Guidance for Industry 
ANDAs:  Stability Testing of 
Drug Substances and Products 
 
 
 
 
 
Questions and Answers 
 
 
 
 
 
 
 
 
 
 
   
  
 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
 
May 2014 
Generics 
 
   
 
 
Guidance for Industry 
ANDAs:  Stability Testing of 
Drug Substances and Products 
 
 
 
Questions and Answers 
 
 
 
 
 
Additional copies are available from: 
Office of Communications 
Division of Drug Information, WO51, Room 2201 
Center for Drug Evaluation and Research 
Food and Drug Administration 
10903 New Hampshire Ave., Silver Spring, MD 20993  
Phone: 301-796-3400; Fax: 301-847-8714 
druginfo@fda.hhs.gov  
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm 
 
 
 
 
 
 
 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
 
May 2014 
Generics 
 
 
   
 
 
TABLE OF CONTENTS 
 
 
 
I.  INTRODUCTION............................................................................................................. 1 
II.  QUESTIONS AND ANSWERS ....................................................................................... 1 
A.  General ............................................................................................................................................ 1 
B.  Drug Master File ............................................................................................................................ 5 
C.  Drug Product Manufacturing and Packaging ............................................................................. 6 
D.  Amendments to Pending ANDA Application ............................................................................ 12 
E.  Stability Studies ............................................................................................................................ 13 
  Contains Nonbinding Recommendations 
1
Guidance for Industry  
ANDAs:  Stability Testing of Drug Substances and Products 
Questions and Answers 
 
 
This guidance represents the Food and Drug Administrations (FDAs) current thinking on this topic.  It 
does not create or confer any rights for or on any person and does not operate to bind FDA or the public.  
You can use an alternative approach if the approach satisfies the requirements of the applicable statutes 
and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for 
implementing this guidance.  If you cannot identify the appropriate FDA staff, call the appropriate 
number listed on the title page of this guidance.  
 
 
I.  INTRODUCTION  
 
This guidance provides answers to questions from the public comments we received on the draft 
guidance for industry on ANDAs: Stability Testing of Drug Substances and Products2 (FDA 
stability guidance) that published in the Federal Register of September 25, 2012.  The final 
guidance for industry of the same title published in the Federal Register of June 20, 2013.  
Comments received on the draft of this guidance published in the Federal Register of August 27, 
2013 have also been incorporated.  General issues; drug master files (DMFs); drug product 
manufacturing and packaging; and stability studies are discussed in this guidance and are 
intended to clarify the stability testing data recommendations for abbreviated new drug 
applications (ANDAs).  In this document, the terms drug substance and active pharmaceutical 
ingredient (API) are used interchangeably. 
 
FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidances describe the Agencys current thinking on a topic and should 
be viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited.  The use of the word should in Agency guidances means that something is suggested or 
recommended, but not required.  
 
II.  QUESTIONS AND ANSWERS 
 
A.  General 
 
Q1:   What is the scope of and implementation date for the FDA stability guidance? 
 
A1:  The FDA stability guidance covers all new ANDAs under the Federal Food, 
Drug, and Cosmetic Act, section 505 (j), and DMFs (Type II for drug 
                                                 
1 This guidance has been prepared by the Office of Generic Drugs and Office of Pharmaceutical Science in the 
Center for Drug Evaluation and Research (CDER) at the Food and Drug Administration.                     
2 We update guidances periodically.  To make sure you have the most recent version of a guidance, check the FDA 
Drugs guidance Web page at 
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm. 
  1  Contains Nonbinding Recommendations 
substances that support the ANDAs). It does not apply to postapproval 
changes.  
   
The implementation date is June 20, 2014.   
 
Q2:  How will this guidance affect the Presidents Emergency Plan for AIDS Relief 
(PEPFAR) and positron emission tomography (PET) ANDAs? 
   
