Bruce D. Naumann

A Human Health Risk Assessment of Pharmaceuticals in the Aquatic Environment

Analyses were conducted on four pharmaceutical compounds, representing different therapeutic classes, to evaluate the presence and potential adverse human health effects of trace levels of these substances in aqueous environmental media. Acetylsalicylic acid, clofibrate, cyclophosphamide, and indomethacin have been detected in aqueous environmental media including sewage treatment plant effluent, surface water, drinking water, and groundwater. An extensive literature search and chemical-specific risk assessments were performed to assess the potential human health significance of each compounds individual presence in environmental media. Safe water quality limits were estimated for each pharmaceutical by following the USEPA Methodology for Deriving Ambient Water Quality Criteria for the Protection of Human Health and were compared to the concentrations found in the environment. The calculation of the provisional ambient water quality criteria involved estimation of human exposure to contaminated water, including intake via bioaccumulation in fish, and calculation of cancer risk and non-cancer hazard indices. Parameters detailing the toxicological and pharmacological nature, exposure assessment, and environmental fate and transport of each pharmaceutical were also considered. The overall conclusion was that based on available data, no appreciable risk to humans exists, as the detected concentrations of each of these pharmaceutical compounds found in aqueous media were far below the derived safe limits

Performance-Based Exposure Control Limits for Pharmaceutical Active Ingredients

For many years pharmaceutical companies have established employee exposure limits for the active ingredients used in their products. Historically these limits were derived using traditional risk assessment methods. Because the trend in the pharmaceutical industry is to identify and develop more selective drugs of increasing potency, and because of the difficulty in identifying no-effect levels for certain drugs, a new performance-based approach for setting limits was developed. This method involves assigning materials into one of five hazard categories according to their inherent toxicological and pharmacological properties. The criteria used to assign compounds into performance-based exposure control limit (PB-ECL) categories focus on the degree to which exposure impacts human health. These assignments dictate the level of containment required to assure employee safety that is achieved through the use of engineering controls and safe handling practices. Several matrices were developed to specify general design concepts and controls for unit operations in laboratory and manufacturing operations. Containment options range from conventional handling practices for low potency (PB-ECL Category 1) materials, to technologically advanced systems that result in essentially no open handling for potent or toxic (PB-ECL Category 3) materials, to state-of-the-art facilities employing closed processes and use of robotics for extremely potent (PB-ECL Category 5) materials.

Scientific basis for uncertainty factors used to establish occupational exposure limits for pharmaceutical active ingredients

Abstract The traditional “safety factor”; method has been used for years to establish occupational exposure limits (OELs) for active ingredients used in drugs. In the past, a single safety factor was used to address all sources of uncertainty in the limit setting process. The traditional 100‐fold safety factor commonly used to derive an acceptable daily intake value incorporates a default factor of 10 each to account for interindividual variability and interspecies extrapolation. Use of these defaults can lead to overly conservative health‐based limits, especially when they are combined with other (up to 10‐fold) factors to adjust for inadequacies in the available database. In recent years, attempts have been made to quantitate individual sources of uncertainty and variability to improve the scientific basis for OELs. In this paper we discuss the science supporting reductions in the traditional default uncertainty factors. A number of workplace‐specific factors also support reductions in these factors. Re...

Establishing Data-Derived Adjustment Factors from Published Pharmaceutical Clinical Trial Data

In non-cancer risk assessment the goal traditionally has been to protect the majority of people by setting limits that account for interindividual variability in the human population. The Environmental Protection Agency (EPA) has assigned a default uncertainty factor (?UF) of 10 to account for interindividual variability in response to toxic agents in the general population. Previous studies have suggested that it is appropriate to equally divide this factor into sub-factors of 3.2 each for variability in human pharmacokinetics (PK) and pharmacodynamics (PD). As an extension of this model, one can envision using scientific data from the literature to modify the default sub-factors with compound-specific adjustment factors (AFs) and to create new and more scientifically based defaults. In this paper, data from published clinical trials on six pharmaceutical compounds were used to further illustrate how to calculate and interpret data-derived AFs. The clinical trial data were analyzed for content and the re...

