Guidance for Industry
Container Closure Systems for Packaging
Human Drugs and Biologics
CHEMISTRY, MANUFACTURING, AND CONTROLS DOCUMENTATION
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
Center for Biologics Evaluation and Research (CBER)
May 1999 Guidance for Industry
Container Closure Systems for Packaging 
Human Drugs and Biologics
CHEMISTRY, MANUFACTURING, AND CONTROLS DOCUMENTATION
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or
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(Internet) http://www.fda.gov/cber/guidelines.htm
U.S. Department of Health and Human Services
Food and Drug Administration
Center for Drug Evaluation and Research (CDER)
Center for Biologics Evaluation and Research (CBER)
May 1999 Table of Contents
I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II. BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
A. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
B. CGMP, CPSC and USP Requirements on Containers and Closures . . . . . . . . . . . 3
C. Additional Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
III. QUALIFICATION AND QUALITY CONTROL OF PACKAGING COMPONENTS . 5
A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
B. General Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
C. Information That Should Be Submitted in Support of an Original 
Application for Any Drug Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
D. Inhalation Drug Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
E. Drug Products for Injection and Ophthalmic Drug Products . . . . . . . . . . . . . . . 23
F. Liquid-Based Oral and Topical Drug Products and Topical Delivery Systems . . 27
G. Solid Oral Dosage Forms and Powders for Reconstitution . . . . . . . . . . . . . . . . 33
H. Other Dosage Forms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
IV. POSTAPPROVAL PACKAGING CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
V. TYPE III DRUG MASTER FILES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
A. General Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
B. Information in a Type III DMF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
VI. BULK CONTAINERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
A. Containers for Bulk Drug Substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
B. Containers for Bulk Drug Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
ATTACHMENT A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  A-1
REGULATORY REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  A-1
ATTACHMENT B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  B-1
COMPLIANCE POLICY GUIDES THAT CONCERN PACKAGING . . . . . . . . . .  B-1
ATTACHMENT C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  C-1
EXTRACTION STUDIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  C-1
ATTACHMENT D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  D-1
ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  D-1
ATTACHMENT E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  E-1
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  E-1 GUIDANCE FOR INDUSTRY1
CONTAINER CLOSURE SYSTEMS FOR PACKAGING
HUMAN DRUGS AND BIOLOGICS
CHEMISTRY, MANUFACTURING, AND CONTROLS DOCUMENTATION
I. INTRODUCTION
This document is intended to provide guidance on general principles2 for submitting information
on packaging materials used for human drugs and biologics.3  This guidance supersedes the FDA
Guideline for Submitting Documentation for Packaging for Human Drugs and Biologics, issued
in February 1987 and the packaging policy statement issued in a letter to industry dated June 30,
1995 from the Office of Generic Drugs.4  This guidance is not intended to describe the
information that should be provided about packaging operations associated with drug product
manufacture.
Approaches which differ from those described in this guidance may be followed, but the applicant
is encouraged to discuss significant variations in advance with the appropriate CDER chemistry
review staff or CBER review staff.  This is to prevent applicants or sponsors from spending
unnecessary time and effort in preparing a submission that the FDA may later determine to be
unacceptable.
1 This guidance has been prepared by the Packaging Technical Committee of the Chemistry, Manufacturing, and
Controls Coordinating Committee (CMC CC) in the Center for Drug Evaluation and Research (CDER) and in
conjunction with the Center for Biologics Evaluation and Research (CBER) at the Food and Drug Administration.  This
guidance document represents the Agency's current thinking on container closure systems for the packaging of human
drugs and biological products.  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 In general, this guidance does not suggest specific test methods and acceptance criteria (except for references to The
United States Pharmacopia methods), nor does it suggest comprehensive lists of tests.  These details should be
determined based on good scientific principles for each specific container closure system for particular drug product
formulations, dosage forms, and routes of administration.  Acceptance criteria should be based on actual data for
particular packaging components and container closure systems, and they should be set to ensure batch-to-batch
uniformity of packaging components.
3 As used in this guidance, the terms drug and drug product include biologics unless otherwise noted.
4 The policy statement is a document titled Container/Closure Information Which Should Be Provided In An
ANDA/AADA which was written by the Office of Generic Drugs/Packaging Advisory Group. II. BACKGROUND
The Federal Food, Drug, and Cosmetic Act (the Act) mandates the need for adequate information
related to packaging materials.  Section 501(a)(3) of the Act states that a drug is deemed to be
adulterated "if its container is composed, in whole or in part, of any poisonous or deleterious
substance which may render the contents injurious to health...."  In addition, section 502 of the
Act states that a drug is considered misbranded if there are packaging omissions.  Also, section
505 of the Act requires a full description of the methods used in, and the facilities and controls
used for, the packaging of drugs (see Attachment A).
Section 505(b)(1)(D) of the Act states that an application shall include a full description of the
methods used in, the manufacturing, processing and packing of such drug.  This includes facilities
and controls used in the packaging a drug product. 
A. Definitions5
Materials of construction6 refer to the substances (e.g., glass, high density polyethylene
(HDPE) resin, metal) used to manufacture a packaging component.
A packaging component means any single part of a container closure system.  Typical
components are containers (e.g., ampules, vials, bottles), container liners (e.g., tube
liners), closures (e.g., screw caps, stoppers), closure liners, stopper overseals, container
inner seals, administration ports (e.g., on large-volume parenterals (LVPs)), overwraps,
administration accessories, and container labels.  A primary packaging component means
a packaging component that is or may be in direct contact with the dosage form.  A
secondary packaging component means a packaging component that is not and will not be
in direct contact with the dosage form.
A container closure system refers to the sum of packaging components that together
contain and protect the dosage form.  This includes primary packaging components and
secondary packaging components, if the latter are intended to provide additional
protection to the drug product.  A packaging system is equivalent to a container closure
system.
5 These definitions are intended to clarify the use of certain terms in this guidance only and are not intended to supersede
the definitions of container and package as provided for in 21 CFR 600.3.
6 This term is used in a general sense for the basic material, which should be defined in the application in terms of its
specific chemical composition for a given drug application (e.g., the specific polymer and any additives used to make the
material).
2 A package or market package7 refers to the container closure system and labeling,
associated components (e.g., dosing cups, droppers, spoons), and external packaging
(e.g., cartons or shrink wrap).  A market package is the article provided to a pharmacist or
retail customer upon purchase and does not include packaging used solely for the purpose
of shipping such articles.
Quality refers to the physical, chemical, microbiological, biological, bioavailability, and
stability attributes that a drug product should maintain if it is to be deemed suitable for
therapeutic or diagnostic use.  In this guidance, the term is also understood to convey the
properties of safety, identity, strength, quality, and purity (see 21 CFR 211.94(a)).
An extraction profile refers to the analysis (usually by chromatographic means) of extracts
obtained from a packaging component.  A quantitative extraction profile is one in which
the amount of each detected substance is determined.
B. CGMP, CPSC and USP Requirements on Containers and Closures
Current good manufacturing practice (CGMP) requirements for the control of drug
product containers and closures are included in 21 CFR Parts 210 and 211.  A listing of
the relevant sections is provided in Attachment A.  In addition, a listing of Compliance
Policy Guides that deal with packaging issues is provided in Attachment B.  References in
this guidance to CGMP regulations are provided for completeness.  For additional
information, refer to the FDA Compliance Program Guidance Manual for Pre-Approval
Inspections/Investigations (7346.832) which describes specific responsibilities for CDER
scientists and for field investigators.
The FDA requirement for tamper-resistant closures is included in 21 CFR 211.132 and the
Consumer Product Safety Commission (CPSC) requirements for child-resistant closures
are included in 16 CFR 1700.  An outline of these and other applicable regulatory
requirements is provided in Attachment A.
The United States Pharmacopeial Convention has established requirements for containers
which are described in many of the drug product monographs in The United States
Pharmacopeia/National Formulary (USP/NF).  For capsules and tablets, these
requirements generally relate to the design characteristics of the container (e.g., tight,
well-closed or light-resistant).  For injectable products, materials of construction are also
addressed (e.g., "Preserve in single-dose or in multiple-dose containers, preferably of Type
I glass, protected from light").  These requirements are defined in the "General Notices
and Requirements" (Preservation, Packaging, Storage, and Labeling) section of the USP. 
The requirements for materials of construction are defined in the "General Chapters" of
7 The materials of construction used in the labeling are a concern from a packaging perspective if they affect the
protection and/or safety of the drug product.
3 the USP (see Attachment A).
C. Additional Considerations
1. Submissions of INDs
The packaging information in the chemistry, manufacturing, and controls section
of an IND usually includes a brief description of the components, the assembled
packaging system and any precautions needed to ensure the protection and
preservation of the drug substance and drug product during their use in the clinical
trials.
For general guidance regarding the container closure system information to be
submitted for phase 1 studies, refer to the FDA guidance for industry Content and
Format of investigational New Drug Applications(INDs) for Phase 1 Studies of
Drugs, Including Well-Characterized, Therapeutic, Biotechnology-derived
Products (November 1995).
General guidance regarding the container closure system information to be
submitted for phase 2 or phase 3 studies will be provided in the FDA guidance for
industry INDs for Phase 2 and 3 Studies of Drugs, Including Specified
Therapeutic Biotechnology-Derived Products, Chemistry, Manufacturing, and
Controls Content and Format, when finalized (draft guidance published April 21,
1999).
2. Submissions on Packaging of a Drug Product by Another Firm
a. Contract Packager
A contract packager is a firm retained by the applicant to package a drug
product.  The applicant remains responsible for the quality of the drug
product during shipping, storage, and packaging.
The information regarding the container closure system used by a contract
packager that should be submitted in the CMC section of an application
(NDA, ANDA, or BLA), or in a DMF which is referenced in the
application, is no different from that which would be submitted if the
applicant performed its own packaging operations.  If the information is
provided in a DMF, then a copy of the letter of authorization (LOA) for
the DMF should be provided in the application (see section V.A).
4 b. Repackager8
A repackager is a firm that buys drug product from the drug product
manufacturer or distributor and repackages it for sale under a label
different from that of the manufacturer.  The repackager is responsible for
ensuring the quality and stability of the repackaged drug prpoduct.  The
repackaging operation is required to e in compliance with CGMPs (21 CFR
Part 211), and there are limits to the expiration period that may be used
with the repackaged product unless the repackager conducts stability
studies.9  Packaging qualification information is not required if the
repackager uses the same container closure system approved in the original
application.
All significant phases of the manufacturing and processing of a drug
product (including packaging) should be described as part of the CMC
section of an application (NDA, ANDA or BLA), or in a DMF referenced
in the application.  The only exception is the repackaging of solid oral drug
products for which an approved application already exists.10  For biologics,
repackaging is considered a step in the manufacturing process for which
licensing is required (21 CFR 600.3(u) and 601). 
III. QUALIFICATION AND QUALITY CONTROL OF PACKAGING
COMPONENTS
A. Introduction
CDER and CBER approve a container closure system to be used in the packaging of a
human drug or biologic as part of the application (NDA, ANDA or BLA) for the drug or
biologic.  A packaging system found acceptable for one drug product is not automatically
assumed to be appropriate for another.  Each application should contain enough
information to show that each proposed container closure system and its components are
suitable for its intended use.
The type and extent of information that should be provided in an application will depend
on the dosage form and the route of administration.  For example, the kind of information
that should be provided about a packaging system for an injectable dosage form or a drug
8 This discussion does not apply to the repackaging of drug products for dispensing under the practice of pharmacy.
9 FDA Compliance Policy Guides, Expiration Dating of Unit Repackaged Drugs, 480.200, February 1, 1984, rev.
March 1995 (CPG 7132b.11).
