Bard responds to Nitrosamine Risk Assessment scheme

I came across a post by Yosukemino - Chat GPT’s answer about the risk assessment of nitrosamine in pharmaceuticals (Chat GPT's answer about the risk assessment of nitrosamine in pharmaceuticals)

Out of curiosity, I posed a similar question to Bard ( and received distinct responses when I phrased the question in two different ways. It’s intriguing to observe how the content in each response varies depending on the phrasing of the question.

Q.1 Could you please explain how to perform a risk assessment of nitrosamine impurities in pharmaceuticals?

Performing a Risk Assessment of Nitrosamine Impurities in Pharmaceuticals

The presence of nitrosamine impurities in pharmaceuticals has become a significant concern due to their potential carcinogenicity. Performing a thorough risk assessment is crucial to ensure patient safety and product quality. Here’s a breakdown of the key steps involved:

1. Hazard Identification:

  • Identify potential nitrosamines: Categorize the drug substance and excipients based on their structural features and presence of functional groups known to promote nitrosamine formation. Consult regulatory resources like the FDA guidance “Control of Nitrosamine Impurities in Human Drugs” for a comprehensive list.
  • Evaluate sources of nitrosamine contamination: Assess the manufacturing process, including raw materials, solvents, reactions, and equipment, for potential nitrosamine formation pathways.
  • Gather toxicological data: Compile available information on the carcinogenicity and potency of identified nitrosamines.

2. Exposure Assessment:

  • Determine potential levels of nitrosamine contamination: Analyze samples of the drug product using validated analytical methods to quantify nitrosamine levels.
  • Estimate patient exposure: Consider factors like dosage, duration of treatment, and patient population (e.g., children, pregnant women) to estimate the total daily intake of nitrosamines.

3. Risk Characterization:

  • Compare exposure to acceptable limits: Refer to regulatory guidelines like the ICH M7(R1) for acceptable daily intake (ADI) thresholds of specific nitrosamines.
  • Calculate the theoretical cancer risk: Utilize established risk assessment models like the lifetime risk from oral exposure (T-LRO) to estimate the potential cancer risk associated with the identified nitrosamine impurity at observed levels.
  • Assess the severity of consequences: Consider the type and potency of the nitrosamine and the vulnerability of the target population.

4. Risk Control Measures:

  • Mitigation strategies: Identify and implement control measures to minimize nitrosamine formation during manufacturing, such as selecting alternative reagents, adjusting reaction conditions, or employing nitrosamine scavengers.
  • Monitoring and testing: Establish a robust monitoring program to routinely analyze drug products for nitrosamine impurities and ensure continued compliance with safety standards.
  • Communication and reporting: Communicate the risk assessment findings to regulatory authorities and ensure clear information dissemination to healthcare professionals and patients.

Additional Resources:

  • FDA Guidance: Control of Nitrosamine Impurities in Human Drugs
  • EMA Guidance: Nitrosamine impurities in medicinal products
  • ICH M7(R1): Assessment of Antitumour Activity

Remember: This is a high-level overview of the risk assessment process. The specific methodologies and requirements may vary depending on the specific drug product and regulatory landscape. For comprehensive guidance, consult relevant official resources and seek expert advice from qualified professionals.

I hope this information helps!

Q. 2 Generate Risk Assessment scheme of Nitrosamine Impurities in Pharmaceuticals

Sure, here is a risk assessment scheme for nitrosamine impurities in pharmaceuticals:


Thanks @prealbhatt for sharing this. It looks Bard did great just laying out the structure.

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