SUMMARY MINUTES

of the

BRITISH PHARMACOPOEIA COMMISSION

A meeting of the British Pharmacopoeia Commission was held at 10 South Colonnade, Canary
Wharf, London E14 4PU on Tuesday 12th March 2019.

Present: Professor K Taylor (Chair), Professor A G Davidson (Vice-Chair), Professor M Almond,

Dr J Beaman, Dr A M Brady, Dr G Cook, Dr A Gleadle (lay member), Dr M G Lee, Mr R Lowe,
Professor J Miller, Ms S Palser (lay member) and Dr R Torano.

In attendance: Mr J Pound (Secretary & Scientific Director), Dr F J Swanson.

Apologies for absence were received from Professor M Simmonds and Dr P Varley.

Also present: Ms H Ashraf, Ms N Clothier, Ms H Corns, Mr P Crowley, Mr A Evans, Mr A Gibb,

Ms S Gomersal, Mr H Makwana, Mr S Maddocks (am only), Mr M Whaley (am only) and
Mr S Young. Mr I King (Policy Division), Ms E Razzano (Licensing) and Mr D Deutsch (Licensing)
attended the meeting for the items recorded under minutes 276, 279 and 293 respectively.

273 Introductory Remarks

Welcome The Chair welcomed members to the meeting. He also welcomed Ms Hina
Ashraf who had recently joined the Secretariat and was attending her first meeting.

Staff Ms May-Louise Wall and Dr Catherine Lenihan had recently left the Secretariat and
Dr Alice Gardiner would shortly be transferring within the MHRA. Dr Gary Kemp had been
temporarily promoted to the post of Publications Manager.

Declaration of Interests; Confidentiality of Proceedings Members were reminded of

the need to inform the Secretariat of any changes to their interests throughout the year and
of the need to declare any specific interests at the start of relevant discussions during the
meeting. The Chair reminded members of the confidential nature of the meeting and that
the papers should not be disclosed.

I MINUTES

274 The minutes of the meeting held on 12th November 2018 were confirmed.

II MATTERS ARISING FROM THE MINUTES

275 The following matters arising from the meeting held on 12th November 2018 were noted.

Minute 249 – Dissolution Testing in the BP: Update The response to the BP
consultation had been published on the BP website in February.

Minute 262 – Expert Advisory Group MC2: Medicinal Chemicals Professor Davidson
had submitted proposals relating to several issues raised within the April 2018 MC2
Minutes and the intention was to include these items on the agenda for the July meeting.

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III REPORTS AND CORRESPONDENCE

GOVERNANCE

276 Brexit

An update on how the MHRA was preparing to deal with the outcome of the UK decision to
leave the European Union was provided.

277 Update from the Secretary and Scientific Director: Operational Transformation

Mr Pound provided an update on activities associated with the Medicines and Healthcare
products Regulatory Agency’s Operational Transformation programme.

OPERATIONAL

278 Innovation Board: Update COM(19)1

An update on the activities of the Innovation Board was provided for information.

Background The joint BP-TSO Innovation Board had been established in August 2018
with the aim of providing improvements to the BP brand through a combination of increased
revenue, customer satisfaction or increased efficiencies.

User Research A company had been commissioned to carry out an extensive review of
BP users, including finding out who uses the BP products, together with how and why they
use them. The research would also be used to identify areas for improvement to help meet
the needs of current and future users.

Innovation Board Outputs A number of proposals had already been approved by the
Innovation Board, including improvements to the website registration page to capture
additional information on users and the inclusion of CAS Registry numbers in the BPCRS
catalogue.

BP User Guide A guide on how to use the BP had been prepared and would shortly be
included on the website. The guide provided general information on BP requirements, on
navigating through the whole publication and on how to interpret the various parts of a
monograph.

Track-changed monographs Following requests to highlight changes in revised

monographs the Secretariat had considered a number of options to indicate such changes.
In view of the complexity of the project it was expected that a simple system would first be
introduced with the possibility of including additional features as the project progressed.

279 AQbD Project Update COM(19)2

Introduction Members were provided with an update on the Analytical Quality by Design
(AQbD) feasibility study, which had been initiated in 2012. The project aimed to identify
whether Quality by Design concepts could be used to produce more robust and rugged
monographs, thereby potentially reducing the need for revisions due to analytical
deficiencies. The BP/MHRA feasibility study was unique in its practical evaluation of the
concept and the involvement of Licensing and Inspectorate colleagues.