10 FDA Compliance Policy Guides, "Regulatory Action Regarding Approved New Drugs and Antibiotic Drug Products
Subjected to Additional Processing or Other Manipulation," 446.100, January 18, 1991 (CPG 7132c.06).
5 product for inhalation is often more detailed than that which should be provided about a
packaging system for a solid oral dosage form.  More detailed information usually should
be provided for a liquid-based dosage form than for a powder or a solid, since a liquid-
based dosage form is more likely to interact with the packaging components.
Table 1 illustrates the correlation between the degree of concern regarding the route of
administration with the likelihood of packaging component-dosage form interactions for
different classes of drug products. 
Table 1
Examples of Packaging Concerns for Common Classes of Drug Products
Degree of Concern Likelihood of Packaging Component-Dosage Form Interaction
Associated with the
Route of
High Medium Low
Administration
Highest Inhalation Aerosols Sterile Powders and
and Solutions; Powders for
Injections and Injection; Inhalation
Injectable Powders 
Suspensionsa
High Ophthalmic Solutions
and Suspensions;
Transdermal
Ointments and
Patches; Nasal
Aerosols and Sprays
Low Topical Solutions and Topical Powders; Oral Tablets and Oral
Suspensions; Topical Oral powders (Hard and Soft
and Lingual Aerosols; Gelatin) Capsules
Oral Solutions and
Suspensions
a For the purposes of this table, the term suspension is used to mean a mixture of two
immiscible phases (e.g., solid in liquid or liquid in liquid).  As such, it encompasses a wide
variety of dosage forms such as creams, ointments, gels, and emulsions, as well as
suspensions in the pharmaceutical sense.
For the purpose of this guidance, container closure systems for the most common types of
dosage forms will be discussed in terms of five general categories:  Inhalation Drug
Products (section III.D); Drug Products for Injection and Ophthalmic Drug Products
(Section III.E); Liquid-based Oral and Topical Drug Products and Topical Delivery
Systems (section III.F); Solid Oral Dosage Forms and Powders for Reconstitution (section
6 III.G); and Other Dosage Forms (section III.H).
B. General Considerations
Suitability refers to the tests and studies used and accepted for the initial qualification of a
component or a container closure system for its intended use.  Quality control (QC) refers
to the tests typically used and accepted to establish that, after the application is approved,
the components and the container closure system continue to possess the characteristics
established in the suitability studies.  The subsections on associated components and
secondary components describe the tests and studies for establishing suitability and quality
control for these types of components.  However, the ultimate proof of the suitability of
the container closure system and the packaging process is established by full shelf life
stability studies.
1. Suitability for the Intended Use
Every proposed packaging system should be shown to be suitable for its intended
use:  it should adequately protect the dosage form; it should be compatible with
the dosage form; and it should be composed of materials that are considered safe
for use with the dosage form and the route of administration.  If the packaging
system has a performance feature in addition to containing the product, the
assembled container closure system should be shown to function properly.
Information intended to establish suitability may be generated by the applicant, by
the supplier of the material of construction or the component, or by a laboratory
under contract to either the applicant or the firm.  An adequately detailed
description of the tests, methods, acceptance criteria, reference standards, and
validation information for the studies should be provided.  The information may be
submitted directly in the application or indirectly by reference to a DMF.  If a
DMF is used, a letter authorizing reference (i.e., letter of authorization (LOA)) to
the DMF must be included in the application (see section V.A).
General issues concerning protection, compatibility, safety and performance of
packaging components and/or systems are discussed below.  In this guidance,
component functionality and drug delivery will also be addressed in connection
with specific dosage forms and routes of administration (see sections III.D, III.E,
III.F, III.G, and III.H).
a. Protection
A container closure system should provide the dosage form with adequate
protection from factors (e.g., temperature, light) that can cause a
degradation in the quality of that dosage form over its shelf life.  Common
causes of such degradation are: exposure to light, loss of solvent, exposure
7 to reactive gases (e.g., oxygen), absorption of water vapor, and microbial
contamination.  A drug product can also suffer an unacceptable loss in
quality if it is contaminated by filth.
Not every drug product is susceptible to degradation by all of these factors. 
Not all drug products are light sensitive.  Not all tablets are subject to loss
of quality due to absorption of moisture.  Sensitivity to oxygen is most
commonly found with liquid-based dosage forms.  Laboratory studies can
be used to determine which of these factors actually have an influence on a
particular drug product.
Light protection11 is typically provided by an opaque or amber-colored
container or by an opaque secondary packaging component (e.g., cartons
or overwrap).  The USP test for light transmission (USP <661>) is an
accepted standard for evaluating the light transmission properties of a
container.  Situations exist in which solid and liquid-based oral drug
products have been exposed to light during storage because the opaque
secondary packaging component was removed, contrary to the approved
labeling and the USP monograph recommendation.  A firm, therefore, may
want to consider using additional or alternate measures to provide light
protection to these drug products when necessary.
Loss of solvent can occur through a permeable barrier (e.g., a polyethylene
container wall), through an inadequate seal, or through leakage.  Leaks can
develop through rough handling or from inadequate contact between the
container and the closure (e.g., due to the buildup of pressure during
storage).  Leaks can also occur in tubes due to a failure of the crimp seal.
Water vapor or reactive gases (e.g., oxygen) may penetrate a container
closure system either by passing through a permeable container surface
(e.g., the wall of a low density polyethylene (LDPE) bottle) or by diffusing
past a seal.  Plastic containers are susceptible to both routes.  Although
glass containers would seem to offer better protection, because glass is
relatively impermeable, glass containers are more effective only if there is a
good seal between the container and the closure. 
Protection from microbial contamination is provided by maintaining
adequate container integrity after the packaging system has been sealed. 
An adequate and validated procedure should be used for drug product
manufacture and packaging.
11 For further information regarding photostability studies, see the FDA Guideline for the Photostability Testing of New
Drug Substances and Products (May 1997).
8 b. Compatibility
Packaging components that are compatible with a dosage form will not
interact sufficiently to cause unacceptable changes in the quality of either
the dosage form or the packaging component.
Examples of interactions include loss of potency due to absorption or
adsorption of the active drug substance, or degradation of the active drug
substance induced by a chemical entity leached from a packaging
component; reduction in the concentration of an excipient due to
absorption, adsorption or leachable-induced degradation; precipitation;
changes in drug product pH; discoloration of either the dosage form or the
packaging component; or increase in brittleness of the packaging
component.
Some interactions between a packaging component and dosage form will
be detected during qualification studies on the container closure system and
its components.  Others may not show up except in the stability studies. 
Therefore, any change noted during a stability study that may be
attributable to interaction between the dosage form and a packaging
component should be investigated and appropriate action taken, regardless
of whether the stability study is being conducted for an original application,
a supplemental application, or as fulfillment of a commitment to conduct
postapproval stability studies.
c. Safety
Packaging components should be constructed of materials that will not
leach harmful or undesirable amounts of substances to which a patient will
be exposed when being treated with the drug product.  This consideration
is especially important for those packaging components which may be in
direct contact with the dosage form, but it is also applicable to any
component from which substances may migrate into the dosage form (e.g.,
an ink or adhesive).
Making the determination that a material of construction used in the
manufacture of a packaging component is safe for its intended use is not a
simple process, and a standardized approach has not been established. 
There is, however, a body of experience which supports the use of certain
approaches that depend on the route of administration and the likelihood of
interactions between the component and the dosage form (see Table 1).
For a drug product such as an injection, inhalation, ophthalmic, or
transdermal, a comprehensive study is appropriate.  This involves two
9 parts:  first, an extraction study12 on the packaging component to determine
which chemical species may migrate into the dosage form (and at what
concentration); and, second, a toxicological evaluation of those substances
which are extracted to determine the safe level of exposure via the label
specified route of administration.  This technique is used by the Center for
Food Safety and Applied Nutrition (CFSAN) to evaluate the safety of
substances that are proposed as indirect food additives (e.g., polymers or
additives that may be used in for packaging foods).13
The approach for toxicological evaluation of the safety of extractables
should be based on good scientific principles and take into account the
specific container closure system, drug product formulation, dosage form,
route of administration, and dose regimen (chronic or short-term dosing).
For many injectable and ophthalmic drug products (see sections III.E and
III.F), data from the USP Biological Reactivity Tests and USP Elastomeric
Closures for Injections tests will typically be considered sufficient evidence
of material safety.
For many solid and liquid oral drug products, an appropriate reference to
the indirect food additive regulations (21 CFR 174-186) promulgated by
CFSAN for the materials of construction used in the packaging component
will typically be considered sufficient.  Although these regulations do not
specifically apply to materials for packaging drug products, they include
purity criteria and limitations pertaining to the use of specific materials for
packaging foods that may be acceptable for the evaluation of drug product
packaging components.  Applicants are cautioned that this approach may
not be acceptable for liquid oral dosage forms intended for chronic use (see
section III.F.1).
For drug products that undergo clinical trials, the absence of adverse
reactions traceable to the packaging components is considered supporting
evidence of material safety.
Safety assessments for specific dosage forms are discussed further in
section III of this guidance.
d. Performance
12 See Attachment C for discussion of extraction studies.
13 FDA/CFSAN, Recommendations for Chemistry Data for Indirect Food Additive Petitions, Version 1.2, Chemistry
Review Branch, Office of Pre-Market Approval, June 1995.
10 Performance of the container closure system refers to its ability to function
in the manner for which it was designed.  A container closure system is
often called upon to do more than simply contain the dosage form.  When
evaluating performance, two major considerations are container closure
system functionality and drug delivery.
i. Container Closure System Functionality
The container closure system may be designed to improve patient
compliance (e.g., a cap that contains a counter), minimize waste
(e.g., a two-chamber vial or IV bag), improve ease of use (e.g., a
prefilled syringe), or have other functions.
ii. Drug Delivery
Drug delivery refers to the ability of the packaging system to
deliver the dosage form in the amount or at the rate described in the
package insert.  Some examples of a packaging system for which
drug delivery aspects are relevant are a prefilled syringe, a
transdermal patch, a metered tube, a dropper or spray bottle, a dry
powder inhaler, and a metered dose inhaler.
Container closure system functionality and/or drug delivery are
compromised when the packaging system fails to operate as
designed.  Failure can result from misuse, faulty design,
manufacturing defect, improper assembly, or wear and tear during
use.  Tests and acceptance criteria regarding dosage form delivery
and container closure system functionality should be appropriate to
the particular dosage form, route of administration, and design
features.
e. Summary
Table 2 summarizes typical packaging suitability considerations for
common classes of drug products.
11 Table 2
Typical Suitability Considerations for Common Classes of Drug Products
(This table is a general guide, and is not comprehensive.  See sections III.C through III.H for a
more detailed discussion.)
SUITABILITYa
Route of
Administration/ Performance/
Dosage Form Protection Compatibility Safety Drug
Delivery
Inhalation Aerosols and
L, S, M, W, G Case 1c Case 1s Case 1d
Solutions, Nasal Sprays
Inhalation Powders L, W, M Case 3c Case 5s Case 1d
Injections, Injectable
L, S, M, G Case 1c Case 2s Case 2d
Suspensionsb
Sterile Powders and
L, M, W Case 2c Case 2s Case 2d
Powders for Injection
Ophthalmic Solutions
L, S, M, G Case 1c Case 2s Case 2d
and Suspensions
Topical Delivery
L, S Case 1c Case 3s Case 1d
Systems
Topical Solutions and
Suspensions, and
L, S, M Case 1c Case 3s Case 2d
Topical and Lingual
Aerosols
Topical Powders L, M, W Case 3c Case 4s Case 3d
Oral Solutions and
L, S, M Case 1c Case 3s Case 2d
Suspensions
Oral Powders L, W Case 2c Case 3s Case 3d
Oral Tablets and Oral
(Hard and Soft Gelatin) L, W Case 3c Case 4s Case 3d
Capsules
a If there is a special performance function built into the drug product (e.g., counter cap), it
is of importance for any dosage form/route of administration to show that the container
closure system performs that function properly.
b For definition of the term suspension, see footnote a to Table 1.
