Usp NF 2023

Commentary
USP–NF 2023 Issue 1
November 1, 2022
In accordance with USP’s Rules and Procedures of the Council of Experts (“Rules”), and
except as provided in Section 9.02 Accelerated Revision Processes, USP publishes proposed
revisions to the United States Pharmacopeia and the National Formulary (USP–NF) for public
review and comment in the Pharmacopeial Forum (PF), USP’s free bimonthly journal for public
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proposals advance to official status, a summary of comments received and the appropriate
Expert Committee's responses, as well as Expert Committee-initiated changes, are published
in the Proposal Status/Commentary section of USPNF.com at the time the official revision is
published.
The Commentary is not part of the official text and is not intended to be enforceable by
regulatory authorities. Rather, it explains the basis of Expert Committees’ responses to public
comments on proposed revisions. If there is a difference or conflict between the contents of the
Commentary and the official text, the official text prevails.
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Commentary for USP–NF 2023, Issue 1

Comments were received for the following when they were proposed in Pharmacopeial
Forum:
General Chapters
<432> Determination of Zeta Potential by Electrophoretic Light Scattering
<1042> Cell Banking Practices for Recombinant Biologics
Monographs
Acetyltriethyl Citrate
Albuterol Tablets
Alginic Acid
Amphetamine Sulfate Tablets
Artemether
Atomoxetine Hydrochloride
Calcium Propionate
Carboplatin Injection
Carteolol Hydrochloride
Chlorthalidone
Chlorthalidone Tablets
Curcuminoids Capsules
Curcuminoids Tablets
Cyclophosphamide Capsules
Dextrates
Dextrose and Sodium Chloride Injection
Dutasteride and Tamsulosin Hydrochloride Capsules
Emtricitabine
Fosamprenair Calcium Tablets
Hydrogenated Polydextrose
Linezolid Tablets
Maltodextrin
Meclofenamate
Pamidronate Disodium for Injection
Polyvinyl Alcohol
Potassium Alginate
Quinapril and Hydrochlorothiazide Tablets
Risedronate Sodium Delayed-Release Tablets
Rivaroxaban Tablets
Sodium Alginate
Tinidazole Tablets
Trazodone Hydrochloride Tablets
Triethyl Citrate
Valacyclovir Hydrochloride
Valganciclovir Hydrochloride
Valsartan Tablets

No comments were received for the following proposals:
General Chapters
<126> Somatropin Bioidentity Test

<345> Assay for Citric Acid/Citrate and Phosphate
Monographs
Aloe
Bael Tree Fruit
Bael Tree Fruit Dry Extract
Bael Tree Fruit Powder
Bifidobacterium Animalis Subsp. Lactis
Cetyl Palmitate
Conjugated Linoleic Acids-Free Fatty Acids
Demeclocycline
Lindane Lotion
Manganese Sulfate Injection
Polypropylene Glycol 11 Stearyl Ether
Sugar Spheres
General Chapters
General Chapter: <432> Determination of Zeta Potential By Electrophoretic

Light Scattering
Expert Committee: General Chapters—Physical Analysis
No. of Commenters: 1
Development of the Method
Comment Summary #1: The commenter, referring to the use of term “micelle” in the
“Determination of the Concentration Range” and “Method Validation” sub-sections suggested
replacing that term with the term “particles.”
Response: Comment partially incorporated. The expert committee decided to replace the term
“micelles” with the term “colloidal particles,” stating that the term “colloidal particles” more
closely represents the physical reality of the subject probed by the scattering of light in the zeta
potential measurement test.
General Chapters: <1042> Cell Banking Practices for Recombinant Biologics

Expert Committee: Biologics Monographs 2-Proteins
General Comments

Comment Summary #1: The commenter recommended to indicate whether any particular
statements are based on the CFR, FDA, or other guidelines, or if they represent solely the USP
vision. References and clarifications should be provided in the text.
Response: Comment incorporated. References have been added to the reference list.
Comment Summary #2: The commenter suggested that key terms and definitions should be
based on 21 CFR 600.3, FDA, WHO, and ICH guidance documents, and definitions should be
added to the Glossary with references.
Response: Comment partially incorporated. Wherever possible, key terms in the Glossary were
defined and referenced in accordance with established standards. There were also other terms
used in the chapter that required definition, and therefore the USP Cell Banking Expert Panel
and the BIO2-Proteins Expert Committee has defined the terms.
Comment Summary #3: The commenter recommended organizing the chapter in a more
concise format, eliminating unnecessary repetitions in the text and figures.
Response: Comment incorporated. Several edits have been made to the chapter and figures to
reduce repetition and enhance flow.
Comment Summary #4: The commenter suggested to separate information on mammalian
and bacterial cell lines.
Response: Comment partially incorporated. Information on bacterial and mammalian cell lines
has been separated, except in areas where there are commonalities to avoid repetition.
Comment Summary #5: The commenter suggested to remove the phrase “common practice”
or adequately justify the use of the phrase.
Response: Comment partially incorporated. Most uses of “common practice” have been
removed from the chapter. The remaining uses of “commonly used or common practice” are
justified in the associated text when used in the chapter.
Comment Summary #6: The commenter suggested postponing publishing of USP chapter
<1042> because ICHQ5A is cited several times, and several of the requirements are based on
ICHQ5A, which is undergoing revision.
Response: Comment not incorporated. The timeline for revision and adoption of new version of
ICHQ5A is unknown, and <1042> can be revised if the chapter has different requirements than
the revised ICHQ5A. A statement has been added to the chapter to indicate that the chapter is
consistent with current, R1, ICH Q5A. The chapter can be revised if needed when the revised
version of ICH Q5A becomes official.
Comment Summary #7: The commenter suggested to align the phrase “recombinant biologics”
used in the title and the phrase “biological drug product/biological product” used in the chapter.
Response: Comment incorporated. The definition of recombinant biologic was added to the
Glossary to clarify this term.
Comment Summary #8: The commenter suggested to insert bacterial seed in scope of chapter
<1042> because USP chapter <1238> refers to <1042> for information on bacterial seeds.
Response: Comment partially incorporated. USP will remove reference to <1042> from
<1238>.
Comment Summary #9: The commenter suggested to cite ICH Q5A in Tables 3 and 4 instead
of repeating content that may change in the update of ICH Q5A.
Response: Comment partially incorporated. A footnote was added that states, “For more
information see current version of ICHQ5A. ICHQ5A is under revision during development of
this chapter. The table is aligned with the current R1 version of ICHQ5A.”
Comment Summary #10: The commenter suggested to add guidance where the repetition for
LIVCA (limit of in vitro age) studies are considered necessary.
Response: Comment not incorporated as there is adequate information in the chapter about
when the testing of LIVCA may be necessary.
Introduction

Comment Summary #11: The commenter requested that the risk factors for cell line banking
be revised in accordance with 21 CFR 610.18 and FDA/ICH guidelines as the list of risk factors
is too broad.
Response: Comment partially incorporated. The intent of the list of risk factors was to provide
broad summary information, so the list of risk factors was not revised, but guidances have been
referenced, so users of the chapter can find the specific information. The following statement
was added after the bulleted list: “See ICH and appropriate FDA guidelines for more specific
information.”
Comment Summary #12: The commenter proposed to omit “process validation” as a quality
risk factor.
Response: Comment not incorporated. The intent of the list of risk factors was to provide broad
summary information. It is beneficial to consider process validation as a risk factor as material or
samples may need to be set aside.
Scope
Comment Summary #13: The commenter suggested changing the text, “manufacturing drug
substances for clinical and commercial applications” to “drug substances for commercial
applications” in the sentence: “Each GMP cell bank should be tested and characterized to
satisfy quality standards for identity, purity, and genetic stability and ensured to be free from
adventitious contaminants for use in manufacturing drug substances for clinical and commercial
applications.”
Response: Comment incorporated. The text was changed to “drug substances for commercial
applications” as the commenter suggested in the above sentence.
Comment Summary #14: The commenter suggested deleting “patient bank” from the following
sentence: “During the development phases, the bank can be released before it is fully tested to
start drug substance manufacturing; however, the bank has to be fully tested for safety (identity,
purity, free from adventitious contaminants) prior to a drug substance's release for patient bank
clinical applications.”
Response: Comment incorporated. The term “patient bank” was deleted.
Comment Summary #15: The commenter suggested requirements for genetic stability should
be considered, as appropriate, prior to commercial application.
Response: Comment not incorporated. Describing when genetic characterization, including
genetic stability should not be specifically outlined in the chapter, as this testing may need a
flexible approach.
Comment Summary #16: For clarification, the commenter suggested to add the words
“conditionally and at risk to the following sentence: “The bank can be conditionally released, at
risk, before it is fully tested to start drug substance manufacturing.”
Response: Comment incorporated. The words “conditionally” and “at risk” were added to the
sentence: “The bank can be conditionally released, at risk, before it is fully tested to start drug
substance manufacturing.”
Comment Summary #17: The commenter suggested to add the term “patient bank” to the
Glossary.
Response: Comment not incorporated. The term “patient bank” was removed from the
sentence: “The bank can be released before it is fully tested to start drug substance
manufacturing; however, the bank has to be fully tested, especially for safety prior to a drug
substance's release for patient bank clinical applications.”
General Processes and Considerations of Cell Banking

Comment Summary #18: The commenter suggested to clarify in the text that replacement
Working Cell Banks (WCBs) are produced to ensure continuity of drug substance supply and
replenishment of WCB is based on use, not necessarily when the biologic is approved.
Response: Comment incorporated. The text will be changed to, “To ensure a consistent supply,
it is generally recommended that additional replacement WCBs be produced, as needed, once a
biologic is approved for marketing.” To clarify that the replacement of WCBs is when needed
and not necessarily when the product is approved.
Comment Summary #19: The commenter recommends mentioning the stability in the list of
criteria for replacement WCBs.
Response: Comment not incorporated. Storage stability is listed under Replacement Working
Cell Bank in Figure 2, so additional text is not needed.
Comment Summary #20: The commenter requested to include where the source, origin,
generation, propagation, and selection of the cell line should be documented.
Response: Comment not incorporated. The chapter’s objectives include best documentation
practices, but specifying where to document the information is outside these objectives.
Comment Summary #21: The commenter recommended to clarify or refer to the purity testing
for pmRCB to ensure completeness of guidance.
Response: Comment not incorporated. Purity testing of the pmRCB is discussed later in the
chapter.
Comment Summary #22: Several commenters suggested to move the bar at the right side of
Figure 1 that indicates the use of Good Manufacturing Process to start at “culture premaster
research cell bank (pmRCB) into Master cell bank (MCB)”. One commenter also suggested to
revise Figure 1 and 2 to ensure consistency between the text and the figures.
Response: Comment incorporated. In Figure 1, the bar that indicates the use of Good
Manufacturing Processes was moved to start at the fifth box down from the top, "Culture
premaster research bank (pmRCB) into Master cell bank (MCB), growth characteristics, media,
raw material qualification, cell density, viability and process development.” This sentence was
added, “Need to have documentation that allows RCB to be accepted and moved into GMP.”
Comment Summary #23: The commenter recommended in Figure 1 to remove the bar or split
in GMP and non-GMP according to the text in the document and figure 2. The commenter
indicated that Figure 1 is conflicting with Figure 2 and the text in the document, which (correctly)
states that activities from MCB manufacture onwards should be performed in a GMP
environment.
Response: Comment incorporated. In Figure 1, the bar that indicates the use of Good
Manufacturing Processes has been moved to start at the fifth box down from the top, "Culture
premaster research bank (pmRCB) into Master cell bank (MCB), growth characteristics, media,
raw material qualification, cell density, viability, and process development.”
Comment Summary #24: The commenter suggested to combine Figures 1 and 3, and to
correct that GMP conditions are required before the pre-MCB stage.
Response: Comment partially incorporated. Figure 1 is meant to be broad, and subsequent
figures are meant to provide more specific detail, so Figures 1 and 3 will not be combined.
Figure 1 has been corrected to indicate that the use of Good Manufacturing Processes is not
required in the pre-MCB stage.
Comment Summary #25: The commenter recommended removing the following text,"… which
need to go through purity testing prior to the production of MCBs and subsequent WCBs"
because not all of the details of the testing are discussed.
Response: Comment not incorporated. The details are discussed later in the chapter and are
not needed in this section.
Comment Summary #26: The commenter suggested adding the words, “as needed” to the
following sentence: "To ensure a consistent supply, it is generally recommended that additional
replacement WCBs be produced as needed once a biologic is approved for marketing."

