Stability Data for ANDAs in the USA: a new Q&A Document of the FDA provides further Clarity

The FDA Guidance for Industry with the title "ANDAs: Stability Testing of Drug Substances and Drug Products" was published in the Federal Register on 20 June 2013 (also see our News dated 1 August 2013) and is addressed to applicants for ANDAs in the USA. This guidance describes the stability data the FDA expects in the documents submitted for an ANDA and is rather short having only five pages. As expected, the FDA received vast amounts of questions concerning certain problems that were not answered clearly in the guidance. Therefore, the Agency was prompted to address these questions in a questions and answers document. This document has the title "ANDAs: Stability Testing of Drug Substances and Drug Products - Question and Answers" and was published on the FDA "Guidance"-Website in May 2014.

The questions and answers are addressed in the following five chapters:

  • A. General 
  • B. Drug Master File 
  • C. Drug Product Manufacturing and Packaging 
  • D. Amendments to Pending ANDA Application 
  • E. Stability Studies

Some of the case studies discussed in these chapters are rather complex and therefore are answered in detail. In the following some questions and answers are listed for each chapter by way of example.

A. General
Question: Can an ANDA be submitted with 6 months of accelerated stability and 6 months of long-term stability data?
Answer: Yes. An ANDA applicant should submit this data. However, if 6 months of accelerated data show a significant change or failure of any quality attribute, the applicant should also submit 6 months of intermediate data at the time of submission.

Question: In the event of an adverse change of quality attributes at accelerated condition: When do intermediate stability studies need to be initiated?
Answer: An ANDA applicant should start accelerated, intermediate, and long-term stability studies at the same time so the data are available at the time of submission, if needed.

Question: During the review cycle, will the application need to be updated with 12 months of long-term data?
Answer: Yes. FDA will grant a shelf life period to the drug product of two times the available long-term data at the time of approval (up to 24 months). This is on condition, however, that the submitted stability data are satisfactory, and data evaluation and appropriate commitments are provided. With this the authority follows a recommendation of the Guideline ICH Q1E.

B. Drug Master File
Question: How many months of long-term and accelerated data are required when a "Completeness Assessment" is performed on the Drug Master File?  Also, what should the stability section contain for a Completeness Assessment?
Answer: To pass the Completeness Assessment, the DMF should include the stability protocol and commitments. It also should contain data demonstrating that stability studies have started.  The initial and one additional time point for the accelerated studies and long-term studies are sufficient. If the DMF does not meet the requirements for a successful assessment (see the following question/answer) the DMF holder must hand in updated stability data later.

Question: Are stability data from three current good manufacturing practice (CGMP) batches required to be filed in the DMF to support the active pharmaceutical ingredient retest date? How many months of long-term and accelerated data are required for pilot scale batches?
Answer: Yes. The DMF should contain data from stability studies on at least three primary batches of the API (these batches should be made under cGMP conditions) and the batches should be manufactured to a minimum of pilot scale (also see ICH Q1A(R2)).
The FDA stability guidance recommends 6 months of accelerated data and 6 months of long-term data for the pilot scale batches to be submitted for a full scientific review of the DMF.  Additional long-term data for all three batches, as the data becomes available through the proposed retest period, should be submitted as an amendment.

C. Drug Product Manufacturing and Packaging
Question: What is the Agency's position on using different lots of APIs and/or packaging materials?  How many API lots should be used in the manufacture of finished product lots used to support the ANDA?
Answer: It is not necessary to use different lots of packaging material, except in cases where the packaging material could affect drug product performance and/or delivery. 
A minimum of two lots of the drug substance should be used to prepare the three primary batches of drug product. For nasal aerosols and nasal sprays, you should use three different lots of drug substance.

Question: Should the small scale batches be packaged with commercial equipment?  Is it acceptable to package using research equipment?
Answer: Yes. Small scale batches should be packaged with commercial equipment.  Anyway, the packaging equipment should be similar to that proposed for use prior to market distribution.
No, it is not recommended to package small scale batches using research equipment or by hand. ...

D. Amendments to Pending ANDA Application
Question: What are the recommendations for amendments and responses filed to pending ANDAs after issuance of the final FDA stability guidance?
Answer: All amendments submitted to pending ANDAs after the effective date of the final FDA stability guidance will be held to the standards in place concerning stability data at the time of the original ANDA submission, unless there is a concern with the submitted stability data.

E. Stability Studies
Question: Can the Agency clarify expectations for the storage positions for products placed into the stability program?
Answer: For primary batches of liquids, solutions, semi-solids, and suspensions, the product should be placed into an inverted (or horizontal) position and an upright position. For routine stability studies, the applicant should pick the worst case orientation for the study.

Question: Can the Agency clarify expectations around the number of batches to support tests such as preservative effectiveness and extractable leachable testing?
Answer: One of the primary batches of the drug product should be tested for antimicrobial preservative effectiveness (in addition to preservative content) at the end of the proposed shelf life.  The drug product specification should include a test for preservative content, and this attribute should be tested in all stability studies.
Extraction/leachable studies are generally one-time studies. However, if multiple types of containers/closures are employed for packaging, then additional studies could be recommended.

The FDA tries to clarify the cases described in this Q&A document as clear and as much in detail as possible. In doing so the Agency complements its declarations by numerous indications concerning the provisions in the ICH guidelines Q1A(R2), Q1D, Q1E and in 21 CFR Part 211. Thereby, this very important and updated document covers most situations with regard to stability testing for ANDAs.

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