J:\!GUIDANC\FINAL\1289DFT.WPD

4/17/98

Guidance for Industry

Manufacturing, Processing, or

Holding Active Pharmaceutical

Ingredients

DRAFT GUIDANCE

This guidance document is being distributed for comment purposes only.

Comments and suggestions regarding this draft document should be submitted within 60 days of

publication of the Federal Register notice announcing the availability of the draft guidance. 

Submit comments to Dockets Management Branch (HFA-305), Food and Drug Administration,

12420 Parklawn Dr., rm. 1-23, Rockville, MD 20857. All comments should be identified with

the docket number listed in the notice of availability that publishes in the Federal Register. 

Copies of this draft guidance are available on the Internet at

http://www.fda.gov/cder/guidance/index.htm or http://www.fda.gov/cber/cberftp.html. For

questions on the content of the draft document contact (CDER) Edwin Rivera, 301-594-0095; or

(CBER) John A. Eltermann, 301-827-3031; or (CVM) Jose R. Laureano, 301-594-1785.

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)

Center for Veterinary Medicine (CVM)

March 1998
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TABLE OF CONTENTS

I. INTRODUCTION ........................................................................ 1

II. ORGANIZATION AND PERSONNEL ....................................................... 2

A. Responsibilities of the Quality Control Unit ......................................... 2

B. Personnel Qualifications ........................................................ 3

C. Personnel Responsibilities ....................................................... 3

D. Consultants ................................................................... 4

III. BUILDINGS AND FACILITIES ............................................................. 4

A. Design and Construction Features ................................................. 4

B. Lighting ..................................................................... 5

C. Ventilation, Air Filtration, Air Heating and Cooling ................................... 5

D. Steam, Gases, and Other Utilities ................................................. 5

E. Plumbing, Washing, and Toilet Facilities .......................................... 5

F. Sewage and Refuse ............................................................. 6

G. Sanitation .................................................................... 6

H. Maintenance .................................................................. 6

IV. PROCESS EQUIPMENT ................................................................. 7

A. Equipment Design, Size, and Location ............................................. 7

B. Equipment Construction and Installation ............................................ 7

C. Equipment Cleaning and Maintenance Procedures .................................... 7

D. Equipment Cleaning Methods ................................................... 8

E. Validation of Equipment Cleaning Methods ......................................... 9

F. Clean in Place Methods ........................................................ 10

G. Automatic, Mechanical, Electronic, and Computer Equipment ......................... 10

V. CONTROL OF RAW MATERIALS ......................................................... 11

A. General Controls ............................................................. 11

B. Receipt, Sampling, Testing, and Approval of Raw Materials ........................... 12

C. Use and Reevaluation of Approved Raw Materials ................................. 12

D. Rejected Raw Materials ........................................................ 13

E. Control of Recovered Solvents, Mother Liquors, and Second Crops ..................... 13

F. Process Water Quality ......................................................... 13

VI. PRODUCTION AND PROCESS CONTROLS ................................................ 14

A. Written Procedures and Deviations ............................................... 14

B. Raw Material Weighing and Measuring ........................................... 14

C. Calculation of Yield ........................................................... 15

D. Equipment Identification ....................................................... 15

E. In-Process Controls, Sampling/Testing of APIs and Intermediates ...................... 15

F. Time Limits on Production of APIs and Intermediates ................................ 16

G. Control of API Contamination ................................................... 16

H. Blending of APIs and Intermediates ............................................. 17

VII. PACKAGING AND LABELING CONTROLS ................................................ 18

A. Materials Examination and Usage Criteria ......................................... 18

B. API Label Issuance ............................................................ 19

C. Packaging and Labeling Operations .............................................. 19

D. API Packaging Materials ...................................................... 19
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E. Expiration or Retest Dating ..................................................... 20

VIII. HOLDING AND DISTRIBUTION OF APIs AND INTERMEDIATES ............................ 20

A. Warehousing Procedures ....................................................... 20

B. Distribution Procedures ........................................................ 20

IX. LABORATORY CONTROLS ............................................................. 21

A. General Controls ............................................................. 21

B. Testing and Release for Distribution .............................................. 22

C. Stability Testing .............................................................. 23

D. Reserve Samples ............................................................. 24

E. Laboratory Animals ........................................................... 24

X. RECORDS AND REPORTS ........................................................... 24

A. General Controls ............................................................. 24

B. Equipment Cleaning and Use Record ............................................. 25

C. Raw Material, API Packaging Materials, and Labeling Records ....................... 26

D. Master Production and Control Records ........................................... 26

E. Batch Production and Control Records ............................................ 27

F. Production Record Review ..................................................... 28

G. Laboratory Records ........................................................... 29

H. Distribution Records .......................................................... 30

I. Complaint Files .............................................................. 30

J. Returned APIs and Intermediates ................................................ 31

K. API and Intermediate Salvaging ................................................. 31

XI. VALIDATION .......................................................................... 31

A. Process Validation Strategy .................................................... 31

B. The Validation Protocol ........................................................ 33

C. Prospective Validation ......................................................... 34

D. Concurrent Validation ......................................................... 34

E. Retrospective Validation ....................................................... 36

XII. CHANGE CONTROL/REVALIDATION ................................................... 37

A. Change-Control System ........................................................ 37

B. Change-Control Classification ................................................... 38

XIII. REPROCESSING/REWORKING OF APIs AND INTERMEDIATES ............................. 38

A. Reprocessing by Repeating a Chemical Reaction .................................... 38

B. Reprocessing by Physical Manipulations .......................................... 39

C. Reworking of APIs and Intermediates ............................................ 39

XIV. CONTROL OF CHEMICAL, BIOLOGICAL, AND PHYSICAL CONTAMINANTS ................. 40

XV. APIs FOR CLINICAL TRIALS ............................................................. 40

A. Quality Assurance Measures .................................................... 40

B. Quality Control Unit ........................................................... 41

C. Equipment and Facilities ....................................................... 41

D. Control of Raw Materials ....................................................... 41

E. Production and Process Controls ................................................. 41

F. Process Validation ............................................................ 42

G. Change Documentation ........................................................ 42

H. Laboratory Controls ........................................................... 42
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I. Documentation ............................................................... 42

BIBLIOGRAPHY ............................................................................... 44

GLOSSARY ................................................................................... 47
Draft - Not for Implementation

 This guidance has been prepared by the Division of Manufacturing and Product Quality in the Center for 1

Drug Evaluation and Research (CDER), in a joint effort with CDER’s Office of Pharmaceutical Science, the Center for

Biologics Evaluation and Research (CBER) and the Center for Veterinary Medicine (CVM), in cooperation with the

Office of Regional Operations (ORA). This guidance document represents the Agency’s current thinking on the

manufacture and control of active pharmaceutical ingredients. 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. For additional copies of this guidance, contact (1) the

Drug Information Branch, Division of Communications Management, HFD-210, CDER, FDA, 5600 Fishers Lane,

Rockville, MD 20857 (Phone: 301-827-4573), or (2) Office of Communication, Training, and Manufacturers

Assistance (HFM-40), Center for Biologics Evaluation and Research (CBER), 1401 Rockville Pike, Rockville, MD

20852-1448; (Fax) 888-CBERFAX or 301-827-3844 (Voice Information) 800-835-4709 or 301-827-1800.

GUIDANCE FOR INDUSTRY1

Manufacturing, Processing, or Holding 

Active Pharmaceutical Ingredients

I. INTRODUCTION

This document is intended to provide guidance on FDA's expectations regarding current good

manufacturing practices (CGMP) for manufacturing, processing, packing, or holding (i.e.,

storage) of active pharmaceutical ingredients (APIs). Although this document focuses on the

manufacture of APIs, much of the guidance provided may be useful for the manufacture of

excipients. This guidance does not in any way affect the ability of the Agency to establish specific

requirements or standards regarding APIs within the context of new drug application reviews. 

Likewise, it is not intended to address specific issues relating to the filing of such applications. 

This guidance applies to the manufacture and control of drug and biologic APIs for use in human

and veterinary drug products. In addition, the guidance applies to the later chemical isolation and

purification steps of APIs derived from biological or fermentation processes. It also applies to

sterile APIs, but only up to the point where the API is rendered sterile. The sterilization and

aseptic processing of sterile APIs should be performed in accordance with CGMP regulations for

finished pharmaceuticals (Title 21 Code of Federal Regulations Parts 210 & 211). This guidance

also identifies CGMPs for the manufacture of APIs used in the production of drug products for

clinical trials. However, it does not apply to medical gases, bulk-packaged drug products (final

dosage forms), and manufacturing/control aspects specific to radiopharmaceuticals.

FDA expects appropriate CGMPs to be applied to all steps of an API manufacturing process,

beginning with the use of starting materials. Such practices include the validation of processes

determined to impact the quality and purity of the API. The Agency recognizes that the

stringency of CGMPs in API production, such as the extent of written instructions, in-process

controls, sampling, testing, monitoring and documentation, should increase as the process
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proceeds from early steps to final synthesis and purification stages. In this guidance, the Agency

attempts to clarify its expectations regarding the stringency of CGMPs at different processing

steps. 

APIs not manufactured in accordance with CGMPs are adulterated under Section 501(a)(2)(B) of

the Federal Food, Drug and Cosmetic Act (the Act). This section of the Act deems a drug to be

adulterated if 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, CGMPs to ensure that such drug meets the requirements of the 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. 

II. ORGANIZATION AND PERSONNEL

A. Responsibilities of the Quality Control Unit

There should be a quality control unit that: 

C Has the responsibility and authority to approve or reject all raw materials, packaging

materials, labels, and APIs;

C Has the authority to review and approve production records to ensure that no

errors or deviations have occurred and, if errors or deviations have occurred,

that they have been fully investigated and resolved;

C Is responsible for approving or rejecting intermediates and APIs manufactured,

processed, packed, or held under contract by another company, or establishing

appropriate systems to ensure that this is done by the contractor's quality

control unit; 

C Is one of the organizational units responsible for the review and approval of

validation protocols, changes in product, process, equipment, or other changes

to determine if and when revalidation is warranted;

C Has adequate laboratory facilities for the testing and approval (or rejection) of

raw materials, packaging materials, and APIs; 

C Is responsible for approving or rejecting all procedures, specifications, and

investigations affecting the quality and purity of APIs and intermediates; and
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C Is responsible for performing periodic assessments of procedures, policies,

manufacturing, and control operations. 

The quality control unit may delegate to the manufacturing department the responsibility and

authority to perform in-process testing and release of intermediates. For example, where

intermediates are not isolated and stored before use, production employees could check or test the

intermediate and then immediately approve it for use in further processing. 

The responsibilities and procedures applicable to the quality control unit should be in writing and

followed.

B. Personnel Qualifications

Personnel engaged in the manufacture, processing, packing, holding, or testing of an API and/or

intermediate should have the education, training, and experience, or any combination thereof, to

enable them to perform their assigned functions. Training should extend to CGMPs as well as the

particular operations employees perform. Training in CGMPs should be conducted regularly by

qualified individuals and with sufficient frequency to ensure that employees remain familiar with

CGMP requirements applicable to them. 

An adequate number of qualified personnel should be available to perform and supervise the

manufacture, processing, packing, holding, or testing of each API and/or intermediate. 

C. Personnel Responsibilities

Personnel engaged in the manufacture, processing, packing, or holding of an API or intermediate

should wear clean clothing appropriate for the duties they perform. Protective apparel, such as

head, face, hand, and arm coverings, should be worn as necessary to protect APIs and

intermediates from contamination.