Impact on Monograph Development The project had identified the differences in

approach for companies developing methods to control specific products and

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 pharmacopoeias which provided methods that were suitable for a range of products. The
Working Party had identified critical method parameters using various statistical tools of
analysis, such as the “fishbone diagram” and “Failure Mode Effect Analysis”. A multi-factor
approach had been adopted which had allowed the analysis of several factors at the same
time and provided a better understanding of how these factors individually and cumulatively
affected the performance of the method. It also reduced the number of samples for analysis
to a realistic and representative amount, whilst still providing a high level of assurance that
the eventual method chosen would be suitable for all formulations.

Impact on Monograph Description The Working Party had considered how best to
include AQbD concepts within a monograph and several approaches had been proposed.

Stakeholder Engagement Consultation with stakeholders regarding the implications of

applying AQbD principles to BP monographs would be carried out. It was intended to
launch the consultation in May, with a view to providing feedback to Commission at the
November meeting.

280 British Pharmacopoeia Laboratory COM(19)3

British Pharmacopoeia Laboratory Reports The list of reports concerning new and
revised monographs that had been prepared by the Laboratory since the November 2018
meeting was provided for information.

British Pharmacopoeia Chemical Reference Substances Tables providing information

on BPCRS up to the end of January 2019 were provided for information.

IV FUTURE PUBLICATIONS

281 British Pharmacopoeia 2020 Publications COM(19)4

BP 2020 The Secretariat was currently preparing text for inclusion in the British
Pharmacopoeia 2020 and the British Pharmacopoeia (Veterinary) 2020. All items included
in the 9th Edition of the European Pharmacopoeia, together with those from Supplements
9.1 to 9.8, would be incorporated in either the BP 2020 or the BP (Vet) 2020, as
appropriate. The 2020 publications would be published in August and would come into
effect on 1st January 2020.

Electronic updates The text from Supplement 9.6 to the Ph Eur 9th Edition had been
added to the online BP in December 2018, in advance of its implementation on 1st January
2019. The text from Supplements 9.7 and 9.8 would be available in advance of their
implementation dates on 1st April and 1st July 2019 respectively.

Text for approval The first batch of new and technically revised monographs for the BP
2020 publications had been reviewed by members during February. The final batch of text
would be posted on the Document Review Tool (DRT) on 5th April, with a deadline for
comment of 23rd April.

Preliminaries Members recommended that the British Pharmacopoeia 2020 and the
British Pharmacopoeia (Veterinary) 2020 should be published and confirmed that the draft
Prefaces to both publications were acceptable.

Technical/Editorial Changes In addition to the changes arising through EAG discussions,

the following changes would also be made in the BP 2020: (i) with the exception of those
monographs that would be revised in either the BP 2021 or the BP 2022, the title of
monographs containing split standard terms would be updated as previously agreed;

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 (ii) minor editorial changes would be made to the opening statements of all monographs for
unlicensed formulations.

282 Monographs for Omission from the BP 2020 and BP (Vet) 2020 COM(19)5

BP 2020; BP (Vet) 2020 Since publication of the BP 2019 publications, a number of

monographs had been identified as candidates for omission from the BP 2020 publications.

In accordance with usual practice, the Secretariat would contact countries in which the BP
was used to ascertain if the products were still available/used before finalising the list and
the list would be included on the BP website for public comment. Members endorsed the
recommendation to omit the identified monographs from the BP 2020 and the BP (Vet)
2020, subject to any comments received. In accordance with regulation 252 (2c) of the
Human Medicines Regulations 2012, these monographs would continue to remain in force.

Review; Guiding Principles Several monographs were usually omitted from new editions
of the BP and the BP (Vet). These were generally identified through the day to day work of
the Expert Advisory Groups, as the Secretariat became aware of items that were no longer
licensed and as a consequence of suppression of Ph Eur monographs. The monographs
for omission were currently identified on an ad-hoc basis, there was no formal review
process.

It was intended to carry out a systematic review of the whole monograph portfolio. Several
EAGs had already carried out a review of certain of their monographs.The intention was for
this review to be applied more widely in the future and a series of draft principles had been
developed to help guide decisions and ensure a consistent approach is taken across the
various EAGs.

Members supported the development of a set of principles on which to base future

decisions.

283 Approved Synonyms COM(19)6

New monographs The proposed new Approved Synonyms relating to items added to the
European Pharmacopoeia by means of Supplements 9.7 and 9.8 to the 9th Edition were
approved. The items would be added to Appendices XXI B and XXI B (Vet) by means of
the BP 2020 and would be incorporated within the online updates to the BP 2019
publications.

Title changes The titles of eight monographs had been changed in Supplements 9.7 and
9.8, mostly to indicate the degree of hydration, and these changes would be reflected in the
BP 2020. In accordance with established policy the former titles would be retained as
subsidiary titles, which had the same legal weight as the main title, and the definitions of
relevant formulation monographs would be amended to reflect the new titles.