A2:    For chemistry, manufacturing, and controls (CMC) information, PEPFAR 
ANDAs should follow the guidance for industry on Fixed Dose 
Combinations, Co-Packaged Drug Products, and Single-Entity Versions of 
Previously Approved Antiretrovirals for the Treatment of HIV.3   
 
For PET ANDAs, the Agency recommends a minimum of three batches at or 
near the upper end of the proposed radio-concentration. If different 
synthesizers (methods of synthesis) are used, three batches from each method 
of synthesis at or near the upper end of the proposed radio-concentration are 
recommended. Batches do not have to be made in the same facility. For any 
additional manufacturing facilities, applicants should provide stability data on 
at least one batch at or near the upper end of the proposed radio-concentration 
from each facility, although bracketing approaches may be submitted for 
review.  For additional information, the Agency has published a guidance for 
industry on FDA Oversight of PET Products, Questions and Answers.4 
 
Q3(i): Can an ANDA be submitted with 6 months of accelerated stability and 6 months of 
long-term stability data?  
 
A3(i):  Yes.  An ANDA applicant should submit 6 months of accelerated stability 
data and 6 months of long-term stability data at the time of submission. 
However, if 6 months of accelerated data show a significant change5 or failure 
of any attribute, the applicant should also submit 6 months of intermediate 
data at the time of submission. 
 
Q3(ii): When do intermediate stability studies need to be initiated in the event of failure at 
accelerated condition?  
  
A3(ii):  An ANDA applicant should start accelerated, intermediate, and long-term 
stability studies at the same time so the data are available at the time of 
submission if the accelerated stability study fails. 
 
                                                 
3 See footnote 2. 
4 Ibid. 
5 See the International Conference on Harmonisation (ICH) guidance to industry on  Q1A(R2) Stability Testing 
of New Drug Substances and Products, section 2.2.7.1. 
  2  Contains Nonbinding Recommendations 
Q3(iii): If one among the three batches in accelerated conditions shows a significant 
change, what should be done? 
 
A3(iii):  If accelerated data show a significant change or failure of any attribute in one 
or more batches, an applicant should submit intermediate data for all three 
batches.  In addition, the submission should contain a failure analysis (i.e., 
discussion concerning the observed failure(s)). 
 
Q4:   Can stability bracketing and/or matrixing be used to determine the packaging 
configurations to be placed on stability for an original ANDA without prior approval 
from the Office of Generic Drugs (OGD)? 
 
A4:  Yes. You should follow the International Conference on Harmonisation (ICH) 
guidance for industry on Q1D Bracketing and Matrixing Designs for Stability 
Testing of New Drug Substances and Products6 and its example tables. 
 
Q5(i): If an application that qualifies for the Generic Drug User Fee Act (GDUFA) 10-month 
review is filed with 6 months of accelerated and 6 months of long-term data, and there 
are no blocking patents or exclusivities, will 24 months of shelf life be granted?  
 
Q5(ii): During the review cycle, will the application need to be updated with 12 months of 
long-term data? 
 
A5(i,ii):  FDA will grant a shelf life period of two times the available long-term data at 
the time of approval (up to 24 months) following the recommendation of the 
ICH Q1E Evaluation of Stability Data (ICH Q1E) guidance,7 provided the 
submitted data are satisfactory, and data evaluation and appropriate 
commitments are provided in accordance with ICH Q1E.  Please refer to the 
decision tree (Appendix A) in ICH Q1E.  The ANDA should be updated with 
12 months of long-term data during the review cycle. 
 
Q6:   Can only two lots of finished product at pilot scale batch size ever be considered 
sufficient to support the stability of an ANDA for simple dosage forms?   
 
A6:  According to the FDA stability guidance, the applicant should submit data 
from three pilot scale batches or should submit data from two pilot scale 
batches and one small scale batch.  This applies to all dosage forms. If the size 
of the pilot scale batch does not follow ICH recommendations, the applicant 
should provide a justification.  See also section C, question 20 for additional 
information regarding exceptions. 
 
