implementation and requirements of the ASEAN Guideline on Stability Study of Drug Product. It addresses general issues such as applicability to APIs and established products, as well as issues related to study design elements including photostability testing, batch selection, specification testing parameters, testing frequency, storage conditions, container closure systems, and evaluation. Clarification is provided on topics such as the definition of permeable/impermeable packaging, need for statistical analysis, and requirements for data from less stressful conditions.
This document provides clarification on questions regarding the implementation and requirements of the ASEAN Guideline on Stability Study of Drug Product. It addresses general issues such as applicability to APIs and established products, as well as issues related to study design elements including photostability testing, batch selection, specification testing parameters, testing frequency, storage conditions, container closure systems, and evaluation. Clarification is provided on topics such as the definition of permeable/impermeable packaging, need for statistical analysis, and requirements for data from less stressful conditions.
Questions and Answers/Issues ERSION ! " #" No$e%&er '##( 1 AGL STABILITY Q)A ERSION ! " Ta&*e o+ Contents 1. Introduction 2. General Issues 3. Issues in Design 4. Issues in Annexes 2 ", Introdu-tion This document is intended to provide additional information for the preparation of an application file (ATD!"ualit# section dealing $ith %ta&ilit#'. It should &e read in con(unction $ith the A%)A* %ta&ilit# Guideline
"," A..*i-a&i*it/ o+ ASEAN sta&i*it/ 0uide*ines1 "1 + It needs to &e clarified if this guideline applies to *)s onl#. Does the A%)A* %ta&ilit# Guideline appl# to the sta&ilit# and storage conditions of the Active ,harmaceutical Ingredient (A,I'- A1 + It is alread# mentioned in the scope of the guideline that the drug products covered in this guideline are *)s. Generics and /ariations (if re0uired'. it does not include Active ,harmaceutical Ingredient (A,I'. &iologics1&iotech products. and drug products containing vitamin and mineral preparation. ",' I%.a-t on renewa*s "1 + The impact on the life c#cle management of esta&lished products $hich are alread# registered in A%)A* region also needs clarification. 2or example. $hat is the impact on rene$als ! $ould sta&ilit# need to &e conducted at the ne$ conditions- A1 + 2or products alread# registered in the A%)A* region $here the sta&ilit# profile has &een esta&lished and there is no evidence of adverse events reported there is no need to conduct sta&ilit# at the ne$ condition. ,roof of the existing shelf life can &e o&tained from ,ost 3ar4et %ta&ilit# 3onitoring ,rogram1on going sta&ilit#.. ",2 Lead ti%e &e+ore i%.*e%entation "1 + The proposed A%)A* conditions ma# force to pac4age design of man# products and ne$ sta&ilit# testing to esta&lish a ne$ shelf life. 5hat $ould &e the lead time allo$ed for compliance &efore implementation- A1 + 6ead time (Decem&er 31. 2778' for implementation has &een decided &# consensus in 9a4arta 3eeting (9anuar# 2774' "2 + 5hat is the Impact on ,ending Approval ,roducts (product registrations have &een su&mitted prior to the implementation date &ut revie$ is under$a# $hen the mandator# implementation comes effective' - A2 + ountries ma# decide independentl# on product that have &een su&mitted prior to the implementation date. %ince the date of implementation is onl# a formal start on mandator# implementation to accept TD format and the re0uirements according to ATD.