Personnel should practice good sanitation and health habits, including abstention from eating,

drinking, or smoking in areas designated for production, storage, and quality control testing. 

Only persons authorized by supervisory personnel should enter those areas of buildings and

facilities designated as limited-access areas.

Any person shown anytime (either by medical examination or supervisory observation) to have an

apparent illness or open lesion that may adversely affect the safety and quality of APIs should be

excluded from direct contact with raw materials, intermediates, packaging materials, or APIs until

the condition is corrected or determined not to jeopardize the safety or quality of APIs. All

personnel should be instructed to report any health conditions that may adversely affect APIs to

supervisory personnel. 
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D. Consultants

Consultants advising on the manufacture, processing, packing, or holding of APIs and

intermediates should have sufficient education, training, and experience, or any combination

thereof, to advise on the subject for which they are retained. Records should be maintained

stating the name, address, and qualifications of any consultants and the types of service they

provide.

 

III. BUILDINGS AND FACILITIES

A. Design and Construction Features

Buildings and facilities used in the manufacture, processing, packing, or holding of APIs or

intermediates should be of suitable design, size, construction and location to facilitate cleaning,

maintenance, and proper operations. Adequate space should be provided for the orderly

placement of equipment and materials to prevent mixups and contamination among different raw

materials, intermediates, or APIs. The flow of raw materials, intermediates, and APIs through the

building or buildings should be designed to prevent mixups and contamination. 

To prevent mixups and contamination, there should be defined areas and/or other control systems

for the following activities: 

C Receipt, identification, storage, and withholding from use of raw materials or

intermediates, pending release for use in manufacturing; 

C Holding rejected raw materials, intermediates, and APIs before final

disposition; 

C Storage of released raw materials, intermediates, and APIs;

C Manufacturing and processing operations;

C Packaging and labeling operations; 

C Quarantine storage of intermediates and APIs pending release for distribution;

and 

C Laboratory operations.

Where microbiological specifications have been established for the API (e.g., nonsterile APIs

intended for incorporation into parenteral drug products), facilities should also be designed to
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limit objectionable microbiological contamination.

Operations relating to the crystallization, drying, and packaging of sensitizing APIs, such as

penicillins and cephalosporins, should be performed in dedicated facilities. Dedicated facilities

should also be considered for other APIs having high pharmacological activity or toxicity, such as

some steroids or cytotoxic anticancer agents. 

API manufacturing processes that require viral inactivation or reduction should be appropriately

segregated (e.g., pre- and postviral inactivation or reduction activities). 

B. Lighting

Adequate lighting should be provided in all areas to facilitate cleaning, maintenance, and proper

operations. 

C. Ventilation, Air Filtration, Air Heating and Cooling

Adequate ventilation should be provided where necessary. Equipment for the adequate control

and monitoring of air pressure, microorganisms, dust, humidity, and temperature should be

provided when appropriate (e.g., when APIs are exposed to the environment or handled in the

final dry state). 

Air filtration, dust collection, and exhaust systems should be used in production areas when

appropriate. If air is recirculated to production areas, appropriate measures should be taken to

control contamination and cross-contamination. Air from previral inactivation/reduction areas

should not be recirculated to other areas used for the manufacture of APIs. 

D. Steam, Gases, and Other Utilities 

Steam that comes into contact with APIs and intermediates should be tested and monitored to

ensure that it is of suitable quality and devoid of contaminants, such as boiler additives, that could

adversely affect API quality.

All other utilities (e.g., gases, compressed air) that come into contact with APIs and intermediates

should comply with appropriate specifications and not alter API quality beyond its established

specifications. 

E. Plumbing, Washing, and Toilet Facilities 

Potable water should be supplied under continuous positive pressure in a plumbing system free

from defects that could lead to the contamination of APIs or intermediates. Potable water should

meet the standards prescribed in the Environmental Protection Agency's Primary Drinking Water
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Regulations (Title 40, Code of Federal Regulations, Part 141). Potable water in facilities outside

the United States should meet comparable standards of the European Union, Japan, the World

Health Organization, or other authorities. Drains should be of adequate size and provided with an

air break or suitable mechanical device to prevent back-siphonage. 

Adequate and clean washing and toilet facilities that are easily accessible to working areas should

be provided. These should include hot and cold water, soap or detergent, air dryers or singleservice towels. Shower facilities should be provided if needed for personnel hygiene and/or

reducing the potential of API contamination or cross-contamination. 

F. Sewage and Refuse

Sewage, trash, and other waste (e.g., solids, liquids, or gaseous by-products from manufacturing)

in and from the building and immediate premises should be disposed of in a safe, timely, and

sanitary manner. 

G. Sanitation

Any building used in the manufacture, processing, packing, or holding of APIs and intermediates

should be maintained in a clean and sanitary condition.

Written procedures should be established assigning responsibility for sanitation and describing the

cleaning schedules, methods, equipment, and materials to be used in cleaning buildings and

facilities. Such written procedures should be followed. Sanitation procedures should apply to

work performed by contractors or temporary employees as well as work performed by full-time

employees during the ordinary course of operations. 

Written procedures should also be established for use of suitable rodenticides, insecticides,

fungicides, fumigating agents, and cleaning and sanitizing agents to prevent the contamination of

equipment, raw materials, packaging materials, labeling materials, intermediates, and APIs. 

Rodenticides, insecticides, and fungicides should be registered and applied according to the

Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136), or other locally applicable

regulations. 

H. Maintenance

Any building used in the manufacture, processing, packing, or holding of APIs and intermediates

should be properly maintained and repaired. 
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IV. PROCESS EQUIPMENT 

A. Equipment Design, Size, and Location

Equipment used in the manufacture, processing, packing, or holding of APIs and intermediates

should be of appropriate design, adequate size, and suitably located to facilitate operations for its

intended use and for its cleaning and maintenance. 

Closed equipment should be used when feasible (i.e., when equipment is located outdoors or in

uncontrolled manufacturing environments) to provide adequate protection of APIs and

intermediates. When equipment is opened or open equipment is used, appropriate precautions

should be taken to prevent contamination or cross-contamination of APIs and intermediates. 

B. Equipment Construction and Installation

Equipment should be constructed so that surfaces that contact raw materials, intermediates, or

APIs are not reactive, additive, or absorptive so as to alter the quality and purity of the API

and/or intermediate beyond the official or other established specifications. Any substances

required for operation, such as lubricants, heating fluids, or coolants, should not contact raw

materials, packaging materials, intermediates, or APIs so as to alter the quality and purity of APIs

and intermediates beyond the official or other established specifications. 

Where feasible, equipment should be designed, constructed, and installed to allow for ease of

cleaning, and, as applicable, sanitization. Qualification of equipment should ensure that:

C It is installed according to approved design specifications, regulatory codes,

and the equipment manufacturers’ recommendations; and

C The equipment operates within limits and tolerances established for the

process. 

C. Equipment Cleaning and Maintenance Procedures 

Written procedures should be established and followed for cleaning and maintaining equipment,

including utensils and storage vessels, used in the manufacture, processing, packing, or holding of

APIs and intermediates. Procedures should, at a minimum, include:

C Assigning responsibility for cleaning and maintaining equipment;

C Establishing maintenance and cleaning schedules, including, where appropriate,

sanitizing schedules;
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C Developing a complete description of the methods and materials used to clean

and maintain equipment and, when necessary, instructions for disassembling

and reassembling each article of equipment to ensure proper cleaning and

maintenance; 

C Removing or obliterating previous batch identification;

C Protecting clean equipment from contamination prior to use;

C Inspecting equipment for cleanliness immediately before use, if practical; and 

C Establishing the maximum time that may elapse between the completion of

processing and equipment cleaning. 

D. Equipment Cleaning Methods 

Equipment and utensils should be cleaned, held and, where necessary, sanitized at appropriate

intervals to prevent contamination or cross-contamination that would alter the quality or purity of

the API or intermediate beyond the official or other established specifications. 

Dedicated equipment should be cleaned at appropriate intervals to prevent the build-up of

objectionable material or microbial growth. As processing approaches the purified API, it is

important to ensure that incidental carryover of contaminants or degradants between batches does

not adversely impact the established impurity profile. However, this does not generally apply to

biologic APIs, where many of the processing steps are accomplished aseptically and where it is

often necessary to clean and sterilize equipment between batches. 

Nondedicated equipment should be thoroughly cleaned between different products and, if

necessary, after each use to prevent contamination and cross-contamination. If cleaning a specific

type of equipment is difficult, the equipment may need to be dedicated to a particular API or

intermediate.

 

The choice of cleaning methods, cleaning agents, and levels of cleaning should be established and

justified. When selecting cleaning agents (e.g., solvents) the following should be considered: 

C The cleaning agent’s ability to remove residues of raw materials, precursors,

by-products, intermediates, or APIs; 

C Whether the cleaning agent leaves a residue itself; and 

C Compatibility with equipment construction materials.
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E. Validation of Equipment Cleaning Methods

Equipment cleaning methods should be validated, where appropriate. In general, cleaning

validation efforts should be directed to situations or process steps where contamination or

incidental carryover of degradants pose the greatest risk to API quality and safety. In early

synthesis steps, it may be unnecessary to validate cleaning methods where residues are removed

by subsequent purification steps. 

Validation of cleaning methods should reflect actual equipment use patterns. If various APIs or

intermediates are manufactured in the same equipment and the equipment is cleaned by the same

process, a worst-case API or intermediate can be selected for purposes of cleaning validation. 

The worst-case selection should be based on a combination of potency, toxicity, solubility,

stability, and difficulty of cleaning. 

The cleaning validation protocol should describe the equipment to be cleaned, methods, materials,

and extent of cleaning, parameters to be monitored and controlled, and analytical methods. The

protocol should also indicate the type of samples (rinse, swabs) to be obtained, and how they are

collected, labeled, and transported to the analyzing laboratory. 

Sampling should include swabbing, rinsing, or alternative methods (e.g., direct extraction), as

appropriate, to detect both insoluble and soluble residues. The sampling methods used should be

capable of quantitatively measuring levels of residues remaining on the equipment surfaces after

cleaning. Swab sampling may be impractical when product contact surfaces are not easily

accessible due to equipment design and/or process limitations (e.g., inner surfaces of hoses,

transfer pipes, reactor tanks with small ports or handling toxic materials, and small intricate

equipment such as micronizers and microfluidizers). 

Validated analytical methods sensitive enough to detect residuals or contaminants should be in

place. The detection limit for each analytical method should be sufficiently sensitive to detect the

established acceptable level of the residue or contaminant. The method’s attainable recovery level

should be established. 

Residue limits should be practical, achievable, verifiable, and based on the most deleterious

residue. Limits may be established based on the minimum known pharmacological or

physiological activity of the API or its most deleterious component. 

Equipment cleaning and sanitization studies should address microbiological and endotoxin

contamination for those processes intended or purported to reduce bioburden or endotoxins in the

API, or other processes where such contamination may be of concern (e.g., nonsterile APIs used

to manufacture parenteral products). 
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Cleaning procedures should be checked by appropriate methods after validation to ensure these

procedures remain effective when used during routine production. Where feasible, equipment

should be examined visually for cleanliness. This may allow detection of gross contamination

concentrated in small areas that could go undetected by analytical verification methods. 

