ICH Guideline For Elemental Impurities

INTERNATIONAL CONFERENCE ON HARMONISATION OF TECHNICAL REQUIREMENTS
FOR REGISTRATION OF PHARMACEUTICALS FOR HUMAN USE
ICH HARMONISED GUIDELINE
GUIDELINE FOR ELEMENTAL IMPURITIES

Q3D
Current Step 4 version

dated 16 December 2014
This Guideline has been developed by the appropriate ICH Expert Working Group and has been subject to
consultation by the regulatory parties, in accordance with the ICH Process. At Step 4 of the Process the
final draft is recommended for adoption to the regulatory bodies of the European Union, Switzerland,
Japan, USA and Canada.
Q3D
Document History
Code
History
Date
Q3D
Approval by the Steering Committee under Step 2a.
6 June 2013
Q3D
Approval by the Steering Committee under Step 2b and

release for public consultation.
6 June
2013
14 June
2013
Q3D
Post sign-off corrigendum in:

Table 4.1 W and Al were removed from the list of included
elemental impurities in Class 2B and 3 respectively.
Table A.2.1 the Class for Ni was changed to read 3 instead
of 2.
26 July
2013
Q3D
Post sign-off minor editorial corrections including: removal of

references to Appendix 5 (pgs i & 13); deletion of redundant
text (pg 4); change of Option 2 to Option 2a (pg 10); insertion
of omitted text under Safety Limiting Toxicity (pg 35);
removal of duplicated redundant text (pg 41); replacing
references to metals in text and metal in Table A.4.7 title
with elementals and elements (pg 73); and deletion of
header Table A.4.10 (pg 75).
Q3D
Addition of line numbers to facilitate the provision of

comments by stakeholders.
30 September
2013
Q3D
Approval by the Steering Committee under Step 4 and

recommendation for adoption to the ICH regulatory bodies.
12 November
2014
Current Step 4 version

Code
History
Date
16 December
2014
Q3D
Corrigendum to correct: the modifying factor in the text of the

safety assessment for Selenium (changed to 2 instead of 10
consistent with Section 3.1); and two references for
consistency in the safety assessments for Barium (deleted
reference) and Vanadium (revised reference).
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ICH Harmonised Guideline
Having reached Step 4 of the ICH Process at the ICH Steering Committee meeting on 12 November
2014, this guideline is recommended for adoption
to the regulatory parties to ICH.
TABLE OF CONTENTS
1.
INTRODUCTION ..................................................................................................................................... 1
2.
SCOPE..................................................................................................................................................... 1
3. SAFETY ASSESSMENT OF POTENTIAL ELEMENTAL IMPURITIES ....................................................... 1

3.1 Principles of the Safety Assessment of Elemental Impurities for Oral, Parenteral and Inhalation
Routes of Administration ..............................................................................................................1
3.2 Other Routes of Administration .....................................................................................................2
3.3 Justification for Elemental Impurity Levels Higher than an Established PDE ....................................3
3.4 Parenteral Products .......................................................................................................................4
4.
5.
ELEMENT CLASSIFICATION.................................................................................................................. 4
RISK ASSESSMENT AND CONTROL OF ELEMENTAL IMPURITIES ...................................................... 5
5.1 General Principles ........................................................................................................................5

5.2 Potential Sources of Elemental Impurities ......................................................................................5
5.3 Identification of Potential Elemental Impurities ..............................................................................6
5.4 Recommendations for Elements to be Considered in the Risk Assessment ........................................7
5.5 Evaluation....................................................................................................................................8
5.6 Summary of Risk Assessment Process ...........................................................................................8
5.7 Special Considerations for Biotechnologically-Derived Products .....................................................9
6.
CONTROL OF ELEMENTAL IMPURITIES .......................................................................................9
7.
CONVERTING BETWEEN PDES AND CONCENTRATION LIMITS ...................................................10
8.
SPECIATION AND OTHER CONSIDERATIONS ..................................................................................... 12
9. ANALYTICAL PROCEDURES................................................................................................................ 12
10. LIFECYCLE MANAGEMENT ................................................................................................................ 12
GLOSSARY ................................................................................................................................................... 13
REFERENCES................................................................................................................................................ 17
Appendix 1: Method for Establishing Exposure Limits ......................................................................... 18
Appendix 2: Established PDEs for Elemental Impurities ...................................................................... 21
Appendix 3: Individual Safety Assessments ............................................................................................. 23
Appendix 4: Illustrative Examples............................................................................................................ 68