Case Studies of Categorical Data-Derived Adjustment Factors

Investigations were performed on representative compounds from five different therapeutic classes to evaluate the use of categorical data-derived adjustment factors to account for interindividual variability. The five classes included antidepressants, angiotensin converting enzyme (ACE) inhibitors, nonsteroidal anti-inflammatory drugs (NSAIDS), cholesterol lowering agents, and antibiotics. Each of the case studies summarized the mode of action of the class responsible for both the therapeutic and adverse effects and the key pharmacodynamic (PD) and pharmacokinetic (PK) parameters that determine the likelihood of these responses for individual compounds in the class. For each class, an attempt was made to identify the key factors that determine interindividual variability and whether there was a common basis to establish a categorical default adjustment factor that could be applied across the class (or at least across specific subclasses within the class). Linking the PK and PD parameters to the critical endpoint used to establish a safe level of exposure was an important underlying theme throughout the investigations. Despite the wealth of PK and PD information in the published literature on the surrogate compounds representing these classes, it was difficult to derive a categorical adjustment factor that could be applied broadly within each class. The amount of information available may have hindered rather than helped the evaluations. Derivation of categorical defaults for different classes of “common” chemicals may be more straightforward if sufficient data are available. In a few cases (e.g., tricyclic antibiotics, ACE inhibitors and selected antiinflammatory agents) categorical defaults could be proposed, although it is unclear whether the reduction in uncertainty resulting from their application would be offset by the additional uncertainties that may have resulted from their application. Residual uncertainties may remain depending on the level of confidence in the underlying assumptions used to support the categorical defaults. Regardless of the conclusions on the utility of categorical defaults, these investigations provided further support for the use of data-derived adjustment factors on a compound-specific basis.

The Scientific Basis of Uncertainty Factors Used in Setting Occupational Exposure Limits

The uncertainty factor concept is integrated into health risk assessments for all aspects of public health practice, including by most organizations that derive occupational exposure limits. The use of uncertainty factors is predicated on the assumption that a sufficient reduction in exposure from those at the boundary for the onset of adverse effects will yield a safe exposure level for at least the great majority of the exposed population, including vulnerable subgroups. There are differences in the application of the uncertainty factor approach among groups that conduct occupational assessments; however, there are common areas of uncertainty which are considered by all or nearly all occupational exposure limit-setting organizations. Five key uncertainties that are often examined include interspecies variability in response when extrapolating from animal studies to humans, response variability in humans, uncertainty in estimating a no-effect level from a dose where effects were observed, extrapolation from shorter duration studies to a full life-time exposure, and other insufficiencies in the overall health effects database indicating that the most sensitive adverse effect may not have been evaluated. In addition, a modifying factor is used by some organizations to account for other remaining uncertainties—typically related to exposure scenarios or accounting for the interplay among the five areas noted above. Consideration of uncertainties in occupational exposure limit derivation is a systematic process whereby the factors applied are not arbitrary, although they are mathematically imprecise. As the scientific basis for uncertainty factor application has improved, default uncertainty factors are now used only in the absence of chemical-specific data, and the trend is to replace them with chemical-specific adjustment factors whenever possible. The increased application of scientific data in the development of uncertainty factors for individual chemicals also has the benefit of increasing the transparency of occupational exposure limit derivation. Improved characterization of the scientific basis for uncertainty factors has led to increasing rigor and transparency in their application as part of the overall occupational exposure limit derivation process.