Explanation of Codes in Table 2:
12 Protection: L (protects from light, if appropriate)
S (protects from solvent loss/leakage)
M (protects sterile products or those with microbial limits from
microbial contamination)
W (protects from water vapor, if appropriate)
G (protects from reactive gases, if appropriate)
Compatibility: Case 1c:  Liquid-based dosage form that conceivably could interact with its
container closure system components (see examples described in section
III.B.1).
Case 2c:  Solid dosage form until reconstituted; greatest chance
for interacting with its container closure system components
occurs after it is reconstituted.
Case 3c:  Solid dosage form with low likelihood of interacting
with its container closure system components.
Safety: Case 1s:  Typically provided are USP Biological Reactivity Test
data, extraction/toxicological evaluation, limits on extractables,
and batch-to-batch monitoring of extractables.
Case 2s:  Typically provided are USP Biological Reactivity Test
data and possibly extraction/toxicological evaluation.
Case 3s:  Typically, an appropriate reference to the indirect food
additive regulations is sufficient for drug products with aqueous-
based solvents.  Drug products with non-aqueous based solvent
systems or aqueous based systems containing co-solvents
generally require additional suitability information (see section
III.F).
Case 4s:  Typically, an appropriate reference to the indirect food
additive regulations is sufficient.
Case 5s:  Typically, an appropriate reference to the indirect food
additive regulations for all components except the mouthpiece for
which USP Biological Reactivity Test data is provided.
Performance: Case 1d:  Frequently a consideration.
Case 2d:  May be a consideration.
Case 3d:  Rarely a consideration.
2. Quality Control of Packaging Components
In addition to providing data to show that a proposed container closure system is
suitable for its intended use, an application should also describe the quality control
measures that will be used to ensure consistency in the packaging components (see
section III.C.3).  These controls are intended to limit unintended postapproval
13 variations in the manufacturing procedures or materials of construction for a
packaging component and to prevent adverse affects on the quality of a dosage
form.
Principal consideration is usually given to consistency in physical characteristics
and chemical composition.
a. Physical Characteristics
The physical characteristics of interest include dimensional criteria (e.g.,
shape, neck finish, wall thickness, design tolerances), physical parameters
critical to the consistent manufacture of a packaging component (e.g., unit
weight), and performance characteristics (e.g., metering valve delivery
volume, or the ease of movement of syringe plungers).  Unintended
variations in dimensional parameters, if undetected, may affect package
permeability, drug delivery performance, or the adequacy of the seal
between the container and the closure.  Variation in any physical parameter
is considered important if it can affect the quality of a dosage form.
 
b. Chemical Composition
The chemical composition of the materials of construction may affect the
safety of a packaging component.  New materials14 may result in new
substances being extracted into the dosage form or a change in the amount
of known extractables.  Chemical composition may also affect the
compatibility, functional characteristics or protective properties of
packaging components by changing rheological or other physical properties
(e.g., elasticity, resistance to solvents, or gas permeability).
A composition change may occur as a result of a change in formulation or
in a processing aid (e.g., using a different mold release agent) or through
the use of a new supplier of a raw material.  A change in the supplier of a
polymeric material or a substance of biological origin is more likely to bring
with it an unexpected composition change than a change in the supplier of
a pure chemical compound, because polymeric and natural materials are
often complex mixtures.  A composition change may also occur with a
change in the manufacturing process, such as the use of different operating
conditions (e.g., a significantly different curing temperature), different
equipment, or both.
14 These are substances not previously determined to be safe by extraction/toxicological evaluation studies (e.g., the USP
Biological Reactivity Tests or another appropriate method conducted on the packaging component as part of the
qualifying process).
14 A change in formulation is considered a change in the specifications for the
packaging component.  This change in the formulation of a packaging
component by its manufacturer should be reported to the firm that
purchases that component and to any appropriate DMF.  The firm that
purchases the component should, in turn, report the change to its
application as required under 21 CFR 314.70(a) or 601.12.  Manufacturers
who supply a raw material or an intermediate packaging component should
inform their customers of any intended changes to formulations or
manufacturing procedures and update the DMF in advance of implementing
such a change.  Changes which seem innocuous may have unintended
consequences on the dosage form marketed in the affected packaging
system.
The use of stability studies for monitoring the consistency of a container
closure system in terms of compatibility with the dosage form and the
degree of protection provided to the dosage form is accepted.  Currently
there is no general policy concerning the monitoring of a packaging system
and components with regard to safety.  One exception involves inhalation
drug products for which batch-to-batch monitoring of the extraction profile
for the polymeric and elastomeric components is routine.
3. Associated Components
Associated components are packaging components that are typically
intended to deliver the dosage form to the patient but are not stored in
contact with the dosage form for its entire shelf life.  These components are
packaged separately in the market package and are either attached to the
container upon opening or used only when a dose is to be administered. 
Measuring spoons, dosing cups, measuring syringes, and vaginal delivery
tubes are examples of associated components that typically contact the
dosage form only during administration.  A hand pump or dropper
combined into a closure are examples of an associated component that
would contact the dosage form from the time the packaging system is
opened until the dosing regimen is completed.
The complete and assembled component and its parts should meet
suitability criteria appropriate for the drug product and the actual use of the
component (see sections III.B.1 and III.B.2).  Safety and functionality are
the most common factors to be established for suitability.  The length of
time that the associated component and the dosage form are in direct
contact should also be taken into consideration when assessing the
suitability of an associated component.
4. Secondary Packaging Components
15 Unlike primary and associated packaging components, secondary
packaging components are not intended to make contact with the dosage
form.  Examples are cartons, which are generally constructed of paper or
plastic, and overwraps, which may be fabricated from a single layer of
plastic or from a laminate made of metal foil, plastic, and/or paper.
A secondary packaging component generally serves one or more of the
following additional functions:
a. Provides protection from excessive transmission of moisture or
solvents into or out of the packaging system
b. Provides protection from excessive transmission of reactive gases
(atmospheric oxygen, inert headspace filler gas, or other organic
vapors) into or out of the packaging system
c. Provides light protection for the packaging system
d. Provides protection for a packaging system that is flexible or needs
extra protection from rough handling
e. Provides an additional measure of microbiological protection (i.e.,
by maintaining sterility or by protecting the packaging system from
microbial intrusion)
When information on a container closure system is submitted in an application, the
emphasis would normally be on the primary packaging components.  For a
secondary packaging component, a brief description will usually suffice unless the
component is intended to provide some additional measure of protection to the
drug product.  In this case, more complete information should be provided, along
with data showing that the secondary packaging component actually provides the
additional protection (see sections III.B.1 and III.B.2).
Because secondary packaging components are not intended to make contact with
the dosage form, there is usually less concern regarding the materials from which
they are constructed.  However, if the packaging system is relatively permeable,
the possibility increases that the dosage form could be contaminated by the
migration of an ink or adhesive component, or from a volatile substance present in
the secondary packaging component.  (For example, a solution packaged in a
LDPE container was found to be contaminated by a volatile constituent of the
secondary packaging components that enclosed it.).  In such a case, the secondary
packaging component should be considered a potential source of contamination
and the safety of its materials of construction should be taken into consideration.
16 C. Information That Should Be Submitted in Support of an Original
Application for Any Drug Product15
Additional discussion and information regarding the CMC information to be
provided in an application (NDA, ANDA, or BLA) can be found in the guidances
and guidelines listed in Attachment E.
1. Description
A general description of the entire container closure system should be provided in
the CMC section of the application.  In addition, the following information should
be provided by the applicant for each individual component of the packaging
system:
a. Identification by product name, product code (if available), the
name and address of the manufacturer, and a physical description 
of the packaging component (e.g., type, size, shape, and color)
b. Identification of the materials of construction (i.e., plastics, paper,
metal, glass, elastomers, coatings, adhesives, and other such
materials) should be identified by a specific product designation
(code name and/or code number) and the source (name of the
manufacturer).16  Alternate materials of construction should also be
indicated.  Postconsumer recycled plastic should not be used in the
manufacture of a primary packaging component.  If used for a
secondary or associated component, then the safety and
compatibility of the material for its intended use should be
addressed appropriately.
c. Description of any operations or preparations that are performed on
a packaging component by the applicant (such as washing, coating,
sterilization, or depyrogenation)17
2. Information About Suitability
15 See Table 3 for additional information.  This section applies to primary packaging components and to those associated
and secondary packaging components that provide protection to the drug product or for which there may be a safety
concern (see section III.B).
16 Where possible, this information should be included in the application.  Alternatively, it may be provided in a drug
master file (see section V) and a letter of authorization (LOA) to the DMF submitted in the application.  The LOA
permits the Agency to review the information in support of a particular application.
17 For further information see the FDA guidance for industry Submission of Documentation for the Sterilization Process
Validation in Applications of Human and Veterinary Drug Products (November 1994).
17 a. To establish safety and to ensure consistency, the complete
chemical composition should be provided for every material used in
the manufacture of a packaging component.
b. Test results from appropriate qualification and characterization
tests should be provided.  Adequate information regarding the tests,
methods, acceptance criteria, reference standards, and validation
information should be provided.
To address protection, use of USP tests (see Attachment A) for
light transmission, moisture permeation, microbial limits, and
sterility are generally considered sufficient.  Testing for properties
other than those described in USP (e.g., gas transmission, solvent
leakage container integrity) may also be necessary.
To address safety and compatibility, the results of
extraction/toxicological evaluation studies should be provided for
drug products that are likely to interact with the packaging
components and introduce extracted substances into the patient
(see Table 1).  For drug products less likely to interact, other tests
(e.g., USP Biological Reactivity Test) or information (e.g.,
appropriate reference to the indirect food additive regulations at 21
CFR 174-186) could be used to address the issue of safety and
compatibility (see Table 2).  For example, an appropriate reference
to an indirect food additive regulation is generally sufficient for a
solid oral dosage form product.
To address performance, the results of USP and non-USP
functionality tests are considered sufficient if the test and
acceptance criteria are appropriate for the intended purpose.
Tests described in the USP are typically considered sufficient
standards for establishing specified properties and characteristics of
specified materials of construction or packaging components. 
For non-USP tests, an applicant should provide justification for the
use of the test, a complete and detailed description of how the test
was performed, and an explanation of what the test is intended to
establish.  If a related USP test is available, comparative data
should be provided using both methods.  Supporting data should
include a demonstration of the suitability of the test for its intended
use and its validation.
Testing on an assembled container closure system is usually
18 performed by the applicant (or a testing laboratory commissioned
by the applicant) and the test results provided in the application. 
Such tests may include vacuum leak testing, moisture permeation,
and weight loss or media fill.
Testing on an individual packaging component is typically
performed by the manufacturer of the component and reported via a
DMF (see section V).