                                                 
6 See footnote 2. 
7 Ibid. 
  3  Contains Nonbinding Recommendations 
Q7:   How is the proposed shelf life supposed to be calculated? Will 6 months of accelerated 
data equal 24 months at long-term? 
 
A7:  ICH Q1E principles will help in the calculation of shelf life.  Data from the 
three ANDA submission batches (i.e., 6 months), accelerated data meeting all 
criteria (without significant change per ICH Q1A(R2)), and 12 months long-
term data without variability will not need statistical evaluation, and with 
appropriate post approval stability commitments, can be used to support 
extrapolation to a 24 months shelf life.  
 
If there is a significant change in the accelerated data, ICH Q1E, Appendix A, 
provides more details regarding when intermediate condition stability data are 
recommended.   
 
Q8:   Will the recommendation for 6 months accelerated data be met by providing 24 weeks 
of data as 12 weeks is typically accepted as equivalent to 3 months?  
 
A8:  No.  FDA, following the recommendations of ICH stability guidances refers 
to timeframes in terms of months and not weeks. 
 
Q9:   When a patent is due to shortly expire and there are no approved ANDAs, can we file 
with 3 months stability data with a commitment to supply 6 months data when 
available? 
 
A9:  No.  Data recommendations in the FDA stability guidance should be followed 
irrespective of patent status.    
 
Q10:  How long do the three pilot scale batches, submitted as a part of an ANDA, need to be 
stored before destruction? 
 
A10:  Sample storage times are discussed in 21 CFR 320.38 and 21 CFR 320.63 in 
connection with bioequivalence study samples.  In general, ANDA 
submission batch samples should be stored for 1 year after approval of the 
ANDA, and samples of the drug product used for bioequivalence studies must 
be stored following the requirements listed in 21 CFR 320.38 and 21 CFR 
320.63. In addition, the guidance for industry on Handling and Retention of 
BA and BE Testing Samples8 may be helpful regarding the procedure for 
handling reserve samples from relevant bioavailability and bioequivalence 
studies.  Additional information on sample quantities (for retention purposes) 
is discussed in 21 CFR 211.170 (a) and (b), Reserve Samples. 
 
                                                 
8 See footnote 2. 
  4  Contains Nonbinding Recommendations 
B.  Drug Master File 
 
Q1:   Please clarify the effect of the FDA stability guidance on Drug Master File (DMF) 
holders. 
 
Q1(i): How many months of long-term and accelerated data are required when a 
Completeness Assessment is performed on the DMF? Also, what should the DMF 
stability section contain for a Completeness Assessment? 
 
A1(i):   To pass the Completeness Assessment, DMFs should include the stability 
protocol, commitments, and data demonstrating that stability studies have 
started.  The initial and one additional time point for the accelerated studies 
and long-term studies are sufficient.  If the DMF does not meet the 
recommendations under A1(ii) below at the time of the Completeness 
Assessment the DMF holder should amend the DMF with updated stability 
data to prepare for full scientific review.  
 
Q1(ii): Are stability data from three current good manufacturing practice (CGMP) batches 
required to be filed in the DMF to support the API retest date? Also, how many months 
of long-term and accelerated data are required for pilot scale batches? 
 
A1(ii):  Yes.  Per ICH Q1A(R2) data from formal stability studies should be provided 
on at least three primary batches9 and the batches should be manufactured to a 
minimum of pilot scale10 for the drug substance to be filed in the DMF.  These 
batches should be made under CGMPs.  The FDA stability guidance 
recommends 6 months of accelerated data and 6 months of long-term data for 
the pilot scale batches to be submitted for a full scientific review of the DMF.   
Additional long-term data for all three batches, as the data becomes available 
through the proposed retest period, should be submitted as an amendment. 
 
