Packaging
device using three different solvents: dimethyl sulphoxide, ethanol-water and phosphate buffer. Each solvent pulled a different subset of compounds, requiring three separate toxicology reports. “It took over 100 hours of work,” he says. “But in the end, none of the compounds posed a toxicological concern.” In another case, however, the story was different. A known mutagen and carcinogen, alpha-methylstyrene, was detected in a product intended for intravenous delivery. The level detected exceeded the 1.5mg/day threshold set by the regulators for mutagenic impurities. “We had to classify that risk as ‘minimal’ rather than ‘negligible’,” Erexson says. “There’s no such thing as zero risk. But we quantified it and put it in perspective.”
Perhaps the most dramatic example came from a neonatal product called Survanta, a synthetic surfactant used to treat premature infants with respiratory distress by replacing the missing natural fluid in a baby’s lungs. Several extractables were identified in the packaging, and due to the tiny body weight of the patients (as low as 0.5kg) every compound exceeded the calculated permitted daily exposure. “By the numbers, everything failed,” Erexson says. “But this is a life-saving drug. It’s given once, maybe twice. We had to argue that the benefit far outweighed any theoretical risk. And the regulators accepted that.”
As pharmaceutical formulations become more complex, with the rise of biologics, mRNA therapies and combination products, the margin for error in drug stability is shrinking. These advanced therapies are often highly sensitive to environmental changes and chemical interactions, meaning even trace levels of leachables from packaging materials can compromise their effectiveness, safety or shelf life. In this evolving landscape, advanced E&L testing could help ensure that increasingly sophisticated drugs, such as antibody- drug conjugates (ADCs) – a class of targeted cancer therapies that combine the precision of antibodies with the cell-killing power of cytotoxic therapeutics – remain safe, effective and stable. “Some ADCs don’t even reach the tumour because their linkers aren’t stable enough,” Erexson explains. A leachable could hypothetically accelerate that degradation or interact with the payload, he explains. “These are powerful drugs, and they’re sensitive to even minor changes in their environment.” Cell and gene therapies present toxicologists with additional challenges, due to the use of ancillary materials. Such compounds are used during manufacturing but aren’t intended to be present in the therapeutic. They are often complex biological materials, such as recombinant insulin and human serum albumin, which could potentially interact with the final product. Regulatory agencies have responded to pharma’s more complex medicines with increasingly detailed guidance. In the US, the United States Pharmacopeia (USP) chapters 1663 and 1664 address
www.worldpharmaceuticals.net
best practices for designing E&L studies, including storage conditions and analytical thresholds.
New guidance Globally, ICH Q3E is being developed to provide harmonised guidance for assessing and controlling E&L in drug products. For medical devices and combination products, ISO 10993-17 is the primary reference for toxicological risk assessment, and was updated in 2023. Not everyone is pleased with how these standards are evolving, though. “The new version of ISO 10993-17 is 73 pages of verbose garbage,” Erexson says. “It adds complexity without actually improving patient safety.”
“By the numbers, everything failed. But this [was] a life-saving drug. It’s given once, maybe twice. We had to argue that the benefit far outweighed any theoretical risk. And the regulators accepted that.”
One major concern is regulatory divergence. “The
FDA’s Center for Devices and Radiological Health (CDRH) is now relying almost exclusively on ISO 10993-17,” Erexson claims, “while ignoring ICH Q3E, which is not smart.”
While it is true that CDRH relies heavily on ISO 10993-17 for medical devices, the ICH Q3E is a guideline specifically for extractables and leachables in drug products, while ISO 10993-17 is for the biological evaluation of medical devices, which includes assessing leachable substances. These are distinct regulatory frameworks for different product types. So, there is an argument that it is more a matter of different guidelines applying to different regulatory domains. However, this disconnect could lead to duplicated studies, delayed approvals and unnecessary cost burdens, particularly for multinational drug developers juggling submissions in multiple regions. One of the most important lessons Erexson has learned over his career is the value of early collaboration. Too often, toxicologists are brought in after the materials have already been selected, he says: “Then we’re expected to make the toxicology problem go away. More often than not, this is not possible.” He argues that toxicologists should be involved at the very start of product development, alongside formulation scientists, packaging engineers and quality assurance teams. This proactive approach can help avoid packaging material choices that are later flagged for E&L issues, saving time and money, and ensuring patient safety isn’t compromised under regulatory pressure. As the pharmaceutical landscape continues to evolve, so too must the discipline of E&L. New therapeutic modalities bring fresh challenges. But the core principle remains unchanged: packaging must protect the drug, not alter it. ●
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