3. Information About Quality Control
The fabricator/manufacturer of a packaging component and the drug product
manufacturer who uses this firm share the responsibility for ensuring the quality of
packaging components.  These firms should have a quality control program in
place so that consistent components are produced.  The drug product
manufacturer must have an inspection program for incoming packaging
components and materials (21 CFR 211.22, 211.84 and 211.122).  For most drug
products, a drug product manufacturer may accept a packaging component lot
based on receiving a Certificate of Analysis (COA) or Certificate of Certification
(COC) from the component supplier and the performance of an appropriate
identification test, provided the suppliers test data are periodically validated (21
CFR 211.84(d)(3)).  Acceptance of a packaging component lot based on a
supplier's COA or COC may not be appropriate in all cases (e.g., some packaging
components for certain inhalation drug products).
a. Applicants
The tests and methods used by the applicant for acceptance of each batch
of a packaging component that they receive should be described.  If a batch
is to be accepted based on a supplier's COA or COC, then the procedure
for supplier validation should be described.  The data from the suppliers
COA or COC should clearly indicate that the lot meets the applicants
acceptance criteria.  Acceptance criteria for extractables should also be
included, if appropriate.
Dimensional and performance criteria should be provided.  Dimensional
information is frequently provided via a detailed schematic drawing
complete with target dimensions and tolerances and may be provided via
the packaging component manufacturer's DMF.  A separate drawing may
not be necessary if the packaging component is part of a larger unit for
which a drawing is provided or if the component is uncomplicated in design
(e.g., a cap liner).
b. Manufacturers of Packaging Components Sold to Drug Product
19 Manufacturers
Each manufacturer of a packaging component sold to a drug product
manufacturer should provide a description of the quality control measures
used to maintain consistency in the physical and chemical characteristics of
the component.  These generally include release criteria (and test methods,
if appropriate) and a description of the manufacturing procedure.  If the
release of the packaging component is based on statistical process
control,18 a complete description of the process (including control criteria)
and its validation should be provided.
The description of the manufacturing process is generally brief and should
include any operations performed on the packaging component after
manufacture but prior to shipping (e.g., washing, coating, and/or
sterilization).  In some cases it may be desirable for the description to be
more detailed and to include in-process controls.
This information may be provided via a DMF (see section V).
c. Manufacturers of Materials of Construction or of Packaging
Components Used to Make Other Packaging Components
The quality control procedures of the manufacturer of a packaging
component may sometimes rely in whole or in part on the quality control
procedures of a manufacturer who makes an intermediate packaging
component that is used to create the component.  If so, each contributor to
the final packaging system should provide a description of the quality
control measures used to maintain consistency in the physical and chemical
characteristics of the separate components and of the assembled packaging
system that they provide.
The manufacturer of each material of construction should be prepared to
describe the quality control measures used to maintain consistency in the
chemical characteristics of their product.
This information may be provided via a DMF (see section V).
4. Stability Data (Packaging Concerns)
Stability testing of the drug product should be conducted using the container
18 Statistical process control is defined as "[t]he application of statistical techniques for measuring and analyzing the
variation in processes." Juran, J.M., ed., 1988, Quality Control Handbook, 4th ed., McGraw-Hill, p. 24.2.
20 closure systems proposed in the application.  The packaging system used in each
stability study should be clearly identified.
The container closure system should be monitored for signs of instability.  When
appropriate, an evaluation of the packaging system should be included in the
stability protocol.  Even when a formal test for quality of the packaging system is
not performed, the applicant should investigate any observed change in the
packaging system used in the stability studies.  The observations, results of the
investigation, and corrective actions should be included in the stability report.  If
the corrective action requires a change in an approved container closure system, a
supplemental application should be submitted.
For general guidance on conducting stability studies, refer to the FDA Guideline
for Submitting Documentation for the Stability of Human Drugs and Biologics
(February 1987).  The stability guideline is undergoing revision and will be
superseded by the FDAs draft guidance for industry Stability Testing of Drug
Substance and Drug Products (June 1998), once it is issued in final form.
21 Table 3
Information That Should Be Submitted in an Original Application for Any Drug Product
Description Overall general description of the container closure system, plus:
For Each Packaging Component:
C Name, product code, manufacturer, physical description
C Materials of construction (for each:  name, manufacturer, product code)
C Description of any additional treatments or preparations
Suitability Protection:  (By each component and/or the container closure system, as appropriate)
C Light exposure
C Reactive gases (e.g., oxygen)
C Moisture permeation
C Solvent loss or leakage
C Microbial contamination(sterility/container integrity, increased bioburden,
microbial limits)
C Filth
C Other
Safety:  (for each material of construction, as appropriate)
C Chemical composition of all plastics, elastomers, adhesives, etc.a
C Extractables, as appropriate for the materialb
Extraction/toxicological evaluation studies, as appropriate
Appropriate USP testing
Appropriate reference to the indirect food additive regulations (21 CFR
174-186)
C Other studies as appropriate
Compatibility:  (for each component and/or the packaging system, as appropriate)
C Component/dosage form interaction, USP methods are typically accepted
C May also be addressed in post-approval stability studies
Performance:  (for the assembled packaging system)
C Functionality and/or drug delivery, as appropriate
Quality Control For Each Packaging Component Received by the Applicant:
C Applicant's tests and acceptance criteriac
C Dimensional (drawing) and performance criteria
C Method to monitor consistency in composition, as appropriate
For Each Packaging Component Provided by the Supplier:
C Manufacturer's acceptance criteria for release, as appropriate
C Brief description of the manufacturing process
Stability C See section III.C.4
a Including any additives used in the manufacture of a packaging component
b See Attachment C for further discussion of extraction studies.  Testing of plastics should be performed on the
packaging component, not on the unformed resin.  For a blow/fill/seal product, extractables should be evaluated on
the formed drug product container itself.  This also applies to a container closure system which is manufactured as
part of the drug product manufacturing process.
c Note that an applicant's acceptance tests may include, among others, test parameters indicated under the description,
suitability, and quality control sections of this table.
22 D. Inhalation Drug Products
Inhalation drug products include inhalation aerosols (metered dose inhalers); inhalation
solutions, suspensions, and sprays (administered via nebulizers); inhalation powders (dry
powder inhalers); and nasal sprays.  The CMC and preclinical considerations for inhalation
drug products are unique in that these drug products are intended for respiratory-tract
compromised patients.  This is reflected in the level of concern given to the nature of the
packaging components that may come in contact with the dosage form or the patient (see
Table 1).
Guidance regarding the container closure system information to support the approval of
applications for inhalation drug products will be provided in two guidance documents
when finalized:  the guidance for industry Metered Dose Inhaler (MDI) and Dry Powder
Inhaler (DPI) Drug Products; Chemistry, Manufacturing and Controls Documentation (a
draft was issued in October 1998) and the guidance for industry Nasal Spray and
Inhalation Solution, Suspension, and Spray Drug Products; Chemistry, Manufacturing
and Controls Documentation, which is currently under development.
E. Drug Products for Injection and Ophthalmic Drug Products
These dosage forms share the common attributes that they are generally solutions,
emulsions, or suspensions, and are all required to be sterile.  Injectable dosage forms
represent one of the highest risk drug products (see Table 1).  Any contaminants present
(as a result of contact with a packaging component or due to the packaging systems
failure to provide adequate protection) can be rapidly and completely introduced into the
patient's general circulation.  Although the risk factors associated with ophthalmics are
generally considered to be lower than for injectables, any potential for causing harm to the
eyes demands caution.
1. Injectable Drug Products
Injectable drug products may be liquids in the form of solutions, emulsions, 
suspensions, or dry solids that are to be combined with an appropriate vehicle to
yield a solution or suspension.  Injections are classified as small-volume parenterals
(SVPs), if they have a solution volume of 100 mL or less, or as large-volume
parenterals (LVPs), if the solution volume exceeds 100 mL.19  For solids that must
be dissolved or dispersed in an appropriate diluent before being injected, the
diluent may be in the same container closure system (e.g., a two-part vial) or be
part of the same market package (e.g., a kit containing a vial of diluent).
19 The terms SVP and LVP as used in this guidance correspond to the definitions of small-volume injection and large-
volume injection, respectively, in USP 23, page 1650.
23 An SVP may be packaged in a disposable cartridge, a disposable syringe, a vial, an
ampule or a flexible bag.  An LVP may be packaged in a vial, a flexible bag, a glass
bottle or, in some cases, as a disposable syringe.
Cartridges, syringes, vials, and ampules are usually composed of Type I or II glass,
or polypropylene.  Flexible bags are typically constructed with multilayered plastic. 
Stoppers and septa in cartridges, syringes, and vials are typically composed of
elastomeric materials.  The input (medication) and output (administration) ports
for flexible bags may be plastic and/or elastomeric materials.  An overwrap may be
used with flexible bags to retard solvent loss and to protect the flexible packaging
system from rough handling. 
The potential effects of packaging component/dosage form interactions are
numerous.  Hemolytic effects may result from a decrease in tonicity and pyrogenic
effects may result from the presence of impurities.  The potency of the drug
product or concentration of the antimicrobial preservatives may decrease due to
adsorption or absorption.  A cosolvent system essential to the solubilization of a
poorly soluble drug can also serve as a potent extractant of plastic additives.  A
disposable syringe may be made of plastic, glass, rubber, and metal components,
and such multicomponent construction provides a potential for interaction that is
greater than when a container consists of a single material.
Injectable drug products require protection from microbial contamination (loss of
sterility or added bioburden) and may also need to be protected from light or
exposure to gases (e.g., oxygen).  Liquid-based injectables may need to be
protected from solvent loss, while sterile powders or powders for injection may
need to be protected from exposure to water vapor.  For elastomeric components,
data showing that a component meets the requirements of USP Elastomeric
Closures for Injections will typically be considered sufficient  evidence of safety. 
For plastic components, data from USP Biological Reactivity Tests will typically
be considered sufficient evidence of safety.  Whenever possible, the extraction
studies should be performed using the drug product.  If the extraction properties of
the drug product vehicle may reasonably be expected to differ from that of water
(e.g., due to high or low pH or due to a solubilizing accipient), then drug product
should be used as the extracting medium. If the drug substance significantly affects
extraction characteristics, it may be necessary to perform the extractions using the
drug product vehicle.  If the total of extracts significantly exceeds the amount
obtained from water extraction, then an extraction profile should be obtained.  It
may be advisable to obtain a quantitative extraction profile of an elastomeric or
plastic packaging component and to compare this periodically to the profile from a
new batch of the packaging component.  Extractables should be identified
whenever possible.  For a glass packaging component, data from USP Containers: 
Chemical Resistance  Glass Containers will typically be considered sufficient
evidence of safety and compatibility.  In some cases (e.g., for some chelating
24 agents), a glass packaging component may need to meet additional criteria to
ensure the absence of significant interactions between the packaging component
and the dosage form.
Performance of a syringe is usually addressed by establishing the force to initiate
and maintain plunger movement down the barrel, and the capability of the syringe
to deliver the labeled amount of the drug product.
2. Ophthalmic Drug Products
These drug products are usually solutions marketed in a LDPE bottle with a
dropper built into the neck (sometimes referred to as droptainer), or ointments
marketed in a metal tube with an ophthalmic tip (see section III.F.2 for a more
detailed discussion of tubes).  A few solution products use a glass container due to
stability concerns regarding plastic packaging components.  Ophthalmic ointments
that are reactive toward metal may be packaged in a tube lined with an epoxy or
vinyl plastic coating.  A large volume intraocular solution (for irrigation) may be
packaged in a glass or polyolefin (polyethylene and/or polypropylene) container.