Q2:     Will submissions to DMFs be accepted based on stability data from production scale 
batches?  
 
A2:  Yes.  Per ICH Q1A(R2), section II, A, 8, Stability Commitment (2.1.8), the 
submission is appropriate if satisfactory stability data from at least three 
production batches made under CGMP are filed in the DMF with 6 months of 
accelerated data and data for samples stored under long-term conditions that 
cover the proposed retest period. 
 
Q3:     Should executed batch records for the three batches be included in the DMF 
submission? 
 
A3:  One representative executed batch record will be sufficient.   
 
                                                 
9 Primary batch is defined in ICH Q1A(R2) Glossary. 
10 See ICH Q1A(R2) Glossary. 
  5  Contains Nonbinding Recommendations 
C.  Drug Product Manufacturing and Packaging 
 
Q1:   Can the split bulk solution filled into different fill volumes be considered discrete 
batches? 
 
A1:  To be consistent with ICH Q1A(R2), we recommend that discrete finished 
product batches be produced that represent different batches of bulk solution.  
Split filling one batch of bulk solution into different fill volume sizes would 
not constitute discrete batches.    
 
Q2:   Can you clarify the packaging recommendations for the submission batches for blow-
fill-seal containers? 
 
A2:  Blow-fill-seal containers are not an exception from regular packaging and are 
usually packaged inside a secondary container or a carton.  The secondary 
packaging should be included in all three batches.  ICH Q1A(R2) addresses 
secondary packaging usefulness (see section II, B, 4, Drug Product Container 
Closure System (2.2.4)). 
 
Q3:   Should all three batches be stored in final proposed packaging?  
 
A3:  Yes.  You should package all three batches in the container closure system 
proposed for marketing. ICH Q1A(R2) addresses this question (see section II, 
B, 4, Drug Product Container Closure System (2.2.4)).   
 
Q4:   What is the Agencys position on using different lots of APIs and/or packaging 
materials? How many API lots should be used in the manufacture of finished product 
lots used to support the ANDA? 
 
A4:  It is not necessary to use different lots of packaging material, except in cases 
where the packaging material could affect drug product performance and/or 
delivery.  A minimum of two lots of the drug substance should be used to 
prepare the three primary batches of drug product.11    
 
Q5:   Should the small scale batches be packaged with commercial equipment? Also, is it 
acceptable to package using research equipment or by hand? 
   
A5:  Yes.  Small scale batches should be packaged with commercial equipment, or 
the packaging equipment should be similar to that proposed for use prior to 
market distribution. No, it is not recommended to package small scale batches 
using research equipment or by hand.  Please refer to ICH Q1A(R2) section II, 
B, 3, Selection of Batches (2.2.3) and the glossary definition for primary 
batches.  
 
                                                 
11 For nasal aerosols and nasal sprays, you should use three different lots of drug substance. 
  6  Contains Nonbinding Recommendations 
Q6:   What will the recommendation for secondary packaging be?   
 
A6:  We recommend following ICH Q1A(R2) section II, B, 4, Drug Product 
Container Closure System (2.2.4). 
 
Q7:    What are the recommendations for stability testing data of modified release dosage 
forms? 
 
A7:   Per ICH Q1A(R2) the applicant should provide data on three batches of all 
dosage forms including modified release dosage forms.  ICH stability 
guidances do not distinguish among different dosage forms. 
 
Q8:   What are the recommendations for the submission of oral solutions, ophthalmic 
solutions, oral and ophthalmic suspensions, transdermal patches, ointments, creams, 
granules for reconstitution, and parenterals?   
 
A8:  The applicant should provide three discrete batches and 6 months of 
accelerated data and 6 months of long-term data at the time of submission for 
all dosage forms.  Also, refer to other questions and corresponding answers 
that specifically discuss other dosage forms included in this document (e.g., 
questions Q7, Q13). 
 
