Guidance for Industry
Drug Master Files for
Bulk Antibiotic Drug Substances
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
 November 1999
CMC Guidance for Industry
Drug Master Files for
Bulk Antibiotic Drug Substances
Additional copies are available from:
Office of Training and Communications
Division of Communications Management
Drug Information Branch, HFD-210
5600 Fishers Lane
Rockville, MD  20857
(Tel) 301-827-4573
(Internet)  http://www.fda.gov/cder/guidance/index.htm
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
November 1999
CMC 1
Guidance for Industry
Drug Master Files for Bulk Antibiotic Drug Substances
I. INTRODUCTION
This guidance is intended for those in industry whose approved applications for bulk
antibiotic drug substances (i.e., bulk applications) were converted to Type II Drug Master
Files (DMFs) when section 507 of the Federal Food, Drug, and Cosmetic Act was
repealed as part of the enactment of section 125 of Title I of the Food and Drug
Administration Modernization Act on November 21, 1997.2  This guidance explains the
purpose of DMFs, discusses the type of information expected in a Type II DMF, outlines
administrative procedures governing review of DMFs, and clarifies your responsibilities
as a DMF holder.  The information presented in this guidance is also relevant to the
submission of new DMFs for bulk antibiotic drug substances.
II.  BACKGROUND
Prior to the repeal of section 507, bulk antibiotic drug substances were handled
differently from other bulk drug substances.  Bulk antibiotic drug substances were either
batch certified or exempted from batch certification through the approval of an antibiotic
drug application.  Information about other bulk drug substances, drug substance
intermediates, and materials used in their preparation were filed and maintained as Type
II DMFs according to 21 CFR 314.420, or drug substance information could be filed as
part of the marketing application for the finished dosage form of the drug.  With the
repeal of section 507 in the Modernization Act, bulk antibiotic drug substances are being
handled in the same way as all other bulk drug substances under section 505 of the
Federal Food, Drug, and Cosmetic Act.
                                                
1 This guidance has been prepared by the Antibiotic Working Group of the Chemistry, Manufacturing, and
Controls Coordinating Committee (CMCCC) in the Center for Drug Evaluation and Research (CDER) at
the Food and Drug Administration.  This guidance document represents the Agency's current thinking on
drug master files for bulk antibiotic drug substances.  It does not create or confer any rights for or on any
person and does not operate to bind FDA or the public.  An alternative approach may be used if such
approach satisfies the requirements of the applicable statute, regulations, or both.
2  See also the guidance for industry and reviewers on Repeal of Section 507 of the Federal Food, Drug, and
Cosmetic Act (May 1998).
1 With the implementation of the Modernization Act, the agency administratively
converted all bulk antibiotic applications to DMFs.  Following the conversion of these
applications, the Agency gave each affected holder the newly assigned DMF number.
Persons holding bulk applications were not required to take any action for their
application to be converted to a DMF.  However, following conversion, holders were
expected to reference the new DMF number on all letters of authorization (LOAs) or
other correspondence relating to the DMF for the bulk antibiotic drug substance and
maintain the DMF in accordance with 21 CFR 314.420.  Holders who did not wish to
maintain a DMF were allowed to incorporate the information into one or more dosage
form applications, or close their application in accordance with Agency record keeping
practices.  The incorporation of DMF information into a dosage form application usually
applies to situations where the manufacturer of the bulk antibiotic drug substance and the
dosage form applicant are the same corporate entity.
III.  WHAT IS A DRUG MASTER FILE (DMF)?
A Drug Master File (DMF) is a submission to the Agency of confidential detailed
information for the following purposes (21 CFR 314.420(a)):
  A DMF allows you (the holder) to incorporate information by reference when
you submit an application (investigational new drug application (IND), new
drug application (NDA), abbreviated new drug application (ANDA), another
DMF, export application, or amendments and supplements to these).
  A DMF allows you to authorize other persons (applicants) to reference
information in your DMF in support of a submission to the Agency without
having to disclose the information to the applicant.
IV. WHAT IS A TYPE II DMF AND WHAT INFORMATION SHOULD BE
INCLUDED IN IT?
There are multiple types of DMFs, but you should submit information pertaining to the
manufacture of bulk antibiotic drug substances as Type II DMFs (21 CFR 314.420(a)(2)).
A Type II DMF is used to provide information on drug substances, drug substance
intermediates, and materials used in their preparation.  It should include information on
the following:
  physical, chemical, biological (e.g., anti-microbial), and stability
characteristics of the drug substance;
  the name and location of the manufacturing site(s);
  the method of manufacture (e.g., microbial strain used, fermentation process,
isolation process) and/or synthesis, and purification;
2   the process controls used during manufacturing and packaging; and
  the specifications used to ensure the identity, strength and/or potency, quality,
and purity of the drug substance.
For additional guidance on information that should be submitted in a Type II DMF, see
21 CFR 312.23(a)(7) and 314.50(d)(1)(i) and relevant CDER guidances such as the
guidance on  Submitting Supporting Documentation in Drug Applications for the
Manufacture of Drug Substances (February 1987).3  For guidance on information and
data that should be submitted in support of sterility assurance for a sterile bulk antibiotic
drug substance, see CDER and CVM's guidance on Submission of Documentation for
Sterilization Process Validation in Applications for Human and Veterinary Drug
Products (November 1994).