', Genera* Issues '," Additiona* C*ari+i-ation "1 + :indl# provide the selection criteria for the term ;esta&lished products<. The term ;esta&lished products< should &e clearl# defined. A1 + )sta&lished product means a product that is registered &efore the A%)A* sta&ilit# mandator# implementation date i.e. 31 st Decem&er 2778 and sho$n to &e sta&le under real mar4et condition. "2 + :indl# clarif# on the nature of =adverse events>. %hould it &e of 0ualit# in nature. A2 + Adverse events means undesira&le events related to 0ualit# under storage condition. 3 ',' Sta&i*it/ Data +or 3a4or and 3inor ariations ','," Sta&i*it/ -onditions 2, Issues in Desi0n 2," P5otosta&i*it/ Testin0 "1 + Is photosta&ilit# testing necessar# for all products- A1 + *o. onl# if appropriate li4e in the case of *) and products that are photosensitive. 2,' Se*e-tion o+ Bat-5es "1 + 2or conventional dosage forms (e.g. immediate release solid dosage forms. solutions' and $hen the drug su&stances are 4no$n to &e sta&le. sta&ilit# data on at least t$o pilot scale &atches are accepta&le. ,lease clarif# if this is onl# valid for generics and variations and not for *). A1 + ?es. It applies onl# to generics and variations since the sta&ilit# of *) has not &een #et esta&lished. "2 + 2or Generics and /ariations6 *um&er of @atches for Accelerated %tud# is min. 2 for &oth conventional and critical dosage forms. please confirm that 2 &atches are accepted for &oth as it should &e the same num&er as in Aeal Time %tud# A2 + 2or conventional dosage forms (e.g. immediate release solid dosage forms. solutions' and $hen the drug su&stances are 4no$n to &e sta&le. sta&ilit# data on at least t$o pilot scale &atches are accepta&le. 2or critical dosage forms (e.g. prolonged release forms' or $hen the drug su&stances are 4no$n to &e unsta&le. sta&ilit# data on three primar# &atches are to &e provided. The same num&er of &atches are re0uired for real time stud#. 2,2 S.e-i+i-ation 7Testin0 Para%eter8 "1 + )xtracta&les $ould &e expected for ophthalmic products in sta&ilit# studies ! compan# might perform an extracta&les evaluation &ut $ould not normall# include this in sta&ilit# testing. A1 + )xtracta&les is part of development $or4 or investigation of a ne$ container component extractive studies to identif# all potential extractives from the container (e.g. plastic &ottle. ru&&er stopper' ma# &e underta4en. In most of cases (and from practical perspective' this can &e done at starting and end time points in sta&ilit# testing. 2,9 Testin0 Fre:uen-/ "1 + Alternatives to accelerated stud#. ,lease clarif# and give example of the case &eing applied $ith this condition. A1 + ,lease refer to the updated version of the Guideline %ta&ilit# (%ection 4.B.2 C Alternatives to Accelerated %tud# has &een deleted and ignore the relevant statement on testing fre0uenc# in section 4.D 2,; Stora0e Condition 7Genera* Case8 "1 + 5hat are the o&(ectives of stress stud#- 5hat is the stress stud# condition- A1 + %tress studies are necessar# for anal#tical method validation. pharmaceutical formulation. identif#ing and monitoring potential degradants in the finished product during sta&ilit# testing etc. onsiderations in favour of stress sta&ilit# testing+ 4 1. intrinsic sta&ilit# of the molecule 2. identification of li4el# degradants 3. no standard method. 17!37E degradation. stress factors. conditions and time 4. solid state degradation (supporting information &ecause decomposition at high temperatures ma# ta4e place &# a different reaction mechanism'. In the 9a4arta meeting $e onl# sho$ed that 47 7 1FDE AG is more stressful than 2D 7 187E AG as far as humidit# is concerned. It means sta&ilit# testing at an extremel# high humidit# condition. e.g.. 2DH187E AG. as recommended &# IG is not necessar# if data from accelerated studies at 47 7 1FDE AG are availa&le. "2 + %tress studies are not needed for anal#tical method validation. It is done to o&tain data earl# on. on the overall sta&ilit# of the compound A2 + It is needed for the development of anal#tical procedures earl# on $hich then needs to &e validated. %pecial emphasis should &e given to specificit# of sta&ilit# indicating methods "3 + 2or *) Drug ,roducts. meaning of ;long!term< ma# &e different to that of ;real time<. A3 + According to the glossaries. the $ords ;real!time< used &# A%)A* and ;long! term< used &# IG have the same meaning. 