The American Academy of Ophthalmology (AAO) recommended to the Agency
that a uniform color coding system be established for the caps and labels of all
topical ocular medications.  An applicant should either follow this system or
provide an adequate justification for any deviations from the system.  The AAO
color codes, as revised and approved by the AAO Board of Trustees in June 1996,
are shown in Table 5. 
Although ophthalmic drug products can be considered topical products (section
III.F.2), they have been grouped here with injectables because they are required to
be sterile (21 CFR 200.50(a)(2)) and the descriptive, suitability, and quality control
information is typically the same as that for an injectable drug product.  Since
ophthalmic drug products are applied to the eye, compatibility and safety should
also address the container closure system's potential to form substances which
irritate the eye or introduce particulate matter into the product (see USP <771>
Ophthalmic Ointments).
See Table 4 for additional information.
25 Table 4
Information That Typically Should Be Submitted for Injectable 
or Ophthalmic Drug Products
Description Overall general description of container closure system, plus:
For Each Packaging Component:
C Name, product code, manufacturer, physical description
C Materials of construction (for each:  name, manufacturer and product code)
C Description of any additional treatments (e.g., procedures for sterilizing and
depyrogenating packaging components)
Suitability Protection:  (By each component and/or the container closure system, as appropriate)
C Light exposure, when appropriate
C Reactive gases (e.g., oxygen)
C Moisture permeation (powders)
C Solvent loss (liquid-based dosage forms)
C Sterility (container integrity) or increased bioburden
C  Seal integrity or leak testing of tubes (ophthalmics)
Safety:  (for each material of construction, as appropriate)
C Chemical composition of all plastics, elastomers, adhesives, etc.a
C For elastomeric closures:  USP Elastomeric Closures for Injections testing 
C For glass components:  USP Containers:  Chemical Resistance  Glass
Containers
C For plastic components and coatings for metal tubes:  USP Biological Reactivity
Tests
C If the extraction properties of the drug product vehicle may reasonably be
expected to differ from that of water (e.g., due to high or low pH or due to a
solubilizing excipient), then drug product should be used as the extracting
medium.
C If the total weight of extracts significantly exceeds the amount obtained from
water extraction, then an extraction profile should be obtained.
C For plastic or elastomeric components undergoing heat sterilization, it is current
practice to request that the extraction profile be obtained at 121EC/1 hour using
an appropriate solvent.
Compatibility:  (for each component and/or the packaging system, as appropriate)
C For coatings on metal tubes:  Coating integrity testing
C For elastomeric components:  Evaluation of swelling effects
C For plastic components (including tube coatings):  USP Containers: 
Physicochemical Tests - Plastics testing
C For ophthalmics: Particulate matter and eye irritants
C Stability studies also support compatibility
Performance:   (For the assembled packaging system)
C Functionality and/or drug delivery
26 Quality Control For Each Packaging System Received by the Applicant:
C Applicants tests and acceptance criteriac
C Dimensional (drawing) and performance criteria
C Method to monitor consistency in composition of most plastic and elastomeric
components (e.g., periodic comparison to the original extraction profile is
recommended)
For Each Packaging Component Provided by the Supplier:
C Manufacturers acceptance criteria for release, as appropriate
C Description of the manufacturing process, as appropriate (e.g.,
procedure/validation for sterilization and depyrogenation)
Stability C See section III.C.4
a. Including any additives used in the manufacture of a packaging component
b. Testing for plastics should be performed on the packaging component, not on the unformed resin.
c. Note that applicant's acceptance tests may include, among others, test parameters indicated under the
description, suitability, and quality control sections of this table.
d Refer to the Guidance for Industry for the Submission of Documentation for Sterilization Process Validation
in Applications for Human and Veterinary Drug (November 1994).
Table 5
AAO Recommended Color Coding of Caps and Labels
 for Topical Ophthalmic Medications
Class Color Pantone Number
Anti-Infectives Tan 467
Anti-Inflammatories/Steroids Pink 197, 212
Mydriatics and Cycloplegics Red 485C
Nonsteroidal Anti-Inflammatories Gray 4C
Miotics Green 374, 362, 348
Beta-Blockers Yellow or Bluea 290, 281
Yellow C
Adrenergic Agonists (e.g., Propine) Purple 2583
Carbonic Anhydrase Inhibitors Orange 1585
Prostaglandin Analogues Turquoise 326C
a The AAO notes that as new classes of drugs are developed this coding system may be modified in the future by
reassigning the blue color to a new class of drugs while keeping yellow for beta-blockers.
F. Liquid-Based Oral and Topical Drug Products and Topical Delivery Systems
A wide variety of drug products fall into this category.  The presence of a liquid phase
implies a significant potential for the transfer of materials from a packaging component
into the dosage form.  The higher viscosity of semisolid dosage forms and transdermal
systems may cause the rate of migration of leachable substances into these dosage forms
27 to be slower than for aqueous solutions.  Due to extended contact, the amount of
leachables in these drug products may depend more on a leachable materials affinity for
the liquid/semisolid phase than on the rate of migration.
1. Liquid-Based Oral Drug Products
Typical liquid-based oral dosage forms are elixirs, emulsions, extracts, fluid
extracts, solutions, gels, syrups, spirits, tinctures, aromatic waters, and
suspensions.  These products are usually nonsterile but may be monitored for
changes in bioburden or for the presence of specific microbes.  
These dosage forms are generally marketed in multiple-unit bottles or in unit-dose
or single-use pouches or cups.  The dosage form may be used as is or admixed first
with a compatible diluent or dispersant.  A bottle is usually glass or plastic, often
with a screw cap with a liner, and possibly with a tamper-resistant seal or an
overcap that is welded to the bottle.  The same cap liners and inner seals are
sometimes used with solid oral dosage forms.  A pouch may be a single-layer
plastic or a laminated material.  Both bottles and pouches may use an overwrap,
which is usually a laminated material.  A single-dose cup may be metal or plastic
with a heat-sealed lid made of a laminated material.
A liquid-based oral drug product typically needs to be protected from solvent loss,
microbial contamination, and sometimes from exposure to light or reactive gases
(e.g., oxygen).
For glass components, data showing that a component meets the requirements of
USP Containers:  Glass Containers are accepted as sufficient evidence of safety
and compatibility.  For LDPE components, data from USP Containers tests are
typically considered sufficient evidence of compatibility.  The USP General
Chapters do not specifically address safety for polyethylene (HDPE or LDPE),
polypropylene (PP), or laminate components.  A patient's exposure to substances
extracted from a plastic packaging component (e.g., HDPE, LDPE, PP, laminated
components) into a liquid-based oral dosage form is expected to be comparable to
a patient's exposure to the same substances through the use of the same material
when used to package food.  Based on this assumption, an appropriate reference
to the indirect food additive regulations (21 CFR 174-186)20 is typically considered
sufficient to establish safety of the material of construction, provided any
limitations specified in the regulations are taken into consideration.  This
assumption is considered valid for liquid-based oral dosage forms which the patient
will take only for a relatively short time (acute dosing regimen).
20 See Attachment A for a listing of the FDA regulations for indirect food additives.
28 For liquid-based oral drug products which the patient will continue to take for an
extended period (i.e., months or years (chronic drug regimen)), a material of
construction that meets the requirements for indirect food additives will be
considered safe  on that basis alone  only if the patient's exposure to
extractables can be expected to be no greater than the exposure through foods, or
the length of exposure is supported by toxicological information.  For example, if
the dosage form is aqueous-based and contains little or no cosolvent (or other
substance, including the active drug substance, liable to cause greater extraction of
substances from plastic packaging components than would be extracted by water),
meeting the requirements of the indirect food additive regulations will usually
satisfy the issue of safety.
If the dosage form contains cosolvents (or if, for any reason, it may be expected to
extract greater amounts of substances from plastic packaging components than
water), then additional extractable information21 may be needed to address safety
issues.
Performance is typically not a factor for liquid-based oral drug products.
See Table 6 for additional information.
2. Topical Drug Products
Topical dosage forms include aerosols, creams, emulsions, gels, lotions, ointments,
pastes, powders, solutions, and suspensions.  These dosage forms are generally
intended for local (not systemic) effect and are generally applied to the skin or oral
mucosal surfaces.  Topical products also include some nasal and otic preparations
as well as some ophthalmic drug products.  Ophthalmic drug products are
discussed in section III.E.2.  Vaginal and rectal drug products may be considered
to be topical if they are intended to have a local effect.  Some topical drug
products are sterile or may be subject to microbial limits.  In these cases, additional
evaluation may be necessary when determining the appropriate packaging.
A liquid-based topical product typically has a fluid or semi-solid consistency and is
marketed in a single- or multiple-unit container (e.g., a rigid bottle or jar, a
collapsible tube, or a flexible pouch).  A powder product may be marketed in a
sifter-top container.  An antibacterial product may be marketed as part of a sterile
dressing.  There are also a number of products marketed as a pressurized aerosol
or a hand-pumped spray.
A rigid bottle or jar is usually made of glass or polypropylene with a screw cap. 
21 See Attachment C for a discussion of extraction studies.
29 The same cap liners and inner seals are sometimes used as with solid oral dosage
forms.
A collapsible tube is usually constructed from metal or is metal-lined, from LDPE
or from a laminated material.  Tubes are identified as either blind-end or open-end. 
In the former, there is no product contact with the cap on storage.  Usually, the
size of the tube is controlled by trimming it to an appropriate length for the target
fill volume.  Fill volume is commonly determined as an in-process measurement
using bulk density.  Usually there is no cap liner, although the tube may have a
liner.  Aluminum tubes usually include a liner.  A tube liner is frequently a lacquer
or shellac whose composition should be stated.  A tube is closed by folding or
crimping the open end.  The type of fold (roll or saddle) should be described, as
well as the type and composition of any sealant.  If the tube material is self-sealing
through the application of heat alone, this should be stated.  If the market package
includes a separate applicator device, this should be described.  Product contact is
possible if the applicator is part of the closure, and therefore an applicator's
compatibility with the drug product should be established, as appropriate.
Dressings consist of dosage form on a bandage material (e.g., Absorbent Gauze
USP or Gauze Bandage USP) within a flexible pouch.  The pouch should maintain
the sterility and physical stability of the dressing.
Unlike inhalation aerosols, topical aerosols are not intended to be inhaled.  The
droplet size of the spray does not need to be carefully controlled, nor is the dose
usually metered.  The spray may be used to apply dosage form to the skin (topical
aerosol) or mouth (lingual aerosol) and functionality of the sprayer should be
addressed.  A topical aerosol may be sterile or may conform to acceptance criteria
for microbial limits.
The packaging system for a liquid-based topical product should deter solvent loss
and should provide protection from light when appropriate.  Because these dosage
forms may be placed in contact with mucosal membranes or with skin that has
been broken or otherwise compromised, the safety of the materials of construction
for the packaging components should be evaluated.  For liquid and semisolid
dosage forms, the same information as described in section III.F.1 is accepted for
establishing safety and compatibility.  For solid dosage forms, an appropriate
reference to the indirect food additive regulations is typically considered sufficient
to establish safety.
See Table 6 for additional information.
3. Topical Delivery Systems
Topical delivery systems are self-contained, discrete dosage forms that are
30 designed to deliver drug via intact skin or body surface.  USP Pharmaceutical
Dosage Forms defines three types of topical delivery systems:  transdermal, ocular,
and intrauterine.
Transdermal systems are usually applied to the skin with an adhesive and may be in
place for an extended period.  Ocular systems are inserted under the lower eyelid,
typically for seven days.  Intrauterine systems are held in place without adhesive
and may stay in place for a year.