F. Clean in Place Methods

Where feasible, clean in place (CIP) methods should be used to clean process equipment and

storage vessels. CIP methods might include fill and soak/agitate systems, solvent refluxing, highimpact spray cleaning, spray cleaning by sheeting action, or turbulent flow systems. 

CIP systems should be subjected to cleaning validation studies to ensure that they provide

consistent and reproducible results. When practical, equipment in CIP systems should be

disassembled during cleaning validation to facilitate inspection and sampling of inner product

surfaces for residues or contamination, even though the equipment is not normally disassembled

during routine use. 

Once CIP systems are validated, appropriate documentation should be maintained to show that

critical parameters (e.g., time, temperature, turbulence, cleaning agent concentration, rinse cycles)

are achieved with each cleaning cycle. 

G. Automatic, Mechanical, Electronic, and Computer Equipment 

Automatic, mechanical, or electronic processing equipment, or other types of equipment,

including computers, used in the manufacture of APIs and intermediates should be routinely

calibrated, inspected, and checked to ensure proper performance. Written records of those

calibration checks and inspections should be maintained.

Written procedures should be established for:

C System operations;

C System qualification and validation;

C Corrective actions to be taken in cases of malfunctions;

C Detecting and recording errors and implementing corrections;

C Restarting the system and recovering data;

C Authorizing, implementing, and recording changes; and 
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C Use of electronic signatures.

Systems should be appropriately qualified and validated to demonstrate the suitability of the

hardware and software to perform assigned tasks in a consistent and reproducible manner. The

depth and scope of validation should depend on the diversity, complexity, and criticality of the

system. 

All changes to a system should be approved by the quality control unit in advance and performed

by authorized and competent personnel. Records should be kept of all changes including

modifications and enhancements to the hardware, software, and any other critical components of

the system to demonstrate that the modified system is maintained in a validated state. 

Procedures should be established to prevent unauthorized entries or changes to existing data. 

Systems should identify and document the persons entering or verifying critical data. Input to and

output from the computer or related system should be checked for accuracy at appropriate

intervals. Where critical data are entered manually, there should be an additional check on the

accuracy of the entry. This may be performed by a second operator or by the system itself.

Appropriate controls should be exercised over computers and related systems to ensure that

changes in master production and control records or other records are made only by authorized

personnel.

A back-up system should be available to respond to system breakdowns or failures that result in

permanent loss of critical records. Back-ups may consist of hard copies or other forms (e.g.,

tapes or microfilm) that ensure back-up data are exact, complete, and secure from alteration,

inadvertent erasure, or loss.

V. CONTROL OF RAW MATERIALS

A. General Controls

Written procedures should be established describing the purchase, receipt, identification,

quarantine, storage, handling, sampling, testing, and approval or rejection of raw materials. Such

procedures should be followed.

Raw materials should be handled and stored in a manner to prevent contamination and crosscontamination. Bagged and boxed raw materials should be stored off the floor and suitably

spaced to permit cleaning and inspection. Raw materials that are stored outdoors should be in

suitable containers. Identifying labels should remain legible and containers should be

appropriately cleaned before opening to prevent contamination. 
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For solvents or reagents delivered in bulk vessels (e.g., tanker trucks), a procedural or physical

system, such as valve locking or unique couplings, should be used to prevent accidental discharge

of the solvent into the wrong storage tank. 

Each container or grouping of containers of raw materials should be assigned and identified with a

distinctive code, lot, or receipt number. This code should be used in recording the disposition of

each lot. A system should be in place to identify each lot’s status. Large containers (e.g., tanks,

silos) that are used for storing raw materials, including their attendant manifolds, filling and

discharge lines, should be appropriately identified. 

B. Receipt, Sampling, Testing, and Approval of Raw Materials

Upon receipt and before acceptance, each container or grouping of containers of raw materials

should be examined visually for appropriate labeling, container damage, seal integrity (where

appropriate), and contamination. Raw materials should be held under quarantine until they have

been sampled, tested or examined, as appropriate, and released for use. 

Representative samples of each shipment of each lot should be collected for testing or

examination in accordance with an established procedure. The number of containers to sample

and the sample size should be based upon appropriate criteria (e.g., raw material variability,

confidence levels, degree of precision desired, past quality history of the supplier, and the quantity

needed for analysis). Raw material containers selected for sampling should be opened, sampled,

and resealed in a manner that prevents contamination of their contents and of other raw materials. 

Sample containers should be properly identified. 

At least one test should be conducted to verify the identity of each raw material. A supplier's

certificate of analysis might be used in lieu of performing other testing provided that the

manufacturer has a system in place to evaluate vendors and establishes the reliability of the

supplier’s test results at appropriate intervals. For hazardous or highly toxic raw materials, where

on-site testing may be impractical, suppliers’ certificates of analysis should be obtained showing

that the raw materials conform to specifications. In addition, the identity of these raw materials

should be confirmed by examination of containers and labels. The lack of on-site testing for

hazardous raw materials should be documented. 

C. Use and Reevaluation of Approved Raw Materials 

Approved raw materials should be stored under suitable conditions, and where appropriate,

rotated so that the oldest stock is used first. Raw materials should be reevaluated, as necessary,

to determine their suitability for use (e.g., after prolonged storage or after exposure to heat or

high humidity). 
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D. Rejected Raw Materials

Rejected raw materials should be identified and controlled under a quarantine system designed to

prevent their use in manufacturing or processing operations for which they are unsuitable. 

E. Control of Recovered Solvents, Mother Liquors, and Second Crops

Written procedures should be established for the recovery of solvents, mother liquors, second

crops or other materials. These should include adequate tests and controls to ensure that

recovered materials are suitable for use in manufacturing processes and do not adversely affect the

quality of APIs and intermediates. 

Solvents may be recovered and reused in the same process or in different processes, provided that

the recovery procedures are validated to ensure that recovered solvents meet appropriate

standards before reuse or commingling with other approved materials. The quality of solvent

mixtures should be monitored at suitable intervals. 

Mother liquors may be reused provided that the quality of the API or intermediate is not adversely

affected by their reuse. Procedures for secondary recovery of reactants, intermediates, or the API

should ensure that these recovered materials meet specifications suitable for their intended use.

The use of recovered solvents, mother liquors, and other recovered materials should be

adequately documented in batch production records. 

F. Process Water Quality 

Water used in the production of APIs should be routinely tested and, at a minimum, meet the

standards for potable water, as stated in the United States Environmental Protection Agency's

(EPA) National Primary Drinking Water Regulations (NPRDWR) or comparable standards of

other authorities such as the European Union, Japan, or the World Health Organization. The

potable water supply, regardless of source, should be assessed for chemicals that may affect the

API process. Information should be periodically sought from local authorities concerning

potential contamination by pesticides or other hazardous chemicals. 

Water of suitable quality, with tighter chemical and microbiological quality specifications, should

be used during certain process steps (e.g., cell cultures, final crystallization and isolation) and

during early process steps if impurities that affect API quality are present in the water and cannot

be removed in later steps. For example, if water is used for a final wash of a filter cake, or if the

API is crystallized from an aqueous system, the water should be suitably treated (e.g.,

deionization, ultrafiltration, reverse osmosis, or distillation) and routinely tested to ensure

compliance with appropriate chemical and microbiological specifications. If used for final rinses 
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during equipment cleaning, the water should be of the same quality as that used in the

manufacturing process. 

Water used in the final isolation and purification steps of nonsterile APIs intended for use in the

preparation of parenteral products should be tested and controlled for bioburden and endotoxins. 

Where water is treated to achieve an established quality, the treatment process and associated

distribution systems should be qualified, validated, maintained, and tested following established

procedures to ensure water of the desired quality. 

VI. PRODUCTION AND PROCESS CONTROLS

A. Written Procedures and Deviations

Written production and process control procedures should be established and followed to ensure

that APIs and intermediates have the quality and purity they purport or are represented to

possess. These procedures, including any changes, should be drafted, reviewed, and approved by

the responsible organizational units and reviewed and approved by the quality control unit. The

written procedures should be reviewed at defined intervals and updated whenever necessary. 

Outdated procedures should be withdrawn from circulation and archived. 

Production and process control procedures should be followed in the execution of the various

production and process control functions and should be documented promptly. Deviations from

written procedures should be documented and explained. 

B. Raw Material Weighing and Measuring

Raw materials used for manufacturing APIs and intermediates should be weighed or measured as

appropriate to maintain their identity, quality, and purity. Suitable equipment and procedures

should be used during these activities to prevent raw material contamination or crosscontamination. Weighing and measuring devices should be of suitable accuracy for the intended

use. Where necessary, they should be calibrated to ensure accurate results within appropriate

ranges. 

Raw materials subdivided for later use in manufacturing operations should be transferred into

suitable containers and appropriately labeled with the following information: 

C Material name and item code;

C Receiving or control number; and

C Weight or quantity of raw material in the new container. 
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Weighing, measuring, or subdividing operations for raw materials should be adequately

supervised. Raw materials should be verified prior to use to ensure that they are those specified in

the batch record for the intended API or intermediate. 

C. Calculation of Yield

Actual yields and percentages of expected yields should be determined at the conclusion of each

appropriate phase of manufacturing or processing of an API or intermediate. Expected yields

with appropriate ranges should be established based on previous laboratory, pilot scale, or

manufacturing data.

Deviations from expected yields should be investigated and documented. Investigations should

include:

C Determining the disposition of affected lots; and

C Taking corrective action, where needed, to minimize the likelihood of problem

recurrence. 

D. Equipment Identification

Major equipment (e.g., reactors, storage containers) and permanently installed processing lines

used during the production of an API or intermediate should be identified appropriately. This can

be accomplished by identifying individual vessels, documentation, computer control systems, or

alternative means.

Batch production records should identify the major equipment used in the manufacture of each

batch of an API and intermediate. 

E. In-Process Controls, Sampling/Testing of APIs and Intermediates 

Written procedures should be established and followed that describe the sampling methods for inprocess materials, intermediates, and APIs. Sampling plans and procedures should be based on

valid data and scientifically sound sampling practices. Sampling should be conducted in an area

and using procedures designed to prevent contamination of the sampled material and other APIs

or intermediates. Procedures should be established to ensure the integrity of samples after

collection. Each sample should be labeled to establish its identity. 

Written procedures should be established to monitor the progress and control the performance of

those manufacturing processes that may cause variability in the quality characteristics of APIs and 
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intermediates. In-process controls and specifications should be derived from laboratory-, or pilotscale batches and may be adjusted later based on data obtained from full-scale production batches. 

The type and extent of in-process controls should depend on several considerations, including: 

C The nature of the API or intermediate being manufactured

C The reaction or process step being conducted; and

C The degree to which the step introduces variability in the process.

Less stringent in-process controls may be appropriate in early processing steps whereas tighter

controls should be applied to later synthesis, isolation, and purification steps. 

In-process tests may be performed by qualified production department personnel and the process

adjusted without prior quality control approval, provided adjustments are made within

preestablished limits approved by the quality control unit. All in-process tests and results should

be documented in the batch record. 

APIs and intermediates failing to meet established specifications should be rejected and held under

quarantine until an investigation determines the appropriate disposition of the materials. Materials

to be reprocessed or reworked should be appropriately identified. 

F. Time Limits on Production of APIs and Intermediates

When appropriate, time limits for the completion of manufacturing steps should be established to

ensure the quality of APIs and intermediates. Deviations from established time limits should not

compromise the quality or purity of the API or intermediate. Such deviations should be

documented and explained. 