Use of toxicokinetic and toxicodynamic data to reduce uncertainties when setting occupational exposure limits for pharmaceuticals

Abstract Occupational exposure limits for pharmaceutical active ingredients should be based on all of the available preclinical and clinical data generated during drug development, including toxicokinetic (TK) and toxicodynamic (TD) data. The framework for limit setting proposed by the International Programme on Chemical Safety (IPCS) subdivides traditional 10‐fold uncertainty factors (UFs) into separate partial‐log default values based upon TK and TD considerations and allows for incorporation of compound‐specific data when available. We propose an extension of this method by providing more detailed guidance on the development and use of TK and TD data to maximize the use of scientific information in the limit setting process. Specific recommendations are made on how TK and TD parameters may be used to support replacement of default UFs with data‐derived values. Proper application of TK and TD data reduces the uncertainties when establishing limits for specific compounds and provides better assurance tha...

Toxicokinetic and toxicodynamic considerations when deriving health-based exposure limits for pharmaceuticals

The purpose of this paper is to describe the use of toxicokinetic (TK) and toxicodynamic (TD) data in setting acceptable daily exposure (ADE) values and occupational exposure limits (OELs). Use of TK data can provide a more robust exposure limit based on a rigorous evaluation of systemic internal dose. Bioavailability data assist in extrapolating across different routes of exposure to be protective for route-based differences of exposure. Bioaccumulation data enable extrapolation to chronic exposures when the point of departure (PoD) is from a short-term critical study. Applied in the context of chemical-specific adjustment factors (CSAFs), TK data partially replace traditional default adjustment factors for interspecies extrapolation (extrapolation from studies conducted in animals to humans) and intraspecies variability (to account for human population variability). Default adjustments of 10-fold each for interspecies and intraspecies extrapolation are recommended in several guidelines, although some organization recommend other values. Such default factors may overestimate variability for many APIs, while not being sufficiently protective for variability with other APIs. For this reason, the use of chemical specific TK and TD data are preferred. Making full use of existing TK and TD data reduces underlying uncertainties, increases transparency, and ensures that resulting ADEs reflect the best available science.

The Importance of Human Data in the Establishment of Occupational Exposure Limits

The use of animal vs. human data for the purposes of establishing human risk was examined for four pharmaceutical compounds: acetylsalicylic acid, cyclophosphamide, indomethacin and clofibric acid. Literature searches were conducted to identify preclinical and clinical data useful for the derivation of acceptable daily intakes (ADIs) from which a number of risk values including occupational exposure limits (OELs) could be calculated. OELs were calculated using human data and then again using animal data exclusively. For two compounds, ASA and clofibric acid use of animal data alone led to higher OELs (not health protective), while for indomethacin and cyclophosphamide use of animal data resulted in the same or lower OELs based on human data alone. In each case arguments were made for why the use of human data was preferred. The results of the analysis support a basic principle of risk assessment that all available data be considered

A harmonization effort for acceptable daily exposure application to pharmaceutical manufacturing – Operational considerations

A European Union (EU) regulatory guideline came into effect for all new pharmaceutical products on June 1st, 2015, and for all existing pharmaceutical products on December 1st, 2015. This guideline centers around the use of the Acceptable Daily Exposure (ADE) [synonymous with the Permitted Daily Exposure (PDE)] and operational considerations associated with implementation are outlined here. The EU guidance states that all active pharmaceutical ingredients (API) require an ADE; however, other substances such as starting materials, process intermediates, and cleaning agents may benefit from an ADE. Problems in setting ADEs for these additional substances typically relate to toxicological data limitations precluding the ability to establish a formal ADE. Established methodologies such as occupational exposure limits or bands (OELs or OEBs) and the threshold of toxicological concern (TTC) can be used or adjusted for use as interim ADEs when only limited data are available and until a more formal ADE can be established. Once formal ADEs are derived, it is important that the documents are routinely updated and that these updates are communicated to appropriate stakeholders. Another key operational consideration related to data-poor substances includes the use of maximum daily dose (MDD) in setting cross-contamination limits. The MDD is an important part of the maximum allowable/safe concentration (MAC/MSC) calculation and there are important considerations for its use and definition. Finally, other considerations discussed include operational aspects of setting ADEs for pediatrics, considerations for large molecules, and risk management in shared facilities.