Regulatory Open Forum

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  • 1.  Mixing API lots for clinical batch manufacturing

    Posted 11-Jan-2023 11:51
    Hello Everyone,

    Our company is looking to manufacture a clinical lot for a study to be conducted in EU.
    I would like to confirm, if we can mix two API lots (same supplier, same specs but one is the leftover from the previous campaign and the other half from the newly purchased lot) to produce one FDF lot?

    Thank you )

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    Valeria
    Canada
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  • 2.  RE: Mixing API lots for clinical batch manufacturing

    Posted 11-Jan-2023 14:02
    Hi Valeria,

    Yes you can use two API lots to manufacture one DP lot. You might have to clearly say this in Module 3 sections (e.g. 3.2.P.5.4, 3.2.P.8.3 etc.)

    Best Regards,



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    Saifulla Khan
    Regulatory Affairs Manager
    Wilmington NC
    United States
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  • 3.  RE: Mixing API lots for clinical batch manufacturing

    Posted 12-Jan-2023 09:43
    I typically include a table at the end of 32P54 that lists all the DP lots and the API lots that were used to manufacture each DP lot.

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    Tom Stothoff
    Senior Director, Regulatory Affairs CMC
    Chicago
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  • 4.  RE: Mixing API lots for clinical batch manufacturing

    Posted 12-Jan-2023 10:18

    It is generally acceptable to mix two API lots from the same supplier and with the same specifications in order to produce a single FDF (finished drug product) lot, as long as the mixing process is controlled and validated. However, the regulatory authorities in the EU have the final say on whether this is acceptable for your specific product and study.

    It is important to ensure that the two lots are compatible and that the mixing process does not affect the quality or safety of the final product. You should also consult your company's standard operating procedures (SOPs) and any relevant guidelines from regulatory authorities to ensure that you are following the appropriate processes and regulations.

    Additionally, you should inform the regulatory authorities and the ethics committee in charge of the study, regarding the mix of the two lots, and provide them with the justification and validation of the mixing process.

    It is also recommended that you retain samples of each lot before and after mixing, in case a future investigation is required.



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    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
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