Written procedures should be established for intermediates that are stored before further

processing. Where necessary, these procedures should specify appropriate storage conditions,

packaging materials, temperature, time, and protection from humidity and light when these are

critical for maintaining the quality of the intermediate. 

G. Control of API Contamination 

Appropriate measures should be taken during final filtration and isolation steps to avoid

contamination or cross-contamination of APIs. Such measures should include:

C Use of equipment designed to minimize contamination;
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C Use of adequately cleaned and maintained equipment, and where necessary,

dedicated equipment;

C Location of equipment in a controlled environment;

C Use of suitably filtered liquid and gaseous materials (e.g., gases that are used

to vent or blanket dryers); and

C Use of adequately purified solvents and other purified raw materials.

In addition, special precautions should be taken during drying, milling, micronizing, sieving,

blending, and packaging operations due to the contamination risks associated with handling dry

powders. Such precautions should include:

C Use of closed systems for isolation and drying, where possible;

C Use of automated powder transfer systems (e.g., vacuum, gravity systems)

when charging and discharging vessels; and

C Use of appropriate air handling and dust extraction systems. 

When appropriate, written procedures should be established and followed to minimize

objectionable microbiological contamination in APIs and intermediates that (1) are of biologic

origin; (2) are sensitive to microbiological deterioration; or (3) have established microbiological

specifications.

Written procedures should be established and measures taken to control bioburden and endotoxin

contamination of nonsterile APIs intended for use in the preparation of parenteral drug products. 

H. Blending of APIs and Intermediates 

In-process blending (e.g., collecting several centrifuge loads in a single dryer or blender, blending

of several intermediate batches for use in subsequent process steps, blending of tailings) should be

adequately controlled and documented. Appropriate specifications should be established for inprocess materials to be blended to ensure the quality of the blend. 

Blending of batches or lots that individually do not conform to purity specifications with other

lots that do conform for the purpose of salvaging materials or disguising defects should be

avoided 
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When blending several API batches to increase batch size,

C Each batch incorporated into the blend should meet established purity

specifications; 

C Each batch incorporated into the blend should have been produced by the same

process; 

C The lot or control number assigned to each blend should allow traceability

back to the individual batches that make up the blend; and

C The expiration or retest date assigned to the blended API batch should be

based on the manufacturing date of the oldest batch in the blend. 

For dry blended APIs, the maximum lot size for final API blends should be limited to the

maximum working capacity of the largest blender used. 

Where physical attributes of the API are critical (e.g., APIs intended for use in solid oral dosage

forms or suspensions), blending operations should be validated to show homogeneity of the

blended batch. Validation should include testing for critical attributes (e.g., particle size

distribution, bulk, and tap density) that may be affected by the blending process. 

VII. PACKAGING AND LABELING CONTROLS

A. Materials Examination and Usage Criteria

There should be written procedures describing the receipt, preparation, identification, storage,

handling, sampling, examination, and/or testing of API labeling and packaging materials. Such

written procedures should be followed and documented. Labeling and packaging materials

should be representatively sampled and examined or tested, as appropriate, before use. 

All labeling and packaging materials should conform to established specifications. Those that do

not comply with such specifications should be rejected to prevent their use in operations for which

they are unsuitable. Records should be maintained for each shipment of labeling and packaging

materials showing receipt, examination, or testing, and whether accepted or rejected.

Labeling for each different API form or grade should be stored separately with suitable

identification. Such storage should provide adequate security to avoid mix-ups. If gang printed

labels are used for different APIs, these should be adequately differentiated by size, shape or

color. If cut labels are used, appropriate measures should be taken to prevent label mix-ups. 
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19

Obsolete and outdated labeling should be destroyed. Other obsolete packaging materials should

be destroyed or otherwise disposed of in a way that precludes mixups with currently acceptable

materials.

Printing devices used to print labels during packaging operations should be monitored to ensure

that all imprinting conforms to the print specified in the batch production record. 

B. API Label Issuance

Strict controls should be exercised over labels issued for use in labeling operations. Labels issued

for a batch should be carefully examined for proper identity and conformity to the specifications in

the master or batch production records. The results of this examination should be documented. 

Quantities of labels issued, used, and returned should be reconciled. Discrepancies should be

investigated and documented. 

C. Packaging and Labeling Operations 

Written procedures should be established to ensure that correct labels, labeling, and packaging

materials are used for APIs. Such procedures should be followed and documented. 

Physical or spatial separation from other API operations should be provided to prevent mixups

and contamination. Packaging and labeling facilities should be inspected immediately before use

to ensure that all materials not required for the next packaging run have been removed. This

inspection should be documented. 

Each API should be identified with a lot or control number that permits determination of the

history of its manufacture and control. Packaged and labeled APIs should be examined to ensure

that containers and packages in the lot bear the correct label. 

API containers that are shipped outside of the manufacturer’s control should be sealed in a

manner that alerts the recipient of possible tampering if the seal is breached or missing. 

D. API Packaging Materials 

API packaging materials should not be reactive, additive, or absorptive so as to alter the quality

or purity of the API beyond the official or established requirements. Packaging materials should

provide adequate protection against deterioration or contamination that may occur during

transportation and recommended storage of the API. 

API packaging materials should be cleaned, as appropriate, and where indicated by the nature of

the API, sanitized, to ensure that they are suitable for their intended use. Standards or
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20

specifications, methods of testing, and, where indicated, methods of cleaning, sanitizing, and

processing API packaging materials should be written and followed. 

E. Expiration or Retest Dating

Antibiotic APIs and all biologic APIs should be labeled with an expiration date. For other APIs,

the container label or certificate of analysis (COA) should specify an appropriate expiration date

or retest date to ensure the quality of the API at the time of use. Expiration or retest dates should

relate to any storage conditions stated on the label and should be supported by appropriate

stability studies, as stipulated in Section IX.C. 

Storage conditions should be specified on the label of API containers when it is critical to

maintain such conditions to ensure the quality of the API. Where applicable, labeled storage

conditions should comply with standard definitions for "Freezer," "Cold," or "Controlled Room

Temperature," as defined in the United States Pharmacopeia (USP) or guidelines of the

International Conference on Harmonisation (ICH). Statements of specific storage conditions

should be used instead of more general terms such as “room temperature” when it is critical for

maintaining the quality of APIs. 

For most biotechnological and biologic APIs, precisely defined storage temperatures should be

established and stated on the label. The label on each container should also bear any warnings to

protect the contents from excessive heat, freezing, light or moisture. 

VIII. HOLDING AND DISTRIBUTION OF APIs AND INTERMEDIATES 

A. Warehousing Procedures

Written procedures describing the warehousing of APIs and intermediates should be established

and followed. They should include:

C Storage under a quarantine system before release by the quality control unit;

and

C When appropriate, storage under specified conditions of temperature,

humidity, and light so that the quality and purity of APIs and intermediates are

not adversely affected. 

B. Distribution Procedures

Written procedures should be established and followed describing the distribution of APIs and,

where applicable, intermediates. They should include: 
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21

C Distribution of the oldest approved stock of an API or intermediate before

distribution of newer stock with deviations recorded and explained;

C A system by which the distribution of each lot of API or intermediate can be

readily determined to facilitate its recall if necessary; and

C Transportation of APIs and intermediates in a manner that does not adversely

affect their purity or quality.

IX. LABORATORY CONTROLS

A. General Controls

Specifications, standards, sampling plans, test procedures, or other laboratory control

mechanisms, including changes in same, should be drafted by the appropriate organizational unit

and reviewed and approved by the quality control unit. Laboratory controls should be followed

and documented at the time of performance. Deviations from written specifications, standards,

sampling plans, test procedures, or other laboratory control mechanisms should be documented

and justified. 

Laboratory controls should include the establishment of scientifically sound and appropriate

specifications, standards, sampling plans, and test procedures to ensure that raw materials,

intermediates, APIs, and containers conform to established standards of quality and purity. 

Procedures should be established to determine conformance to appropriate written specifications

for the acceptance of each lot of raw materials, containers, intermediates, and APIs. Such

procedures should also cover appropriate sampling and retesting of any materials used in the

manufacturing or holding of an intermediate or API that are subject to deterioration or

degradation. Laboratory test samples should be representative, properly handled, and adequately

identified. 

A program should be in place to calibrate or demonstrate suitability of instruments, apparatus,

gauges, and recording devices at suitable intervals. The program should contain specific

directions, schedules, limits for accuracy and precision, and provisions for remedial action in the

event accuracy and/or precision limits are not met. Instruments, apparatus, gauges, and

recording devices not meeting established specifications should not be used.

Secondary laboratory reference standards (e.g., production lots that are further purified and

qualified in the laboratory) should be appropriately prepared, identified, stored, and tested, as

necessary, to ensure their suitability for use. The suitability of each lot of secondary reference

standard should be determined prior to use by comparing against a primary reference standard
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Copies may be obtained from the Association of Official Analytical Chemists, 2200 Wilson Blvd., Suite 400, 2

Arlington, VA 22201-3301.

 See the January 1996 “Guideline for Industry Impurities in New Drug Substances” and the ICH Harmonized 3

Tripartite Guideline “Impurities in New Drug Substances,” recommended for adoption at Step 4 of the ICH process on

30 March 1995. 

22

obtained from an official source and periodically requalifying each lot in accordance with a written

protocol. Primary reference standards need not be tested if stored under conditions consistent

with those described in the labeling. 

Analytical reagents should be prepared and labeled following established procedures. Retest or

expiration dates should be used, as appropriate, for analytical reagents, or standard solutions. 

Analytical methods should be validated unless the method employed is set forth in the current

revision of the United States Pharmacopeia/National Formulary, Association of Official

Analytical Chemists, Book of Methods, or other recognized standard references, or detailed in a 2

Drug Master File or approved new drug application and are used unmodified. The suitability of

all testing methods used should nonetheless be verified under actual conditions of use and

documented. 

B. Testing and Release for Distribution

Appropriate laboratory tests should be conducted on each lot of API or intermediate to determine

satisfactory conformance to established specifications. Intermediates should be tested as

appropriate for conformance to specifications. 

Microbiological testing should be conducted on each lot of API required to be free of

objectionable microorganisms. Appropriate testing should also be conducted on each lot of API

required to be pyrogen free or with a specified endotoxin limit (e.g., APIs intended for use in the

preparation of parenteral drug products). 

Impurity profiles should be established and maintained for each API that identify or quantify each

impurity observed (i.e., organic impurities, inorganic impurities, and residual solvents). In

general, all impurities at or above 0.1% should be identified. Test procedures for establishing 3

impurity profiles should be written and followed.

Intermediates and APIs failing to meet established standards or specifications should be rejected. 

Adequate written procedures should be followed for rejected materials that are reprocessed or

reworked. 
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This guidance applies to stability testing for active pharmaceutical ingredients. FDA recommends that 4

manufacturers also consult the Agency’s February 1987 Guideline For Submitting Documentation For The Stability Of

Human Drugs And Biologics and the relevant International Conference On Harmonisation (ICH) guidances, including: 

Stability Testing of New Drug Substances and Products, Quality of Biotechnological Products: Stability Testing of

Biotechnological/Biological Products, and Light Stability Testing of New Drug Substances And Products.