In addition to providing the specific information described above, each submission to
your DMF should include a transmittal letter and administrative details about the
submission.  For information on these additional items, as well as the format, assembly
and delivery of DMF submissions, see CDER's guidance on Drug Master Files
(September 1989).4
V. WHEN ARE LETTERS OF AUTHORIZATION NEEDED?
Before the Agency can review information in your DMF, you must send an LOA to the
applicant who is incorporating information by reference from your DMF (21 CFR
314.420(b)).  The applicant must include a copy of the LOA in their submission (21 CFR
314.50(g)(1)).  The LOA permits FDA to access the information in your DMF.  The LOA
is required even if the applicant is also the holder of the DMF.  A copy of the LOA
should also be submitted to your DMF.  For details on information that should be
included in the LOA see CDER's guidance on Drug Master Files.
VI. WHAT ARE THE POLICIES RELATED TO PROCESSING AND
REVIEWING DMFS?
Ordinarily, the information in your DMF is reviewed only in conjunction with an
application that references the information through an LOA.  The Agency neither
approves or disapproves your DMF, but makes a judgment on the adequacy of the
referenced information in support of the application that references it (21 CFR
314.420(a)).  If upon review, the information provided in your DMF is determined to be
inadequate, you will receive a letter from the Agency describing the deficiencies.  At the
same time, the Agency will notify the applicant who relies on information in your DMF
                                                
3  For relevant CDER guidances see http://www.fda.gov/cder/guidance/index.htm
4 CDER's guidance on Drug Master Files (September 1989) is currently being revised.  Applicants should
refer to the updated guidance when it is finalized.
3 of the inadequate status, but details of the deficiencies are not disclosed to the applicant.
When you submit the requested information to your DMF in response to the Agencys
letter, a copy of the transmittal letter should be sent to the FDA review division issuing
the letter, and the affected applicant should be notified that the response was submitted.
This provides notice to the applicant and review division that the DMF has been amended
and the deficiencies have been addressed.
VII. WHAT ARE MY RESPONSIBILITIES AS A DMF HOLDER ?
As a DMF holder you have a number of obligations.  Failure to meet these obligations
may delay approval of applications that rely on the information in your DMF or result in
the Agency closing your DMF.  The following discusses your responsibilities.
A. Changes to your DMF
Any addition, deletion, or change to information in your DMF is required to be
submitted to the Agency in duplicate (21 CFR 314.420(c)).  This includes changes
you formerly reported to the Agency under 21 CFR 314.70 when the information
was part of an approved bulk application.  The submission describing the change
should include appropriate cross-references to the affected information in
previous submissions, including the date(s), volume(s), section(s), and/or page
number(s).  Additionally, you must notify each person (applicant) authorized to
reference information in your DMF of pertinent changes (21 CFR 314.420(c)).
Notification should be provided well in advance to give the affected persons
(applicants) ample time to amend or supplement their applications as necessary
under 21 CFR 314.70.
B. Annual Update
You should update your DMF on an annual basis.  The update should identify all
changes and additional information incorporated into your DMF since the
previous update.  If no changes were made to your DMF, you should provide a
statement that the information remains current.  For more information on annual
updates see CDER's guidance on Drug Master Files.
C. Listing of Persons Authorized to Reference your DMF
Your DMF must contain a complete list of persons currently authorized to
reference information in your DMF (21 CFR 314.420(d)).  For more information
on this topic see CDER's guidance on Drug Master Files.
D. Appointment of an Agent
4 If you have an appointed agent for your DMF, you should include a signed letter
of appointment in your DMF that includes the agents name, address, and scope
of responsibility (administrative and/or scientific).
E. Transfer of Ownership
If you intend to transfer ownership of your DMF to another party, you should
notify the Agency and persons authorized to reference the DMF (applicants) in
writing.  Details regarding information to be included in the letter are provided in
CDER's guidance on Drug Master Files.
F. Incorporation of Information into a Dosage Form Application
If you do not wish to maintain a DMF, the information may be filed as part of
one or more dosage form applications (IND, NDA, or ANDA).  The dosage form
applicant is then responsible for ensuring this information meets regulatory
requirements.  If the information is certified as being current and there have been
no changes, it may be submitted to the dosage form application(s) as an annual
report.  If the information is not current or changes have been made, the DMF
information should be filed as (1) a prior approval supplement, changes being
effected supplement, or annual report for an NDA or ANDA or (2) an information
amendment or annual report for an IND.  The reporting category would depend on
the nature of the change.
5 GLOSSARY
Agency:  The Food and Drug Administration.
Agent:  Any person who is appointed by a DMF holder to serve as the contact for the
holder.
Applicant:  Any person who submits an application or abbreviated application or an
amendment or supplement to them to obtain FDA approval of a new drug or an antibiotic
drug  (21 CFR 314.3(b)).
Application:  The investigational new drug application (IND), new drug application
(NDA), abbreviated new drug application (ANDA), other DMF or export application that
references the DMF.
Drug Substance:  An active ingredient that is intended to furnish pharmacological
activity or other direct effect in the diagnosis, cure, mitigation, treatment, or prevention
of disease or to affect the structure or any function of the human body, but does not
include intermediates used in the synthesis of such ingredient (21 CFR 314.3(b)).
Export Application:  An application submitted under section 802 of the Federal Food,
Drug, and Cosmetic Act to export a drug that is not approved for marketing in the United
States.
Holder:  Any person who submits a DMF.
Letter of Authorization:  A written statement by the holder or designated agent
permitting other persons to refer to information in a DMF in support of applications.
Person:  Includes individual, partnership, corporation, and association (Section 201(e) of
the Federal Food, Drug, and Cosmetic Act).
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