Q9:   Are 6 months of stability data required on all three batches, or would one batch at 6 
months and two lots at 3 months be acceptable? 
 
A9:  Following ICH stability guidances, 6 months accelerated stability data on all 
three submission batches should be provided.   
 
Q10:   Should the executed batch records for the three batches be included in the ANDA 
submission? 
 
A10:  Yes. 
 
Q11:   Does all relevant CMC batch information for the three stability batches need to be 
included in the application? 
 
A11:  Yes.  When more than one lot of API or excipients is used, the corresponding 
section in Module 3 should contain appropriate CMC information. 
 
Q12:   If you are an applicant submitting an ANDA with two API sources, are you required to 
perform stability on three batches of drug product for each API source? 
 
A12:  If you propose to add additional sources of API for the same drug substance, 
you should provide the following CMC information:  
 
  7  Contains Nonbinding Recommendations 
  Comparison and justification of comparability (by the applicant) of the 
physico-chemical properties and impurities of the drug substance from 
each source.  
  Appropriate stability data on three batches of drug product qualifying 
the first API source used in the bioequivalence (BE) studies as 
recommended by the FDA stability guidance. 
  A single pilot scale batch of the drug product bio-strength(s) 
manufactured using the second or each of the other proposed API 
source(s) used to support the ANDA application, along with 
comparative dissolution data.  
  Appropriate stability data (accelerated and long-term for 6 months at 
the time of filing) on the strength(s) manufactured for each API 
source.  Appropriate stability data may in some cases include 
intermediate condition stability data. 
 
Q13:   What is meant by small scale? Small is not a defined word in ICH guidance.  
What are the packaging expectations from the small batch, as well as from the two 
pilot scale batches? Traditionally, ANDAs are submitted with 100,000 units for solid 
oral dosage forms. Is this still applicable? 
 
A13:  The interpretation of what constitutes a small scale batch for the purpose of 
filing ANDAs is further elaborated below for various dosage forms and their 
packaging recommendations.  Unless specifically noted below, one primary 
batch should be fully packaged. 
 
Oral dosage forms 
 
(a) Tablets/Capsules (e.g., immediate release, extended release, chewable, 
orally disintegrating and delayed release tablets or capsules):  Two of the 
three batches should be of at least 10 percent of the proposed production batch 
or 100,000 finished dosage units, whichever is greater (i.e., pilot scale 
batches).  The third batch can be smaller than the 10 percent of the proposed 
production batch, but should not be less than 25 percent of the pilot scale 
batch.  We recommend stability data be generated for the three ANDA 
submission batches in the proposed marketing container.  A minimum of 
100,000 units in all proposed presentations is recommended.  Representative 
samples from all three batches must be packaged in a sufficient number of 
proposed marketing presentations to comply with 21 CFR 211.166(a)(1-5) and 
211.166(b) .   
 
(b) Powders/Solutions/Suspensions:  Two of the three batches should be at 
least 10 percent of the proposed maximum size commercial batch.  The third 
batch can be smaller than 10 percent of the proposed commercial batch, but 
should not be less than 25 percent of the pilot scale batch.  To capture 
variability introduced by packaging, the product from all the batches should 
be used in the packaging process.  We recommend packaging representative 
  8  Contains Nonbinding Recommendations 
samples from all three batches of a sufficient number of proposed marketing 
presentations to comply with 21 CFR 211.166(a)(1-5) and 211.166(b) . 
 