Response: Comment incorporated. The words “as needed” were added to this sentence: “To
ensure a consistent supply, it is generally recommended that additional replacement WCBs be
produced as needed once a biologic is approved for marketing."
Comment Summary #27: The commenter recommends that Section 2 of the chapter be
revised and expanded in accordance with ICH Q5D.
Response: Comment partially incorporated. A reference to ICH Q5D has been added instead of
re-stating what is in the guidance.
Comment Summary #28: The commenter suggested defining the terms “production cell line”
and “premaster research cell bank (pmRCB)”.
Response: Comment incorporated. The terms are defined in the Glossary for clarification.
Comment Summary #29: The commenter suggested to add “premaster research cell bank” to
the Glossary.
Response: Comment incorporated. The term “premaster research cell bank” is defined in the
Glossary.
Comment Summary #30: The commenter suggested changing the word “purity” to “clonality” in
Figure 1.
Response: Comment not incorporated. “Purity” is specifically meant as the purity needs to be
tested before moving into a GMP facility.
Comment Summary #31: The commenter recommended to remove the text, “evaluation of the
integrity and stability of those genes for the intended purposes should be included as a part of
the cell substrate characterization” because this characterization is not always done.
Response: Comment not incorporated. The term, “should” in the statement, “evaluation of
integrity should be included in characterization” provides some flexibility; however it is strongly
recommended to evaluate integrity.
Comment Summary #32: The commenter requested to remove the requirement to test the
purity of the pmRCB before the production of MCBs and subsequent WCBs.
Response: Comment not incorporated. Although purity testing is not a requirement included in
regulatory guidances, purity testing is usually required to take a product into a GMP setting. The
purity testing is included in this above 1000 general chapter with the intent to provide
information in addition to what can be found in regulatory guidance.
Comment Summary #33: The commenter requested to clarify how stability should be tested.
Response: Comment not incorporated. Stability testing can be product specific and appropriate
testing may change throughout phases of development which is why it is not included in the
chapter. ICH documents can be referenced for guidance on stability testing.
Comment Summary #34: The commenter suggested to change to the wording to indicate
purity testing of the RCB or handling the RCB under quarantine followed by purity testing of the
MCB.
Response: Comment partially incorporated. Sterility is a risk when moving into a GMP facility,
so this text was added to the chapter: “Appropriate qualification testing of RCB is recommended
to be performed prior to moving into GMP.”
PRODUCTION CELL LINE/STRAIN DEVELOPMENT AND RCB GENERATION

3.1 Common Cell Line Types and Associated Expression Constructs
Comment Summary #35: Commenter recommends adding references to original publications

that cover the historical information and properties of common CHO cell lines and E. coli strains.
Response: Comment not incorporated. The current references provide information about the
CHO cell lines and E. coli strains.
Comment Summary #36: The commenter recommended adding to the general information list
that ease of engineering may be enabled by availability of a fully elucidated CHO genomic
sequence.

Response: Comment not incorporated. It is not necessary to state that the CHO genomic
sequence is fully elucidated because the availability of the CHO genomic sequence can be
considered common knowledge.
Comment Summary #37: The commenter recommended to add the following reference: ‘Frye
et al; Biologicals Volume 44, Issue 2, March 2016, Pages 117-122’.
Response: Comment incorporated.
Comment Summary #38: The commenter suggested adding information about additional
testing considerations that are needed when retroviruses (e.g., lentiviruses) are used to insert
the gene of interest.
Response: Comment partially incorporated. A statement about the use of retroviruses was
included, but the topic will not be added to the chapter, as the use of retroviruses would need
additional conversation with the appropriate regulatory authority.
Comment Summary #39: The commenter suggested making changes to the text to indicate
that changing cell lines during drug development is not common.
Response: Comment partially incorporated. Changes were made to reflect that it is not
common practice to change cell lines during drug development. This sentence was added: “In
addition, comparability and other product impacts should be evaluated.”
Comment Summary #40: The commenter suggested that the statement, “CHO cells have the
capacity for efficient, post-translational modifications, such as glycosylation, which enable the
CHO-derived therapeutic proteins to be” needs to have more text added to the end of the
sentence.
Response: Comment not incorporated. The full sentence in the document is a complete
statement, “CHO cells have the capacity for efficient, post-translational modifications, such as
glycosylation, which enable the CHO-derived therapeutic proteins to be both compatible with
and bioactive in humans.”
Comment Summary #41: The commenter suggested changing “non-secreting (NS0) mouse
myeloma cells” to “non-IgG secreting (NS0) mouse myeloma cells”.
Response: Comment not incorporated. The change was not made because the NS0 cells can
secrete things other than IgG.
Comment Summary #42: The commenter suggested to remove the detailed annotation of the
GOI and the description of cloning.
Response: Comment not incorporated. The annotation of the GOI and the description of
cloning aligns with what is in ICH Q5B.
Comment Summary #43: The commenter requested clarification of the benefit of CHO cell use
and the ability to integrate DNA to generate stable recombinant protein expressing cell lines.
Response: Comment not incorporated. The text clearly explains the benefit of using CHO cells.
CHO cells have the capacity for efficient, post-translational modifications, such as glycosylation,
they are able to adapt and grow suspension culture and have a lower adventitious virus safety
risk.
Comment Summary #44: The commenter suggested to add the word “commercial” to the
sentence “All CHO cell substrates used for commercial recombinant protein production are
expected to be single-cell derived.” as there may be cases where cells are pooled.
Response: Comment partially incorporated. The word “commercial” was added to the
sentence. Discussion of pooling cells is a business and scientific risk consideration, and it is out
of scope of the chapter to provide such guidance.
Comment Summary #45: The commenter suggested the following edits to the sentence:
“Selection of recombinant cell lines is can be performed using stepwise increases in the media
concentration of MTX, which results in amplification of the transfected DHFR gene together with
the GOI, consequentially possibly increasing the productivity of the GOI.” because many
companies have worked on strategies that omit the MTX.
Response: Comment incorporated. The suggested edits to the sentence were incorporated.

“Expression plasmids are often linearized prior to transfection and are generally integrated into
the CHO host cell genome by random integration.” because linearization is not a prerequisite for
random integration.
Response: Comment incorporated. The sentence was edited by adding the words ”often” and
“generally” to the sentence.
Comment Summary #47: The commenter suggested the following edits to the sentence
“Therefore, evaluation of the integrity and stability of the overexpressed genes for the
intended purposes should be included as a part of the cell substrate genetic stability
characterization. In addition, knocked out genes should be characterized.” The commenter
also suggested including a statement about genes that have been knocked out.
Response: Comment incorporated. The sentence was edited as the commenter suggested. A
statement that indicated that knocked out genes should be characterized was also included.
Comment Summary #48: The commenter suggested to make Table 1 more Cell Banking
focused as the table is focused on choosing an expression system.
Response: Comment partially incorporated. Table 1 is intended to be an example of original
choice of cell line. The title of Table 1 was changed to “Comparison of two Common Cell
Substrates for Recombinant Therapeutic Products” to clarify the purpose of the table.
Comment Summary #49: The commenter suggested changing “primary, secondary and
tertiary” to “higher order structure”. The sentence will now read, “Secreted recombinant proteins
are properly folded and are identical in higher order structure to the natural human protein”.
Response: Comment incorporated. The suggested edit of using “higher order structure” was
incorporated.
Comment Summary #50: The commenter recommended adding the word chromosomes to the
sentence: “New chromosomal structures, known as homogeneously staining regions (HSRs),
can be found in the metaphase chromosomes of MTX-selected CHO cells”.
Response: Comment incorporated. The word “chromosomes” was added to the sentence.
Comment Summary #51: The commenter suggested to add “antibiotic resistance genes that
are sometimes used for CHO cells, (e.g., neomycin, bleomycin)” to the sentence: “Selection
markers such as DHFR or GS for recombinant cell line selection.”
Response: Comment partially incorporated. The phrase, “the commonly used” was added to
the sentence: “Selection markers such as the commonly used DHFR or GS for recombinant
cell line selection” because the list of selection markers is not meant to be an exhaustive list.
Comment Summary #52: The commenter requested that text be added to clarify the
characterization process as to whether the knock-in or knock-out has to be characterized in
every cell line made using that host or just once for the host cell line.
Response: Comment not incorporated. Text is clear as written. Cell substrate characterization
only refers to new genes knocked out or over expressed. The location in the text indicates this.
Comment Summary #53: The commenter requested to clarify copy number considerations
regarding stability.
Response: Comment not incorporated. Copy number alone is not stability indicating.
Comment Summary #54: The commenter requested to clarify antibiotic use.
Response: Comment not incorporated. The text is clear about the use of antibiotics because
the use of antibiotics in production systems are not recommended.
3.2 PRODUCTION CELL LINES/STRAINS AND RECOMMENDED DOCUMENTATION
Comment Summary #55: The commenter suggested to replace the word “purity” with “strain
ID” in the sentence: “Cell line purity can be assessed with PCR or using short tandem repeat
(STR) profiling or DNA fingerprinting or another appropriate technology to verify the identity of
the host cells.”

Response: Comment incorporated. The word “purity” was replaced with “strain ID”.
Comment Summary #56: The commenter requested clarification because the phrase “RCBs
are thawed and expanded to generate the pm RCB” implies that it is a prerequisite to generate
a pmRCB, but it is not a perquisite.
Response: Comment incorporated. The phrase “or MCB as appropriate” will be added to the
end of the sentence: “Once the final production strains/cell lines are identified, the
corresponding RCBs are thawed and expanded to generate the pmRCB.”
Comment Summary #57: The commenter suggested edits to the following sentence: “Because
the RCB/pmRCB is usually generated in a non-GMP facility, it is recommended that
RCB/pmRCBs from mammalian cell lines should be tested and found sterile for contaminants
and negative for mycoplasma before transfer to a GMP facility for the generation of the MCB”
Response: Comment incorporated. The suggested edits were made to the sentence.
Comment Summary #58: The commenter suggested removing the testing of purity on MCB
and WCB as purity testing may be a recommendation for business-critical reasons, but not a
quality requirement.
Response: Comment not incorporated. The chapter provides recommendations and describes
best practices which includes testing the purity of the MCB and WCB.
Comment Summary #59: The commenter suggested the following edits to the sentence: “For
an E. coli derived RCB/pmRCB, testing for purity, identity, and bacteriophages is
recommended before entry to a GMP facility.”
Response: Comment incorporated. The suggested edits of adding “RCB” and the phrase “is
recommended” have been added to the sentence.
Comment Summary #60: The commenter suggested adding language to indicate that the post-
banking evaluation of the RCB/pmRCB for growth, viability, and viable cell density to aid MCB
production and characterization is recommended but not a requirement.
Response: Comment not incorporated. Post-banking evaluation of the RCB/pmRCB for growth,
viability, and viable cell density is a requirement. RCB will be added before the pmRCB.
Comment Summary #61: The commenter requested to clarify components referenced.
Response: Comment not incorporated. The Expert Panel and Expert Committee decided it was
not necessary to show how to describe components.
Comment Summary #62: The commenter requested to clarify when and how pmRCB testing
can be accomplished.
Response: Comment not incorporated. Timing is specified as before entering GMP. The
chapter does not need to be more specific about timing.
Comment Summary #63: The commenter requested to clarify DMSO use and hold time
determination.
Response: Comment not incorporated. The DMSO hold time is specific for each cell line.
Comment Summary #64: The commenter requested to clarify "appropriate storage conditions".
Response: Comment partially incorporated. A reference to USP chapter <1044>
Cryopreservation of Cells was added.
Comment Summary #65: The commenter suggested the following edit to the statement,
“Figure 4 shows an example of a cell banking process for a mammalian (CHO) cell bank”.
Response: Comment incorporated. The word “banking” was added to the sentence.
Comment Summary #66: The commenter suggested to add text to indicate that mammalian
cell banks are typically kept in at least two different geographical locations.
Response: Comment incorporated. This text was added to the chapter: “To avoid any
unexpected loss of the cell bank, the containers are typically kept in at least two different
geographical locations.”