23

C. Stability Testing

A formal testing program should be established to assess the stability characteristics of APIs. The

results of such testing should be used to determine appropriate storage conditions and retest or

expiration dates. The testing program should be ongoing and include: 

C The number of lots placed on stability per year, sample size, and test intervals;

C Storage conditions for samples retained for testing; and

C Stability indicating test methods.4

Stability samples should be stored in containers that simulate the market container. For example,

if the API is marketed in polyliners within fiber drums, stability samples should be packaged in

bags of the same material and in smaller scale drums of similar or identical composition to the

market drums.

An adequate number of batches of each API should be tested at suitable intervals to determine an

appropriate retest or expiration date. This generally includes samples from the first three

commercial size batches, but fewer batches may be appropriate in the initial testing program if

data from previous studies or from literature show that the API is stable for at least two years.

For those biotechnological/biologic and other APIs having shelf-lives of one-year or less, stability

samples should be obtained and tested monthly for the first three months, and at three-month

intervals thereafter. 

When stability data from pilot-scale batches are used to establish a tentative expiration date:

C The pilot batches should be manufactured by procedures that simulate the final

process to be used on a commercial manufacturing scale;

C The quality of the API should represent the material to be made on a

commercial scale. 

After the initial retest or expiration date has been established, at least one batch of API

manufactured during a given year should be added to the stability testing program to detect
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changes in the stability profile. Changes in manufacturing site, materials, or manufacturing

processes should be evaluated to determine if these changes affect API stability.

D. Reserve Samples

Appropriately identified reserve samples representative of each lot of API should be retained for

one year after the expiration date of the lot, or, for APIs having retest dates, three years after the

batch is distributed.

Reserve samples should consist of at least twice the quantity necessary for all tests required to

determine whether the API meets its established specifications. The samples should be stored in

containers that would be equivalent or more protective than the marketed packaging system. 

Representative reserve samples should be examined visually at least once a year for evidence of

deterioration unless visual examination would affect the integrity of the reserve samples. Any

evidence of deterioration should be investigated. The results of the examination should be

documented and maintained. 

E. Laboratory Animals

Animals used in testing raw materials, in-process materials, intermediates, or APIs for compliance

with established specifications should be maintained and controlled to ensure their suitability for

their intended use. Animals should be identified and adequate records maintained showing the

history of their use.

X. RECORDS AND REPORTS

A. General Controls

Any production, control, or distribution record specifically associated with a batch of API should

be retained for at least one year after the expiration date of the batch. For APIs with retest dates,

records should be retained for at least three years after the batch is completely distributed to either

internal or external recipients. 

Records should be maintained for all raw materials and API containers for at least one year after

the expiration date of the batch. For APIs with retest dates, these records should be retained for

at least three years after the API batch is completely distributed to either internal or external

recipients.

All records or copies of such records should be readily available for authorized inspection and

copying by FDA during the retention period at the establishment where the activities described in 
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25

such records occurred. Records kept off site should be promptly retrievable by electronic or

other means. 

Records may be retained either as originals, electronic records, or as true copies, such as

photocopies, microfilm, microfiche, or other accurate reproductions of the original records. 

Where reduction techniques, such as microfilming, are used, suitable reader and copying

equipment should be readily available. 

Written records should be maintained so that data therein can be used for evaluating, at least

annually, the quality standards of each API to detect the need for changes in specifications or

manufacturing or control procedures. Written procedures should be established and followed for

such evaluations and should include provisions for:

C A review of a representative number of batches, whether approved or rejected,

and their associated records; and

C A review of process changes, stability data/protocols, complaints, recalls,

returned or salvaged APIs, and deviation investigations conducted for the API

being evaluated. 

Procedures should be established to ensure that designated officials of the firm, if they are not

personally involved in or immediately aware of such actions, are notified in writing of any

investigations conducted, any recalls, reports of inspectional observations issued by the FDA, or

regulatory actions relating to CGMPs brought by the Agency.

Electronic records and electronic signatures used under this section should comply with Part 11 of

Title 21 of the Code of Federal Regulations.

B. Equipment Cleaning and Use Record

A written record should be maintained of major equipment cleaning and maintenance (except

routine maintenance such as lubrication and adjustments), that shows the date, time, API or

intermediate, the lot number of each batch processed, and the person who performed the cleaning.

Where equipment is dedicated to manufacturing one API or intermediate and lots or batches are

manufactured in numerical sequence, the records of cleaning, maintenance, and use should be part

of the batch record or maintained separately (e.g., equipment log books). The persons performing

and checking the cleaning and maintenance should date and sign or initial the record showing that

the work was done. Entries in the record should be in chronological order. 
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C. Raw Material, API Packaging Materials, and Labeling Records 

These records should include the following:

C The identity and quantity of each shipment of each lot of raw materials,

intermediates, API packaging materials, and labeling; the name of the supplier;

the supplier's lot number(s) if known; the receiving code; and the date of

receipt;

C The name and location of the manufacturer, if different from the supplier; 

C The results of any test or examination performed and the derived conclusions;

C Documentation of the examination and review of labeling and API packaging

materials for conformity with established specifications; and

C The disposition of rejected raw materials, API packaging materials, and

labeling.

D. Master Production and Control Records

Master production and control records for each API and intermediate, including each batch size

thereof, should be prepared, dated, and signed by one person and independently checked, dated,

and signed by at least one other person. The quality control unit should review and approve

master production and control records. The preparation of master production and control

records should be described in a written procedure and followed. 

Master production and control records should include:

C The name of the API or intermediate and an identifying reference code, if

applicable; 

C A complete list of raw materials or intermediates designated by names or codes

sufficiently specific to indicate any special quality characteristics; 

C An accurate statement of the quantity and unit of measure of each raw material

or intermediate (variations in the amounts of raw materials or intermediates

should be reasonable and justified);

C A statement of expected weights or measures at appropriate phases of

processing;
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C A statement of expected yields, including the maximum and minimum weights

or measures, or the percentages of expected yield beyond which investigation

is initiated; 

C The manufacturing location and the major equipment to be used; 

C Complete manufacturing instructions and, where appropriate, special notations

and precautions to be followed, or cross references to same; 

C Any sampling instructions and in-process controls with their limits, where

appropriate; and

C Requirements for storage of APIs or intermediates, including the packaging

materials, labeling, and special storage conditions, where applicable. 

E. Batch Production and Control Records

Batch production and control records should be prepared for each batch of API or intermediate

produced and should include complete information relating to the production and control of each

batch. These records should include an accurate reproduction or reference to the appropriate

master production and control record, checked for accuracy, dated, and signed. 

Batch records should include documentation that each significant step in the production of the

batch was accomplished including:

C Dates, and where appropriate, times; 

C Identity of individual major equipment used;

C Specific identification of each batch, including weights, measures, and batch

numbers of raw materials, intermediates, or any reprocessed/reworked

materials used during manufacturing;

C In-process and laboratory control results;

C A statement of the actual yield compared against an expected yield at

appropriate phases of manufacture; 

C Description of API and intermediate packaging and labeling;

C Any sampling performed;
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C Signatures of the persons performing and directly supervising or checking each

significant step in the operation;

C Any deviation investigations conducted or reference to that investigation if

stored separately; and

C Results of release testing.

F. Production Record Review 

Written procedures should be established and followed for the review and approval of batch

production, control, and laboratory records, including packaging and labeling, to determine

compliance of the API or intermediate with established specifications before a batch is released or

distributed. 

Batch production and control records for critical process steps should be reviewed and approved

by the quality control unit before a batch is released or distributed. Where the quality control unit

does not review noncritical process steps, the review should be performed by qualified production

personnel or other units following procedures approved by the quality control unit. 

Written procedures should be established and followed for investigating unexplained

discrepancies, including:

C Results out of the expected yield range established in master production and

control records;

C Failure of a batch to meet specifications; and

C Any out-of-specification (OOS) test results.

The investigation should extend to other batches of the API or other batches that may have been

associated with the specific failure or discrepancy, regardless of whether the batch has already

been distributed. 

 

A written record of the investigation should be prepared and should include:

C The reason for the investigation;

C A summary of the investigation conducted, including all laboratory tests and

results;

C Scientifically sound and appropriate justification for excluding any OOS
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29

laboratory result;

C For laboratory results found invalid, the subsequent laboratory results

supporting the final determination of conformity to all appropriate

specifications for acceptance;

C The conclusions and corrective actions taken regarding batches associated with

the failure or discrepancy; and

C The signature(s) and date(s) of the person(s) responsible for approving the

record of investigation.

G. Laboratory Records

Laboratory records should include complete data derived from all tests necessary to ensure

compliance with established specifications and standards, including examinations and assays, as

follows:

C A description of samples received for testing including the source, quantity, lot

number or other distinctive code, date sample was taken, and date the sample

was received for testing; 

C A statement of or reference to each method used in testing the sample;

C A statement of the weight or measure of sample used for each test;

C A complete record of all raw data secured during each test, including graphs,

charts, and spectra from laboratory instrumentation, properly

C identified to show the specific raw material, intermediate, or API, and lot tested;

C A record of all calculations performed in connection with the test, including

units of measure, conversion factors, and equivalency factors; 

C A statement of the test results and how they compare with established

standards of quality and purity for the raw material, intermediate, or API

tested; 

C The initials or signature of the person who performs each test and the date(s)

the tests were performed; and

C The initials or signature of a second person showing that the original records
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30

have been reviewed for accuracy, completeness, and compliance with

established standards.

Complete records should be maintained for: 

C Any modifications to an established analytical method, to include the reason for

the modification and data to verify that the modification produces results that

are at least as accurate and reliable as the established method;

C Preparation and testing of laboratory reference standards, reagents, and

standard solutions;

C Periodic calibration of laboratory instruments, apparatus, gauges, and

recording devices;

C All stability testing performed on APIs; and

C OOS investigations. 

H. Distribution Records

Distribution records should contain the name of the API or intermediate, the name and address of

the consignee, date, quantity shipped, and lot or control number. 

I. Complaint Files

Written procedures describing the handling of all written and oral complaints regarding an API

should be established and followed. Similar procedures should be established for complaints

involving marketed intermediates. These procedures should provide for the quality control unit to

review of all complaints involving the possible failure of an API to meet any of its specifications,

determine the need for an investigation, and ascertain whether the complaint represents a serious

and unexpected event that would require notification to users of the API. 

A written record of each complaint should be maintained in a file designated for APIs. The file

should be kept at the establishment where the API was manufactured, processed, or packed or at

another facility if the written records in such files are readily available for inspection at that other

facility. Complaint records should be maintained for at least one year after the expiration date of

the API, or one year after the date the complaint was received, whichever is longer. For APIs

with retest dates, such written records should be maintained for at least three years after the batch

is distributed. The written record should include the name of the API, batch or lot number, name

and address of the complainant, nature of complaint, and reply to the complainant.
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If an investigation is conducted in response to a complaint, the record should include the findings

of the investigation and any conclusions or corrective actions taken. The record (or copy) of the

investigation should be kept at the establishment where the investigation occurred. If an

investigation is not conducted, the written record should include the reason that an investigation

was found to be unnecessary, and the name of the responsible person making such a

determination. 

J. Returned APIs and Intermediates 

Written procedures for the receipt, holding, testing, and disposition of returned APIs and

intermediates should be established and followed. These procedures should provide for the

identification and holding of returned APIs and intermediates. Where an API or intermediate is

placed back into inventory, the reason for its return should not have been due to quality issues,

and the integrity of the returned material should have been verified. If the quality or purity of the

API or intermediate cannot be ensured, the returned material should be destroyed, reprocessed, or

reworked as appropriate. If the reason for the return implicates associated batches, an

appropriate investigation should be conducted as described in Section XII.F.4. 

