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Setting limits based on toxicity data?<br />

NOVARTIS<br />

Toxic residual solvents/heavy metal catalysts limits are described in ICH<br />

or CPMP guidances (or draft guidance)<br />

However, there are extensive discussions in the quality and safety<br />

community on what are suitable/acceptable limits e.g. for genotoxins<br />

‣ Few compounds are sufficiently experimentally characterized (e.g. in rodent<br />

carcinogenicity studies) to do a reliable risk assessment<br />

‣ The draft position paper from the CPMP Safety Working Party is not very<br />

clear on this issue<br />

‣ Extensive comments via EFPIA and PhRMA have been submitted<br />

‣ It appears that the EFPIA proposal to adopt the concept of a “Threshold of<br />

Toxicological Concern (TTC) as applied in the food contact substances area<br />

may be acceptable to the CPMP<br />

‣ TTC lies at 1.5ug/day for lifetime exposure<br />

(exceptions: very potent carcinogens such as a few nitrosamines)<br />

‣ Proposed ICH topic?<br />

L. Müller, Swissmedic, 21-Oct-2003

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