Guidelines for the Stability Testing in Support of Changes to Nonprescription (OTC) Monograph Drug Products Not Regulated by an NDA/ANDA

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Voluntary Codes and Guidelines |

Adopted:
March 2011

Introduction

Due to the great variety of changes that may be encountered after an OTC monograph drug is marketed, it is impossible to address stability requirements for all changes in an exhaustive manner in this guideline. Some of the more common examples of changes that can occur are listed below. However, since a significant body of information typically exists for these OTC monograph drug products, general guidance from the examples provided within this guideline can be used in the decision-making process as to the extent of additional stability testing necessary to support a given product change.

The parent guideline “Guideline for the Stability Testing of Non-Prescription (OTC) Drug Products Not Regulated by an NDA/ANDA” describes the requirements for stability testing and data package(s) for new products. The parent guideline can be followed to generate stability data for OTC monograph drug product launches in the U.S. per climatic zone II.

Three underlying assumptions within this additional guidance to post-market changes are that 1) a post-market stability program is in place with pre-defined initial and ongoing requirements and 2) the capability exists to conduct accelerated stability testing concurrently or upfront prior to marketed product stability 3) the capability exists to assign a different expiration dating period to the changed product in the event that it is warranted.

Because of the significant body of information that typically exists for OTC monograph drug products, the significance of the change can be categorized into one of the three following categories:

  • Minor – A change that has a minimal potential to have an adverse effect on the identity, strength, quality, purity, or potency of the drug product.
  • Moderate – A change that has a moderate potential to have an adverse effect on the identity, strength, quality, purity, or potency of the drug product.
  • Major – A change that has a substantial potential to have an adverse effect on the identity, strength, quality, purity, or potency of a drug product.

In the case of multiple changes occurring simultaneously, the combined changes may or may not have an additive effect as to their impact and must be considered as well. Each situation should be evaluated appropriately.

Table 1 presented below outlines the recommended pre- and post-market stability requirements for each of the three types of changes. Within a given change category, the presence or absence of a significant body of information can lead to a more or less conservative approach. In general, the net impact to a product’s expiration dating period is that only certain types of major changes would warrant a change in the current expiration dating period. For moderate or minor category changes, it is anticipated that the current expiration dating period will be maintained for the changed product. If the generated stability data for the change is not comparative, a reevaluation of the change should be performed.

Table 1: Stability Data Packages to Support Product Changes

Type of Change

Pre-Market Stability Data

Post-Market Stability Data  

Expiry Dating Period 

Minor

None

None beyond the regular annual batches.

Maintain current expiration dating period if supported; can market product immediately.

Moderate

Comparative accelerated data on minimum of 1 batch2 of drug product with the proposed change based on product history/knowledge base.

1st production batch (minimum of one batch) on long-term stability through expiry period.3

Maintain current expiration dating period if supported; can market product immediately.

Major

3-months of comparative accelerated data and available long-term data generated up-front on minimum of 1 batch2 of drug product with the proposed change.

1st production batch (minimum of one batch) on long-term stability through expiry period.3

Maintain current expiration dating period if supported; market product after 3-months comparative data.

1Alternative methods (i.e., MVTR, Extractables) and knowledge base are also used when deciding how much data is required to support a change.
2Pilot scale batches acceptable.
3If already part of the comparative stability package, no additional commercial lots are required.

Site Changes

A change in the manufacturing, packaging or testing site of the OTC monograph drug product can be supported by a sufficient body of data (Table 2) to show that such a change does not affect the stability of the drug product. If the data are found acceptable, the established expiration period may be retained.

Table 2: Stability Data to Support Manufacturing Site Changes

Definitions/Examples

Type of Change 

a. Manufacturing site change within a facility with the same equipment, SOP’s, environmental conditions, controls, personnel (eg. Remodeling an existing building, add-on to an existing facility).

Minor

b. Packaging site change for solid oral dosage form drug products.

Minor

c. Test laboratory site change to a new location.

Minor

a. Change within a contiguous campus, or between facilities in adjacent city blocks, with the same equipment, SOP’s, environmental conditions, controls, personnel.