British Approved Names As a consequence of additions to the Ph Eur, the following

changes would be made in a future BAN publication: Esomeprazole Sodium and Nilotinib
Hydrochloride would be added as new BAN (Modified) to the entries for Esomeprazole and
Nilotinib respectively.

284 British Approved Names 2017: Supplement No. 3 COM(19)7

Supplement No. 3 to British Approved Names 2017, containing 35 new names, had been
prepared and a copy was provided for confirmation. The text had been agreed by the
Expert Advisory Group on Nomenclature and had been sent to manufacturers for comment.

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 All the entries were either recommended International Nonproprietary Names (rINN) which
had UK product licences or were Ph Eur monograph titles which had previously been
approved for inclusion in the list of BANs. Members were invited to examine the draft text
and to send any comments to the Secretariat by 26th March.

Liposomal products The draft Supplement included three modified entries relating to
liposomal forms of Amphotericin, Daunorubicin and Doxorbubicin. Members were informed
that products prepared using active pharmaceutical ingredients encapsulated with
liposomes released the drug substance over a longer time than conventional-release
formulations of the same strength. This could lead to a patient receiving a fatal dose of a
particular drug if the wrong formulation was administered. This matter had been discussed
at the recent EAG NOM meeting when it had been agreed that distinctive names for
liposomal and non-liposomal forms were required to distinguish between the two forms.
Members endorsed the recommendations to add the following BANM in the Supplement:
Liposomal Amphotericin B; Liposomal Daunorubicin Hydrochloride; Liposomal Doxorubicin
Hydrochloride; Pegylated Liposomal Doxorubicin Hydrochloride.

285 Monograph Initiation: Candidate Monographs COM(19)8

EAG Recommendations A number of monographs had been identified for addition to the
BP work programme through routine EAG activities. These related to formulations
associated with new Ph Eur drug substance monographs or to potential family
monographs. Members endorsed the addition of the identified items to the work
programme.

2017 PCA Prescribing Data The Secretariat had examined the 500 most prescribed items
in the 2017 Prescription Cost Analysis data prepared by NHS Digital. A number of items
had been identified as potential candidate monographs and it was agreed that these should
all be added to the work programme.

Candidate drug substance monographs A number of drug substances had been

identified for which over 500,000 items had been prescribed, but which were not the subject
of a current monograph and were not included on the Ph Eur work programme. It was
agreed that the Secretariat should first contact manufacturers to ascertain if they would be
willing to provide data to support development of a Ph Eur monograph before any requests
for additions to the work programme were submitted.

V ANALYTICAL ISSUES

NONE.

VI EXPERT ADVISORY GROUPS / PANELS OF EXPERTS

286 Expert Advisory Groups, Panels of Experts and Working Parties COM(19)9

Following the membership review, letters of invitation had been sent to all new and
re-appointed members and letters of thanks had been sent to those who had retired from
the various Expert Advisory Groups and Panels of Experts.

Expert Advisory Group ABS: Antibiotics There had been an outstanding vacancy on
EAG ABS for a member with expertise in the field of veterinary medicine. Dr Gillian Clarke
(Acting Head of Pharmaceuticals, Veterinary Medicines Directorate) had been identified as
a suitable candidate member and she had attended the recent meeting of EAG ABS as an
invited expert. The appointment was supported by the Chair and Vice-Chair of EAG ABS

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 and further justification had been provided in the meeting papers. Members endorsed the
appointment of Dr Clarke to EAG ABS.

Working Party AQbD: Analytical Quality by Design The need for additional expertise on
the Working Party had been identified and Dr Phil Borman (Director of QbD Development
for Small Molecules, GlaxoSmithKline) had been proposed as a suitable member. His
appointment was supported by the Chair of WP AQbD and justification had been provided.
Members endorsed the appointment of Dr Borman to WP AQbD.

287 Expert Advisory Group ABS: Antibiotics COM(19)10

The report of the EAG ABS meeting (27:9:18) was approved.

288 Expert Advisory Group MC3: Medicinal Chemicals COM(19)11

The report of the EAG MC3 meeting (8:10:18) was approved and the following points were
raised.

Amitriptyline Preparations; Related substances It was noted that the approach for
naming impurities should be in accordance with recommendations in the Style Guide.

Rotigotine Transdermal Patches; Uniformity of content It was questioned whether a

method which included a symmetry factor requirement of “between 0.8 and 2.8” was
suitable. The Laboratory would be asked to confirm the suitability of the requirements
during the work to establish the corresponding BPCRS.

