Continuous Education by Perfect Pharmaceutical Consultants Pvt. Ltd, Pune, India
© Perfect Pharmaceutical Consultants Pvt. Limited, November 2012 1
TYPICAL FDA COMMENTS ON IMPURITY PROFILING IN CTD/CEP/DMF
SUBMISSIONS
By Rajkumar Gupta, Managing Director Perfect Pharmaceutical Consultant Pvt. Ltd and
Director Global Institute of Regulatory affairs, Pune
Mr. R.M. Gupta (M. Pharm.), is a free lancer consultant for US DMF, COS, ANDA, ACTD,
CTD, eCTD and other regulatory submissions. guptarmg1952@gmail.com
He is associated with Perfect Pharmaceutical Consultants Pvt. Limited
(http://sites.google.com/site/ppcdmf ) and Global Institute of Regulatory affairs (Pune, India).
He is dedicated solely to pharmaceutical regulatory profession.
He is well recognized GMP auditor and cGMP Trainer of Trainers (cGMP TOT) for
Pharmaceuticals (Parenteral/Liquid Orals/ Tablets/Capsules/Vaccines/Beta lactam)
/API/Herbal/Medical Devices/ manufacturing Facilities
He is also an expert on Impurity Profiling
This article is solely written by him to guide, educate and train young Regulatory, QC and QA
personnel at large. The article is based on self experience of 25 years of the author
1. INTRODUCTION
Impurity profiling is a highly intelligent, tedious and expensive task in standardizing the drug
products for marketing Authorization. This task usually more complex when the proper impurity
standards are not available and synthesis of the same require extra ordinary high cost and time. It
has been observed that many a time application for ANDA/DMF/CEP is delayed due to extra
ordinary delay in compiling impurity profiling. Further, the approval of many of drug product is
denied for inadequate impurity profiling.
This article provides typical FDA comments on data on impurity profiling included in
Regulatory submissions for marketing Authorization. The purpose of the article is to assist the
regulatory professionals to understand the FDA perspective on Impurity Profiling and to avoid
queries on the same.
Many of the queries are referenced from FDA 483 Notes and Scientific Discussions available on
the internet.