Q3D
1.
INTRODUCTION
Elemental impurities in drug products may arise from several sources; they may be residual catalysts
that were added intentionally in synthesis or may be present as impurities (e.g., through interactions
with processing equipment or container/closure systems or by being present in components of the drug
product). Because elemental impurities do not provide any therapeutic benefit to the patient, their
levels in the drug product should be controlled within acceptable limits. There are three parts of this
guideline: the evaluation of the toxicity data for potential elemental impurities; the establishment of a
Permitted Daily Exposure (PDE) for each element of toxicological concern; and application of a riskbased approach to control elemental impurities in drug products. An applicant is not expected to
tighten the limits based on process capability, provided that the elemental impurities in drug products
do not exceed the PDEs. The PDEs established in this guideline are considered to be protective of
public health for all patient populations. In some cases, lower levels of elemental impurities may be
warranted when levels below toxicity thresholds have been shown to have an impact on other quality
attributes of the drug product (e.g., element catalyzed degradation of drug substances). In addition, for
elements with high PDEs, other limits may have to be considered from a pharmaceutical quality
perspective and other guidelines should be consulted (e.g., ICH Q3A).
This guideline presents a process to assess and control elemental impurities in the drug product using
the principles of risk management as described in ICH Q9. This process provides a platform for
developing a risk-based control strategy to limit elemental impurities in the drug product.
2.
SCOPE
The guideline applies to new finished drug products (as defined in ICH Q6A and Q6B) and new drug
products containing existing drug substances. The drug products containing purified proteins and
polypeptides (including proteins and polypeptides produced from recombinant or non-recombinant
origins), their derivatives, and products of which they are components (e.g., conjugates) are within the
scope of this guideline, as are drug products containing synthetically produced polypeptides,
polynucleotides, and oligosaccharides.
This guideline does not apply to herbal products, radiopharmaceuticals, vaccines, cell metabolites,
DNA products, allergenic extracts, cells, whole blood, cellular blood components or blood derivatives
including plasma and plasma derivatives, dialysate solutions not intended for systemic circulation, and
elements that are intentionally included in the drug product for therapeutic benefit. This guideline
does not apply to products based on genes (gene therapy), cells (cell therapy) and tissue (tissue
engineering). In some regions, these products are known as advanced therapy medicinal products.
This guideline does not apply to drug products used during clinical research stages of development.
As the commercial process is developed, the principles contained in this guideline can be useful in
evaluating elemental impurities that may be present in a new drug product.
Application of Q3D to existing products is not expected prior to 36 months after publication of the
guideline by ICH.
3.
SAFETY ASSESSMENT OF POTENTIAL ELEMENTAL IMPURITIES
3.1
Principles of the Safety Assessment of Elemental Impurities for Oral, Parenteral and
Inhalation Routes of Administration
The method used for establishing the PDE for each elemental impurity is discussed in detail in
Appendix 1. Elements evaluated in this guideline were assessed by reviewing the publicly available
data contained in scientific journals, government research reports and studies, international regulatory
Guideline for Elemental Impurities

standards (applicable to drug products) and guidance, and regulatory authority research and assessment
reports. This process follows the principles described in ICH Q3C: Residual Solvents. The available
information was reviewed to establish the oral, parenteral and inhalation PDEs. For practical purposes,
the PDEs to be applied to the drug product that are presented in Appendix 2 Table A.2.1 have been
rounded to 1 or 2 significant figures.
A summary safety assessment identifying the critical study for setting a PDE for each element is
included in Appendix 3. There are insufficient data to set PDEs by any route of administration for
iridium, osmium, rhodium, and ruthenium. The PDEs for these elements were established on the basis
of their similarity to palladium.
The factors considered in the safety assessment for establishing the PDE are listed below in
approximate order of relevance:
The likely oxidation state of the element in the drug product;

Human exposure and safety data when it provided applicable information;
The most relevant animal study;
Route of administration;
The relevant endpoint(s).
Standards for daily intake for some of the elemental impurities discussed in this guideline exist for
food, water, air, and occupational exposure. Where appropriate, these standards were considered in
the safety assessment and establishment of the PDEs.
The longest duration animal study was generally used to establish the PDE. When a shorter duration
animal study was considered the most relevant, the rationale was provided in the individual safety
assessment.
Inhalation studies using soluble salts (when available) were preferred over studies using particulates
for inhalation safety assessment and derivation of inhalation PDEs. Depending on available data,
inhalation PDEs were based on either local (respiratory system) or systemic toxicity. For PDEs
established for inhalation (and oral or parenteral routes as applicable), doses were normalized to a 24hour, 7-day exposure.
In the absence of data and/or where data are available but not considered sufficient for a safety
assessment for the parenteral and or inhalation route of administration, modifying factors based on oral
bioavailability were used to derive the PDE from the oral PDE:
Oral bioavailability <1%: divide by a modifying factor of 100;

