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发表于 2017-8-31 17:51:17
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本帖最后由 beiwei5du 于 2017-8-31 17:57 编辑
For those of you that are not familiar with this document, it is a series of fourteen (14)
questions and answers relating to implementation of Health Based Exposure Limits
(HBELs). Before I start on the 14 questions, a discussion of HBEL versus PDE values
requires some clarification. The more general term is HBEL. PDE is only one method to
derive a HBEL. Unfortunately the 2014 EMA is sometimes read as requiring PDE values
for all actives. It should be clear from reading that document that a PDE is only one
avenue for establishing a HBEL. That 2014 document also discusses using the TTC
concept for genotoxic materials, as well as stating for certain products, like biotechnology
actives and product where the most relevant safety data is on humans, the PDE formula
maynotbe appropriate.
That said, the wording of the EMA document may contribute to that misreading. The
beginning of Section 4.1 states “The procedure proposed in this document for
determination of health based exposure limits for a residual active substance is based on
the method for establishing the so-called Permitted Daily Exposure (PDE)… .” Obviously
the PDE is not theonlyprocedure to establish a HBEL given in that 2014 document. In
addition, Section 6 of the 2014 document is titled “Reporting of the PDE determination
strategy”; it would seem appropriate if there were other means of determining a HBEL,
that section should have been titled “reporting of the HBEL determination strategy”.
Fortunately the new draft Q&A clarifies this and emphasizes the general idea of a HBEL
as compared to one embodiment of it (the PDE).
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