2,( Container C*osure S/ste% "1 + ,ermea&le!impermea&le needs definition in the case of foils1films used in &lister pac4ing of ta&lets and capsules. In addition the sampling of the primar# pac4aging material is a critical 0ualit# issue and the specifications ma# not sufficientl# protect the product. if the &listering operation has not &een properl# validated. A1 + The classification of pac4aging as moisture!permea&le or moisture! impermea&le should &e evaluated &ased on actual data on $ater vapor permea&ilit# (A%)A* Guideline provides a start'. There should &e flexi&ilit# in the definition of pac4 permea&ilit# to allo$ scientificall# ro&ust arguments to &e provided on a product &# product &asis. The sta&ilit# of a product depends not onl# on the nature of the pac4aging material &ut also on factors such as conditions during pac4aging. pac4 design and pac4 geometr#. including headspace. This matter should &e discussed further $ith the expert forum1committee. "2 + 2or all semi!permea&le container. should data on $ater permea&ilit# al$a#s &e su&mitted in all sta&le and less sta&le drug- A2 + *o. if it is 4no$n $ith certaint# that the degradation mechanism is not $ater mediated. 2,< E$a*uation "1 + %tatistical anal#sis could &e expected for initial applications and products sho$ing variation in sta&ilit# profile C including IDE confidence intervals as $ell as regression anal#sis. of degradants as $ell as assa# ! this $ould re0uire additional anal#sis. A1 + %tatistical Anal#sis is not al$a#s necessar#. onfer IG "1)+ 5here the long!term data and accelerated data for an attri&ute sho$ little or no change over time and little or no varia&ilit#. a statistical anal#sis is normall# considered unnecessar# &ut (ustification for the omission should &e provided. 5 2,= Sta&i*it/ Co%%it%ent "1 + If su&mitted data is &ased on conditions that are less stressful (e.g. 37o1BDE AG' than those re0uired (37 o 1FDE AG'. $hat has to &e done- A1 + In the transition period (until end of 2778. national authorities ma# decide either not to allocate a shelf life and to re0uire more data &efore the product is approved. or to allocate a shelf life &ased on technical (udgement and to re0uire a commitment that the applicant $ill generate data under the ne$ guideline conditions (37 o 1FDE AG. or 47 o 1FDE AG. or &oth' $ithin a specified period. 2,> State%ents/La&e*in0 "1 + It $ould &e good to provide a la&eling guidance similar to the )3)A Guidance e.g. if the sta&ilit# is conducted at 37 o 1FDE AG then storage condition $ording could &e ;%tore &elo$ 37 o <. @ut for storage condition of ;%tore &elo$ 2D o <. then $hat is the suita&le sta&ilit# testing condition. at 2D o 1FDE AG-' A1 + onfer ,3,1"5,1B7I1IB1Aev 1 *ote for Guidance on Declaration of %torage onditions+ Aesults from sta&ilit# studies. presented at the time of su&mission. should serve as guidance and there should &e a direct lin4age &et$een the la&el statements and the demonstrated sta&ilit# characteristics of the finished product. The relevant storage condition can &e used &ased on product characteristics during product development stage e.g. 2D 7 1B7EAG. 37 7 1FDEAG 9, Issues in Anne?es 9," Redu-ed Desi0n 7Bra-@etin0 and 3atri?in08 9, ' E?tra.o*ation o+ Data "1 + %u&mitted data for real time storage is for 12 months onl#. Go$ever. statistical anal#sis indicate that the shelf life can &e 4 #ears. 5ill an extrapolated shelf life of 4 #ears &e granted- A1 + *o. The extrapolated shelf!life ma# &e up to t$ice. &ut should not &e more than 12 months &e#ond. the period covered &# real time data. depending on the change over time. varia&ilit# of data o&served. proposed storage conditions and extent of statistical anal#ses performed. onfer Appendix A+ Decision Tree for Data )valuation for Aetest ,eriod or %helf 6ife )stimation for Drug %u&stances or ,roducts in "1) )/A6JATIK* 2KA %TA@I6IT? DATA 9,2, E?a%.*e o+ T/.es6 T5i-@ness and Per%ea&i*it/ Coe++i-ient o+ Pa-@a0in0 3ateria*s "1 + Due to variation in ph#sical characteristic of pac4aging material &eing used &# drug manufacturers (all semi!permea&le container'. should data on $ater permea&ilit# al$a#s &e su&mitted in all sta&le and less sta&le drug- A1 + As far as it concerns the material #es. &ut please note that the sta&ilit# of a product depends not onl# on the nature of the pac4aging material &ut also on factors such as conditions during pac4aging. pac4 design and pac4 geometr#. including headspace. 6