Comment Summary #67: The commenter requested clarification of EOP cells and at the limit
of in vitro cell age production and testing for Figure 3 since EOP and LIVCA cells may not be
the same (different timelines may be present).
Response: Comment incorporated. End of Process (EOP) was spelled out in the last box of
Figure 3 to specify production and testing of End of Process cells at the limit of in vitro cell age
(LIVCA).
Comment Summary #68: The commenter requested clarification about what should be added
to the label. The following edits are suggested: "Label the vials in advance with the appropriate
information (e.g., cell bank lot number, tube number, and production date)."
Response: Comment incorporated. The phrase “the appropriate information” was added to the
sentence.
Comment Summary #69: The commenter suggested changing the word “usually” to “may” in
the following sentence: “During development, the production strains/cell lines used for
manufacturing clinical materials may continue to evolve to meet the commercial manufacturing
needs.”
Response: Comment incorporated. The word “usually” was changed to “may” in the sentence.
Comment Summary #70: The commenter suggested to remove cDNA copy number from the
section on Specification Analysis in Figure 4.
Response: Comment partially incorporated. The title of the section was changed, so it does not
read Specification Analysis as Plasmid copy number is incorporated in Figure 4 as an additional
test, not for specification.
Comment Summary #71: The commenter requested clarification of the appropriate cleanroom
quality control procedures.
Response: Comment not incorporated. It is the responsibility of each company to determine
cleanroom procedures with their quality assurance.
Comment Summary #72: The commenter suggested to add “and cell density” to the end of the
sentence: “Fill freezing containers to appropriate volume” in Figure 4.
Response: Comment incorporated. The phrase “and cell density” was added to the sentence.
Comment Summary #73: The commenter requested clarification of the distinction between cell
bank characterization tests and tests required for release based on a specification in Figure 4.
Response: Comment incorporated. The title, Specification Analyses was removed from Figure
4, and the text in the box in Figure 4 was replaced with "Refer to Table 3 for release testing and
additional testing for characterization”.
Comment Summary #74: The commenter requested to delete the mention of cleanroom
procedures.
Response: Comment not incorporated. It is the responsibility of each company to determine
cleanroom procedures with their quality assurance.
Comment Summary #75: The commenter recommended to align the glycerol concentrations,
”Mix with “87%” glycerol” in the process flow text that mentions 20-30% glycerol. The
commenter also suggested to provide example of in-process control.
Response: Comment incorporated. Remove “87%” from Figure 5. The “87%” is the stock used
and the final concentration should be 20-30%. Text has been added to the Figure to provide
example of in-process control.
Comment Summary #76: The commenter recommended removing the “87%” concentration
from Figure 5.
Response: Comment incorporated. The “87%” concentration was removed.
Comment Summary #77: The commenter recommended removing the “87%” concentration
from the Figure 5.
Response: Comment incorporated. “87%” was removed from Figure 5.
Comment Summary #78: The commenter recommends that the following two sentences be
moved to the sub-section Additional Considerations: "To avoid any unexpected loss of the cell

bank, the containers are typically kept in at least two different geographical locations. During
transportation, the containers are shipped and are continuously monitored for temperature to
confirm that they remain acceptably frozen."
Response: Comment incorporated. The two sentences were moved to the section Additional
Considerations.
ADDITIONAL CONSIDERATIONS
Comment Summary #79: The commenter suggested to change “new pre-and post-launch cell
lines” to “clinical” and “commercial” cell lines, respectively.
Response: Comment partially incorporated. The phase “pre- and post-launch” will be removed,
so it will read: “The new cell lines may be from a new species (e.g., a change from NS0 to CHO)
or from the same species with additional genetic modifications to improve the cell culture
performance and/or the quality/productivity of the therapeutic proteins.”
4. CLONALITY
Comment Summary #80: The commenter recommended changing the title of the section to
"Mammalian Cell Line Clonality”. And to add the following statement: "This section discusses
clonality of production cell lines-derived from mammalian cells."
Response: Comment incorporated. The section title was changed, and the statement was
added.
4.1 OVERVIEW
Comment Summary #81: The commenter suggested changing “limited dilution” to “limiting
dilution” in the sentence: “These practices include limiting dilution, fluorescence-activated cell
sorting”.
Response: Comment incorporated. “Limited dilution” was changed to “limiting dilution.”
Comment Summary #82: The commenter suggested adding the following phrase, “acquiring
images of the single cell at Day 0 and on subsequent days to follow the outgrowth of the clones”
to the sentence: “The supplemental evidence for the single-cell derivation of the cell line can be
based on the use of a qualified imaging system, acquiring images of the single cell at Day 0 and
on subsequent days to follow the outgrowth of the clones”.
Response: Comment incorporated. The phrase that the commenter suggested was added to
the sentence.
Comment Summary #83: The commenter indicated that it is general when images are used as
supportive information in the following statement from the General Chapter, “Images are
evaluated for quality—based on criteria including image focus and clarity, cell shape, lack of
debris or artifacts in the well—as well as for conformation that the entire well was captured in
the image”
Response: Comment not incorporated. The commenter’s position was considered; no
requested change was specifically identified.
Comment Summary #84: The commenter requested to omit the section “Other Automated
Clone Selection Technology” because the section is very focused on high-speed laser
manipulation methods.
Response: Comment partially incorporated. A sentence has been added to clarify the text
contains one example, other methods can be used.
4.2 METHODOLOGY

LIMITING DILUTION CLONING
Comment Summary #85: The commenter suggested to include seeding density

considerations.
Response: Comment partially incorporated. This sentence “The appropriate number of rounds
(e.g., 2 rounds) at an appropriate seeding density” was added for clarity.
Comment Summary #86: The commenter suggested to delete 96 well plates, or modify
language to allow flexibility for 384 well plates.
Response: Comment incorporated. 96-well plates were deleted.
Comment Summary #87: The commenter requested to add clarifying language on the use of
fluorescence imaging the process as many production cells do not express fluorescent markers.
Response: Comment partially incorporated. The phrase “as applicable” was added to the
fluorescence imaging.
Comment Summary #88: The commenter suggested to add the text, “Any reagent” used in the
selection process should be tested for adventitious agents.
Response: Comment partially incorporated. The phrase “any reagent” was not added. The
following text was added to the chapter, “Any biologically derived agent should be tested for
adventitious agents. For example, if antibodies used…. “
Comment Summary #89: The commenter recommended deletion of this statement, “The
process can be completed in as little as 7 days, with the identification of stable clones by 4
weeks.” because the timelines are subjective.
Response: Comment partially incorporated. The sentence was not deleted, but clarifying
language was added. The process in some cases can be completed in as little as 7 days, with
the identification of stable clones by 4 weeks.
Comment Summary #90: The commenter suggested a revision to exclude single cell printing.
Response: Comment partially incorporated. The phrase “commonly used” was removed to
indicate that single cell printing is not commonly used.
4.3 ASSURANCE OF CLONALITY
Comment Summary #91: The commenter suggested to remove the text, “When probability
calculations are included, they should be done so prospectively.” as this is not the practice used
by the commenter.
Response: Comment not incorporated. The commenter’s position was considered, and the
existing language reflects only that these are commonly used practices when probability
calculations are included.
Comment Summary #92: The commenter suggested to remove "consistent process and PQ"
as it does not seem to fit in this section.
existing language reflects that these are common practices for assurance of clonality.
Comment Summary #93: The commenter suggested to remove reference to Southern blotting
as the Southern blot does not provide much information on clonality.
Response: Comment incorporated. The reference to Southern blotting was removed.
5. CELL BANK CHARACTERIZATION
Comment Summary #94: The commenter suggested to revise the introductory paragraph of
this section to remove statements such as “inherently variable”.
Response: Comment incorporated. The text was edited to remove “inherently variable”.

Comment Summary #95: The commenter suggested that genetic stability and characterization
should be done beyond end of production.
Response: Comment not incorporated. The language in the chapter is appropriate to allow
flexibility for testing beyond a typical manufacturing process.
5.1 CELL BANK QUALIFICATION AND CHARACTERIZATION
Comment Summary #96: The commenter suggested switching Section 5.1 and section 5.3 in
the chapter to improve the flow of the chapter.
Response: Comment incorporated. Sections 5.1 and 5.3 were switched to improve the flow of
the chapter.
Comment Summary #97: The commenter suggested combining sections 5.2 and 5.3 or better
define the purpose of each section.
Response: Comment not incorporated. Sections 5.1 and 5.3 will be switched which will improve
the flow of the chapter and redundancies will not be an issue.
Comment Summary #98: The commenter requested to delete restriction analysis map and
plasmid stability are not listed as specification analyses in Table 3.
Response: Comment incorporated. Text from the box has been deleted.
Comment Summary #99: Commenter suggested adding information about monitoring genetic
stability of cell banks under long term storage to sub-section 5.1.
Response: Comment not incorporated. The testing of LIVCA genetic stability is sufficient to
cover stability of banks under long term storage.
Comment Summary #100: The commenter suggested to exclude NGS from section 5.1 or if
NGS is kept, to provide guidance on the NGS data that is submitted or what comparisons are
made.
Response: Comment partially incorporated. The statement has been revised to clarify that NGS
is not one of the most common methodologies. The following edits has been made: “The most
common methodologies for the assessment of gross structure of the expression construct are
restriction endonuclease (RE) mapping analysis. DNA sequencing (NGS) is beginning to be
used for genetic characterization.”
Comment Summary #101: The commenter suggested including a reference to PDA Technical
Report 71 Emerging Methods for Virus Detection.
Response: Comment not incorporated. The expert committee did not agree with the
commenter that the PDA reference was appropriate for discussion of genetic characterization.
Comment Summary #102: Commenter suggested to include that NGS should occur on cells at
a representative cell age from a representative commercial process.
Response: Comment not incorporated. NGS is not being used for this purpose.
Comment Summary #103: Commenter recommended to reference to PDA Technical Report
71 Emerging Methods for Virus Detection.
Response: Comment not incorporated. The expert committee did not agree with the
commenter that the PDA report was appropriate for genetic characterization.
Comment Summary #104: Commenter suggested to clarify what qualifies End of Production
(EOP) cells to be analyzed and provide a worse-case scenario.
Response: Comment not incorporated. EOP can be cultured as long it needs to be for each
user of the general chapter’s process.
Comment Summary #105: The commenter suggested to correct the improper use of an
acronym: Next generation sequencing (NGS) of DNA.
Response: Comment incorporated. The improper use of the acronym was corrected to Next
Generation Sequencing (NGS).

Comment Summary #106: The commenter suggested referencing PDA Technical Report 71
Emerging Methods for Virus Detection.
Response: Comment not incorporated. The PDA technical report is not an appropriate
reference for this section as the scope of the document is safety and adventitious agents.
Comment Summary #107: The commenter suggested revising section 5.1 for clarity.
expert committee identified that no additional information was needed for clarity.
Comment Summary #108: The commenter recommended to clarify that lytic phage
contamination is different from lysogenic phage contamination. Alternatively, reference a
suitable paper or guidance to delineate the differences.
Response: Comment not incorporated. The type of phage contamination referenced by the
commenter is too specific for inclusion in this chapter.
Comment Summary #109: The commenter recommended to include a discussion of risk-
based approach in the Cell Bank Characterization section.
Response: Comment not incorporated. Risk based approach is not needed at the
characterization stage. Characterization should be exhaustive as possible and not risk based.
Risk based information is already included in chapter.
Comment Summary #110: The commenter requested to clarify that genetic characterization
should be on the Master cell bank or the Working Cell Bank, but both are not necessary.
Response: Comment partially incorporated. Genetic characterization of the Master cell bank is
always needed, and a comparison of the Working Cell Bank is optional and only done if
necessary. The following edits have been made, “Genetic characterization is performed on
samples taken at EOP and compared to the MCB. If necessary, WCB could be tested with
bridging to the MCB.”
Comment Summary #111: The commenter requested clarification as to if the chapter is
specifying different sequencing than what is described in ICH Q5B.
Response: Comment not incorporated. The chapter cites ICH Q5B, and the user should follow
ICH Q5B.
Comment Summary #112: The commenter suggested to add the word “identical” to the
following sentence: "DNA sequence and RE pattern of the EOP cells at LIVCA should be
identical to those of the MCB and/or the WCB.”
expert committee identified that no additional information was needed for clarity.
Comment Summary #113: The commenter requested clarification on if NGS is a common DNA
sequencing approach.
Response: Comment incorporated. NGS is not a common approach. Edits have been made to
the chapter so that sequencing can be done with any platform.
5.2 MAMMALIAN CELL BANK TESTING
Comment Summary #114: The commenter suggested to remove “the same copy number”
from the following sentence: “For an engineered cell line, the inserted GOI should remain intact
and at the same copy number”. The commenter suggested replacing “same” with “at a like”.
Response: Comment partially incorporated. The following edits are made, "For an engineered
cell line, the inserted GOI should remain intact and at a consistent copy number should be
determined to support consistent production.
Comment Summary #115: The commenter requested clarification on whether or not the
Master cell bank should comply with the test for hemadsorbing extraneous agents. The
commenter also suggested including references for this test.