Minor

a. Manufacturing site change to a different facility with the same equipment, SOP’s, environmental conditions, controls.

Moderate

 

Formulation Changes

Historically, all changes in drug product formulation were grouped together and required stability documentation to support the change. An exception was the deletion of a color. Excipients may play a critical role in certain complex dosage forms. Table 3 provides information on stability recommendations to support formulation changes.

Table 3: Stability Data to Support Formulation Changes

Definition/Examples 

Type of Change 

a. All Dosage Forms: Deletion or partial deletion of an ingredient intended to affect the color, taste or fragrance of the drug product.

Minor

b. Solid Oral and Semisolid Dosage Forms: The total additive effect of all excipients changes does not exceed 10% with individual changes within the limits specified in SUPAC-IR and –SS.

Minor

c. Semisolid Dosage Forms: Change in supplier of structure-forming excipient which is primarily single chemical entity (purity> 95%).

Minor

a. Semisolid Dosage Forms: Change in supplier or grade of a structure forming excipient.

Moderate

b. Semisolid Dosage Forms: Change in the particle size distribution of active drug substance, if the drug is in suspension.

Moderate

a. Modified Release Dosage Forms: Change in the technical grade and/or specifications of a nonrelease controlling excipient.

Minor

b. Modified Release Dosage Forms: change in release controlling excipient quantity or quality.

Major

a. All Dosage Forms: Any qualitative or quantitative change in total excipients beyond the range greater than 10% (of total formula composition).

Moderate

b. Change of the formula added on to a fabric substrate (i.e., lotion on a fabric wipe, baby wipe, hand sanitizing wipe).

Moderate

c. Semisolid Dosage Forms: Change in the crystalline form of the drug substance, if the drug is in suspension.

Major

b. Semisolid Dosage Forms: Change in the particle size distribution of active drug substance, if the drug is in suspension.

Moderate

a. Modified Release Dosage Forms: Change in the technical grade and/or specifications of a nonrelease controlling excipient.

Minor

b. Modified Release Dosage Forms: change in release controlling excipient quantity or quality.

Major

a. All Dosage Forms: Any qualitative or quantitative change in total excipients beyond the range greater than 10% (of total formula composition).

Moderate

b. Change of the formula added on to a fabric substrate (i.e., lotion on a fabric wipe, baby wipe, hand sanitizing wipe).

Moderate

c. Semisolid Dosage Forms: Change in the crystalline form of the drug substance, if the drug is in suspension.

Major

 

Addition of a New Strength

The addition of a new strength for a monograph OTC drug product is permissible provided the new active concentration is within the approved drug monograph. Demonstration of equivalent stability between the current OTC drug product and the new strength will allow extension of the current OTC drug product expiration dating to the new strength. Depending on issues specific to the drug products (e.g. dosage form), availability of a significant body of information for the current OTC drug dosage form, a minor, moderate, or major category stability data package may be appropriate as shown in Table 4. New strengths intermediate to those of a current monograph OTC drug products may be supported by bracketing/matrixing studies.

Table 4: Stability Data to Support Addition of a New Strength

Definition/Examples 

Type of Change 

New strength of identical qualitative and quantitative composition*:

 

a. Addition of a score to an immediate release tablet.

Minor

b. Change in the fill of an immediate release gelatin capsule.

Moderate

c. Change in the size of an immediate release tablet or capsule.

Moderate

New strength involving a change in the drug substance (API) to excipient(s) ratio, while maintaining qualitative composition of excipients in the formula:

 

a. Simple solutions

Moderate

b. Semisolid topical dosage forms

Moderate

c. Immediate release solid oral dosage forms

Moderate

d. Semisolid and modified release oral dosage forms

 

*No change in drug substance (API) to excipient(s) ratio from the current monograph OTC drug product.

