1、各国的法规仅针对于成品进行留样观察,同时ICH q7却没有针对于API留样观察的规定,但是最好进行留样观察;
2、中间体和起始物料是否留样在各国法规上均未有强行规定;
3、关于制剂成品的留样观察,在美国CGMP中有提及,从这个要求中,并不要求每批进行留样观察,但是基于怎样的acceptable statistical procedures需要考虑???(根号N+1???)
Except for those for drug products described in paragraph (b)(2) of this section, reserve samples from representative sample lots or batches selected by acceptable statistical procedures shall be examined visually at least once a year for evidence of deterioration unless visual examination would affect the integrity of the reserve sample. Any evidence of reserve sample deterioration shall be investigated in accordance with §211.192. The results of the examination shall be recorded and maintained with other stability data on the drug product. Reserve samples of compressed medical gases need not be retained. The retention time is as follows: (1) For a drug product other than those described in paragraphs (b) (2) and (3) of this section, the reserve sample shall be retained for 1 year after the expiration date of the drug product. (2) For a radioactive drug product, except for nonradioactive reagent kits, the reserve sample shall be retained for: (i) Three months after the expiration date of the drug product if the expiration dating period of the drug product is 30 days or less; or (ii) Six months after the expiration date of the drug product if the expiration dating period of the drug product is more than 30 days. (3) For an OTC drug product that is exempt for bearing an expiration date under §211.137, the reserve sample must be retained for 3 years after the lot or batch of drug product is distributed. |