Response: Comment partially incorporated. The following sentence has been revised for
clarification, “The MCB should also be assessed by the in vitro virus assay with the two
endpoints of cytopathic effect and hemadsorption.”
Comment Summary #116: The commenter recommended that the chapter provide guidance
that is clear and consistent on the situations where LIVCA studies are considered necessary
and should be repeated. The commenter suggested the following edits, "The testing on LIVCA
cells should be conducted for the initial MCB or WCB. When new WCB are expanded to or
beyond the LIVCA, conduct testing to assess against the existing LIVCA."
Response: Comment partially incorporated. Two sentences with LIVCA were edited. "The
testing on LIVCA cells should be conducted for the initial MCB or WCB. When new WCB are
expanded to or beyond the LIVCA, testing should be conducted to assess against the existing
LIVCA original MCB."
Comment Summary #117: The commenter suggested to clarify requirements for initial and
future WCB. EOP testing is required for initial WCB but not for further/future WCBs.
Response: Comment not incorporated. Current text is consistent with ICH Q5A and ICH Q5A
Table 1, Footnote F.
Comment Summary #118: The commenter suggested to delete the phrase, “using human cells
with PERT as end point”, and to list only “Infectivity assay”
Response: Comment incorporated. ICH Q5A does not specify PERT as an endpoint.
Comment Summary #119: The commenter suggested to provide language that product-
enhanced reverse transcriptase (PERT) assay (may not be needed if the cell line is known to
express retroviruses [e.g., CHO/NS0 cell lines] and may be co-cultured with a relevant cell line
depending on the test article.)
Response: Comment partially incorporated. The following text was deleted in the general
chapter: “Product-enhanced reverse transcriptase (PERT) assay (may not be needed if the cell
line is known to express retroviruses [e.g., CHO/NS0 cell lines] and may be co-cultured with
human cell lines.)” The text was replaced with the following text: "If infectivity is not detected and
no retrovirus or retrovirus-like particles have been observed by EM, reverse transcriptase (RT)
or other appropriate assays should be performed to detect retroviruses that may be
noninfectious."
Comment Summary #120: The commenter suggested to delete the phrase, “using human cells
with PERT as end point”, list only “Infectivity assay”
Response: Comment incorporated. The phrase, “using human cells with PERT as end point”
was deleted.
Comment Summary #121: The commenter indicated that “nucleic acid amplification test” may
be used for specific contaminants using degenerate or specific primers.
Response: Comment not incorporated. New technology of nucleic acid amplification tests
would need to be validated for use.
Comment Summary #122: The commenter indicated that comparability should be undertaken
with ethical use of animals. It is not ethical to infect animals with viruses just for the sake of
comparability.
Response: Comment not incorporated. The current version of ICH Q5A, cited in the general
chapter, includes information on animal testing.
Comment Summary #123: The commenter requested further clarification on when the genetic
characterization is performed.
Response: Comment partially incorporated. Text has been changed to clarify when genetic
testing is performed. “Genetic characterization is performed on samples taken at EOP and
compared to the MCB. If necessary, WCB could be tested with bridging to the MCB.”
Comment Summary #124: The commenter requested to change the text as to not specify the
exact same copy number be achieved.

Response: Comment incorporated. The text was changed to, “For an engineered cell line, the
inserted GOI should remain intact and at a consistent copy number should be determined to
support consistent production.”
5.3 CELL BANK QUALIFICATION AND CHARACTERIZATION
Comment Summary #125: Commenter suggested specifying that purity testing be required for
MCB and WCB in Table 3. The commenter also requested to clarify the difference between
Specification Analysis and Additional Tests in Table 3.
Response: Comment partially incorporated. A footnote will be added to Microbial Purity under
“Additional Tests” to specify that the purity test needs to be performed on EOP if not done in
MCB and WCB. Specification tests are release tests; additional tests are characterization tests.
A change was made to change “Additional Tests” to “Characterization Tests” for clarity.
Comment Summary #126: The commenter recommended that the following text be added to
the last sentence of the first paragraph: “Use of each test should be agreed upon with the
applicable health authority and aligned with the latest version of the ICH Q5A guidance.”
Response: Comment not incorporated. ICH Q5A is referenced several other places in the
chapter. The use of each test needs agreement from applicable regulatory authority.
Comment Summary #127: The commenter suggested not to mention specific methods in
Table 3 and that specific methods should not be specified as there are multiple appropriate
methods. The commenter also requested clarification of the use of strain ID and nucleic acid
profiling.
Response: Comment not incorporated. Table 3 is aligned with the current R1 version of ICHQ5.
Strain ID is sequencing. Nucleic acid profiling is phenotype.
Comment Summary #128: The commenter suggested to remove DNA sequence or DNA
sequencing from either list of specification tests or additional tests.
Response: Comment not incorporated. There is a difference between early (MCB and WCB)
and late (EOP) stage and the testing performed. Characterization is more extensive in earlier
stages. EOP is end of process and DNA sequencing can only be an additional test due to the
stage of the cells.
Comment Summary #129: The commenter suggested to omit strain ID for the “Working Cell
Bank” from Table 3.
Response: Comment incorporated. Strain ID for the “Working Cell Bank” was removed from
Table 3.
Comment Summary #130: The commenter suggested to delete Table 3 and Table 4 and refer
to guidance per current ICH Q5A.
Response: Comment not incorporated. Table 3 and Table 4 will be retained as these tables
add value to the general chapter.
Comment Summary #131: The commenter suggested to edit Table 4 because it specifies the
repetition of antibody production tests at EOP, which would exceed the existing guidance in
ICHQ5A.
Response: Comment incorporated. The antibody tests in Table 4 have been updated to align
with ICH Q5A. The Master cell bank (MCB) is only bank tested with the antibody production test.
Comment Summary #132: The commenter recommended to define similar terms in the
Glossary at the end of the chapter.
Response: Comment not incorporated. The commenter’s position was considered and based
on the scope and anticipated user of the general chapter, it was identified that additional
definition was not necessary.
Comment Summary #133: The commenter suggested to remove the footnote a of Table 3 that
specifies “only for bacterial cell banks” since the title of the table specifies bacterial cell banks.

Response: Comment incorporated. The footnote was removed from Table 3.
Comment Summary #134: The commenter suggested to update “antibody production tests” to
align with ICH Q5A. The commenter also suggested to add “bar code assay” as a contemporary
ID test to Table 4.
Response: Comment partially incorporated. Antibody tests at End of production (EOP) will be
updated to align with ICH Q5A. The “bar code assay” comment was not incorporated. The bar
code assay is captured within sequencing, so it will not be added to the table.
Comment Summary #135: The commenter suggested to update antibody production tests to
align with ICH Q5A in Table 4.
Response: Comment incorporated. Antibody tests at EOP were updated to align with ICH Q5A.
Comment Summary #136: The commenter suggested to include assays for characterization of
stability in Table 4.
Response: Comment not incorporated. Table 4 does not apply to genetic stability
characterization. Genetic and cell line stability are normally separated.
Comment Summary #137: The commenter suggested to update Table 4 to align with ICH and
FDA requirements or to rename Table 4 to be more specific about the types of characterization
presented in the table.
Response: Comment partially incorporated. The title of the table has been updated to be more
specific about the types of characterization presented in the table. Table 4 is aligned with the
current R1 version of ICHQ5.
Comment Summary #138: The commenter requested that antibody production tests be
recommended for MCB in Table 4 to align with current FDA and ICH guidance.
Response: Comment incorporated. The antibody production test has been updated to only be
recommended for the Master cell bank in Table 4.
Comment Summary #139: The commenter suggested to add a footnote or asterisk to indicate
that the requirement for testing of WCB and EOP for porcine or bovine contaminants is only
required when bovine and porcine materials are being used to generate the banks.
Response: Comment incorporated. A footnote was added to indicate the contaminant testing is
only necessary if bovine or porcine product used in development. The plus signed was changed
to “if applicable” for the columns to indicate the testing is only performed in necessary.
Comment Summary #140: The commenter recommended to change the” –“to a “+” for Identity
test for the MCB in Table 4 because ICH guidance requires identity tests for MCB.
Response: Comment incorporated. The minus sign was changed to a plus sign.
Comment Summary #141: The commenter suggested to fill in the blank spaces with a + or –
where appropriate in Table 4.
Response: Comment incorporated. The negative sign was added to “Infectivity and Reverse
transcriptase” assay.
Comment Summary #142: The commenter suggested to use category of tests (purity, identity
etc.) in Table 4. Also, the commenter suggested to change additional tests to characterization
tests.
Response: Comment not incorporated. There are multiple categories included in Table 4 that
are accurate for the function of the tests.
Comment Summary #143: The commenter suggested that “Bovine and porcine virus in vitro
assay” should be tested on the MCB only. The commenter also suggested that the test for virus
should be related to what was used in the process.
Response: Comment incorporated. “Bovine and porcine virus in vitro assay” has been changed
to “MCB +, WCB -, EOP” - A footnote has been added to specify that testing for viruses should
be related to what was used in the process.
Comment Summary #144: The commenter suggested that the “Nucleic acid fingerprinting”
should be required for MCB in Table 4.

Response: Comment incorporated. “Nucleic acid fingerprinting” was changed to indicate it was
required.
Comment Summary #145: The commenter suggested to add a “-“ sign to WCB for Infectivity
and Reverse transcriptase assay in Table 4.
Response: Comment incorporated. A minus sign was added to WCB for “Infectivity and the
Reverse” transcriptase assay in Table 4.
Comment Summary #146: The commenter suggested to clarify requirements for initial and
future WCB in Table 4. EOP testing is required for initial WCB but not for further/future WCBs.
Response: Comment not incorporated. Current text is consistent with ICH Q5A. User should
review Q5A Table 1, Footnote F.
Comment Summary #147: The commenter suggested to add a “+” for Identity testing for MCB,
and add a footnote to explain when identity testing may not be applicable in Table 4.
Response: Comment partially incorporated. In Figure 4, Identity for MCB has been changed to
+; however, the footnote was not changed as the text in footnote c is consistent with ICH Q5A.
Comment Summary #148: The commenter suggested to add a footnote: “Bovine and porcine
virus in vitro assay can be omitted for MCB, WCB and EOP if parental cell line used to generate
MCB had been tested negative for Bovine and porcine viruses and no animal-derived raw
material were used in transfection and subsequent steps leading to the generation of MCB and
WCB as well as in the production of EOP”. If bovine and porcine raw materials were used but
they have been sterilized by heat treatment or other means, there is no need to perform Bovine
and porcine virus assay as well.
Response: Comment partially incorporated. MCB, WCB, and EOP were marked with a ‘-‘ for
the Bovine and porcine virus in vitro assay. A footnote was added “When bovine and porcine
raw materials are used these tests should be performed. Bovine and porcine virus in vitro Assay
can be omitted for MCB, WCB and EOP if parental cell line used to generate MCB had been
tested negative for Bovine and porcine viruses and no animal-derived raw material were used in
transfection and subsequent steps leading to the generation of MCB and WCB as well as in the
production of EOP.”
Comment Summary #149: The commenter suggested to specify the type of identity test
described in Table 4 by indicating if the test is a cell line identity test or a species identity test.
The commenter also recommended that the MCB should also be tested, so the commenter
suggested changing the minus to a plus for MCB under the Identity test.
Response: Comment incorporated. The type of identity test was specified in Table 4, and the
minus was changed to a plus for the MCB under the identity test.
Comment Summary #150: The commenter suggested to replace the plus with a minus for
EOP for antibody production tests in Table 4.
Response: Comment incorporated. The plus sign was replaced by a minus sign for EOP in
Table 4.
Comment Summary #151: The commenter suggested to omit the requirement to test for
“Bovine and porcine virus” in vitro assay from the MCB, WCB and EOP in Table 4, as this test
should not be made a requirement if the test article does not have a history with such materials.
Response: Comment incorporated. The requirement to test for Bovine and porcine virus in vitro
assay from the MCB, WCB and EOP in Table 4 was removed.
Comment Summary #152: The commenter suggested to replace the minus with plus for the
MCB in the Reverse transcriptase assay as the test is necessary for the MCB.
Response: Comment incorporated. The minus sign was changed to a plus sign for the MCB
reverse transcriptase assay.
Comment Summary #153: The commenter suggested to move footnote “b” to Adventitious
Virus Detection.

Response: Comment incorporated. Footnote ‘b’ was moved to Adventitious Virus Detection
header.
Comment Summary #154: The commenter suggested adding NAT based testing as alternative
to antibody production testing.
Response: Comment incorporated. A footnote was added, “alternative validated method (e.g.,
NAT) agreed upon with the regulatory authority may be used.”
Comment Summary #155: The commenter suggested to mark a plus sign for Identity Tests for
the MCB, and make WCB and EOP a minus sign.
Response: Comment partially incorporated. MCB has been changed to a plus sign. The
commenter’s position was considered, and the decision was made for WCB and EOP to retain
the plus sign to align with ICH Q5D.
Comment Summary #156: The commenter suggested making edits to indicate that a Reverse
Transcriptase (RT) Assay is to be performed if the TEM and Infectivity Assay are negative.
Response: Comment incorporated. Footnote was changed to “Not required if infectivity assay is
positive.” Footnote was moved from EOP to reverse transcriptase.
Comment Summary #157: The commenter suggested to revise Figure 4 and 5, Tables 3 and 4
to be more cohesive.
Response: Comment incorporated. Edits were made to Figures 4 and 5 to align with Tables 3
and 4.
Comment Summary #158: The commenter suggested adding references to USP chapters
<63> Mycoplasma Tests and <71> Sterility.
Response: Comment not incorporated. The chapters are both referenced within the general
chapter.
Comment Summary #159: The commenter requested to change the minus to a plus for WCB
in the In Vitro Assay row of Table 4.
Response: Comment not incorporated. The table is aligned with ICH Q5A.
Comment Summary #160: The commenter suggested to remove RAP from footnote d in
Figure 4.
Response: Comment incorporated. RAP was removed from footnote d in Figure 4.
Comment Summary #161: The commenter suggested to revise Bovine and porcine virus in
vitro assay to include requirements for serum-free media.
Response: Comment incorporated. Bovine and porcine virus in vitro assay was revised to
include requirements for serum-free media.
Comment Summary #162: The commenter suggested to change to plus sign for MCB for
Identity Tests in Table 4.
Response: Comment incorporated. The minus sign was changed to a plus sign for the MCB for
the Identity test in Table 4.
Comment Summary #163: The commenter suggested to remove RAP from footnote d,
“Species-specific viruses present in rodent cell lines may be detected by mouse, rat, or hamster
antibody production tests (MAP, RAP, or HAP).”
Response: Comment incorporated. RAP was removed from footnote d.
Comment Summary #164: The commenter suggested to add a reference to MMV and
Vesivirus to footnote e of Table 4.
Response: Comment incorporated. References to MMV and Vesivirus were added to footnote
e in Table 4.
Comment Summary #165: The commenter suggested to change MCB to a plus sign for
Reverse transcriptase assay.
Response: Comment incorporated. A plus sign was added for the MCB for the Reverse
transcriptase assay.
Comment Summary #166: The commenter suggested to add a footnote “Bovine and porcine
virus in vitro Assay can be omitted for MCB, WCB and EOP if parental cell line used to generate