A transdermal system is usually comprised of an outer barrier, a drug reservoir
(with or without a rate-controlling membrane), a contact adhesive, and a
protective liner.  An ocular system usually consists of the drug formulation
contained in a rate-controlling membrane.  An intrauterine system may be
constructed of a plastic material impregnated with active ingredients or a coated
metal.  It is shaped to remain in place after being inserted in the uterus.
Each of these systems is generally marketed in a single-unit soft blister pack or a
preformed tray with a preformed cover or overwrap.
Compatibility and safety for topical delivery systems are addressed in the same
manner as for topical drug products.  Performance and quality control should be
addressed for the rate-controlling membrane.  Appropriate microbial limits should
be established and justified for each delivery system.  Microbiological standards are
under development; therefore the review division for a specific application should
be consulted.
See Table 6 for additional information.
31 Table 6
Information That Typically Should Be Submitted for Liquid-Based Oral 
and Topical Drug Products and for Topical Drug Delivery Systems
Description Overall general description of container closure system, plus:
For Each Packaging Component:
C Name, product code, manufacturer, physical description
C Materials of construction (for each:  name, manufacturer and product code)
C Description of any additional treatments (e.g., procedure for washing
components)
Suitability Protection:  (by each component and/or the container closure system, as appropriate)
C Light exposure
C Reactive gases (e.g., oxygen)
C Solvent loss
C Moisture permeation (liquid-based oral products would typically meet USP
requirements for a tight or class A container)
C Microbial contamination (container integrity, increased bioburden, microbial
limits, as appropriate)
C Seal integrity or leak testing of tubes (topical drug products) and unit dose
containers (liquid-based oral drug products)
Safety:  (for each material of composition, as appropriate)
C Chemical composition of all plastics, elastomers, adhesives, etc.a
C For most liquid-based oral drug products:  appropriate reference to the indirect
food additive regulations
C For liquid-based oral drug products with chronic dosing regimens that contain
alcohol or a cosolvent:  information to establish that exposure to extractables
will be no greater than that expected to result from the use of similar packaging
components when used with foods,b or that the exposure is acceptable based on
toxicological data.
C For topical drug products (plastic coatings for metal tubes), and plastic drug
delivery system components:  USP Containers testing
C For topical delivery systems:  appropriate reference to indirect food additive
regulations
Compatibility:  (for each component of the packaging system, as appropriate)
C For LDPE and glass components, USP Containers testingc
C For coatings for metal tubes:  coating integrity testing
Performance:  (for the assembled packaging system)
C Functionality and/or drug delivery should be addressed, as appropriate.
Quality Control For Each Packaging Component Received by the Applicant:
C Applicant's tests and acceptance criteriad
C Dimensional (drawing) and performance criteria
C Method to monitor consistency in composition, as appropriate
For Each Packaging Component Provided by the Supplier:
C Manufacturer's acceptance criteria for release, as appropriate
C Description of the manufacturing process, as appropriate
32 Stability C See section III.C.4
a Including any additives used in the manufacture of a packaging component
b The materials of construction should be acceptable for contact with foods that have extraction characteristics similar
to those of the drug product (e.g., aqueous, acidic, alcoholic, or fatty).
c Plastics testing should be performed on the packaging component, not on the unformed resin.
d Note that applicant's acceptance tests may include, among others, test parameters indicated under the description,
suitability, and quality control sections of this table.
G. Solid Oral Dosage Forms and Powders for Reconstitution
The most common solid oral dosage forms are capsules and tablets.  For the purpose of
this guidance, oral powders and granules for reconstitution are also included in this group. 
 
The risk of interaction between packaging components and a solid oral dosage form is
generally recognized to be small.  Powders that are reconstituted in their market container,
however, have an additional possibility of an interaction between the packaging
components and the reconstituting fluid.  Although the contact time will be relatively short
when compared to the component/dosage form contact time for liquid-based oral dosage
forms, it should still be taken into consideration when the compatibility and safety of the
container closure system is being evaluated.
A typical container closure system is a plastic (usually HDPE) bottle with a screw-on or
snap-off closure and a flexible packaging system, such as a pouch or a blister package.  A
typical closure consists of a cap, often with a liner, and frequently with an inner seal.  If
used, fillers, desiccants, and other absorbent materials are considered primary packaging
components.
The most common forms of flexible packaging are the blister package and the pouch.  A
blister package usually consists of a lidding material and a forming film.  The lidding
material is usually a laminate which includes a barrier layer (e.g., aluminum foil) with a
print primer on one side and a sealing agent (e.g., a heat-sealing lacquer) on the other side. 
The sealing agent contacts the dosage form and the forming film.  The forming film may
be a single film, a coated film, or a laminate.  A pouch typically consists of film or laminate
which is sealed at the edges by heat or adhesive.  Leak testing is usually performed on
flexible packages as part of the in-process controls.
Solid oral dosage forms generally need to be protected from the potential adverse affects
of water vapor.  Protection from light and reactive gases may also be needed. For example
the presence of moisture may affect the decomposition rate of the active drug substance or
the dissolution rate of the dosage form.  The container should have an intrinsically low
rate of water vapor permeation, and the container closure system should establish a seal to
protect the drug product.  Three standard tests for water vapor permeation have been
established by the USP for use with solid oral dosage forms.
33 1. Polyethylene Containers (USP <661>):  This test is conducted on
containers heat-sealed with foil laminate; therefore only the properties of
the container are evaluated.  The level of protection from water vapor
permeation provided by a packaging system marketed with a heat-sealed
foil laminate inner seal (up to the time the inner seal is removed) is
expected to be approximately the same as that determined by this test.  The
acceptance criteria are those established in USP <671>.
2. Single-Unit Containers and Unit-Dose Containers for Capsules and Tablets
(USP <671>):  This test measures the water vapor permeation of a single-
unit or unit-dose container closure system and establishes acceptance
criteria for five standards (Class A-E containers).
3. Multiple-Unit Containers for Capsules and Tablets (USP <671>):  This test
is intended for drugs being dispensed on prescription, but has also been
applied to the drug product manufacturers container closure system.  If
the container closure system has an inner seal, it should be removed prior
to testing.  The results from this study reflect the contributions to water
vapor permeation through the container, and through the seal between the
container and the closure.  Acceptance criteria have been established for
two standards (tight and well-closed containers).
For solid oral dosage forms, a reference to the appropriate indirect food additive
regulation for each material of construction is typically considered sufficient evidence of
safety.  However, for a powder for reconstitution dosage form, reference only to the
indirect food additive regulations as evidence of safety for the materials of construction is
not recommended.  Compatibility for solid oral dosage forms and for powders for
reconstitution is typically addressed for plastics and glass by meeting the requirements of
the USP Containers test.
The USP monographs for Purified Cotton and Purified Rayon will typically be considered
sufficient standards to establish the safety of these materials as fillers in the packaging of
tablets or capsules, with the following caveats:  cotton need not meet the monograph
requirements for sterility, fiber length, or absorbency; and rayon need not meet the
monograph requirements for fiber length or absorbency.  Appropriate tests and acceptance
criteria for identification and for moisture content should be provided for both cotton and
rayon filler.  Rayon has been found to be a potential source of dissolution problems for
gelatin capsules and gelatin-coated tablets and this characteristic should be considered
when choosing a filler.22  The use of other fillers may be considered with appropriate tests
and acceptance criteria.
22 Hartauer, K.J. et al., "The Effects of Rayon Coiler on the Dissolution Stability of Hard Shelled Gelatin Capsules,"
Pharmaceutical Technology, 17:76-83 (1993). 
34 If a desiccant or other absorbent material is used, the composition should be provided (or
an appropriate DMF referenced).  The component should differ in shape and/or size from
the tablets or capsules with which it is packaged.  This will help distinguish between the
component and the dosage form.  Because these are considered primary packaging
components, appropriate tests and acceptance criteria to establish suitability should be
provided (see Table 7 for additional information).
35 Table 7
Information That Typically Should Be Submitted for Solid Oral 
Drug Products and Powders
Description Overall general description of container closure system, plus:
For Each Packaging Component:
C Name, product code, manufacturer
C Materials of construction
C Description of any additional treatments
Suitability Protection:  (by each component and/or the container closure system, as appropriate)
C Light exposure
C Moisture permeation
C Seal integrity or leak tests for unit-dose packaging
Safety:  (for each material of construction, as appropriate)
C Chemical composition of all plastics, elastomers, adhesives, etc.a
C For tablets, capsules, and powders, appropriate reference to the indirect food
additive regulation may be submitted, but may not be appropriate for Powders
for Reconstitution.
C For rayon and cotton fillers, data from USP monographs.  For non-USP
materials, data and acceptance criteria should be provided.
C For dessicants and other absorbent materials:  the size and shape should differ
from that of the dosage form.
Compatibility:  (on each component or the packaging system)
C For glass and plastic containers, data from USP Containersb testing.
Performance:  (on each component or the packaging system, as appropriate)
C Functionality and/or drug delivery, as appropriate 
Quality Control For Each Packaging Component Received by the Applicant:
C Applicant's tests and acceptance criteriac
C Dimensional (drawing) and performance criteria
C Method to monitor consistency in composition, as appropriate
For Each Packaging Component Provided by the Supplier:
C Manufacturer's acceptance criteria for release, as appropriate
C Description of manufacturing process, as appropriate
Stability C See section III.C.4
a Including any additives used in the manufacture of a packaging component
b Testing of plastics should be performed on the packaging component, not on the unformed resin.
c Note that applicant's acceptance tests may include, among others, test parameters indicated under the description,
suitability, and quality control sections of this table.
36 H. Other Dosage Forms
The CGMP requirements for container closure systems for compressed medical gases are
described in 21 CFR 210 and 211.  The containers are regulated by the U.S. Department
of Transportation.  For more detailed information refer to the CDER Compressed Medical
Gas Guideline (February 1989).
When submitting information for a drug product or dosage form not specifically covered
by the sections above, a firm should take into consideration: (1) the compatibility and
safety concerns raised by the route of administration of the drug product and the nature of
the dosage form (e.g., solid or liquid-based); (2) the kinds of protection the container
closure system should provide to the dosage form; and (3) the potential effect of any
treatment or handling that may be unique to the drug product in the packaging system. 
Quality control procedures for each packaging component should ensure the maintenance
of the safety and quality of future production batches of the drug product.
IV. POSTAPPROVAL PACKAGING CHANGES
For an approved application (NDA, ANDA or BLA), a change to a container closure system, to a
component of the container closure system, to a material of construction for a component, or to a
process involving one of the above must be reported to the application.  The filing requirements
are specified under 21 CFR 314.70 (supplements and other changes to an approved application)
for an NDA or ANDA, and under 21 CFR 601.12 (changes to an approved application) for a
BLA.  The submission should address the items described and discussed in sections III.B and
III.C of this guidance.  The Agency intends to provide additional guidance on postapproval
changes in container closure systems in the future.
V. TYPE III DRUG MASTER FILES
A. General Comments
The responsibility for providing information about packaging components rests foremost
with the applicant of an NDA, ANDA or BLA, or the sponsor of an IND.  This
information may be provided to the applicant by the manufacturer of a packaging
component or material of construction and may be included directly in the application. 
Any information that a manufacturer does not wish to share with the applicant or sponsor
(i.e., because it is considered proprietary) may be placed in a Type III DMF and
incorporated into the application by a letter from the manufacturer to the applicant which
authorizes reference to the DMF.  The letter of authorization should specify the firm to
whom authorization is granted, the component or material of construction being
described, and where the information and/or data is located in the file by page number
and/or date of submission.  This last item is especially important for files that contain
information on multiple components or have several volumes.
