The potential for
N
-nitrosamine impurities in
pharmaceutical products presents a challenge for the quality management
of medicinal products.
N
-Nitrosamines are considered
cohort-of-concern compounds due to the potent carcinogenicity of many
of the structurally simple chemicals within this structural class.
In the past 2 years, a number of drug products containing certain
active pharmaceutical ingredients have been withdrawn or recalled
from the market due to the presence of carcinogenic low-molecular-weight
N
,
N
-dialkylnitrosamine impurities. Regulatory
authorities have issued guidance to market authorization holders to
review all commercial drug substances/products for the potential risk
of
N
-nitrosamine impurities, and in cases where a
significant risk of
N
-nitrosamine impurity is identified,
analytical confirmatory testing is required. A key factor to consider
prior to analytical testing is the estimation of the daily acceptable
intake (AI) of the
N
-nitrosamine impurity. A significant
proportion of
N
-nitrosamine drug product impurities
are unique/complex structures for which the development of low-level
analytical methods is challenging. Moreover, these unique/complex
impurities may be less potent carcinogens compared to simple nitrosamines.
In the present work, our objective was to derive AIs for a large number
of complex
N
-nitrosamines without carcinogenicity
data that were identified as potential low-level impurities. The impurities
were first cataloged and grouped according to common structural features,
with a total of 13 groups defined with distinct structural features.
Subsequently, carcinogenicity data were reviewed for structurally
related
N
-nitrosamines relevant to each of the 13
structural groups and group AIs were derived conservatively based
on the most potent
N
-nitrosamine within each group.
The 13 structural group AIs were used as the basis for assigning AIs
to each of the structurally related complex
N
-nitrosamine
impurities. The AIs of several
N
-nitrosamine groups
were found to be considerably higher than those for the simple
N
,
N
-dialkylnitrosamines, which translates
to commensurately higher analytical method detection limits.