MCB had been tested negative for Bovine and porcine viruses and no animal-derived raw
material were used in transfection and subsequent steps leading to the generation of MCB and
WCB as well as in the production of EOP”. If bovine and porcine raw materials were used but
they have been sterilized by heat treatment or other means, there is no need to perform Bovine
and porcine virus assay as well.
Response: Comment incorporated. A footnote was added that Bovine and porcine virus in vitro
assay can be omitted for MCB, WCB and EOP if the parental cell line used to generate the MCB
had tested negative for Bovine and porcine viruses, and no animal-derived raw material was
used the steps to produce the EOP.
Comment Summary #167: The commenter suggested that Table 4 align with the new revision
of ICH Q5A.
Response: Comment partially incorporated. ICH Q5A will not be revised and official for some
time, so a footnote was added that states: For more information see current version of ICHQ5A.
ICHQ5A is under revision during development of this chapter. The table is aligned with the
current R1 version of ICH Q5A.
Comment Summary #168: The commenter suggested to move footnote “a” to the “In vitro
assay” and to move footnote “b” to Adventitious Virus Detection in Table 4.
Response: Comment incorporated. Footnote a was removed from “In vitro Assay” and footnote
b was moved to Adventitious Virus Detection in Table 4.
Comment Summary #169: The commenter suggested to specify that Bovine and porcine virus
testing should only be required if materials of animal origin have been used in the cell line
development or cell banking process. If no materials of animal origin are used, testing for these
viruses should not be necessary.
Response: Comment incorporated. Text was added to clarify that Bovine and porcine virus
testing is only required if materials of animal origin have been used in the cell line development.
Comment Summary #170: The commenter requested that minus sign be added to the “WCB”
column for “infectivity” and “reverse transcriptase”. The commenter suggested that there should
be a plus sign for the MCB for the Reverse transcriptase assay.
Response: Comment incorporated. A minus sign was added to the WCB column for infectivity
and reverse transcriptase. A plus sign was added to the MCB for the Reverse transcriptase
Assay.
Comment Summary #171: The commenter suggested to remove “to confirm species identity”.
Response: Comment not incorporated. It is necessary to confirm the cell line identity. Protein
identity is characterized as part of the control strategy (coding sequence confirmation).
5.4 GENERAL CONSIDERATIONS FOR QUALIFICATION OF REPLACEMENT WCBS
Comment Summary #172: The commenter suggested the following edited text: “There is an
option to use scale-down cell culture evaluation criteria including cell culture process key
performance indicators (KPIs).
Response: Comment not incorporated. It is expected to do at least one full scale evaluation.
Small scale data can be supportive in nature.
5.5 OTHER GENERAL CONSIDERATIONS FOR CELL BANKS
Comment Summary #173: The commenter requested to add considerations for vial tracking
such as the need for tracking the number of vials made, the number of vials used and the
number of vials remaining.
Response: Comment not incorporated. Tracking vial # is a business practice but is not needed
to assess the quality of the cell bank.

Comment Summary #174: The commenter recommended rewording the following statement;
"Each cell bank vial or bag should be labeled with the appropriate information (e.g., identity,
lot number, and date of freezing) on liquid nitrogen-resistant cryolabels;"
Response: Comment partially incorporated. The statement was changed to align with response
to another comment [Sec 3.2: "Label the vials in advance with the appropriate information (e.g.,
cell bank lot number, tube number, and production date)."]
Comment Summary #175: The commenter suggested the following edits for clarification: “post-
bank thaw testing with assessment of cell viability should be performed to demonstrate that
the cells survived the cryopreservation process.”
Response: Comment partially incorporated. Suggested text changed to below to replace
current text, “Post-bank thaw testing with assessment of cell viability should be performed and
documented. A viability limit should be set and justified to demonstrate that the cells
survived the cryopreservation process. The viability limit could be set based on
historical data.”
Comment Summary #176: The commenter recommended shifting the focus from specific
growth rate to cell bank viability as a parameter for cell bank stability.
Response: Comment incorporated. Discussion of specific growth rate was removed.
Comment Summary #177: The commenter suggested to change “freeze-thaw” to “thaw in the
Cell Bank Storage Stability and Monitoring sub-section of 5.5 Other General Considerations for
Cell Banks”.
Response: Comment incorporated. “Freeze-thaw” was changed to “thaw.”
Comment Summary #178: The commenter recommended deleting this sentence: “Limits
should be updated as additional freeze-thaw data become available.”
Response: Comment incorporated. The sentence was deleted.
Comment Summary #179: The commenter suggested to change the word “must” to “should” to
allow for flexibility in this statement, “Data for WCB stability monitoring must include data from.”
The commenter indicated that for microbial cell banks, viability may not be determined during
production of clinical or commercial material. Changing “must” to “should” will address this.
Response: Comment incorporated. The word “must” was changed to “should.”
Comment Summary #180: The commenter indicated that it is relevant to not only look at
statistical trends but also process demands. The evaluation should be a mix of evaluation of
trends and if the performance is fit for the intended use. A cell bank may be fit for the intended
use although a slight trend for e.g., decreasing viability is present. Process demands are a
business need not a quality aspect. Criteria would be developed based on experience with the
product developed to meet business needs.
Response: Comment not incorporated. The commenter’s position was considered; no
requested change was specifically identified.
Comment Summary #181: The commenter suggested to clarify or delete this sentence: “Limits
should be updated as additional freeze-thaw data become available.”
Response: Comment incorporated. The sentence was deleted.
“Limits should be updated as additional freeze–thaw data become available” - “if relevant for the
process.”
Response: Comment not incorporated. The sentence was deleted.
Comment Summary #183: The commenter suggested the following edits, including adding a
specific example: "Data for WCB stability monitoring must include data from when 1 or more
vials of the cryopreserved WCB are thawed for: A clinical or commercial production campaign.
Until WCB is used for a clinical or commercial production campaign, data from lab scale post
banking evaluation can be used.”

Response: Comment partially incorporated. The specific example that was suggested to be
added may not be applicable in all situations, so it was not added to the chapter. The word
“must” was changed to “can” to allow for more flexibility.
Comment Summary #184: The commenter requested clarification of the statement, "use
appropriate purity controls and limits."
Response: Comment not incorporated. The phrase, "use appropriate purity controls and limits"
was deleted from the general chapter to improve clarity.
Comment Summary #185: The commenter suggested to add verbiage to specify a time point
for start of stability monitoring.
Response: Comment not incorporated. The general chapter is intended to allow flexibility for
when stability monitoring should begin.
GLOSSARY
Comment Summary #186: The commenter suggested to add definitions for End of production
(EOP) cells and LIVCA.
Response: Comment not incorporated. Definitions for EOP and LIVCA already exist in the
Glossary.
REFERENCES
Comment Summary #187: The commenter requested to correct the authors for the citation.
The authors should be Berting, Farcet, and Kreil.
Response: Comment incorporated. The author names were corrected.
Monographs
Monograph/Section(s): Acetyltriethyl Citrate/Organic Impurities

Expert Committee: Simple Excipients
EC-initiated Change #1: Preparation of standard solutions was changed from one standard
solution containing three reference standards (USP Triethyl Aconitate RS, USP Triethyl
Aconitate RS, and USP Acetyltriethyl Citrate RS) to three separate standard solutions each
containing only one reference standard, due to the presence of a Z-isomer of triethyl aconitate
in USP Triethyl Aconitate RS that coelutes with triethyl citrate and also due to potential
presence of triethyl aconitate and triethyl citrate in acetyltriethyl citrate used as a reference
standard. The System suitability and Analysis sections of the test were updated to reflect the
use of separate standard solutions.
EC-initiated Change#2: In Table 2, triethyl aconitate with relative retention time of 0.93 was
specified as triethyl (E)-prop-1-ene-1,2,3-tricarboxylate.
Monograph/Section(s): Albuterol Tablets/Organic Impurities

Expert Committee: Small Molecules 5

Comment Summary #1: The commenter recommended removing the reporting threshold in the
test for Organic Impurities as it will vary based on product-specific factors.
Response: Comment not incorporated. Based on comments received on a proposed policy for
reporting thresholds, USP determined that the issue of the removal of reporting thresholds from
monographs needs further stakeholder engagement. USP intends to conduct further
stakeholder engagement.
Comment Summary #2: The commenter recommended revising the acceptance criterion for
Levalbuterol related compound C for consistency with what has been approved.
Response: Comment incorporated. The acceptance criterion for Levalbuterol related compound
C is widened from “NMT 0.15%” to “NMT 0.2%” consistent with the current approved criterion.
Comment summary #3: The commenter recommended adding a footnote to refer to ICH M7
guidelines for the Levalbuterol related compound D impurity, as it possesses a structural alert
for mutagenicity.
Response: Comment not incorporated. The Expert Committee determined that the proposed
acceptance criterion is consistent with what has been approved by the agency and will consider
future revisions to the monograph upon receipt of additional supporting data.
Monograph/Section(s): Alginic Acid/Impurities

Expert Committee: Complex Excipients
Comment Summary #1: The commenter suggested modifying the statement under Standard
stock solution in the test for Limt of Lead and Arsenic. The statement was proposed to modify
from” ...and 500 µL of lead” to” ...and 500 µL of a standard solution containing 1000 mg/L of
lead”.
Response: Comment incorporated. As per the suggestion, the statement was modified
Th“...and 500 µL of lead” to “...and 500 µL of a standard solution containing 1000 mg/L of lead
to provide additional clarity.
Comment Summary #2: Under Emission wavelengths, the commenter suggested to correct
the wavelength of yttrium internal standard emission line from “371.030 nm” to “224.306 nm”
since this is much closer to the elements being analyzed.
Response: Comment incorporated. As per the suggestion, the yttrium internal standard
emission line was corrected from “371.030 nm” to “224.306 nm”, since this is much closer to the
elements being analyzed.
Comment Summary #3: Under Analysis, the commenter suggested removing the statement
related to in-line addition of internal standard since it was already added manually.
Response: Comment incorporated. As per the suggestion, the statement related to the in-line
addition of internal standard was removed since it was already added manually.
Comment Summary #4: The commenter requested the removal of the testing for lead and
arsenic in alginates. The commenter quoted a USP 2016 stimuli article which states,” Unless
there is a known quality or safety related reason to maintain the specific elemental impurity
limit(s) currently in place for selected components (drug substance and excipients),
implementation of <232> renders the specific element chapters and limit tests in monographs as
unnecessary”. The commenter also confirmed that they are not aware of any specific risk of
lead and arsenic in alginates that require any specific controls.
Response: Comment not incorporated. Comments related to the applicability of elemental
impurity testing to alginate monographs were discussed by the Complex Excipients Expert
Committee. The expert committee considered the fact that alginates are naturally derived
materials. The committee confirmed that additional data will be required from different alginate
manufacturers to decide on the outright removal of the elemental testing from alginate
monographs. Any such decision, based on limited data, may risk the overall safety of the

material. The committee determined that it could compromise the ability of a public standard to
control such materials in terms of quality and safety.
Comment Summary #5: The commenter recommended not to reduce the limit of lead from 10
ppm to 5 ppm. It stated that process and/or analytical capability should not be the basis for
lowering elemental impurity limits in existing monographs. Using process capability to tighten
existing monograph limits for elemental impurities directly conflicts with ICH Q3D, which states
that limits should be based on patient safety.
Response: Comment incorporated. Specific comments related to the lowering of the elemental
impurity limits were considered and discussed with the Complex Excipient Expert Committee.
Based on all of the data provided, the Expert Committee decided to keep the limit for lead
unchanged at 10 ppm.
Comment Summary #6: The commenter suggested USP not to implement lowering the limits
for lead and arsenic to 5 μg/g. Rather, USP should remove specifications for lead and arsenic
from this monograph. It also said that ICH Q3D already addresses the need for safety control for
these elements in the finished drug products. The commenter quoted USP 2016 stimuli article
which states, “Unless there is a known quality or safety related reason to maintain the specific
elemental impurity limit(s) currently in place for selected components (drug substance and
excipients), implementation of <232> renders the specific element chapters and limit tests in
monographs as unnecessary”.
Response: Comment partially incorporated. Specific comments related to the lowering of the
elemental impurity limits were considered and discussed with the Complex Excipient Expert
Committee. Comments related to the applicability of elemental impurity testing to alginate
monographs were discussed with the Complex Excipients Expert Committee. The expert
committee considered the fact that alginates are naturally derived materials. The committee
confirmed that additional data will be required from different alginate manufacturers to decide on
the outright removal of the elemental testing from alginate monographs. Any such decision,
based on limited data, may risk the overall safety of the material. The committee confirmed that
it could compromise the ability of a public standard to control such materials in terms of quality
and safety. Hence this suggestion from the stakeholder was not accepted.
Comment Summary #7: The commenter suggested developing Alginic acid as a flexible
monograph with the option to use wet chemistry tests as an alternative, to determine elemental
impurities such as lead and arsenic.
Response: Comment not incorporated. The Complex Excipients Expert Committee
recommended keeping the elemental impurity testing for lead and arsenic based on ICP-OES.
ICP-OES based procedure has been incorporated to accurately and precisely quantify the
specific elemental impurities. The committee decided not to add an option to use wet chemistry
tests for this purpose, because it would be contrary to the purpose of this revision.
Monograph/Section(s): Amphetamine Sulfate Tablets/Dissolution

Comment Summary #1: The commenter requested to add a dissolution test which
accommodates their approved drug product.
Response: Comment partially incorporated. The Expert Committee determined that the
dissolution parameters and tolerance from the commenter are consistent or tighter than that
published for Dissolution Test 2 except for the Medium which requires deaeration. The Medium
in Dissolution Test 2 is updated from “Medium: water; 500 mL” to “Medium: water; 500mL,
deaerated if necessary”.

