The Ministry of Health, Labour and Welfare of Japan (MHLW) issued a notice dated October 8, 2020, requiring manufacturers to carry out a risk evaluation/assessment of nitrosamines contamination for all chemically synthesized drugs by April 30, 2023 (Step 1). In addition, confirmatory testing should be conducted, when there is any risk for the presence of nitrosamine impurities (Step 2). If the nitrosamines identified exceed the AI limit, manufactures are required to implement effective risk mitigating measures by October 31, 2024 (Step 3).
I think the above situation is almost the same as in the U.S. and Europe. There is a concern that small and med-sized pharmaceutical companies may not have sufficient technology or equipment to measure trace amounts of nitrosamines.
@Naiffer_Host, @Abe
Thank you for sharing the information. As Dr. Abe mentioned, “call for review in Japan” was noticed in Oct. 2021. The working group of experts from the government and industry is dealing with this issue in Japan, and the Q&A document is now under preparation. After the Q&A is published, the risk assessment of nitrosamines will be a hot topic, I guess. We all are waiting for it eagerly.
In addition to the concerns Dr. Abe posted, I focus on the ICH M7, which generic drug companies may not be familiar with. The concept of purge, SAR, Ames test, LTL approach, analysis of trace amounts of organic impurities may sound unfamiliar to them. Because they need to deal with lots of products and materials, some support from the government is crucial to perform the risk assessment of nitrosamines appropriately. And the assessment of nitrite amount in excipients is another problem.
Anyway, I think we should start the discussion and share the information in Japan as soon as possible. Some of the webinars are on planning. And the discussion in this community is very informative and helpful for us. Do you have additional comments, guys?
The time for risk mitigation seems very short. But the MHLW is possibly going to be taking advantage of the fact that multinational companies will have completed their risk evaluation for EU and US. However, smaller local companies may have some challenges here.
I want to share the article originally written in Japanese. It is from “nikkan yakugyo” and includes responses from the industry. The rough summary I wrote in English is as follows;
Carcinogen self-inspection, issues related to costs and deadlines, and various responses depending on the size of the company and the number of items.
Since it is an international trend, it is understandable that “call for review in Japan” is necessary, but responses are different among the group of JPMA, GE Pharmaceutical Manufacturers Association, and OTC Pharmaceutical Manufacturers Association. And responses are also different depending on the size of the company and the number of items.
For companies that do business globally and have experience in the risk assessment of nitrosamine, the content of the self-inspection is within the expected range.
On the other hand, it will be a heavy burden for generic companies, especially with a large number of items, after dealing with the assessment under ICH Q3D.
It requires performing the risk assessment on all possible substances such as APIs, excipients, reagents, packaging materials and containers, and printing inks. Considering works to send and collect questionnaires to all those suppliers, the one-and-a-half-year deadline of step1 is considered strict.
Since the number of outsourced test facilities that have equipment with high sensitivity and meet GMP standards is not so many, there is a concern that the test will not proceed as expected by the concentration of requests.
There is a concern that re-evaluation will be necessary due to new findings regarding nitrosamine contamination.
In conclusion, early Q & A issuance and establishment of a system for consultation are now strongly desired.
I hope it will help you understand situations in Japan.
Dear Japan colleagues… my colleague @ShinKim from USP’s APAC team is working with some local partners to develop a Nitrosamine Training/Workshop. Potential collaboration? Thanks in advance for all your support.
It is pleasure to speak with you Yosukemino-san.
I am Shin, customer engagement manager responsible for managing Japan & S. Korea.
I personally look forward to working with you and will keep you posted on the Nitrosamine education course once it is organized and ready to be hosted.
Due to yearly NHI price revision, in generic manufacturers with lots of products in Japan, we don’t have many resources to control nitrosamines in each product. This is a problem from a different perspective.
We must cooperate and share nitrosamines information because we don’t have enough information and expertise to perform a risk assessment and control nitrosamines.