Parenterals 
 
Solutions/Powders for Solutions (lyophilized cakes)/Suspensions/Sterile 
Topicals (Ophthalmic and Otic drug products):  Two of the three batches 
should be at least (a) 10 percent of the proposed maximum size commercial 
batch (i.e., pilot scale size), (b) 50 L (per batch if the fill volume 
configurations per vial is larger than 2.0 mL), or (c) 30 L (per batch if the fill 
volume size is up to 2.0 mL) whichever is larger including packaging.12  
When multiple fill volume sizes are proposed by the applicant (e.g., 1 mL, 2 
mL, and 3 mL), then 50 L per batch size is recommended.  The third batch can 
be smaller than 10 percent of the proposed commercial batch, but should not 
be less than 25 percent of the pilot scale batch (with packaging).13  To capture 
variability introduced by packaging, the product from each of multiple fill 
volume batches should be used in the packaging process.  We recommend 
manufacturing all the batches to meet sterility requirements.  Packaging 
requirements are also discussed in 21 CFR 211.166(a) (1-5) and 211.166 (b). 
 
Transdermal Patches    
 
Two of the three batch sizes for each strength should be at least 10 percent of 
the proposed commercial production batch (with packaging) or 25,000 units 
(for each strength), whichever is greater.  The third batch can be smaller than 
10 percent of the proposed commercial batch (with packaging), but should not 
be less than 60 percent of the pilot scale batch (with packaging).  For 
transdermal matrix products, where different strengths are identified by the 
transdermal patch size (surface area), to comply with the three batch size 
recommendation, we recommend providing data on patches manufactured 
using three distinct matrix laminates at the time of submission (each laminate 
can be cut to support multiple strengths in the application, where applicable).  
We recommend you contact the appropriate OGD review division if you are 
manufacturing transdermal patches using other technologies (e.g., reservoir).14  
 
You should include a representative sample from all three batches using 
different components of backing, adhesives, release liner, and other critical 
excipients used in packaging a sufficient number of proposed marketing 
presentations to comply with 21 CFR 211.166(a)(1-5) and 211.166(b).   
 
                                                 
12 Amount packaged = 50 L or 30 L (minus) filling/flushing loss. 
13 Ibid. 
14 See the guidance for industry on Residual Drug in Transdermal and Related Drug Delivery Systems. 
  9  Contains Nonbinding Recommendations 
Topicals  
 
(a) Creams/Lotions/Gels:  For nonsterile semi-solid dosage forms,15 the two 
pilot scale batches should be at least 100 Kg or 10 percent of the production 
batch, whichever is larger, packaged.16  The third batch can be smaller than 10 
percent of the proposed commercial batch, but not less than 40 percent of the 
pilot scale batch, packaged.17  Packaging requirements are also discussed in 
21 CFR 211.166(a) (1-5) and 211.166 (b). 
 
(b) Inhalation Solutions/Nasal Sprays (nasal nonmetered dose atomizer): 
Please refer to the following guidances for industry for information: Nasal 
Spray and Inhalation Solution, Suspension, and Spray Drug Products  
Chemistry, Manufacturing, and Controls Documentation, and Bioavailability 
and Bioequivalence Studies for Nasal Aerosols and Nasal Sprays for Local 
Action.18 
 
Please contact OGD to discuss other dosage forms and/or routes of 
administration not covered in this document.                   
 
Q14:   Is it acceptable to use a technical grade of the drug substance for the small scale 
batches or one of the two pilot scale batches of finished drug product?   
 
A14:  No.  The applicant should follow CGMP requirements for ANDA submission 
as they relate to drug substance and finished drug product.  Because the drug 
substance quality can affect the drug product stability, the drug substance used 
for the ANDA batches (supporting the application) should be of the same 
quality intended for the market product.  We would consider data from the use 
of a different grade drug substance for a product as supporting data.   
 
Q15:   Do the small scale batches need to be manufactured in accordance with all CGMP 
regulations, or is it acceptable to manufacture the small scale batches in a research 
setting? 
 
 A15:  All ANDA submission batches should be made following CGMP. 
 
 
Q16:   Should the small scale batches meet the same finished product specification as the pilot 
scale batches?  
 