Monograph/Section(s): Artemether/Organic Impurities
Comment summary #1: The commenter recommended removing the reporting threshold as it
will vary based on product-specific factors.
Monograph/Section(s): Atomoxetine Hydrochloride/Organic Impurities

Comment Summary #1: The commenter recommended removing the reporting threshold in the
Monograph/Section(s): Calcium Propionate/Multiple sections

EC-initiated Change#1: A note of “The peak eluting at RRT 0.3 is the calcium ion peak. This
peak and the peaks eluting before it is excluded from integration. These peaks are not from
organic impurities of Calcium Propionate” was added in the Analysis section of the Organic
Impurities test to offer clarity.
EC-initiated Change#2: “Plot the calibration curve versus potential, in mV, on two-cycle
semilogarithmic paper with µg of fluoride per 100 mL of solution on the logarithmic scale” was
changed to “Construct a calibration curve by plotting potential, in mV, versus logarithm of µg of
fluoride per 100 mL of solution” in the Limit of Fluoride test to offer users more flexibility in
constructing the calibration curve, and the footnote 1 was deleted in this test because this
footnote, which contains a broken link to a semilogarithmic paper supplier, is not needed
anymore with the change made for constructing the calibration curve.
Monograph/Section(s): Carboplatin Injection/Organic Impurities

EC-initiated Change #1: Change from “Any individual unspecified degradation product” to “Any
unspecified degradation product” in Table 1, to be consistent with ICH terminology.
Comment Summary #1: The commenters recommended revising the acceptance criteria for
“Cyclobutane dicarboxylic acid” and “Total degradation products” to be consistent with what
have been approved by the agency.
Response: Comment incorporated. The acceptance criteria for “Cyclobutane dicarboxylic acid”
is revised from “NMT 0.4%” to “NMT 1.0%,” and the limit for the “Total degradation products” is
revised from “NMT 0.5%” to “NMT 2.5%.” In addition, a footnote is added to “Total degradation
products” in Table 1 to indicate that the amount of “Cyclobutane dicarboxylic acid” is included in
the limit for “Total degradation products.”

Comment Summary #2: The commenter recommended removing the reporting threshold from
the test for Organic Impurities as it will vary based on product-specific factors.
Monograph/Section(s): Carteolol Hydrochloride/Organic Impurities

Monograph/Section(s): Chlorthalidone/Multiple Sections

the Organic Impurities test as it will vary based on product-specific factors.
Comment Summary #2: The commenter recommended harmonizing the Assay and Organic
Impurities methods with the current EP monograph with regard to the injection volume and
gradient program for both methods and the concentration of the Standard solution in the
Organic Impurities method.
Response: Comment not incorporated. The Assay and Organic Impurities methods are based
on the validated procedures and are suitable for the intended use. As appropriate, the Expert
Committee will consider future revisions to this monograph upon receipt of supporting
information.
Monograph/Section(s): Chlorthalidone Tablets/Multiple Sections

the Organic Impurities test as it will vary based on product-specific factors.
Comment Summary #2: The commenter indicated that they utilize the EP Chlorthalidone
System Suitability CRS in the preparation of the System Suitability Solution for peak
identification in their organic impurities test.

Response: Comment not incorporated. USP Reference Standards that have been qualified as
suitable for use are provided for the analysis.
Comment Summary #3: The commenter indicated that the concentration (1 μg/mL) for the
Sensitivity Solution in the Organic Impurities test differs from their LOQ concentration (0.5
μg/mL).
Response: Comment not incorporated. The concentration of the Sensitivity solution at 0.1%
level is consistent with the reporting threshold and is suitable for the Organic Impurities test.
Comment Summary #4: The commenter indicated that the proposed Organic Impurities
method includes the signal-to-noise ratio requirement based on the Sensitivity solution, whereas
their method does not include a signal to noise ratio requirement.
Response: Comment not incorporated. The Expert Committee determined that the signal-to-
noise ratio requirement is important in controlling the system sensitivity for a public standard.
Comment Summary #5: The commenter indicated that the RRT for Chlorthalidone EP Impurity
J is 0.95 in their Organic Impurity method, but 1.1 in the proposed Organic Impurities method.
Response: Comment not incorporated. The RRT value of 1.1 is consistent with the supporting
data.
Comment Summary #6: The commenter indicated their method also accounts for the RRT
values of other impurities (CPSP and Chlorthalidone EP Impurity G), whereas the proposed
USP Organic Impurities method does not establish RRT values for these compounds.
Response: Comment not incorporated. These are not specified impurities in the commenter’s
approved specification but are controlled under the any unspecified impurity at NMT 0.2%.
Comment Summary #7: The commenter recommended revising the sonication time from NLT
15 minutes to NLT 10 minutes for Sample stock solution in the Assay test and Sample solution
in the Organic Impurities test.
Response: Comment incorporated. The sonication time was moved to the Note and revised to
“NLT 10 minutes” to provide flexibility and accommodate different formulations.
Comment Summary #8: The commenter recommended removing the Tailing factor
requirement of “NMT 2.0” from the Assay test as this system suitability requirement is not
explicitly stated in their method.
Response: Comment not incorporated. The Expert Committee determined that the tailing factor
requirement of NMT 2.0 is suitable to be included in the Assay test based on the supporting
data.
Monograph/Section(s): Curcuminoids Capsules/Identification, Performance Tests

Expert Committee: Botanical Dietary Supplements and Herbal Medicines
EC-initiated Change #1: The Expert Committee changed the description of the HPTLC data for
Identification A to be corrected to reflect HPTLC data for curcuminoids rather than turmeric
rhizome (Curcuma longa).
EC-initiated Change #2: The Expert Committee added an explanation to the statement
“making any necessary modification” in the Analysis under Disintegration and Dissolution for
further clarity.
Monograph/Section(s): Curcuminoids Tablets/Identification, Performance Tests

Expert Committee: Botanical Dietary Supplements and Herbal Medicines
EC-initiated Change #1: The Expert Committee made a modification in Identification A to

follow the recommendations provided to the Curcuminoids Capsules monograph.

EC-initiated Change #2: To provide additional clarity, the Expert Committee made a
modification to use the same clarification wording as in is used in the Disintegration and
Dissolution section of the Curcuminoids Capsules monograph.
Monograph/Section(s): Cyclophosphamide Capsules/Multiple sections

EC-initiated Change #1: The EC revised the resolution requirement between

cyclophosphamide related compound A and cyclophosphamide peaks in the test for Organic
Impurities from “NLT 5.0” to “NLT 3.0” based on supporting data.
Comment summary #1: The commenter recommended removing the reporting threshold from
Comment summary #2: The commenter requested their Assay be used in the monograph.
Response: Comment not incorporated. The EC determined that the requested changes provide
no major benefit over the published proposal.
Comment summary #3: The commenter requested changing the Autosampler temperature
from 4° to ambient in Assay.
Response: Comment not incorporated. The Autosampler temperature was proposed based on
a validated method of analysis. The EC will consider future revision to the monograph upon the
receipt of necessary supporting data.
Comment summary #4: The commenter requested their Dissolution procedure for Tier 2 be
used in the monograph.
Response: Comment not incorporated. The request is accounted for in the statement included
in the published proposal indicating that it is permissible to use Dissolution 〈711〉, For Dosage
Forms Containing or Coated with Gelatin as an alternative procedure.
Monograph/Section(s): Dextrates/Multiple sections

EC-initiated Change#1: In the Definition and the Assay, retain the upper limit of NMT 99.0%. A
product with a DE greater than 99.0% would be "dextrates" rather than just simply "dextrose”.
EC-initiated Change#2: The EC changed title of “USP Hydrated Dextrates RS” to “Dextrates
Monohydrate RS” to be consistent with naming of USP RS. The incorporated title change is also
consistent with the supporting data, which describes the material as monohydrate (hydrate
containing single molecule of water of crystallization per molecule) and is therefore more
specific.
EC-initiated Change#3: In the Identification B test, the upper limit of Melting range or
temperature was relaxed from 144° to 146°. The melting point for dextrose is 146° which is in
alignment with assay data (the dextrose equivalence (assay) for bulk lot is 99%) and melting
point data was received, so an upper limit of 144° may not be inclusive of a highly hydrolyzed
product.
EC-initiated Change#4: In the Definition and Assay, the phrase ‘on dried basis’ was removed
to address a problem with calculation. The Assay calculation originally is based on %TDA.
Comment Summary #1: Commenter suggested to change column and detector temperatures,
as their HPLC column and detector temperatures are not calibrated to ±1 °C as proposed.

Response: Comment incorporated. Variance (±1 °C) associated with column and detector
temperatures are adjusted to a note because these details are informative that help to achieve
system suitability requirements.
Monograph/Section(s): Dextrose and Sodium Chloride Injection/Assay

Comment Summary #1: The commenter recommended removing the new Sample solution for
products that are terminally sterilized because they stated that it is not suitable for products
containing higher strengths of dextrose.
Response: Comment incorporated. The new Sample solution for products that are terminally
sterilized in the Assay was removed and a Note was added to the original Sample solution
stating that “ammonium hydroxide may be omitted for finished products containing up to 10%
dextrose that have been terminally heat sterilized”.
Monograph/Section(s): Dutasteride and Tamsulosin Hydrochloride Capsules/Organic

Impurities
Comment summary #2: Commenter recommended revising the acceptance criteria for “any
unspecified degradation product” associated with dutasteride and tamsulosin hydrochloride to
align with what has been approved by the agency, and to be consistent with the identification
threshold as per ICH-Q3B.
Response: Comment incorporated. Based on specifications obtained from a manufacturer with
an FDA approved drug product application, the acceptance criteria for “any unspecified
degradation product” for Dutasteride and Tamsulosin hydrochloride are each revised to NMT
1.0%.
Comment summary #3: The commenter requested to revise the acceptance criteria for the
“total degradation products” of tamsulosin hydrochloride to be consistent with what has been
approved by the agency.
Response: Comment incorporated. Based on specifications obtained from a manufacturer with
an FDA approved drug product application, the acceptance criteria for “total degradation
products” associated with tamsulosin hydrochloride is increased to NMT 1.0%.
Comment summary #4: The commenter recommended removing chlorodutasteride from the
list of specified impurities as it may be sufficiently controlled in the drug substance.
Response: Comment incorporated. Removed chlorodutasteride as a specified impurity
controlling it under any unspecified degradation product acceptance criteria.
Comment summary #5: The commenter recommended removing the list of process impurities
in the acceptance criteria Table 3 and Table 5 because the agency is unable to confirm whether
these impurities are process-only for all approved products.
Response: Comment incorporated. The process impurities listed in Tables 3 and 5 did not have
any associated acceptance criteria and the relative retention times were provided for
information. No other identified impurities with associated acceptance criteria remain.