Records of returned APIs and intermediates should be maintained and should include the name,

batch or lot number, reason for the return, quantity returned, date of disposition, and ultimate

disposition.

K. API and Intermediate Salvaging 

APIs and intermediates that have been subjected to improper storage conditions, including

extremes in temperature and humidity, smoke, fumes, pressure, age, or radiation due to natural

disasters, fires, accidents, or equipment failures should not be salvaged.

Whenever there are doubts that APIs and intermediates have been subjected to adverse conditions

described above, salvaging operations should only be conducted if there is both (1) evidence from

inspection of the premises that the APIs and intermediates and their associated packaging were

not subjected to improper storage condition and (2) evidence from laboratory tests and assays that

the APIs and intermediates meet all applicable standards of quality and purity.

XI. VALIDATION

A. Process Validation Strategy 

A written program should be established and followed for validating the manufacturing processes

for all APIs. Validation studies should ensure that a specific manufacturing process is capable of 
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performing in a reliable and consistent manner and results in a homogeneous API that consistently

meets predetermined specifications. 

Validation should embrace steps in the processing of APIs that are critical to the quality and

purity of the final API, and should include: 

C Definition of the API in terms of its critical quality attributes. Among the

attributes that should be considered are chemical purity; qualitative and

quantitative impurity profiles; physical characteristics such as particle size, bulk

and tap density; polymorphic forms; moisture and solvent content;

homogeneity; and microbial quality (if the product is susceptible to microbial

contamination). 

C Identification of process parameters that could affect the critical quality

attributes of the API. Critical parameters should be determined by scientific

judgement and typically should be based on knowledge derived from research,

scale-up batches, or manufacturing experiences. 

C Determination of the range for each critical process parameter expected to be

used during routine manufacturing and process control. Data to substantiate

the ranges for critical process parameters generally should be obtained from

laboratory- or pilot-scale batches, unless a specific parameter can only be

determined from a production-scale batch. 

Examples of processing steps that could be defined by the API manufacturer as critical include: 

C Phase changes, such as dissolution or crystallization;

C Phase separation, such as filtration or centrifugation;

C Steps that cause chemical changes; 

C Steps that alter temperature or pH;

C Mixing of multiple raw materials; and

C Steps that cause changes in surface area, particle size, bulk and tap density or

homogeneity.

Critical process parameters (e.g., reaction times, reaction temperatures, reactant ratios,

concentrations, pressures, pH, and impurity levels) should be controlled and monitored during

process validation studies. Process parameters unrelated to quality, such as variables controlled

to minimize energy consumption or equipment use, need not be included in the process validation. 
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Process validation should confirm that the impurity profile for each API is within the limits

specified and is comparable to the profile determined during process development or for batches

used for pivotal/toxicological studies. 

B. The Validation Protocol

A written validation protocol should be established that specifies how process validation will be

conducted. The protocol should be reviewed and approved by the quality control unit and other

designated organizational units. 

The validation protocol should include the following: 

C Purpose and scope of the validation;

C Functions and responsibilities of all organizational units involved in the

validation;

C Type of validation to be conducted with appropriate justification for type

chosen;

C Number of process validation runs;

C Quality of materials used in the process (e.g., recovered vs. fresh solvents);

C Description of the process (e.g., discussion of the chemistry, unit operations,

process flow diagram);

C All major process equipment used, its type/design, and its installation and

operational qualification (IQ/OQ); 

C The critical quality attributes of the API;

C The critical process parameters and operating ranges;

C Sampling plans (i.e., sampling points, frequency, quantities, and procedures for

collecting samples);

C Specifications and test data to be collected;

C Acceptance criteria needed to conclude that the validation has been successful;

and
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C Steps to follow in the event of a process validation failure. 

The above information need not be incorporated in the validation protocol if the protocol makes

specific reference to other documents that contain the information (e.g., COA’s, development

reports, and IQ/OQ reports). Any changes to the validation plan should be documented with

appropriate justification. 

C. Prospective Validation

Prospective validation should be conducted prior to the commercial distribution of an API

produced by a new or substantially modified process. This validation approach should involve

obtaining and evaluating documented processing and analytical control information for multiple

batches manufactured, sampled, and tested according to a preestablished validation plan. 

When prospectively validating a process, data from laboratory- and/or pilot-scale batches should

identify critical quality attributes and specifications, critical steps, control ranges, and in-process

tests. Scale-up batches could be used to generate data to confirm or refine earlier work, and

production-scale batches should provide data showing consistency of the process. 

The number of process runs should depend on the complexity of the process or the magnitude of

the process change being considered. Although three consecutive, successful production lots

should be used as a guide, there could be situations where additional process runs are warranted

to prove consistency of the process (e.g., complex API processes or API processes with

prolonged completion times). If a validation lot fails for reasons unrelated to process

performance (e.g., power failure or equipment breakdown), that lot should be removed from the

validation study and an additional validation run conducted. 

Validated analytical methods capable of quantifying API quality attributes should be used during

process validation. Resulting data should be evaluated and included in a validation report

approved by the same organizational units that approved the protocol. 

D. Concurrent Validation

FDA considers concurrent validation to be a subset of prospective validation. The Agency

recognizes that in a limited number of cases it may be impossible to complete validation of an API

process in a timely manner when data from replicate production runs are unavailable because: 

C Only a limited number of API batches intended for clinical or orphan drug

products have been produced;

C API batches are produced infrequently (e.g., limited market demand, complex

multi-step API processes with long completion times); or
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C APIs batches are produced by a modified process (e.g., a validated process

goes outside the proven acceptable range of a critical operating parameter and

the batch is subjected to intensive analytical tests).

In such cases, firms should do all of the following:

C Document the reasons for not completing process validation before shipment

of the API;

C Perform all of the elements of prospective validation, as discussed in Section

XIII.C., exclusive of replicate production run testing, before releasing any

batch for distribution;

C Conduct intensive in-process monitoring and testing, along with intensive

testing of each API batch, to show that each production run resulted in an API

meeting its predetermined quality characteristics and specifications (such data

should also be assessed under the validation protocol to determine consistency

of the process);.

C Provide for the Quality Control unit to evaluate batch production records, inprocess controls, and analytical data from each process run to determine

whether each batch should be released.

The level of intensive in-process and final API testing should be greater than levels for validated

routine production runs, and should only be reduced to routine levels after the process has been

determined to be validated. In addition, data from production runs that are evaluated as part of

the validation studies should encompass the operating ranges that are approved for use during

routine process control.

The Agency cautions that this validation approach should be applied with discretion so as not to:

C Unduly delay completion of, or avoid performing, meaningful validation; or

C Distribute API batches manufactured before completion of validation for a

prolonged period of time.

This approach should not be viewed as a viable alternative where the number and frequency of

API production runs permit timely completion of validation prior to API distribution. If analysis

of data shows that the process used to manufacture the distributed batches was not, in fact,

validated, no additional batches should be distributed until corrections have been implemented and

the process has been determined to be validated.
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E. Retrospective Validation

Retrospective validation could be conducted for a well-established process that has been used

without significant changes (e.g., changes in raw materials, equipment, systems, facilities, or in the

production process) that affect the critical quality attributes of the API. This validation approach

should be used only when there is sufficient history on past API batches to demonstrate the

process consistently produces acceptable products, and where: 

C Critical quality attributes and critical process parameters have been identified

and documented;

C Appropriate in-process specifications and controls have been established and

documented;

C There have not been excessive process/product failures attributable to causes

other than operator error or equipment failure unrelated to equipment

suitability; and

C Impurity profiles have been established for the existing API.

In addition to the information described in Section XIII.B., the validation protocol should include

the batch selection criteria and analytical data that will be evaluated to determine consistency of

the process. 

The number of batches to review will depend on the process, but, in general, data from 10 to 30

consecutive batches should be examined to assess process consistency. The review should include

any batches that failed to meet specifications. All batches within the selected review period

should have been manufactured by the same process and have the same documented history of

controls and tests as current APIs. Additional testing of retained samples may be warranted to

obtain the necessary data to retrospectively validate the process. 

Data obtained should be evaluated by appropriate personnel, and a final validation report

summarizing the results and appropriate conclusion should be prepared. This report should be

reviewed and approved by the organizational units that approved the original protocol.

Retrospective validation could also be employed to provide additional data to supplement

prospective validation and either build confidence in a particular manufacturing process or impugn

it as test results are received. 
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XII. CHANGE CONTROL/REVALIDATION 

A. Change-Control System

To provide mechanisms for ongoing process optimization and ensure a continuing state of process

control, a formal change control system should be established to evaluate and approve proposed

changes to specifications, test procedures, raw materials, facilities, support systems, equipment

(including computer hardware), processing steps, packaging materials, and computer software. 

The change-control program should include procedures to: 

C Prevent unauthorized modifications to a validated system;

C Evaluate proposed changes against development and technology transfer

documents;

C Identify and evaluate all proposed changes to assess their potential affects on

the API process and determine if, and to what extent, revalidation is needed; 

C Ensure that all documents affected by changes are promptly revised; and

C Determine the impact of changes on the critical chemical and physical

attributes of the API (e.g., impurity profiles, stability, and particle size).

Any proposals for changes should be drafted, reviewed, and approved by the appropriate

organizational units, and reviewed and approved by the quality control unit. 

Changes implemented to improve process yields should be evaluated carefully to determine if

these result in new or higher levels of impurities. The impurity profile of the resulting batches

should be comparable to the impurity profile of the API batches used in drug safety and clinical

testing. Process changes should also be evaluated to ensure that these do not have an adverse

effect on analytical methods due to increased interference caused by new or higher levels of

impurities and by-products. Analytical methods should be modified as necessary to ensure they

are capable of detecting and quantifying impurities.

Dosage form manufacturers should be notified of changes in the API production process that

could affect the critical attributes of the API (e.g., impurity profile, crystal form, particle size,

residual solvent content, or stability) and thus have a significant impact upon the dosage forms

produced from that API. 

 
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B. Change-Control Classification

The change-control program should provide for a classification scheme to evaluate changes in raw

materials, manufacturing sites, scale of manufacturing, manufacturing equipment, and production

processes. This classification procedure should be used in determining what level of testing,

validation, and documentation is needed to justify changes to a validated process.

Changes should be categorized as minor or major depending on the nature and extent of the

changes, and the effects these changes could impart on the process. In all cases, scientific

judgement should determine what additional testing and validation studies are needed to justify a

change in a validated process. 

A minor change should be defined as one that is unlikely to have a detectable impact on the

critical attributes of the API. Such changes would not shift the process in any discernible manner,

and might be implemented with minimal testing and revalidation. For example, "like-for-like"

equipment replacements where equipment is repaired to its initial validated state or in which

identical or similar equipment is introduced into the process, would unlikely affect the process if

adequately installed and qualified. 

A major change should be defined as one that would likely significantly affect the critical quality

attributes of the API. For example, a change in solvent used for the final crystallization could

significantly affect the impurity profile, physical attributes, and other critical quality attributes of

the API. Such changes should be justified by additional testing, and if appropriate, revalidation. 

XIII. REPROCESSING/REWORKING OF APIs AND INTERMEDIATES

A. Reprocessing by Repeating a Chemical Reaction

Due to the potential for formation of by-products, reprocessing an API or intermediate by

repeating a chemical reaction (adding fresh reagents or solvents to unreacted or base material and

starting over) should be preceded by a careful evaluation to ensure that the quality of the final API

is not adversely impacted. 