Changes in Manufacturing Process and/or Equipment

A change limited to the manufacturing process of the OTC monograph drug product, such as a change in the type of equipment used, can be supported by a sufficient body of data to show that such a change does not compromise the stability of the drug product. The commitment to conduct stability studies on product produced by the revised manufacturing process may be appropriate as shown in table 5 below to generate a stability data package to support the manufacturing process or equipment change. If the data are found acceptable, the established expiration period may be retained.

Table 5: Stability Data to Support Manufacturing Process Changes

Definition/Examples

Type of Change

Process: Changes in processing parameters such as mixing times, operating speeds within application/validation ranges.

Minor

Equipment:

 

a. Change to equipment of the same design and operating principles.

Minor

b. Changes to equipment of different design and/or operating principles
a. Solids
b. Semisolid
c. Liquids

Moderate

Process: Changes in processing parameters such as mixing times, operating speeds outside of application/validation ranges:
a. Solids
b. Semisolids
c. Liquids

Moderate

Equipment: Changes to equipment of different design and/or operating principles
a. Solids
b. Semisolid
c. Liquids

Moderate

Process: Changes in types of process used in the manufacture of the product, such as a change from wet granulation to direct compression of dry powder:
a. Solids
b. Semisolids
c. Liquids

Major

 

Change in Batch Size

A key question in considering an increase in batch size beyond the production batch size used to establish an expiration period is whether the change involves a change in equipment or its mode of operation, or other manufacturing parameters described for the approved batch size. If no equipment change is made, then the next concern is the size of the change relative to the approved batch size with larger changes expected to present a greater stability risk in the drug product. Table 6 below presents the recommended stability data packages for a variety of batch size situations not involving equipment or mode of operation changes.

If an equipment change is part of the batch size change, please refer to the previous section on manufacturing process and/or equipment changes.

Table 6: Stability Data to Support Batch Size Changes

Definition/Examples

Type of Change

Solids (i.e. tablets, capsules, powders, for reconstitution), semisolids, and liquids: A change in batch size up to and including a factor of ten times the size of the pre-market batch.

Minor

Solids (i.e. tablets, capsules, powders, for reconstitution), semisolids, and liquids: A change in batch size beyond a factor of ten times the size of the pre-market batch.

Moderate

 

Change in Container/Closure System (Primary Packaging)

The Stability data packages for changes in container and closure of OTC drug products vary (Table 7). The first factor used in determining the stability data package recommendation is whether or not the protective properties of the container/closure system are affected by the proposed change. Protective properties of the container/closure system include, but are not limited to, moisture permeability, oxygen permeability, and light transmission. Changes that may affect these properties should be supported by a greater amount of data to support the change. The second factor is the nature of the dosage form itself. A solid dosage form will generally be less affected by a container change than a liquid dosage form.

Table 7: Stability Data to Support Container/Closure Changes

Definition/Examples

Type of Change

Closure changes:
Adding or changing a child resistant feature to a packaging system or changing from a metal to a plastic screw cap, while the inner seal remains unchanged

 

Minor

Changing the secondary packaging:
Changing a carton

Minor

Removal or non-drug product material:
Removing:
a. an insert
b. a filler

Minor
Moderate

Changing shape of a container or closure:
a. Without changing the size – solids
b. Without changing the size – liquids and creams 

Minor
Moderate

Changing size of container/closure:
a. Within the established approved package size range and head space ratio
b. Outside the established approved package size range and head space ratio

Minor
 

Moderate

Adding or changing a component to increase protection within the same system:
a. Adding, or changing to, a heat-induction seal:
i: For a solid oral drug product.
ii. For a liquid oral drug product
b. Adding or changing a desiccant or a filler
c. Adding an overwrap or carton.

Minor
Moderate
Moderate
Minor

Changing the manufacturer or formulation of a container/closure component, including bottle or blister resin, cap, liner, seal, laminate, desiccant, filler, etc., within the same system:
a. Using an approved or compendia container or closure equivalency protocol for:
i. a solid oral drug product
ii. a liquid oral drug product.
b. Without an approved or compendia container or closure equivalency protocol

Minor
Minor


Moderate

Changing to a different container and closure system:
For any solid or liquid oral drug product

Major