37 Information in a Type III DMF is not restricted to data of a proprietary nature.  DMF
holders may include in their files as much or as little information as they choose.  In
addition, a manufacturer of a packaging component is not required to maintain a Type III
DMF.  Without a DMF there is no procedure for the Agency to review proprietary
information except by submission to the application.
The Agency ordinarily reviews a DMF only in connection with an application (IND, NDA,
ANDA, or BLA).  If the combined information from the application and the DMF is not
adequate to support approval of the application or safety for the IND, then the Agency
may request additional information from the applicant and/or the DMF holder, as
appropriate.
In the event of a change in the DMF, the holder of a DMF must notify the holder of each
application supported by the DMF (21 CFR 314.420(c)).  Notice should be provided well
before the change is implemented to allow the applicant or sponsor enough time to file a
supplement or an amendment to the affected application.
General information on format and content of a DMF and a LOA may be found in the
CDER Guideline for Drug Master Files (September 1989).
B. Information in a Type III DMF
Section III of this guidance describes the kind of descriptive, suitability, and quality
control information which the Agency usually reviews concerning packaging components
and materials of construction for drug products.  The following are examples of the items
that have been submitted via a Type III DMF.
1. Descriptive Information:
a. General description of the component and the address of the
manufacturing site
b. Description of the manufacturing process for a packaging
component and operations performed after manufacture, but prior
to shipment (washing, coating, sterilization or depyrogenation)
c. Description of the acceptance, in-process, and release controls for
materials of construction, the manufacturing process, and the
finished product (component part or assembled component)
d. Characterization of the key properties
2. Information About Suitability
38 a. Protection provided by the component
b. Safety information on the materials of construction or the finished
component
c. Compatibility of the materials of construction or the finished
component with the specific dosage form, the specific drug
product, or equivalent materials
3. Information About Quality Control:
a. Dimensional (an engineering drawing) and performance criteria for
the component
b. A description of the quality control measures used to maintain
consistency in the physical and chemical characteristics of
packaging components
c. A summary of the quality assurance/quality control criteria when
release of the component is based on statistical process control
VI. BULK CONTAINERS
A. Containers for Bulk Drug Substances
Drug substances are generally solids, but some are liquids or gases.
The container closure system for storage or shipment of a bulk solid drug substance is
typically a drum with double LDPE liners that are usually heat sealed or closed with a
twist tie.  A desiccant may be placed between the bags.
The drum provides protection from light and mechanical strength to protect the liner
during shipment and handling.  The majority of the protection from air and moisture is
provided by the liner.  Because LDPE is not a particularly good moisture barrier, a drug
substance that is moisture sensitive may need additional protection.  An alternative to a
LDPE bag is a heat-sealable laminate bag with a comparatively low rate of water vapor
transmission.
Qualification of the packaging system is usually based on establishing compatibility and
safety of the liner but may also include characterization for solvent or gas transmission
(see section III.B).
The container closure system for the storage or shipment of a bulk liquid drug substance is
typically plastic, stainless steel, a glass-lined metal container, or an epoxy-lined metal
39 container with a rugged, tamper-resistant closure.  Qualification of the container closure
system may include characterization for solvent and gas permeation, light transmittance,
closure integrity, ruggedness in shipment, protection against microbial contamination
through the closure, and compatibility and safety of the packaging components as
appropriate (see section III.B).
The application (or Type II DMF) should include a detailed description of the complete
container closure system for the bulk drug substance as well as a description of the
specific container, closure, all liners, inner seal, and desiccant (if any), and the composition
of each component.  A reference to the appropriate indirect food additive regulation is
typically considered sufficient to establish the safety of the materials of construction (also
note the discussion on this subject in section III).  The tests, methods, and criteria for the
acceptance and release of each packaging component should be provided.
Stability studies to establish a retest period for bulk drug substance in the proposed
container closure system should be conducted with fillers or desiccant packs in place (if
used).  Smaller versions which simulate the actual container closure system may be used. 
Stability recommendations for container closure systems of different types are described in
the Guideline for Submitting Documentation for the Stability of Human Drugs and
Biologics (February 1987).23
Container closure systems for compressed medical gases are discussed in section III.H.
B. Containers for Bulk Drug Products
A container closure system for bulk drug products may be used for storage prior to
packaging or for shipment to repackagers or contract packagers.  In all cases, the
container closure system should adequately protect the dosage form and should be
constructed of materials that are compatible and safe.
Container closure systems for on-site storage have generally been considered a CGMP
issue under 21 CFR 211.65.  However, if a firm plans to hold bulk drug products in
storage, then the container closure system and the maximum storage time should be
described and justified in the application.  In addition, stability data should be provided to
demonstrate that extended storage in the described containers does not adversely affect
the dosage form.  Even when the storage time before packaging will be short, a firm
should use a container closure system that provides adequate protection and that is
manufactured from materials that are compatible and safe for the intended use (see section
III.B).
23 The 1987 stability guidance will be superseded by the FDA guidance for industry Stability Testing of Drug
Substances and Drug Products, issued in draft for comment in June 1998, once it is issued in final form. 
40 A container closure system for the transportation of bulk drug products to contract
packagers (section II.C.3) should be described in the application.  The container closure
system should be adequate to protect the dosage form, be constructed with materials that
are compatible with product being stored, and be safe for the intended use.  The protective
properties of the shipping container are verified by the practice of including annual batches
of the packaged product in postapproval stability studies.
A container closure system specifically intended for the transportation of a large volume of
drug product to a repackager (section II.C.3), whether for a solid or liquid dosage form, is
considered a market package.  The package should meet the same requirements for
protection, compatibility, and safety as a smaller market package;24 should be included in
the stability studies for application approval and in the long term stability protocol; and
should be fully described in the application.  The length of time that the dosage form will
spend in the bulk container may be a factor in determining the level of detail of the
supporting information.  Two examples of a large-volume shipping package are a 10,000-
tablet HDPE pail with tamper-evident closure, and a 10-liter polyethylene terephthalate
(PET) container with a screw cap closure with dispenser attachment for a liquid drug
product.  Both are intended for sale to a mass distribution pharmacy.  A special case is the
pharmacy bulk package which is described in USP <1>.
24 FDA Compliance Policy Guides, "Regulatory Action Regarding Approved New Drugs and Antibiotic Drug Products
Subjected to Additional Processing or other Manipulation," Section 446.100, January 18, 1991 (CPG 7132c.06).
41 ATTACHMENT A25
REGULATORY REQUIREMENTS
1. The Federal Food, Drug, and Cosmetic Act
a. Section 501
A drug or device shall be deemed to be adulterated if its container is composed, in
whole or in part, of any poisonous or deleterious substance which may render the
contents injurious to health (section 501(a)(3)); or if it is a drug and the methods
used in, or the facilities or controls used for, its manufacture, processing, packing,
or holding do not conform to or are not operated or administered in conformity
with current good manufacturing practice to assure that such drug meets the
requirements of this Act as to safety and has the identity and strength, and meets
the quality and purity characteristics, which it purports or is represented to possess
(section 501(a)(2)(B)).  
b. Section 502
A drug or device shall be deemed to be misbranded:
C  [i]f it purports to be a drug the name of which is recognized in an official
compendium, unless it is packaged and labeled as prescribed therein (section
502(g))
C  [i]f it is a drug and its container is so made, formed, or filled as to be
misleading (section 502(i)(1))
C  [i]f it is a drug and its packaging or labeling is in violation of an applicable
regulation issued pursuant to section 3 or 4 of the Poison Prevention Packaging
Act of 1970" (section 502(p))
c. Section 505
No person shall introduce or deliver for introduction into interstate commerce any
new drug, unless an approval of an application filed pursuant to subsection (b) or
(j) is effective with respect to such drug (section 505(a)).
Section 505(b)(1)(D) requires "a full description of the methods used in, and the
25 Applicants should check the appropriate sources directly for the most up-to-date information.
 A-1 facilities and controls used for, the manufacture, processing, and packing of such
drug."
2. The Code of Federal Regulations 
a. 21 CFR 211 - Current Good Manufacturing Practice for Finished Pharmaceuticals
i. Subpart E, Control of Components and Drug Product Containers and
Closures (21 CFR 211.80 - 211.94)
In particular, 21 CFR 211.94 outlines the requirements for drug product
containers and closures:
(a) Drug product containers and closures shall not be reactive, additive,
or absorptive so as to alter the safety, identity, strength, quality, or
purity of the drug beyond the official or established requirements.
(b) Container closure systems shall provide adequate protection against
foreseeable external factors in storage and use that can cause
deterioration or contamination of the drug product.
(c) Drug product containers and closures shall be clean and, where
indicated by the nature of the drug, sterilized and processed to
remove pyrogenic properties to ensure that they are suitable for
their intended use.
(d) Standards or acceptance criteria, test methods, and, where
indicated, methods of cleaning, sterilizing, and processing to
remove pyrogenic properties shall be written and followed for drug
product containers and closures.
ii. Subpart F, Production and Process Controls (21 CFR 211.100 - 211.115)
iii. Subpart G, Packaging and Labeling Control (21 CFR 211.122 - 211.137)
In particular, 21 CFR 211.132 describes the tamper-resistant packaging
requirements for over-the-counter (OTC) human drug products.  Most
OTC drug products must be packaged in tamper-resistant containers.
b. 16 CFR 1700-1702 - Special Packaging
The U.S. Consumer Product Safety Commission (CPSC) is responsible for
enforcing the Poison Prevention Packaging Act of 1970 (PPPA).  The PPPA
requires special packaging of hazardous household substances to protect children
 A-2 from serious personal injury or serious illness from handling, using, or ingesting the
substances.  Drug products containing controlled substances, most human oral
prescription drug products (including oral investigational drugs used in outpatient
trials), and OTC drug preparations containing aspirin, acetaminophen,
diphenhydramine, liquid methyl salicylate, ibuprofen, loperamide, lidocaine,
dibucaine, naproxen, iron, or ketoprofen, require special packaging (16 CFR
1700.14).
Special packaging is defined under 15 U.S.C. 1471(2)(4), 16 CFR 1700.1(b)(4),
and 21 CFR 310.3(l).  Regulations issued under the PPPA establish performance
standards and test methods that determine if a packaging system is child-resistant
and adult-use-effective (16 CFR 1700.15 and 16 CFR 1700.20, respectively). 
Except as noted below, all PPPA-regulated substances must be in packaging
systems that comply with these special packaging standards.  The standards apply
to both reclosable and nonreclosable packaging systems (unit-dose packaging).
There are several situations where child-resistant packaging for drug products is
not required.  Manufacturers and packagers of bulk-packaged prescription drug
products do not have to use special packaging if the drug is intended to be
repackaged by the pharmacist.  However, the manufacturer or packager is
responsible for child-resistant packaging if the drug product is intended to be
dispensed to the consumer as packaged without repackaging by the pharmacist (16
CFR 1701.1).  Prescribed drugs that are dispensed for use within institutions such
as hospitals and nursing homes do not require child-resistant packaging.  However,
any prescriptions dispensed to patients upon their release for their use at home
would be subject to the PPPA packaging requirements.  In addition, drug product
manufacturers are not required to provide child-resistant packaging for
prescription drug samples that are distributed to physicians and other prescribing
practitioners (i.e., physician samples).26
For OTC preparations, manufacturers or packagers are allowed to market one size
in non-child-resistant packaging as long as child-resistant packages are also
supplied.  The non-child-resistant package requires special labeling (16 CFR
1700.5).