Where such reprocessing occurs, written process change procedures should be approved by the

quality control unit that clearly specify the conditions and limitations of repeating chemical

reactions. In addition, the procedures should establish how this type of reprocessing will be

evaluated, and what additional tests will be conducted on the reprocessed material to show that

the resulting material is of a purity and quality comparable to that normally produced by the

process. These tests should include, as appropriate, purity, impurity profiles, stability testing on

initial reprocessed lots, and testing for physical attributes. 
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B. Reprocessing by Physical Manipulations

Intermediates and API batches that occasionally do not conform to specifications for percent

transmittance/color, or critical attributes (e.g., purity, impurities, particle size) can be reprocessed

by repeating a crystallization step or other physical manipulation steps (e.g., dissolution, filtration,

milling, blending) that are part of an established process. 

If it becomes necessary to more than occasionally reprocess batches by physical manipulation, a

thorough investigation should be conducted and documented to determine the adequacy of the

original process. Appropriate actions should be taken to minimize the risk of recurrence. For

example, if investigation of the nonconformance and/or review of the process reveals an

abnormally high rate of batches that need to be recrystallized, it would be reasonable to

incorporate the recrystallization as part of the normal process. 

All reprocessing procedures should be reviewed and approved by the quality control unit. These

procedures should specify the conditions and limitations for reprocessing by physical

manipulations and require an evaluation of each nonconforming batch to determine its suitability

for reprocessing. For example, one or more recrystallizations from the final solvent might be

justified, but continuous reprocessing of batches until they meet a given quality specification

would indicate a problem with the original process. A specific record should be generated to

document reprocessing steps and subsequent handling and incorporated into the original batch

record. 

Appropriate tests should be conducted on reprocessed batches to ensure that reprocessing does

not adversely affect the quality or purity of the API or intermediate. These tests should include,

as appropriate, purity, physical attributes, and impurity profiles. In all cases, the significance of

the nonconformance and its impact on the critical quality attributes of the API or intermediate

should determine how much analytical data is sufficient to justify the reprocessing.

Reprocessing operations should be subjected to appropriate evaluation to show that these steps

consistently perform the expected functions and result in batches that comply with all established

standards, specifications, and characteristics. 

C. Reworking of APIs and Intermediates 

Reworking batches that do not conform to established standards or specifications by using

processing steps that are different from the validated process should involve extensive evaluation

and documentation to show that the reworked product is of equivalent quality to that produced by

the original process. 

Reworking operations should be subjected to appropriate evaluation to show that such reworking

does not adversely affect the quality or purity of the API or intermediate. Where routine
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analytical methods are inadequate to characterize the reworked batch, alternative methods should

be used.

XIV. CONTROL OF CHEMICAL, BIOLOGICAL, AND PHYSICAL

CONTAMINANTS

Written procedures should be implemented to prevent objectionable chemical, biological, and

physical contamination, including cross-contamination in APIs and intermediates.

Dedicated production, which may include facilities, air handling equipment and/or process

equipment, should be employed where both of the following conditions exist:

C Contaminants pose a special danger to human or animal health. In the case of

human health, these include, but are not limited to, penicillin, cephalosporins,

cytotoxics, toxins, and infectious agents; and

C There are no effective methods for cleaning and removing contaminant

residues from buildings, facilities, and equipment to levels below those

determined by suitable medical and toxicological assessment to pose no serious

health risk to the consumer. 

If a reasonable possibility exists that an API or intermediate has been exposed to crosscontamination, the substance should be tested for the presence of the potential contaminant. APIs

and intermediates that exceed established limits for such contaminants should not be used in

further manufacturing.

XV. APIs FOR CLINICAL TRIALS

A. Quality Assurance Measures

Appropriate quality control measures and CGMP concepts should be applied in the production of

APIs for clinical trials with a suitable mechanism for approval of each batch.

The manufacturing practices used in the production of clinical APIs should be consistent with the

stage of development of the drug product incorporating the API. Processes and analytical

methods should be flexible to provide for changes as knowledge of the API process increases and

testing of a drug product progresses from preclinical through clinical stages.

Once drug development reaches the stage where the API is produced for use in drug products

intended for clinical trials in humans or animals, manufacturers should ensure that the clinical API
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is manufactured in qualified facilities using appropriate production and control procedures to

ensure the safety, quality, and homogeneity of the API.

B. Quality Control Unit

An independent quality control unit similar to that used in commercial production should be

established in clinical production of APIs for the approval or rejection of each batch of API. 

Some of the testing functions commonly performed by the quality control uit could be performed

within other areas.

Quality control measures should include a system for testing of raw materials, packaging

materials, intermediates, and APIs. Labeling for APIs intended for clinical trials should be

appropriately controlled. Labeling for such APIs should identify the material as intended for

investigational use.

C. Equipment and Facilities

During all phases of clinical development, including the use of small-scale facilities or laboratories

to manufacture clinical API batches, procedures should be in place to ensure that equipment is

calibrated, clean, and suitable for its intended use.

Procedures for the use of facilities should ensure that materials are handled in a manner that

prevents contamination and cross-contamination.

D. Control of Raw Materials

Raw materials used in early stages of clinical API production should be evaluated by analytical

testing, or received with a supplier’s certificate of analysis and subjected to identity testing.

E. Production and Process Controls

Laboratory notebooks or batch records can be used to document the production of clinical APIs. 

These should include all pertinent production materials, equipment, processing, and scientific

observations.

Expected yields might be more variable and less defined than the expected yields used in

commercial processes.
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F. Process Validation

At early clinical stages, where a single API batch is often produced and where significant

processing changes often make batch replication difficult or inexact, only limited process

validation is possible.

Concurrent validation might be appropriate in situations where a single or limited number of API

batches are produced for clinical trials. This involves obtaining data from extensive in-process

and end testing to demonstrate that the instant process run yields an API meeting established

specifications and quality characteristics. Process validation should be completed once additional

batches are produced under replicated conditions.

Prospective validation should be used when multiple batches are initially produced for clinical

trials, even when such batches are produced on a pilot scale or small scale. Once pilot- or smallscale production process are scaled up, the commercial production process should be subjected to

full validation studies.

G. Change Documentation

Changes to the process are expected during clinical development as knowledge of the process is

gained and the production is scaled up. All process modifications should be adequately

documented.

H. Laboratory Controls

All analysis performed to evaluate a batch of API for clinical trials should be scientifically sound.

A system for retaining reserve samples of APIs should be established and followed. This system

should ensure that reserve samples are retained for an appropriate lenth of time after approval,

termination, or discontinuation of an investigational new drug application (IND), a new drug

application (NDA), or biologics license application (BLA). Additional reserve samples should be

maintained for API batches used in pivotal toxicological and/or biobatches.

I. Documentation

A system should be in place to ensure that information obtained during the development and

production of APIs for clinical trials is documented. This information should be integrated into a

process development report.

The development and implementation of the analytical methods used to support the release of a

batch of APIs for clinical trials should be appropriately documented.
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A system for retaining production and control records should be used. This system should ensure

that records are retained for an appropriate length of time after the approval, termination, or

discontinuation of an IND or NDA.
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BIBLIOGRAPHY

Avallone, H.L., "GMP Inspections of Drug-Substance Manufacturers," Pharmaceutical

Technology, June 1992, pp. 46-55.

Barr, D.B., W.C. Crabbs, and D. Cooper, "FDA Regulation of Bulk Pharmaceutical Chemical

Production," Pharmaceutical Technology, September 1993, pp. 54-70.

Bulk Pharmaceuticals Committee, PMA QC Section,"Concepts for the Process Validation of Bulk

Pharmaceutical Chemicals," Pharmaceutical Technology, December 1993, pp. 32-40.

Cooper, D.E., "Problems in Bulk Pharmaceutical Chemical Production: An FDA Investigator's

View," Pharmaceutical Technology, June 1984, pp. 72-80.

Demmer, F., et al., "FDA Regulation of Bulk Pharmaceutical Chemicals -- An Industrial

Commentary: Part I," Pharmaceutical Technology, October 1994, pp. 80-90.

_____, “FDA Regulation of Bulk Pharmaceutical Chemicals -- An Industrial Commentary: Part

II," Pharmaceutical Technology, December 1994, pp. 36-43.

European Federation of Pharmaceutical Industries' Associations/European Chemistry Industry

Council, EFPIA/CEFIC Final Draft Good Manufacturing Practices for Active Ingredient

Manufacturers, August 1996.

Federal Ministry of Health, Republic of Germany, “Commercial Executive Order for the

Manufactures of Active Ingredients for Drugs,” October 26, 1994. 

Food and Drug Administration (FDA), Biotechnology Inspection Guide, Office of Regional

Operations, November 1991.

FDA, “Current Good Manufacturing Practices for Finished Pharmaceuticals,” 21 CFR part 211.

_____, Guide to Inspections of Bulk Pharmaceutical Chemicals, Office of Regional Operations

and Center for Drug Evaluation and Research, September 1991, Reformatted May 1994.

_____, Guide to Inspections of High Purity Water Systems, Office of Regional Operations, July

1993.

_____, Guideline to Inspection of Validation of Cleaning Processes, Office of Regulatory

Affairs, July 1993.
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_____, Guideline for Submitting Documentation for the Stability of Human Drugs and Biologics,

Center for Drugs and Biologics, February 1987.

_____, Guideline for Submitting Supporting Documentation in Drug Applications for the

Manufacture of Drug Substances, Center for Drugs and Biologics, February 1987.

Fry, E.M., "An FDA Perspective on Bulk Pharmaceutical Chemicals," Pharmaceutical

Technology, February 1984, pp. 48-53.

Gold, D.H., "GMP Issues in Bulk Pharmaceutical Chemical Manufacturing," Pharmaceutical

Technology, April 1992, pp. 74-84.

International Conference on Harmonisation (ICH), Q1A Stability Testing of New Drug

Substances and Products, FDA, September 1994.

ICH, Q3A Impurities in New Drug Substances, FDA, January 1996.

International Pharmaceutical Excipients Council, Good Manufacturing Practices Guide for Bulk

Pharmaceutical Excipients, July 1995.

Lord, A.G., "BPC's and cGmp's," Pharmaceutical Engineering, May/June 1988, vol. 8, no. 3, pp.

30-35.

Martinez, E.R., “An FDA Perspective on Bulk Pharmaceutical Chemical GMPs, Control and

Validation," Pharmaceutical Engineering, May/June 1994, vol. 14, no. 3, pp. 8-14.

Moore, R.E., "FDA's Guideline for Bulk Pharmaceutical Chemicals - A Consultant's

Interpretation," Pharmaceutical Technology, September 1992, pp. 88-100.

Pharmaceutical Inspection Convention, Guidelines for the Manufacture of Active Pharmaceutical

Ingredients (Bulk Drug Substances), PH 2/87, June 6, 1987.

PMA Committee on Guidelines for Bulk Pharmaceutical Chemicals, PMA Guidelines for the

Production, Packing, Repacking, or Holding of Bulk Pharmaceutical Chemicals, Second

Edition, Revised - June 1978.