Therefore, tables 3 and 5 listing the process impurities with associated relative retention times
are removed. The Acceptance criteria section maintains the limits for “any unspecified
degradation product” and “total degradation products.”
Comment summary #6: The commenter requested a consistent designation on whether
dutasteride acid is a process impurity or degradation product across the two dutasteride-
containing drug product monograph proposals published in PF 46(5). The commenter requested
the removal of the impurity if designated as a process impurity.
Response: Comment incorporated. See the response to comment #5. Tables 3 and 5 listing the
process impurities with associated relative retention times are removed. The Acceptance criteria
section maintains the limits for “any unspecified degradation product” and “total degradation
products.”
Monograph/Section(s): Emtricitabine/Multiple sections

EC-Initiated Change #1: The EC changed “Any individual unspecified impurity” to “Any
unspecified impurity” in Table 2 of the Organic Impurities section to be consistent with ICH
terminology.
EC-Initiated Change #2: The EC updated the descriptions for the USP Emtricitabine System
Suitability Mixture A RS and USP Emtricitabine System Suitability Mixture B in the USP
Reference Standards <11> section to be consistent with the current USP practice.
Comment Summary #1: The commenter indicated that the following impurities have different
limits from those in agency-approved products: Emtricitabine acid; Emtricitabine S-sulfoxide;
Emtricitabine R-sulfoxide; Lamivudine; Emtricitabine 5-fluorouracil analog; Emtricitabine
enantiomer; Emtricitabine 5-epimer; and Emtricitabine 2-epimer.
Response: Comment partially incorporated. The Acceptance criteria were widened from
“0.15%” to “0.50%” for Emtricitabine acid and from “0.15%” to “0.20%” for Lamivudine,
consistent with data provided The Expert Committee will consider future revisions to this
monograph upon receipt of supporting information.
Comment Summary #2: The commenter requested to widen the limits for the Emtricitabine S-
sulfoxide impurity.
Response: Comment not incorporated. The Expert Committee will consider future revisions to
this monograph upon receipt of supporting information.
Comment Summary #3: The commenter requested to include 197A for Identification A.
Comment Summary #4: The commenter requested relaxing the System suitability requirement
for Relative standard deviation for the Assay test to “NMT 2.0%” from the proposed “NMT
0.73%”.
Response: Comment not incorporated. A relative standard deviation of “NMT 0.73%” is current
USP practice and in line with General Chapter <621>.
Comment Summary #5: The commenter requested relaxing the limit for Residue on Ignition
from the proposed “NMT 0.10%” to “NMT 0.1%” based on their FDA-approved limit.
Response: Comment incorporated. The limit for ROI has been revised from NMT 0.10% to
NMT 0.1%.
Comment Summary #7: The commenter requested to add additional impurities (FTC-
Dioxolane and FTC-Disulfide) with limits to the monograph.

Comment Summary #8: The commenter requested removing the Lamivudine impurity from the
monograph, as it is not included in their FDA-approved specifications.
Response: Comment not incorporated. The impurity is consistent with known FDA-approved
product specifications.
Monograph/Section(s): Fosamprenair Calcium Tablets/Multiple sections

EC-initiated Change #1: The EC changed “Any individual unspecified impurity” to “Any
unspecified impurity” in Table 1 of the Organic Impurities: Early-Eluting Impurities section and in
Table 3 of the Organic Impurities: Late-Eluting Impurities section to be consistent with ICH
terminology.
EC-initiated Change #2: The EC removed the Relative response factor (F) for all impurities in
Table 1 of the Organic Impurities: Early-Eluting Impurities section and in Table 3 of the Organic
Impurities: Late-Eluting Impurities section. In addition, as the Relative response factor is not
needed, the “(1/F)” from the equations and corresponding definitions are removed.
EC-initiated Change #3: The EC update the description for the USP Fosamprenavir Calcium
System Suitability Mixture RS to be consistent with what is listed in the API monograph.
EC-initiated Change #4: The EC changed the nominal concentration for Sample solutions
prepared throughout the proposed monograph based on the labeled amount of fosamprenavir
as opposed to the fosamprenavir calcium.
Comment Summary #1: The commenter indicated that the concentration of the Standard
solution in the Dissolution test is incorrect as it should be “0.78 mg/mL of fosamprenvir” as
opposed to “0.78 mg/mL of fosamprenavir calcium.”
Response: Comment incorporated. The Standard solution preparation is changed to “0.83
mg/mL” of USP Fosamprenavir Calcium RS, which is equivalent to 0.78 mg/mL of
fosamprenavir. In addition, as there is no dilution of the Sample solution, the “D” from the
Dissolution equation and corresponding definition is removed.
Comment Summary #2: The commenter indicated that the Dissolution acceptance criteria are
different from those in agency-approved products.
Response: Comment not incorporated. The acceptance criteria are based on known approved
specifications. The Expert Committee will consider future revisions to this monograph upon
receipt of supporting information.
Comment Summary #3: The commenter recommended removing the reporting threshold as it
Comment Summary #4: The commenter requested UV cuvette length information be added to
the Dissolution test as, when using the default 1 cm path length cell, the instrument is saturated
at the 0.78 mg/mL concentration of the Standard solution.
Response: Comment incorporated. The path length of a 0.02 cm cell is consistent with the
sponsor’s method and avoids the instrument being saturated. Therefore, the path length of a
0.02 cm cell is added to the proposed monograph.
Monograph/Section(s): Hydrogenated Polydextrose/Specific tests, Assay


Comment Summary #1: The commenter suggested to incorporate a note ‘Temperature can be
adjusted depending on titrator’s capability’. This change was suggested under the water
determination test, wherein drift was not getting stabilized at procedure recommended
temperature of 50C. Analysis at 42 C resolved the issue since the drift stabilized below 20
µg/min.
Response: Comment incorporated. As per the stakeholder’s suggestion a note has been added
‘Temperature can be adjusted depending on titrator’s capability.’ This temperature change will
help control the instrument drift.
Comment Summary #2: The commenter suggested to incorporate a note ‘Molecular weights
for the standards can be selected as available commercially, while maintaining the required
calibration range’. This change was suggested under the test molecular weight limit. Since the
use of any of the commercially available standards for the calibration curve does not affect the
final calibration and the results if the standards selected are within the recommended calibration
range.
Response: Comment incorporated. As per the stakeholder’s suggestion, a note has been
added ‘Molecular weights for the standards can be selected as available commercially, while
maintaining the required calibration range.’ This will not have any impact on the calibration
curve as well as the end results.
Comment Summary #3: The commenter suggested removing the details about sensitivity for
RI detector under molecular weight limit. The current value of setting a sensitivity of 4 × 10-6
refractive index units full scale is too specific and mandates the use of specific make of
refractive index detector. Removing this instrument specific requirement will not have any
impact on the sensitivity of the detector and in turn the end results.
Response: Comment incorporated. As per the stakeholder’s suggestion, details about the
sensitivity of the RI detector were deleted as this becomes an instrument specific instruction.
Comment Summary #4: The commenter suggested checking on the inclusion of peaks eluted
at the tailing of the main peak (before dextrose) as a part of the main peak as hydrogenated
polydextrose. It also suggested including a note specifying how to integrate the main peak for
the assay.
Response: Comment incorporated. The Expert Committee determined that the peaks eluting at
the tailing of the main peak as shorter chain polymers and to be included as a part of the main
peak of hydrogenated polydextrose. A note stating, ‘Integrate and include smaller peaks eluted
on the tailing of the Hydrogenated Polydextrose to be included as a part of assay’ was
incorporated in the assay section of the monograph under analysis.
Monograph/Section(s): Linezolid Tablets/Organic Impurities

Comment Summary #1: The commenter requested removing the reporting threshold as it will
vary based on product-specific factors. The commenter also commented that the proposed
reporting threshold at 0.005% is much lower than the ICH reporting threshold.
Response: Comment partially incorporated. Based on comments received on a proposed policy
for reporting thresholds, USP determined that the issue of the removal of reporting thresholds
from monographs needs further stakeholder engagement. USP intends to conduct further
stakeholder engagement. The reporting threshold was widened from 0.005% to 0.05% to be in
line with ICH guidelines and the sensitivity solution concentration was increased from 0.05
ug/mL to 0.5 ug/mL to be in line with the Reporting threshold level.
Comment Summary #2: The commenter indicated that acceptance criterion for any individual
unspecified impurity should be consistent with ICH Q3B guidelines and the acceptance criterion
for Linezolid related compound C is different from what has been approved by the FDA.

Response: Comment incorporated. The acceptance criteria were widened from “NMT 0.15%” to
“NMT 0.17%” for any individual unspecified impurity and from “NMT 0.20%” to “NMT 0.2%” for
Linezolid related compound C, consistent with data provided.
Comment Summary #3: The commenter indicated that impurity profile is missing degradation
products.
this monograph upon receipt of the necessary supporting data.
Monograph/Section(s): Maltodextrin/Identification
Comment Summary #1: Commenters suggested identification by Infrared Spectrometry in lieu

of the identity by Dextrose Equivalent (titrimetry). As the current Assay is not an ideal
identification test, other polysaccharides could react with the cupric tartrate titrant, possibly
generating false positive results.
Response: Comment not incorporated. Comments on this topic may be addressed through a
future Forum proposal based on supporting data.
Monograph/Section(s): Meclofenamate Sodium/Multiple Sections

Comment Summary #1: The commenter recommended tightening the Acceptance criteria for
the Assay from “97.0%-103.0%” to “98.0%–102.0%”.
Response: Comment not incorporated. The Acceptance criteria of 97.0%–103.0%, which
remain unchanged in the proposed proposal, are consistent with what have been approved by
the FDA. The Expert Committee will consider future revisions to the monograph upon receipt of
supporting data, as appropriate.
Comment Summary #2: The commenter requested removing the reporting threshold from the
Organic Impurities test as it will vary based on product-specific factors.
stakeholder engagement
Monograph/Section(s): Pamidronate Disodium for Injection/Assay

Comment summary #1: The commenter recommended including a temperature control for the
refractive index detector at the same temperature as the column and adding a note that the
system should be equilibrated until stable base line is obtained.
Response: Comment not incorporated. The comment is outside the scope of the proposed
revisions. The EC will consider future revisions to the monograph upon receipt of the necessary
supporting data.
Monograph/Section(s): Polyvinyl Alcohol/Definition


Comment Summary #1: The commenter enquired about an update in the chemical formula to
specify that the material is partially hydrolyzed. But there is no such statement in the definition
section to indicate the material is partially hydrolyzed.
Response: Comment not incorporated. The degree of hydrolysis with 85-89% included in the
definition section itself indicates, that the current monograph represents partially hydrolyzed
polyvinyl acetate (to polyvinyl alcohol).
Monograph/Section(s): Potassium Alginate/Impurities

stock solution. The statement was proposed to modify from” ...and 500 µL of lead” to “...and 500
µL of a standard solution containing 1000 mg/L of lead”.
Response: Comment incorporated. As per the suggestion, the statement was modified from
“...and 500 µL of lead” to “...and 500 µL of a standard solution containing 1000 mg/L of lead” for
clarity.
wavelength of yttrium internal standard emission line from “371.030 nm” to “224.306 nm”
because this is much closer to the elements being analyzed.
Response: Comment incorporated. As per the suggestion, the yttrium internal standard
emission line was corrected from “371.030 nm” to “224.306 nm”, since this is much closer to the
elements being analyzed.
Comment Summary #3: Under the Analysis, the commenter suggested removing the
statement related to the in-line addition of the Internal standard solution since it was already
added manually.
Response: Comment incorporated. As per the suggestion, the statement related to the in-line
addition of the Internal standard solution was removed since it was already added manually.
Comment Summary #4: The commenter quoted a USP 2016 Stimuli article which states,”
Unless there is a known quality or safety related reason to maintain the specific elemental
impurity limit(s) currently in place for selected components (drug substance and excipients),
impurity testing of alginate monographs were discussed by the Complex Excipients Expert
Committee. The Expert Committee considered the fact that alginates are naturally derived
monographs. Any such decision, based on the limited data, may risk the overall safety of the
control such materials in terms of quality and safety.
Response: Comment incorporated. Comments related to the lowering of the elemental impurity
limits were considered and discussed with the Complex Excipient Expert Committee. As per the
committee’s recommendations, the limit for lead was kept unchanged at 10 ppm.

