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听众
性别保密
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发表于 2017-9-4 07:34:29
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首先关于说明这个问题,需要了解为什么有10ppm这个标准,10ppm其实不是基于toxicity层面进行制定的,是一个比较判断选取值,是基于quality层面和检测层面制定的,而且其制定并不是一个完全科学的选值,而是基于行业一般的规定,所以基于其目的,个人认为:10ppm应该是针对于上一个产品的活性残留物,而非上一个产品。
ESTABLISHMENT OF LIMITS
FDA does not intend to set acceptance specifications or methods for determining whether a cleaning process is validated. It is impractical for FDA to do so due to the wide variation in equipment and products used throughout the bulk and finished dosage form industries. The firm's rationale for the residue limits established should be logical based on the manufacturer's knowledge of the materials involved and be practical, achievable, and verifiable. It is important to define the sensitivity of the analytical methods in order to set reasonable limits. Some limits that have been mentioned by industry representatives in the literature or in presentations include analytical detection levels such as 10 PPM, biological activity levels such as 1/1000 of the normal therapeutic dose, and organoleptic levels such as no visible residue.
选自:https://www.fda.gov/iceci/inspections/inspectionguides/ucm074922.htm
If a default value, such as 10 ppm in the next product, is selected for formulated cleaning agents, it is
preferable that the default value be 10 ppm detergent solids. This makes it more analogous to the 10 ppm drug
active default value typically used. Again it is not a requirement that the 10 ppm be based on formulated
detergent solids. However, the rationale for this recommendation can be illustrated by the example of two
cleaning agents, one called Product ABC containing only 25% sodium lauryl sulfate (SLS) and another called
Product XYZ containing only 50% SLS. Does it make logical sense to set a default limit of ABC at 10 ppm
(equivalent to 2.5 ppm SLS), while the default limit of XYZ is also 10 ppm (equivalent to 5 ppm SLS)? If the
two products were compared on the same solids basis of 10 ppm, the limit for ABC would be set at 40 ppm
formulated product and the limit for XYZ would be set at 20 ppm formulated product. Each of these situations
would result in setting the default limit at 10 ppm SLS. Here again, it is not a requirement that default values
for formulated detergents be set based on detergent solids. However, there is some logic to doing so.
选自:More on Limits for Formulated Cleaning Agents
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