QC Bulk Pharmaceuticals Work Group, "PhRMA Guidelines for the Production, Packing,

Repacking or Holding of Drug Substances," Quality Steering Committee, PhRMA Science and

Regulatory Section, Part I and Part II, Pharmaceutical Technology, December 1995 and January

1996.
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World Health Organization (WHO), "Good Manufacturing Practices for Pharmaceutical

Products," Thirty-second Report of the WHO Expert Committee on Specifications for

Pharmaceutical Preparations, Annex 1, Technical Report Series No. 823, Geneva, 1992.
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GLOSSARY

The following terms and definitions are provided to assist the reader in using this guidance

document. Unless otherwise stated, when the following definitions address APIs, the Agency

intends to apply the same definitions to drug, veterinary, and biologic APIs. 

Acceptance Criteria: The specifications and acceptance/rejection criteria, such as acceptable

quality level and unacceptable quality level, with an associated sampling plan that are necessary

for making a decision to accept or reject a lot or batch of raw material, intermediate, packaging

material, or active pharmaceutical ingredient. This term can also be applied to validation. 

Act: The Federal Food, Drug, and Cosmetic Act, as amended (21 U.S.C. 301 et seq.).

Actual Yield: The quantity that is actually produced at any appropriate phase of manufacture,

processing, or packing of a particular API or intermediate. 

Active Pharmaceutical Ingredient (API): Any substance that is represented for use in a drug

and that, when used in the manufacturing, processing, or packaging of a drug, becomes an active

ingredient or a finished dosage form of the drug. Such substances are intended to furnish

pharmacological activity or other direct effect in the diagnosis, cure, mitigation, treatment or

prevention of disease, or to affect the structure and function of the body of humans or other

animals. APIs include substances manufactured by processes such as (1) chemical synthesis; (2) 

fermentation; (3) recombinant DNA or other biotechnology methods; (4) isolation/recovery from

natural sources; or (5) any combination of these processes. 

Agency: The United States Food and Drug Administration (FDA).

Analytical Methods Validation: The process by which it is established, by laboratory studies,

that the performance characteristics of the method meet the requirements for the intended

analytical applications. 

Batch: A specific quantity of an intermediate or API intended to have uniform character and

quality, within specified limits, and produced according to a single manufacturing order during the

same cycle of manufacture. A batch may also mean a specific quantity of material or API

processed in one process or series of processes so that it could be expected to be homogenous. 

Biologic Active Pharmaceutical Ingredient: A material originating from a biological

manufacturing process intended to furnish pharmacological activity or other direct effect in the

cure, treatment, or prevention of disease or conditions of human beings. 
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Biologic Product: Any virus, therapeutic serum, toxin, antitoxin, or analogous product

applicable to the prevention, treatment, or cure of diseases or conditions of human beings. 

Calibration: The demonstration that a particular instrument or device produces results within

specified limits by comparison with those produced by a traceable standard over an appropriate

range of measurements.

Chemical Reaction: A process that involves a chemical transformation of a starting material or

intermediate to form a new compound (e.g., bond formation, oxidation, reduction).

Cleaning Agent: Any material used to clean process equipment, utensils, and storage vessels. 

These may include soaps, detergents, surfactants, alkalis, acids, or other materials, such as organic

solvents, if the solvent is specifically used for cleaning and is not a solvent used in the next

processing step. 

Concurrent Validation: A subset of prospective validation in which API batches are released

for distribution, based on extensive testing, before completion of process validation. Once data

from additional batches produced under replicated conditions show uniformity, the process may

be considered validated. 

Containment: Achieving a level of control over a raw material, intermediate, or API that

provides proper protection of these materials from external contamination and crosscontamination. 

Contamination: The introduction of impurities of a chemical or microbiological nature, or of

foreign matter, into or onto a raw material, intermediate, or API (e.g., occurring during

production, sampling, packaging or repackaging, storage or transport). 

Continuous Production: A process in which a material is continuously produced in a step or

series of steps. In a continuous process, the batches of raw materials and the process parameters

can be statistically, but not absolutely, correlated to the material produced in a given period of

time. 

Critical Process Parameters: Process parameters that must be controlled within established

operating ranges to ensure that the API or intermediate will meet specifications for quality and

purity. 

Critical Process Steps: Process steps that must be controlled within established operating

ranges to ensure that the API or intermediate will meet specifications for quality and purity. 
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Cross-contamination: A contamination of a material or product with another material or

product. 

Development Report: A report that summarizes the major stages of API development from

early stages through large-scale manufacturing. 

Drug: As defined in Section 201(g)(1) of the Act means (a) articles that are recognized in the

official United States Pharmacopeia, official Homeopathic Pharmacopeia of the United States, or

official National Formulary, or any supplement to them; (b) articles intended for use in the

diagnosis, cure, mitigation, treatment, or prevention of disease in humans or other animals; and 

articles (other than food) intended to affect the structure or any function of the body of humans or

other animals.

Drug Product: A finished dosage form, for example, a tablet, capsule or solution, that contains

an active pharmaceutical ingredient, generally, but not necessarily, in association with inactive

ingredients. The term also includes a finished dosage form that does not contain an API but is

intended to be used as a placebo. 

Enantiomers: Compounds with the same molecular formula as the API, which differ in the

spatial arrangement of atoms within the molecule and are nonsuperimposable mirror images. 

Expected Yield: The quantity of API or intermediate or the percentage of theoretical yield

anticipated at any appropriate phase of production based on data from process development or

process validation. 

Expiry/Expiration Date: The date (usually placed on the containers/labels of an API)

designating the time during which the API is expected to remain within established shelf-life

specifications if stored under defined conditions and after which it should not be used. 

Extraneous Substance: An impurity arising from any source extraneous to the manufacturing

process. 

Identified Impurity: An impurity for which a structural characterization has been achieved. 

Impurity: Any component of an API that is not the entity defined as the API. 

Impurity Profile: A description of the identified and unidentified impurities present in an API. 

In-Process Controls: Testing and activities performed during production to monitor and, if

necessary, adjust the process.
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In-Process Material: Any material manufactured, blended, or derived by chemical reaction that

is produced for, and used in, the preparation of an API. 

Intermediate: A material produced during steps in the synthesis of an API that must undergo

further molecular change or processing before it becomes an API.

Ligand: An agent with a strong affinity to a metal ion. 

Lot: A batch, or a specific identified portion of a batch having uniform character and quality

within specified limits. For an API produced by continuous process, it is a specific identified

amount produced in a unit of time or quantity in a manner that ensures its having uniform

character and quality within specified limits. 

Lot Number (Control Number, or Batch Number): Any distinctive combination of letters,

numbers, or symbols, or any combination of them, from which the complete history of the

manufacture, processing, packing, holding, and distribution of a batch or lot of an API or other

material can be determined. 

Manufacture, Processing, Packing, or Holding: All operations used to manufacture an API to

include packaging and labeling operations, testing, and quality control of an API.

Mother Liquor: The residual saturated liquid that remains after crystallization. A mother liquor

may contain unrecovered or unreacted starting materials, intermediates, the API and/or impurities.

New Molecular Entity: The designated therapeutic moiety (API) in a dosage form that has not

been approved for marketing in the United States (also referred to as a new chemical entity or

new drug substance). It may be a complex, simple ester, or salt of a previously approved API. 

Physical Manipulation: A process other than a chemical reaction that may change the purity or

the physical properties of the material, including but not limited to crystallization,

recrystallization, gel filtration, chromatography, milling, drying, or blending. 

Pilot Scale: The manufacture of an API on a reduced scale by processes representative of and

simulating those to be applied on a larger commercial manufacturing scale. 

Polymorphism: The occurrence of different crystalline forms of the same API. 

Potential Impurity: An impurity that, from theoretical considerations, may arise from or during

manufacture. It may or may not actually appear in the API. 
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Primary Reference Standard: A particular portion, lot or batch of an API or intermediate that

has been shown by an extensive set of analytical tests to be of the highest purity. This standard

may be purchased from a recognized source or may be prepared by independent synthesis or by

further purification of existing production material.

Process Validation: Establishing documented evidence that provides a high degree of assurance

that a specific process will consistently produce a product meeting its predetermined

specifications and quality characteristics.

Prospective Validation: Establishing documented evidence that a system does what it purports

to do prior to the commercial distribution of a new API or an existing API made by a new or

modified process. 

Purification Procedure: A process, such as crystallization, distillation, or chromatography,

intended to improve the purity of an API or intermediate.

Qualification: The action of proving that any equipment or process works correctly and

consistently and produces the expected results. Qualification is part of, but not limited to, a

validation process, i.e., installation qualification (IQ), operation qualification (OQ), and

performance qualification (PQ). 

Quality Assurance: The sum total of the organized activities performed with the intent to

ensure that all APIs are of the quality required for their intended use. 

Quality Control Unit: Any person or organizational element designated by the firm to be

responsible for the duties relating to quality control. 

Quarantine: The status of materials isolated physically or by other effective means pending a

decision on their subsequent use. 

Range for Critical Process Parameter: The range for each process parameter generally

developed on laboratory-, pilot-, or plant-scale batches that encompasses values that are capable

of producing intermediates and APIs having acceptable quality attributes. 

Raw material: Any ingredient intended for use in the production of APIs. These may include

starting materials, process aids, solvents, and reagents. 

Reagent: A substance, other than a starting material or solvent, that is used in the manufacture

of an API or intermediate. 
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Recovery: Any treatment of materials by a process intended to make them suitable for further

use. 

Repeating a Chemical Reaction: Adding fresh reagents or solvents to unreacted or base

material and repeating a chemical reaction from its beginning. This excludes those situations

where a chemical reaction is continued or extended in the same vessel with the addition of more

solvent, to ensure completion of a reaction or increase the yield and/or purity of the API (e.g.,

continuation of a hydrogenation step). 

Reprocessing: Introducing an intermediate or API that does not conform to standards or

specifications, back into the process and repeating one or more steps that are part of the

established manufacturing process (e.g., recrystallization using the same solvent). 

Retest Date: The date when the API should be re-examined to ensure that it is still suitable for

use. 

Retest Period: The period of time during which the API can be considered to remain within

specifications, and therefore acceptable for use in the manufacture of a given drug product,

provided that it has been stored under defined conditions. After this period, the API should be

retested for compliance with specifications before use. 

Retrospective Validation: Establishing documented evidence that a system does what it

purports to do based on a review and analysis of historic information. It is normally conducted on

an API already being commercially distributed and is based on accumulated production, testing,

and control data. 

Reworking: Subjecting an intermediate or API that does not conform to standards or

specifications, to one or more processing steps that are different from the established

manufacturing process (e.g., recrystallizing with a different solvent). 

Solvent: Any liquid used as a vehicle for the preparation of solutions or suspensions in the

synthesis of an API or intermediate. 

Starting Material: A material used in the synthesis of an API, which is incorporated as an

element into the structure of an intermediate and/or of the API. Starting materials are normally

commercially available and of defined chemical and physical properties and structure. 

Theoretical Yield: The quantity that would be produced at any appropriate phase of

manufacture, processing, or packing of a particular API or intermediate, based upon the quantity

of components to be used, in the absence of any loss or error in actual production. 

Toxic Impurity: Impurities having significant undesirable biological activity. 
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Unidentified Impurity: An impurity that is defined solely by qualitative analytical properties

(e.g., chromatographic retention time). 

Validation Protocol: A written plan stating how validation will be conducted and identifying

specific acceptance criteria. For example, the protocol for a typical manufacturing process

identifies processing equipment, critical process parameters/operating ranges, product

characteristics, sampling and test data to be collected, number of validation runs, and acceptable

test results. 

Working Standard: An API, intermediate or other substance of established quality and purity,

as shown by comparison to a primary reference standard, used as a reference for routine

laboratory analysis.