A16:  Yes.  The finished product specification should be the same for all three 
ANDA submission batches submitted.  
                                                 
15 See the CDER Data Standards Manual, Drug Nomenclature Monographs (Dosage Form) 
http://www.fda.gov/Drugs/DevelopmentApprovalProcess/FormsSubmissionRequirements/ElectronicSubmissions/D
ataStandardsManualmonographs/ucm071666.htm.  
16 Amount packaged = 100 Kg or Larger (minus) filling/flushing loss. 
17 Ibid. 
18 See footnote 2. 
  10  Contains Nonbinding Recommendations 
 
Q17:   For sterile products, is it acceptable to manufacture the small scale batches in a  
nonsterile facility and allow variance from sterility and particulate criteria?   
 
A17:  No.  To be consistent with ICH Q1A(R2), sterile product small scale batches 
should be representative of the manufacturing processes to be applied to a full 
production scale batch, and therefore should not be manufactured in a 
nonsterile facility.  Sterility is a critical quality attribute (CQA) for sterile 
products. 
 
Q18:   Should small scale batches be produced at the proposed commercial site?   
 
A18:  Yes.  Small scale batches should be produced at the proposed commercial site.  
The primary batch information submitted in the application is used to support 
the proposed commercial product manufacture.  Product batches produced at a 
different site than the proposed commercial site would not be considered as 
primary batches. 
 
Q19(i): In cases where an intermediate bulk material is identical between the various 
strengths (dose proportional blends, bulk solutions, etc.), is it sufficient to perform 
stability on one lot of each strength, when each strength is produced from a separate 
intermediate bulk? 
  
A19(i):  No.  For ANDAs that contain multiple strengths (that are dose proportional), 
three separate intermediate bulk granulations (or blends) should be 
manufactured.  One batch of bulk granulation (or blend) should be used to 
manufacture all the strengths proposed.  The other two bulk granulations (or 
blends) can be used to manufacture only the lowest and the highest strengths, 
in addition to the strength used in BE studies (i.e., the strength(s) tested in the 
BE studies should have three batches).  Stability testing should still use all 
three batches of drug product. 
 
Q19(ii): Are differences in the capsule shell (i.e., imprint, color, size, etc.), allowed in cases 
where a multi-strength capsule product is dose-proportional across all strengths (based 
on common bead blend)? 
 
A19(ii):   Yes differences in the capsule shell are allowed in the described case. 
 
Q20:   What are the criteria for an exception to the recommendations regarding minimum 
size for pilot scale for ANDA submission batches? What justification would be needed 
if we wanted to deviate from these guidance recommendations? 
 
A20:  The submission ANDA batches can have a smaller size than the established 
pilot scale, according to the ICH definition, when any one of the following 
circumstances prevails: 
  The reference listed drug product has an orphan drug designation. 
  11  Contains Nonbinding Recommendations 
  Use of a controlled drug substance is based on a Drug Enforcement 
Administration allocation. 
  The test batch size is the same as the commercial batch size with the 
commitment that a prior approval supplement (PAS) will be provided 
when there is a scale-up.  
 
Q21:   Are scale-up and postapproval changes (SUPAC) level one and two variations and 
changes permitted among the three ANDA submission batches for components and 
composition? 
 
A21:  No.  The three ANDA submission batches should maintain the chosen formula 
based on product development studies for components and composition.  
 
Q22:   Can FDA provide specific examples of cases where statistical analysis is required and 
the type of statistical analysis needed? 
 
A22:  The FDA stability guidance recommends analysis of data in accordance with 
ICH Q1E, Appendix A.  The flowchart in that guidance provides clear 
situations where analysis is normally recommended or unnecessary.   In 
addition, ICH Q1E B.7 figures provide example diagrams for assay and 
degradation products that illustrate how plots should be generated for the three 
batches using regression lines and upper and lower confidence limits.   
 
Q23:   How many batches of drug product should be tested for split-portions of scored tablets? 
 