Comment Summary #6: The commenter suggested USP not implement lowering the limit of
lead to 5 μg/g. Rather, USP should remove specifications for lead and arsenic from this
monograph. It also said that ICH Q3D already addresses the need for safety control for these
elements in the finished drug products. The commenter quoted USP 2016 Stimuli article which
states, “Unless there is a known quality or safety related reason to maintain the specific
elemental impurity limit(s) currently in place for selected components (drug substance and
excipients), implementation of <232> renders the specific element chapters and limit tests in
monographs as unnecessary”.
Response: Comment partially incorporated. Comments related to the lowering of the elemental
As per the committee’s recommendations, the limit for lead was kept unchanged at 10 ppm.
Comments related to the applicability of elemental impurity testing of alginate monographs were
discussed by the Complex Excipients Expert Committee. The Expert Committee considered the
fact that alginates are naturally derived materials. The committee confirmed that additional data
will be required from different alginate manufacturers to decide on the outright removal of the
elemental testing from alginate monographs. Any such decision, based on the limited data, may
risk the overall safety of the material. The committee determined that it could compromise the
ability of a public standard to control such materials in terms of quality and safety
Monograph/Section(s): Quinapril and Hydrochlorothiazide Tablets /Multiple Sections

EC-initiated Change #1: The phrase "of the labeled amount" was added to the calculation
descriptions within the Assay and the test for Dissolution for clarity and consistency with current
USP style.
Comment Summary #1: The commenter requested removing the reporting threshold from the
Organic Impurities test as it will vary based on product-specific factors.
Comment Summary #2: The commenter requested removing process impurities without
acceptance criteria from the Table 5 in the Organic impurities test. Those include
Chlorothiazide, 5-Chlorohydrochlorothiazide, Hydrochlorothiazide dimer, Quinapril methyl ester,
Quinapril isopropyl ester, Hexahydroquinapril, and Quinapril benzyl ester.
Response: Comment not incorporated. Removing process impurity is outside the scope of this
revision. The Expert Committee may consider future revisions to the monograph upon the
receipt of supporting data.
Monograph/Section(s): Risedronate Sodium Delayed-Release Tablets/Multiple sections

Comment summary #1: The commenter recommended removing the reporting threshold from

Comment summary #2: The commenter recommended lowering the Standard solution
concentration and revising the acceptance criteria for relative standard deviation accordingly in
the test for Organic Impurities to ensure the system precision at impurity quantification level.
Response: Comment not incorporated. The Standard solution concentration of 0.1 mg/mL is
supported by validation data with linearity and accuracy data which covers the unspecified
impurity limit of NMT 0.2%.
Comment summary #3: The commenter requested to replace the Assay and the Organic
Impurities test with their methods, as the commenter found that non-metallic HPLC systems are
not available in the market.
Response: Comment not incorporated. The EC decided to remove the note in the proposal
stating “[NOTE—Use a non-metallic liquid chromatography system for analysis.]” to avoid
possible confusion.
Monograph/Section(s): Rivaroxaban Tablets/Multiple Sections

Comment Summary #2: The commenter requested modifying the preparation of the Standard
stock solution within the test for Dissolution as they observed that rivaroxaban was not soluble.
Response: Comment not incorporated. The expert committee has determined that the solution
preparation as written is suitable for inclusion in the public standard.
Monograph/Section(s): Sodium Alginate/Impurities, Assay

stock solution. The statement was proposed to modify from ”...and 500 µL of lead” to ”...and 500
µL of a standard solution containing 1000 mg/L of lead”.
Response: Comment incorporated to modify “...and 500 µL of lead” to “...and 500 µL of a
standard solution containing 1000 mg/L of lead” for clarity.
the wavelength of yttrium internal standard emission line from “371.030 nm” to “224.306” nm
since this is much closer to the elements being analyzed.
Response: Comment incorporated to correct the internal standard emission line from “371.030
nm” to “224.306 nm.” This wavelength is much closer to the elements being analyzed.
Comment Summary #3: Under the Analysis, the commenter suggested removing the
statement related to in-line addition of internal standard since it was already added manually.
Response: Comment incorporated to remove the statement related to the in-line addition of
internal standard. The internal standard is already being added manually.
Comment Summary #4: In the Assay section of the Sodium Alginate monograph, the
commenter highlighted a typographical error which needed to be corrected from ”Transfer the
filter crucible to a beaker” to ”Transfer the contents of the filter crucible to a beaker”.
Response: Comment incorporated to correct a typographical error from “Transfer the filter
crucible to a beaker” to “Transfer the contents of the filter crucible to a beaker”.

Comment Summary #5: The commenter quoted a USP 2016 Stimuli article which states,
”Unless there is a known quality or safety related reason to maintain the specific elemental
impurity limit(s) currently in place for selected components (drug substance and excipients),
impurity testing of alginate monographs were discussed by the Complex Excipients Expert
Committee. The Expert Committee considered the fact that alginates are naturally derived
monographs. Any such decision, based on the limited data, may risk the overall safety of the
control such materials in terms of quality and safety
Response: Comment incorporated. Specific comments related to the lowering of the elemental
Comments related to the applicability of elemental impurity testing to alginate monographs were
discussed by the Complex Excipients Expert Committee. The expert committee considered the
elemental testing from alginate monographs. Any such decision, based on limited data, may risk
the overall safety of the material. The committee determined that it could compromise the ability
of a public standard to control such materials in terms of quality and safety.
Comment Summary #7: The commenter suggested USP not implement lowering the limit to 5
μg/g. Rather, USP should remove specifications for lead and arsenic from this monograph. It
also said that ICH Q3D already addresses the need for safety control for these elements in the
finished drug products. The commenter quoted USP 2016 Stimuli article which states, ”Unless
there is a known quality or safety related reason to maintain the specific elemental impurity
limit(s) currently in place for selected components (drug substance and excipients),
unnecessary”.
Response: Comment partially incorporated. Comments related to the lowering of the elemental
As per the committee’s recommendations, the limit for lead was kept unchanged at 10 ppm.
Comments related to the applicability of elemental impurity testing to alginate monographs were
discussed by the Complex Excipients Expert Committee. The expert committee considered the
elemental testing from alginate monographs. Any such decision, based on limited data, may risk
the overall safety of the material. The committee determined that it could compromise the ability
of a public standard to control such materials in terms of quality and safety.
Monograph/Section(s): Tinidazole Tablets /Organic Impurities


Monograph/Section(s): Trazodone Hydrochloride Tablets/Organic Impurities

Comment summary #1: The commenter recommended revising the impurity profile based on
complete characterization of degradation products. Furthermore, to remove all process
impurities from the impurity table.
Response: Comment not incorporated. The comment is outside the scope of the revision. The
Expert Committee will consider future revisions to the monograph upon receipt of supporting
data.
Comment summary #2: The commenter recommended tightening the acceptance criterion for
“Any unspecified degradation product” to be consistent with the identification threshold per ICH
Q3B.
data.
Comment summary #3: The commenter recommended removing the reporting threshold in the
Comment summary #4: The commenter recommended deleting the currently official Organic
Impurities test until USP is able to include degradation impurities.
data.
Monograph/Section(s): Triethyl Citrate/Organic Impurities

EC-initiated Change #1: Preparation of standard solutions was changed from one standard
solution containing two reference standards (USP Triethyl Aconitate RS and USP Triethyl
Aconitate RS) to two separate standard solutions each containing only one reference standard
due to the presence of a Z-isomer of triethyl aconitate in USP Triethyl Aconitate RS that
coelutes with triethyl citrate. The System suitability and Analysis sections of the test were
updated to reflect the use of separate standard solutions.
EC-initiated Change #2: In Table 2, triethyl aconitate with relative retention time of 0.98 was
specified as triethyl (E)-prop-1-ene-1,2,3-tricarboxylate.
Monograph/Section(s): Valacyclovir Hydrochloride/Water Determination, Method 1 <921>


Comment Summary #1: The commenter requested revising the lower limit of “5.0%” in the
acceptance criteria (5.0%-11.0%) for the water content to be consistent with the approved
specification.
Response: Comment incorporated. The lower limit was revised from “5.0%” to “3.0%” with the
updated range of “3.0%-11.0% consistent with additional data provided.”
Monograph/Section(s): Valganciclovir Hydrochloride/Multiple sections

Comment Summary #1: The commenter commented that the run time in the Assay is too long
and suggested to shorten the run time until the valganciclovir diastereomer peak 2 eluted
completely.
Response: Comment not incorporated. The expert committee determined that the run time is
consistent with the validation data and suitable for its intended use.
Comment Summary #2: The commenter noted typographical error in the test for organic
impurities calculation that the Relative response factor (Fi) is in denominator in the current
official monograph but in PF proposal, the Fi is in the numerator.
Response: Comment incorporated. The typo has been corrected.
Comment summary #3: The commenter recommended deleting the Tailing factor requirement
in the test for Organic impurities as the Ganciclovir mono-N-methyl valinate peak appears at the
tail of valganciclovir peaks and will interfere with the Tailing factor of valganciclovir diastereomer
peak 2.
Response: Comment not incorporated. The expert committee determined that the proposed
Tailing factor requirement is consistent with the validation data and suitable for its intended use.
Comment Summary #4: The commenter suggested adding the Ganciclovir mono-N-
methylvalinate into Standard solution or System suitability solution and set a resolution
requirement between the Ganciclovir mono-N-methyl valinate peak and valganciclovir
diastereomer peak 2 in the Limit of Ganciclovir Mono-N-methyl Valinate test.
Response: Comment not incorporated. The expert committee determined that the method is
suitable for its intended use. Adding Ganciclovir mono-N-methyl valinate to Standard solution or
System suitability solution can be considered in the future revision if supporting data becomes
available.
Comment Summary #5: The commenter suggested widening the acceptance criterion of
resolution between valganciclovir diastereomer peak 1 and valganciclovir diastereomer peak 2
in the Limit of Ganciclovir Mono-N-methyl Valinate test.
response: Comment not incorporated. The comment is outside the scope of the proposed
revisions. The expert committee will consider future revisions to the monograph upon receipt of
the necessary supporting data.
Comment Summary #6: The commenter noted a typographical error in the calculation under
the Diastereomer Ratio test and recommended to use the Organic Impurities method instead of
the test for Limit of Ganciclovir Mono-N-methyl Valinate to be consistent with the currently
official monograph.
response: Comment incorporated. The typo has been corrected.
Comment Summary #7: The commenter recommended setting the limit of ”Any individual
unspecified impurity” to two decimal places to be consistent with ICH Q3A in the test for Organic
Impurities.

response: Comment not incorporated. The comment is outside the scope of the proposed
revisions. The expert committee will consider future revisions to the monograph upon receipt of
the necessary supporting data.
Comment Summary #8: The commenter recommended retaining the limit of NMT 0.3% for the
sum of two diastereomers of Ganciclovir mono-N-methyl valinate in the Limit of Ganciclovir
Mono-N-methyl Valinate test, to be consistent with currently official monograph.
response: Comment incorporated. The Table 5 is updated to be consistent with the currently
official monograph and a footnote “ ‘b’ - reported as the sum of diastereomers” is added for
clarity.
EC-initiated Changes #1: The calculation in the test for organic impurities is updated from
Result = [(ri × Fi)/(Σri▲Σ(rT▲ (USP 1-Dec-2022)× Fi)] × 100 to
Result = [(ri / Fi)/(Σri[rS +▲Σ(ri▲ (USP 1-Dec-2022) / Fi)] × 100 to be consistent with sponsor validation
data.
EC-initiated Changes #2: The calculation in the Limit of Ganciclovir Mono-N-Methyl Valinate
test is updated from:
▲Result = (rU/ΣrT) × 100▲
To
▲Result = (rU/rT) × 100▲
Where ▲ rT = sum of all the peak responses from the Sample solution
to be consistent with sponsor validation data.
Monograph/Section(s): Valsartan Tablets/Reference Standards <11>

EC-initiated Change #1: The EC added another chemical name based on the reference
standard label and the statement “also known as” for USP Valsartan Related Compound B RS.

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Commentary

USP–NF 2023 Issue 1

For further information, contact:

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

<126> Somatropin Bioidentity Test

General Chapter: <432> Determination of Zeta Potential By Electrophoretic

Development of the Method

General Chapters: <1042> Cell Banking Practices for Recombinant Biologics

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

General Processes and Considerations of Cell Banking

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

PRODUCTION CELL LINE/STRAIN DEVELOPMENT AND RCB GENERATION

Comment Summary #35: Commenter recommends adding references to original publications

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

3.2 PRODUCTION CELL LINES/STRAINS AND RECOMMENDED DOCUMENTATION

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Comment Summary #85: The commenter suggested to include seeding density

4.3 ASSURANCE OF CLONALITY

5. CELL BANK CHARACTERIZATION

Commentary for USP–NF 2023, Issue 1

5.1 CELL BANK QUALIFICATION AND CHARACTERIZATION

Commentary for USP–NF 2023, Issue 1

5.2 MAMMALIAN CELL BANK TESTING

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

5.3 CELL BANK QUALIFICATION AND CHARACTERIZATION

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

5.4 GENERAL CONSIDERATIONS FOR QUALIFICATION OF REPLACEMENT WCBS

5.5 OTHER GENERAL CONSIDERATIONS FOR CELL BANKS

Commentary for USP–NF 2023, Issue 1

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Acetyltriethyl Citrate/Organic Impurities

Monograph/Section(s): Albuterol Tablets/Organic Impurities

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Alginic Acid/Impurities

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Amphetamine Sulfate Tablets/Dissolution

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Atomoxetine Hydrochloride/Organic Impurities

Monograph/Section(s): Calcium Propionate/Multiple sections

Monograph/Section(s): Carboplatin Injection/Organic Impurities

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Carteolol Hydrochloride/Organic Impurities

Monograph/Section(s): Chlorthalidone/Multiple Sections

Monograph/Section(s): Chlorthalidone Tablets/Multiple Sections

Commentary for USP–NF 2023, Issue 1

Monograph/Section(s): Curcuminoids Capsules/Identification, Performance Tests

Monograph/Section(s): Curcuminoids Tablets/Identification, Performance Tests

EC-initiated Change #1: The Expert Committee made a modification in Identification A to