USP: Plastic Components and Systems Used in the Manufacturing of Drug Products


Posted on the ECA website on May 24, 2017

The USP General Chapters—Packaging and Distribution Expert Committee proposes two new general chapters to address the qualification of polymeric components used in the manufacture of both pharmaceutical and biopharmaceutical active pharmaceutical ingredients (APIs) and drug products (DPs):

  • Chapter 665 Polymeric Components and Systems Used in the Manufacturing of Pharmaceutical and Biopharmaceutical Drug Products;
  • Chapter 1665 Plastic Components and Systems Used to Manufacture Pharmaceutical Drug Products.

The drafts of these two chapters have been published for public comment in Pharmacopeial Forum (PF) 43(3) [May–Jun. 2017]. Deadline for comments is July 31, 2017.

Chapter 665 was initially published as Plastic Components and Systems Used in Pharmaceutical Manufacturing 661.3  in PF 42(3) [May–June 2016]. The current proposals take into account comments received on the 661.3 proposal and from the USP Biocompatibility and Material Characterization Workshop held June 20–21, 2016. The chapter number 1665 was previously assigned to a proposed new general chapter Toxicological Safety Assessment of Extractables and Leachables (announced in the stimuli article “USP Plastic Packaging General Chapters: An Overview” in PF 39(6)). However, chapter number 1665 is now assigned to the proposed new general chapter Plastic Components and Systems Used to Manufacture Pharmaceutical Drug Products.

Chapter 665 is structured as follows:


3.1 Initial Assessment:

  • Examines whether a polymeric material, component, or system is fit for its intended use (with respect to patient safety) without further characterization.
  • The first and second steps consider whether there is contact between a component and a process stream and whether the process stream that contacts the polymeric material, component, or system is a liquid.
  • The third step considers whether the material, component, or system is used to manufacture an approved and marketed API, DS, or DP. If a material, component, or system has been established to be acceptable, further characterization of the material, component or system is not required, providing this is justified.
  • The last step considers whether the component or system under assessment is equivalent to a component or system that has already been established to be acceptable (a comparator). For example, a component that is used to manufacture an approved drug product could be a comparator for a second, but similar, component used to manufacture a different, but similar, drug product. In order to link a component or system to a comparator, reference is made to Plastic Components and Systems Used to Manufacture Pharmaceutical Drug Products(chapter 1665).
  • When a comparator has been established for the component under assessment, then further characterization of the material, component, or system is not required as long as a justification is provided. When a comparator cannot be established, proceed to 3.2 Risk Assessmentto establish the appropriate and necessary level of material and component testing.

3.2 Risk Assessment:

  • The testing of materials and components is driven by the risk that the material or component could be unsuited for its intended use. The greater the risk that the material or component could be unsuited for use, the greater the degree of required testing. Risk assessment is accomplished via application of a Risk Assessment Matrix detailed inPlastic Components and Systems Used to Manufacture Pharmaceutical Drug Products (chapter 1665).
  • The outcome of this assessment establishes three levels of risk: low (level A), moderate (level B), and high (level C). These levels are linked to the test requirements defined in section 4.2.1 and 4.2.2.
  • If a component has been tested according to this chapter and meets the specifications contained in this chapter, the component’s materials of construction are deemed to be compliant with this chapter without having been tested according to (chapter 661.1).
  • If the component meets the plastic class VI requirements according to USP general chapter 88, it is not necessary to test the component according to chapter 87.
    4.1 Plastic Materials Not Addressed in chapter 661.1
    4.2 Cured Polymeric Materials
    4.2.1 Test Methods
    5.1 Test Methods
    5.2 Specifications:
  • Biological Reactivity:
    (Manufacturing components or systems that do not meet the requirements of the relevant biological reactivity tests (chapters 87 and 88, as appropriate) are not suitable as manufacturing components or systems for pharmaceutical and/or biopharmaceutical use);
  • Extractable Metals;
  • Organic Extractables Profile.

Chapter 1665 discusses material characterization and selection and safety qualifications of polymeric components and systems used to manufacture drug products (previously proposed to be incorporated in general chapter 1661 to support the use and understanding of the new general chapter 661.3). The chapter is structured as follows:

    3.1 Discussion
    3.2 Material Characterization and Selection
    3.3 Component Characterization and SelectionCHARACTERIZATION PROCESS
    4.1 Initial Assessment
    4.2 Risk Assessment
    4.2.1 Risk evaluation matrix
    4.2.2 Application of the risk evaluation matrix
    4.2.3 Using the risk evaluation matrix
    4.2.4 Linking risk to characterization methodologies4.3 Establishing the Level of Characterization
    4.3.1 Baseline assessment
    4.3.2 Expanded baseline assessment
    4.3.3 Full testing (extractables profiling)4.4 Standard Extraction Protocol
    4.4.1 Extraction solvents
    4.4.2 Extraction temperature
    4.4.3 Extraction duration
    4.4.4 Accomplishing the extraction
    4.4.5 Non-standard extractions
    4.4.6 Accounting for conditioning and related steps employed in manufacturing4.5 Testing the Extracts and Generating the Extractables Profile
    4.6 Evaluation of the Extractables Profile Established by Implementing the Standard Extraction Protocol5. SAFETY QUALIFICATION
    5.1 General
    5.2 Chemical Safety Qualification
    5.3 Additional Safety QualificationGLOSSARY

Following your registration on the Pharmacopeial Forum website you get access to the complete drafts of general chapters 665 and 1665.

Acceptability of Standards from Alternative Compendia

Do your standards require compliance with multiple compendia? You may be able to simplify your standards testing.

The latest addition of the MAPP (Manual of Policies and Procedures) 5310.7 – Acceptability of Standards from Alternative Compendia (BP/EP/JP) published in January 2017 states that it is reasonable to accept an applicant’s proposal to use a quality standard from the BP, EP, or JP as part of the specifications for an excipient, drug substance, or drug product in the drug application, if the standard in the BP, EP, or JP is equivalent to or better than the corresponding standard in the USP/NF.

This is useful information for those responsible for marketing authorization or incoming goods control in the pharmaceutical industry.

Download the document here.

Storage and Transport of Investigational Drug Products (IDP)

Does your company handle investigational drug products (IDP) the same as your commercial products? If so, you may want to consider the proposed new USP chapter on storage and transport of IDP as an addition to the Good Storage and Distribution Practices for Drug Products chapters [1079]. This new subchapter should focus on investigational drug products (IDPs; investigational medicinal products in Europe, IMPs). Transport of small quantities of product to multiple sites, minimal stability data, temperature excursions of single containers along with different distribution requirements in various countries make this a challenge for most companies. To address these challenges, the new chapter proposes the following requirements:

  • Storage in a safe and secured area at labelled storage conditions
  • Segregation for IDPs not dispensed yet and for IDPs awaiting return to sponsor or contractor
  • Site qualification audits need to be performed
  • Anticipation and tracking of expiry or re-test extensions (according to different local regulatory requirements)
  • Packaging qualifications should be the same as for commercially available drug products
  • Consideration of important distribution risk factors (e.g. distance, time, temperature, handoffs, packaging)
  • Confirmation that proper steps are taken to ensure IDP supply chain integrity (including checklists for patients)
  • Unblinded IDPs should be quarantined
  • Comparators should be shipped and stored according their (new) IDP labeling

This new chapter also gives a detailed example for calculating a rating of shipment risk to help identify probability and impact of errors in the supply chain.

Read more on the USP Pharmacopeial Forum.