A23:  In general, one batch testing for each scored strength on the split tablets will 
suffice, as recommended in the guidance for industry, Tablet Scoring: 
Nomenclature, Labeling, and Data for Evaluation.19 
  
Q24:   For drug products that include placebo tablets, how many batches (of placebo tablets) 
are required for submission? Is 6 months of stability data on the placebo tablets needed 
if the ANDA is submitted after the June 2014 deadline? 
 
A24:   One batch of placebo tablets with full CMC information should be included at 
the time of ANDA submission; however, the final packaging presentation 
(containing the placebo tablets) should have data from accelerated and long-
term stability testing.  Six months of accelerated and long-term stability data 
are recommended for the entire packaging presentation including placebo 
tablets, where applicable, at the time of submission. 
  
 
D.  Amendments to Pending ANDA Application 
 
Q1:   What are the recommendations for amendments and responses filed to pending 
ANDAs after issuance of the final FDA stability guidance? 
                                                 
19 See footnote 2. 
  12  Contains Nonbinding Recommendations 
 
A1:  All amendments submitted to pending ANDAs after the effective date of the 
final FDA stability guidance will be held to the standards in place concerning 
stability data at the time of the original ANDA submission, unless there is a 
concern with the submitted stability data.    
 
 
E.  Stability Studies 
 
Q1:   What will be the expected testing time points on accelerated conditions?  
 
A1:  The applicant should test at 0 (initial release), 3, and 6 months; for additional 
time points on accelerated conditions, please follow ICH Q1A(R2) 
recommendations for all ANDAs.20   
 
Q2:   Can the Agency clarify expectations for the storage positions for products placed into 
the stability program? 
   
A2:  For primary batches of liquids, solutions, semi-solids, and suspensions, the 
product should be placed into an inverted (or horizontal) position and an 
upright (or vertical) position. For routine stability studies, the applicant 
should pick the worst case orientation for the study.  
 
Q3:   When and how are reconstitution/dilution studies performed? 
 
A3:  Recommendations listed in ICH Q1A(R2), section II, B, 7, Storage Conditions 
(2.2.7) should be followed for all three batches. These studies should be 
performed when the drug product is labeled for reconstitution or dilution.   
 
Q4:    What types of containers are classified as semipermeable containers, and can the 
Agency clarify the stability expectations for the drug products in semipermeable 
containers? 
 
A4:  Examples of semipermeable containers are provided in the ICH Q1A(R2) 
glossary.  The recommendations for stability expectations for semipermeable 
containers are detailed in ICH Q1A(R2) section II, B, 7, c.  Drug products 
packaged in semipermeable containers (2.2.7.3).   
 
Q5:   Can the Agency clarify expectations around the number of batches to support tests 
such as preservative effectiveness and extractable leachable testing? 
 
A5:  One of the primary batches of the drug product should be tested for 
antimicrobial preservative effectiveness (in addition to preservative content) at 
the end of the proposed shelf life.  The drug product specification should 
                                                 
20 This recommendation also applies to nasal spray, inhalation solution, suspension, aerosols, and liposomal drug 
products. 
  13  Contains Nonbinding Recommendations 
include a test for preservative content, and this attribute should be tested in all 
stability studies. 
 
  Extraction/leachable studies are generally one-time studies; however, if 
multiple types of containers/closures are employed for packaging, then 
additional studies could be recommended. 
 
Q6:   When are in-use stability studies needed? 
   
A6:   Please refer to response A3 under section E, Stability Studies.  
 
Q7:   Are there changes to postapproval protocols and commitments when ICH stability 
guidances are implemented because of scale or type of batches submitted? 
 
A7:  ICH Q1A(R2), section II, B, 8, Stability Commitment (2.2.8) addresses this 
question.  Section 2.1.8 provides information regarding stability commitment 
for drug substances. 
 
  Also, ANDAs and DMFs should include a commitment to place one batch of 
drug product and drug substance, respectively, into the annual long-term 
stability program, and to provide stability data in the annual reports. 
  14