As an MAH, do any of your authorised human medicinal products contain chemically synthesised active substances? If so, read the following to identify what your responsibilities are with regard to reporting results of risk analysis to the appropriate Competent Authorities by 26 March 2020 deadline.

On 20^th December 2019, the EMA published a Q & A on the document entitled ‘Information on nitrosamines for MAHs’ which includes new and updated information. This Q & A document should be read in conjunction with the document Information on nitrosamines for marketing authorisation holders (dated Sept 2019).

Further information for companies in relation to centrally and non-centrally authorised medicines is available from the EMA website and CMDh website.

Background:

In June 2018, authorities in the EU became aware of the presence of a nitrosamine, N-nitrosodimethylamine (NDMA), in valsartan from one manufacturer of active pharmaceutical ingredients (APIs). Subsequently another nitrosamine, N-nitrosodiethylamine (NDEA), was detected and other sartans from more API manufacturers were later implicated.

NDMA and NDEA are classified as probable human carcinogens (substances that could cause cancer) and their presence in sartans was, at the time, unexpected.

An Article 31 review of sartans at risk of containing nitrosamine impurities (i.e. sartans with a tetrazole ring) concluded that manufacturers must review and make necessary changes to their manufacturing processes to minimise nitrosamine impurities as much as possible. In addition, strict limits were set for nitrosamines in these products. The Article 31 review of sartans identified a number of root causes of nitrosamine formation and contamination.

A review was performed which indicated there is a potential for nitrosamines to be present in APIs for other medicines (i.e. non-sartans APIs), depending on the API and the finished product manufacturing processes.

While Nitrosamines are not expected to be formed during the manufacture of the vast majority of APIs outside the class of sartans with a tetrazole ring, it is now known that these impurities can form during production under certain conditions and when certain solvents, reagents and other raw materials are used. In addition, impurities can be carried over during the manufacturing process when using already-contaminated equipment or reagents.

Responsibilities of MAH: 

Despite the low risk of nitrosamines being present, Marketing Authorisation Holders (MAHs) are asked to take precautionary measures to mitigate the risk of nitrosamine formation or presence during the manufacture of ALL authorised human medicinal products containing chemically synthesised APIs  including generics and over-the counter (OTC) products. However, in view of the large number of authorised products, MAHs should use a risk-based approach and prioritize their evaluations and confirmatory testing.

The EMA’s human medicines committee (CHMP) requested in September 2019 that MAHs for human medicines containing chemically synthesised active substances, review their medicines for the possible presence of nitrosamines and test all products at risk.

It is the responsibility of MAHs to work closely with the manufacturers of APIs and finished products to perform risk evaluation and report this to the Competent Authorities where the products are authorised within 6 months of the guideline on “Information on nitrosamines for marketing authorisation holders”. This guideline was published on 26 September 2019, thus MAHs should supply complete risk evaluations to the respective Competent Authorities by 26 March 2020.

In summary MAHs must perform the following steps:

Step 1: Risk Evaluation

MAH’s should perform risk analysis of their medicinal products containing chemically synthesised API. The MAHs should prioritise products in order to establish the sequence in which their products are to be evaluated. The factors to be taken into account are outlined in the dedicated Q&A document on the EMA & CMDh websites. For products of high priority the risk evaluation should be done immediately. The risk evaluation of all products should be concluded at the latest with 6 months of the publication of Information on Nitrosamines for Marketing Authorisation Holders.

If a risk of presence of nitrosamine is identified as a result of the evaluation, the MAH should proceed to step 2 below.

After the individual risk evaluation is finished send the appropriate template for the outcomes of “no risk identified” or “risk identified” including the required email headings and details. The guidance given by the relevant national competent authorities’ website also has to be regarded, refer to Annex 1 in CMDh practical guidance for MAH of nationally authorised products (including MRP/DCP in relation to Art. 5 (3) Referral for Nitrosamines.

For MRP/DCP Products refer to:

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/CMDh_404_2019_Rev.0_2019_09_-_Nitrosamines_-_Information_on_nitrosamines_for_MAHs_.pdf

For Centrally Authorised Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-information-nitrosamines-marketing-authorisation-holders_en.pdf

It is also very useful to refer to the Question & Answer Documents and the templates on the following links:

For MRP/DCP Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-questions-answers-information-nitrosamines-marketing-authorisation_en.pdf

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/CMDh_400_2019_Rev_1_09_2019_clean_-_Q_A_on_sartans_referral.pdf

For Centrally Authorised Products refer to:

https://www.ema.europa.eu/en/documents/referral/nitrosamines-emea-h-a53-1490-questions-answers-information-nitrosamines-marketing-authorisation_en.pdf

Step 2: Conformity Testing

If the presence of nitrosamine is identified as a result of the risk evaluation, confirmatory testing should be carried out using appropriately validated and sensitive methods. Products identified as high priority should be tested as soon as possible.

Confirmatory testing of all medicinal products identified to be at risk of presence of nitrosamines and submission of required changes in the Marketing Authorisations should be concluded within 3 years (by 26/02/2022) of the publication of Information on Nitrosamines for Marketing Authorisation Holders or at an earlier time if otherwise justified.

MAHs should inform the relevant Competent Authorities immediately if tests confirm the presence of nitrosamines impurity irrespective of the amount detected.

Templates:

MAHs must test in accordance to

https://www.hma.eu/fileadmin/dateien/Human_Medicines/CMD_h_/Advice_from_CMDh/Nitrosamins/CMDh_412_2019_Rev.2_2019_12_clean_-_PG_to_MAHs_on_nitrosamines.pdf and report the results to the relevant National Competent Authority using the Templates on:

https://www.hma.eu/226.html

https://www.ema.europa.eu/en/search/search?search_api_views_fulltext=nitrosamine

Step 3: Changes to the Marketing Authorisation

MAHs should apply for a variation in a timely manner to introduce any required changes, such as amendment to the manufacturing process or changes to product specifications.

Refer to Templates on the EMA and CMDh websites to report results to the relevant Competent Authorities. It is also advised to view the relevant Competent Authorities websites to view national requirements on submitting this information.

If you need any clarification or support to help implement the responsibilities of a MAH with regard to Nitrosamines reporting contact us and we will gladly assist you in a timely manner.

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