16 CFR 1702 establishes the procedures for petitioning the CPSC for an
exemption from the PPPA requirements.  Several prescription drugs (e.g., oral
contraceptives in mnemonic packages, powdered colestipol, and
medroxyprogesterone acetate) have been exempted from the special packaging
requirements (16 CFR 1700.14(10)(I)-(xix)).  The CPSC is permitted to grant an
26 Federal Register, Volume 49, March 5, 1984, page 8008 (49 FR 8008), Prescribed Drugs Distributed to Prescribing
Practitioners; Withdrawal of Proposed Statement of Policy and Interpretation.
 A-3 exemption if it finds that packaging is not required to protect children from serious
injury, or that special packaging is not technically feasible, practicable, or
appropriate for that product.
For additional information regarding these packaging requirements and the
protocol test methods, please contact the CPSC.  Their website is located at
www.cpsc.gov and their hotline is 1-800-638-2772.
c. 21 CFR 174-186 - Indirect Food Additive Regulations
Regulations that are applicable to packaging components are:
i. Part 174 - Indirect Food Additives:  General
ii. Part 175 - Indirect Food Additives:  Adhesives and Components of
Coatings
e.g., 175.105 Adhesives
175.300 Resinous and polymeric coatings
iii. Part 176 - Indirect Food Additives:  Paper and Paperboard Components
e.g., 176.170 Components of paper and paperboard in contact
with aqueous and fatty foods
176.180 Components of paper and paperboard in contact
with dry food
iv. Part 177 - Indirect Food Additives:  Polymers
e.g., 177.1380 Fluorocarbon resins
177.1520 Olefin polymers
177.1630 Polyethylene phthalate polymers
v. Part 178 - Indirect Food Additives:  Adjuvants, Production Aids, and
Sanitizers
vi. Part 180 - Food Additives Permitted in Food or in Contact with Food on
an Interim Basis Pending Additional Studies
e.g.,  180.22 Acrylonitrile copolymers
vii. Part 182 - Substances Generally Recognized as Safe
e.g.,  182.70 Substances migrating from cotton and cotton fabrics
 A-4 used in dry food packaging
182.90 Substances migrating to food from paper and
paperboard products
viii. Part 186 - Indirect Food Substances Affirmed as Generally Recognized as
Safe (GRAS)
e.g., 186.1673 Pulp
d. Biologics Provisions, 21 CFR 600, Subpart B, Establishment Standards
i. 21 CFR 600.11(h) - Containers and Closures
ii. 21 CFR 601.2 - Applications for Licenses; Procedures for Filing
e. Other Sections
i. 21 CFR 201 - Labeling
ii. 21 CFR 310.509 - Parenteral drug products in plastic containers
iii. 21 CFR 200.50(a)(3) - Containers of ophthalmic preparations
3. U.S. Pharmacopeia/National Formulary
The following sections are applicable to packaging components:
a. General Notices - PRESERVATION, PACKAGING, STORAGE, AND
LABELING
b. General Tests and Assays
<1> Injections
<51> Antimicrobial Preservatives - Effectiveness
<61> Microbial Limit Tests
<71> Sterility Tests
<87> Biological Reactivity Tests, in vitro
<88> Biological Reactivity Tests, in vivo
<161> Transfusion and Infusion Assemblies
<381> Elastomeric Closures for Injections
C Biological Test Procedures
C Physicochemical Test Procedures
<601> Aerosols
<661> Containers
 A-5 C Light Transmission
C Chemical Resistance - Glass Containers
C Biological Tests - Plastics and Other Polymers 
C Physicochemical Tests - Plastics
C Containers for Ophthalmics - Plastics
C Polyethylene Containers
C Polyethylene Terephthalate Bottles and Polyethylene
Terephthalate G Bottles
C Single-Unit Containers and Unit-Dose Containers for Nonsterile
Solid and Liquid Dosage Forms
C Customized Patient Medication Packages
<671> Containers - Permeation
C Multiple-Unit Containers for Capsules and Tablets
C Single-Unit Containers and Unit-Dose Containers for Capsules
and Tablets
<691> Cotton (or the monograph for Purified Rayon USP)
<771> Ophthalmic Ointments
<1041> Biologics
<1151> Pharmaceutical Dosage Forms
 A-6 ATTACHMENT B
COMPLIANCE POLICY GUIDES THAT CONCERN PACKAGING
(August 1996)
Compliance Policy Guides are issued by the Division of Compliance Policy (in the Office of
Enforcement/Office of Regulatory Affairs).  The following is a list of Compliance Policy Guides
that concern packaging.  Any questions or concerns about the content of any Compliance Policy
Guide should be addressed to the Office of Enforcement/Office of Regulatory Affairs/Division of
Compliance Policy at 301-827-0420 (telephone), 301-827-0482 (FAX) or
www.fda.gov/ora/compliance_ref/cpg/default.html (Internet).
Sub Chapter 410 BULK DRUGS
Sec. 410.100 Finished Dosage Form Drug Products in Bulk Containers -
Applications of Current Good Manufacturing Practice Regulations
(CPG 7132a.06)
Sub Chapter 430  LABELING and REPACKAGING
Sec. 430.100 Unit Dose Labeling for Solid and Liquid Oral Dosage Forms (CPG
7132b.10)
Sec. 430.200 Repacking of Drug Products - Testing/Examination Under CGMPs
(CPG 7132.13)
Sub Chapter 440-448 NEW DRUGS
Sec. 446.100 Regulatory Action Regarding Approved New Drugs and Antibiotic
Drug Products Subjected to Additional Processing or Other
Manipulations (CPG 7132c.06)
Sub Chapter 450-457 OTC
Sec. 450.500 Tamper-Resistant Packaging Requirements for Certain Over-the-
Counter (OTC) Human Drug Products (CPG 7132a.17)
Sec. 450.550 Control and Accountability of Labeling Associated with Tamper-
Resistant Packaging of Over-the-Counter Drug Products (CPG
7132.14 )
Sub Chapter 480 STABILITY/EXPIRATION
 B-1 Sec. 480.100 Requirements for Expiration Dating and Stability Testing (CPG
7132a.04)
Sec. 480.200 Expiration Dating of Unit Dose Repackaged Drugs (CPG
7132b.11)
Sec. 480.300 Lack of Expiration Date of Stability Data (CPG 7132a.10)
 B-2 ATTACHMENT C 
EXTRACTION STUDIES
An extraction study of a packaging component typically involves exposing a sample of the
component, often subdivided into small pieces to increase surface area, to an appropriate solvent
system at elevated temperatures, followed by chemical analysis.  The purpose of elevated
temperature is to increase the rate of extraction, so that a short experimental time may simulate a
longer exposure time at room temperature, or to maximize the amount of extractables obtained
from a sample.
The methods employed to analyze the resulting extracts vary, depending on the purpose of the
extraction study and the nature of the packaging component.  The extraction solvent may be
evaporated to concentrate the extracts or to determine the total weight of nonvolatile
extractables.  Appropriate methods, such as HPLC or gas chromatography, may be used to obtain
qualitative or quantitative extraction profiles of volatile or nonvolatile extractables. 
Extraction studies may be conducted during the qualification of packaging components for any of
the following purposes:
C To perform USP characterization tests on plastics (USP <661>) or elastomers
(USP <381>)
C To perform USP Biological Reactivity Tests (USP <87> and <88>) on plastics or
elastomers
C To obtain qualitative extraction profiles of plastics or elastomers
C To obtain quantitative extraction profiles of plastics or elastomers
C To evaluate whether the FDA indirect food additive regulations provide an
adequate indicator of safety
Extraction studies may also be conducted on a routine basis as a quality control measure to
monitor the chemical compositions of elastomeric or other packaging components.
The solvent that should be used in an extraction study depends on the purpose of the study.  The
ideal situation is for the extracting solvent to have the same propensity to extract substances as
the dosage form, thus obtaining the same quantitative extraction profile.  For this study, the
preferred solvent would be the drug product or placebo vehicle.  When feasible, the dosage form
itself would be used.  A stronger extracting solvent than the drug product would be used to obtain
a qualitative extraction profile that would be used to establish quality control criteria.
 C-1 ATTACHMENT D
ABBREVIATIONS
AAO American Academy of Ophthalmology
ANDA Abbreviated New Drug Application
BLA Biologics License Application
CBER Center for Biologics Evaluation and Research
CDER Center for Drug Evaluation and Research
CFR Code of Federal Regulations
CFSAN Center for Food Safety and Applied Nutrition
CGMP Current Good Manufacturing Practice
CMC Chemistry, Manufacturing, and Control
COA Certificate of Analysis
CPSC Consumer Product Safety Commission
DMF Drug Master File
DPI Dry Powder Inhaler
FDA U.S. Food and Drug Administration (the Agency)
HDPE High Density Polyethylene
IND Investigational New Drug Application
LDPE Low Density Polyethylene
LOA Letter of Authorization
LVP Large-Volume Parenteral
MDI Metered Dose Inhaler
NDA New Drug Application
PET Polyethylene Terephthalate
PETG Polyethylene Terephthalate G
PP Polypropylene
PVC Polyvinyl Chloride
QA Quality Assurance
QC Quality Control
SVP Small-Volume Parenteral
USP/NF U.S. Pharmacopeia/National Formulary
 D-1 ATTACHMENT E
REFERENCES27
Center for Drug Evaluation and Research (CDER) Compressed Medical Gases Guideline
(February 1989)
FDA Guideline for Drug Master Files (September 1989)
FDA Guidance for Industry on the Submission of Documentation for the Sterilization Process
Validation in Applications for Human and Veterinary Drug Products (November 1994)
FDA Guidance for Industry on the Content and Format on Investigational New Drug
Applications (INDs) for Phase 1 Studies of Drugs, Including Well Characterized, Therapeutic,
Biotechnology-Derived Products (November 1995)
FDA Guidance for Industry on the Submission of Chemistry, Manufacturing, and Controls
Information for a Therapeutic Recombinant DNA-Derived Product or a Monoclonal Antibody
Product for In Vivo Use (August 1996)
FDA Guidance for Industry on the Submission of Chemistry, Manufacturing, and Controls
Information and Establishment Description for Autologous Somatic Cell Therapy Products
(January 1997)
FDA Guidance for the Photostability Testing of New Drug Substance and Products (May 1997)
FDA Guidance for Industry on the Submission of Chemistry, Manufacturing, and Controls
Information for Synthetic Peptide Substances (January 1998)
FDA Guidance for Industry on the Content and Format of Chemistry, Manufacturing, and
Controls and Establishment Description Information for a Vaccine or Related Product (January
1999)
FDA Guidance for Industry for the Submission of Chemistry, Manufacturing, and Controls and
Establishment Description Information for Human Plasma-Derived Biological Product or
Animal Plasma or Serum-Derived Products (February 1999)
FDA Guidance for Industry on the Content and Format of Chemistry, Manufacturing, and
27 A list of CDER and CBER guidances and guidelines is provided on the Internet at
www.fda.gov/cder/guidances.index.htm and www.fda.gov/cber/guidelines.htm, respectively.
 E-1 Controls and Establishment Description Information for a Biological In Vitro Diagnostic
Product (March 1999)
FDA Guidance for Industry on the Content and Format of Chemistry, Manufacturing, and
Controls and Establishment Description Information for Allergenic Extract or Allergen Patch
Test (April 1999)
FDA Guidance for Industry for the Submission of Chemistry, Manufacturing, and Controls and
Establishment Description Information for Human Blood and Blood Components Intended for
Transfusion or for Further Manufacture and for the Completion of the FDA Form 356h,
Application to Market a New Drug, Biologic, or an Antibiotic Drug for Human Use (May 1999)
 E-2