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  • 1.  Shelf life extension

    This message was posted by a user wishing to remain anonymous
    Posted 16-Jun-2017 08:53
    This message was posted by a user wishing to remain anonymous

    How confident you are in shelf life extension of finished product in below scenario.

    Pdt has two approved API source. Existing expiry of finished product is 24 months.

    - Available finished product stability data (long term) with API A- 36 months

    - Available finished product stability data  (long term) with API B- 12 months

    If extension seems feasible, What category it could fall for Europe and US?



  • 2.  RE: Shelf life extension

    Posted 17-Jun-2017 08:04
    Hi,

    'How confident' - Review all available stability data

    US - AR (3 commercial batches)
    EU - IB (at least 2 pilot scale batch)

    Best Regards,

    ------------------------------
    Tyng-Yi (Tina) Lee MS RAC
    Consultant
    North Brunswick NJ
    United States of America
    ------------------------------



  • 3.  RE: Shelf life extension

    Posted 18-Jun-2017 01:39
    ​Hi,

    Review FP 36 months long term stability data with API A. Confirm all results meet comfortably shelf life specifications.

    For batches manufactured with API B, compare trend of stability results (Accelerated & Long term) between batches manufactured with API A and API B. If trend is found similar/ equivalent, please include this rational in 32p81 and go for 36 months proposed shelf life with commitment that long term stability data will be provided in next AR.

    Hope this helps!

    Regards,
    Akash Dave

    ------------------------------
    AKASH DAVE
    Pfizer
    New York NY
    United States
    ------------------------------



  • 4.  RE: Shelf life extension

    Posted 18-Jun-2017 01:56
    ​Hi,

    Shelf life extension filling category;

    US
    - AR when protocol is already approved covering proposed shelf life stability time point in the application + 3 commercial batch long term stability data (manufactured with any API supplier + for remaining suppliers result trend need to be compared)
    - PAS when protocol covering proposed shelf life stability time point is approved + 3 pilot scale batch long term stability data
    - PAS when protocol covering proposed shelf life stability time point is not approved in application

    EU
    - Type 1B
    with long term stability studies (covering the entire shelf life) conducted on at least 2 pilot scale batches with a commitment to verify the shelf life on production scale batches.

    Kind Regards,
    Akash Dave

    ------------------------------
    AKASH DAVE
    Pfizer
    New York NY
    United States
    ------------------------------



  • 5.  RE: Shelf life extension

    This message was posted by a user wishing to remain anonymous
    Posted 19-Jun-2017 09:13
    This message was posted by a user wishing to remain anonymous

    Note that we do not have real time stability data for API B. To compare trend, we have to extrapolate and then compare the data. In Europe it can not go as type IB but Type II (based on extrapolation of data).





  • 6.  RE: Shelf life extension

    Posted 14-Sep-2023 04:07

    Dear Anonymous,

    Hope you are well and still around in this community.

    I am curious to know about outcome of this discussion.

    Please feel free to revert.



    ------------------------------
    SUJAN BOSE
    M.Pharm
    ------------------------------



  • 7.  RE: Shelf life extension

    This message was posted by a user wishing to remain anonymous
    Posted 14-Sep-2023 09:16
    This message was posted by a user wishing to remain anonymous

    Was the second API approved as part of original ANDA or post approval?

    For the API A, if the stability protocol in the ANDA was approved covering the proposed 36/48 etc. month expiry, then its AR.

    If the API B was approved post approval, then check the approval letter it probably said 24?




  • 8.  RE: Shelf life extension

    Posted 17-Sep-2023 22:32

    The second API was approved as a part of PAS.

    Yes, for API A, stability protocol was approved covering 36 months.

    In the approval letter for API B there is nothing written about shelf life.

    The API A has 36 months data and API B has 18 months (real time) data. We are planning for 36 months expiry for the both sources.

    Please advice.



    ------------------------------
    SUJAN BOSE
    M.Pharm
    ------------------------------



  • 9.  RE: Shelf life extension

    This message was posted by a user wishing to remain anonymous
    Posted 18-Sep-2023 09:04
    This message was posted by a user wishing to remain anonymous

    If the approval letter for API B via post approval PAS did not mention the expiry date it is assumed as 24 months similar to API A, then submit it in the AR for both API A and B to extend the expiry for DP to 36 months since the post approval stability protocol already covers till 36 months and API A has 36 month real time data.!