289 Expert Advisory Group ULM: Unlicensed Medicines COM(19)12

The report of the EAG ULM meeting (15:10:18) was approved and the following points
were raised.

Sterility of Extemporaneous Preparations The General Monograph on Unlicensed

Medicines would be amended in the BP 2020 to reflect that alternative approaches to the
sterility test might be required since it would be impossible to carry out the pharmacopoeial
test on extemporaneously prepared preparations which were available in limited amounts.

University Collaboration; Validation of Analytical Procedures Further work was being

undertaken by students with a view to supporting monograph development and the
Secretariat had provided some guidance to assist with future projects.

290 Expert Advisory Group MC2: Medicinal Chemicals COM(19)13

The report of the EAG MC2 meeting (24:10:18) was approved and the following points
were raised.

Clenbuterol Oral Solution An identification test using a liquid chromatographic method

with UV-Diode Array Detection had been proposed and accepted. Methods using LC/UV-
DAD had not yet been included within the BP but were under discussion by the ad-hoc
group on New Analytical Technologies.

291 Expert Advisory Group HCM: Herbal and Complementary COM(19)14

Medicines

The report of the EAG HCM meeting (22:11:18) was approved and the following points
were raised.

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 Herbal Photographs The EAG had agreed that it would be useful to include photographs
illustrating characteristic microscopic and macroscopic features of herbal materials in a
future publication.

Cannabis The current position was that there was no immediate requirement to develop a
national monograph for Cannabis (either the herbal material or products).

292 Expert Advisory Group MC1: Medicinal Chemicals COM(19)15

The report of the EAG MC1 meeting (5:12:18) was approved and the following point was
raised.

Busulfan Preparations The Laboratory no longer had an electron capture detector, which
was specified in the current monograph for Busulfan Tablets and a number of other
monographs. However, it was noted that the Laboratory could use the detector owned by
the MHRA Laboratory if testing was required.

VII EUROPEAN PHARMACOPOEIA

293 European Pharmacopoeia Update COM(19)16

European Pharmacopoeia Commission The draft report of the 162nd Session of the EP
Commission (November 2018) was available on the forum section of the BP website. The
163rd Session would be held between 19th and 20th March.

Members discussed items from the 162nd Session and items for the forthcoming March
Session and advised the UK delegation accordingly.

10th Edition of the European Pharmacopoeia An international conference had been

organised by the EDQM to celebrate the forthcoming publication of the 10th Edition of the
European Pharmacopoeia and the 25th anniversary of the establishment of the OMCL
network and the Certification procedure.

Questionnaires sent to the UK National Authority A list of the recent questionnaires

relating to proposals to add items to or remove items from the Ph Eur work programme was
presented for information.

VIII INTERNATIONAL COLLABORATION

294 International Update COM(19)17

Members were provided with an update on international activities.

United States Pharmacopeia A teleconference had been held in February to discuss:

future monograph collaborations; progress on the Memorandum of Understanding (MOU)
between the two organisations; future issues for consideration at the International Meetings
of World Pharmacopoeias. The MOU was now ready to be signed by both parties.

Commonwealth Standards Network (CSN) Mr Pound and Mr Evans had participated in

a teleconference in January with representatives from the British Standards Institution (BSI)
to discuss the BSI project to increase the understanding and provision of standards within
Commonwealth countries. The BP/MHRA had been invited to liaise with BSI to include
medicinal standards required within the UK on their website in order to generate a wider
understanding.

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 Chinese National Medical Products Administration (NMPA) A delegation from the
MHRA, including Dr Samantha Atkinson, had attended the NMPA Symposium in Beijing in
November 2018. This had included a break out session on pharmacopoeias and
discussions on potential collaborations between the BP/MHRA and the Chinese
Pharmacopoeia.

10th International Meeting of World Pharmacopoeias Mr Pound and Mr Gibb had

attended the 10th IMWP meeting in March, held in Geneva. The main topic of discussion
had been the draft White Paper on the Value of Pharmacopoeial Standards, which
focussed on the contribution of such standards to the protection of public health and was
aimed at all stakeholders across the globe.

IX REPORTS OF THE SECRETARY AND SCIENTIFIC DIRECTOR

See under minute 277.

X ANY OTHER BUSINESS

295 BPC Appraisals

Annual appraisals for members of the BP Commission would be carried out in May.

296 Date of next meeting

Monday 1st July 2019.

FOR INFORMATION:

297 Items for Future Meetings

An updated list of items for discussion at future meetings was provided for information. It
was agreed that an entry for annual updates to the BP work programme should be added
to the list. Further updated lists would be provided at future meetings.