Oral bioavailability 1% and <50%: divide by a modifying factor of 10;
Oral bioavailability 50% and <90%: divide by a modifying factor of 2; and
Oral bioavailability 90%: divide by a modifying factor of 1.
Where oral bioavailability data or occupational inhalation exposure limits were not available, a
calculated PDE was used based on the oral PDE divided by a modifying factor of 100 (Ref. 1).
3.2
Other Routes of Administration
PDEs were established for oral, parenteral and inhalation routes of administration. When PDEs are
necessary for other routes of administration, the concepts described in this guideline may be used to
derive PDEs. An assessment may either increase or decrease an established PDE. The process of
derivation of the PDE for another route of administration may include the following:
Consider the oral PDE in Appendix 3 as a starting point in developing a route-specific PDE.
Based on a scientific evaluation, the parenteral and inhalation PDEs may be a more appropriate
starting point.
Assess if the elemental impurity is expected to have local effects when administered by the
intended route of administration:

o
3.3
If local effects are expected, assess whether a modification to an established PDE is

necessary.
o Consider the doses/exposures at which these effects can be expected relative to the adverse
effect that was used to set an established PDE.
o If local effects are not expected, no adjustment to an established PDE is necessary.
If available, evaluate the bioavailability of the element via the intended route of administration
and compare this to the bioavailability of the element by the route with an established PDE:
o When a difference is observed, a correction factor may be applied to an established PDE.
For example, when no local effects are expected, if the oral bioavailability of an element is
50% and the bioavailability of an element by the intended route is 10%, a correction factor
of 5 may be applied.
If a PDE proposed for the new route is increased relative to an established PDE, quality
attributes may need to be considered.
Justification for Elemental Impurity Levels Higher than an Established PDE
Levels of elemental impurities higher than an established PDE (see Table A.2.1) may be acceptable in
certain cases. These cases could include, but are not limited to, the following situations:
Intermittent dosing;
Short term dosing (i.e., 30 days or less);
Specific indications (e.g., life-threatening, unmet medical needs, rare diseases).
Examples of justifying an increased level of an elemental impurity using a subfactor approach of a

modifying factor (Ref. 2,3) are provided below. Other approaches may also be used to justify an
increased level. Any proposed level higher than an established PDE should be justified on a case-bycase basis.
Example 1: element X is present in an oral drug product. From the element X monograph in Appendix
3, a No-Observed-Adverse-Effect Level (NOAEL) of 1.1 mg/kg/day was identified. Modifying
factors F1-F5 have been established as 5, 10, 5, 1 and 1, respectively. Using the standard approach for
modifying factors as described in Appendix 1, the PDE is calculated as follows:
PDE = 1.1 mg/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 220 g/day
Modifying factor F2 (default = 10) can be subdivided into two subfactors, one for toxicokinetics (TK)
and one for toxicodynamics, each with a range from 1 to 3.16. Using the plasma half-life of 5 days,
the TK adjustment factor could be decreased to 1.58 for once weekly administration (~1 half-life), and
to 1 for administration once a month (~5 half-lives). Using the subfactor approach for F2, the
proposed level for element X administered once weekly can be calculated as follows:
Proposed level = 1.1 mg/kg/d x 50 kg / 5 x (1.6 x 3.16) x 5 x 1 x 1 = 440 g/day
For practical purposes, this value is rounded to 400 g/day.
Example 2: The TK adjustment factor approach may also be appropriate for elemental impurities that
were not developed using the modifying factor approach. For element Z, a Minimal Risk Level
(MRL) of 0.02 mg/kg/day was used to derive the oral PDE. From literature sources, the plasma halflife was reported to be 4 days. This element is an impurity in an oral drug product administered once
every 3 weeks (~ 5 half-lives). Using first-order kinetics, the established PDE of 1000 g/day is
modified as follows:
Proposed level = 0.02 mg/kg/d x 50 kg / 1/3.16 = 3.16 mg/day
For practical purposes, this value is rounded to 3000 g/day.

3.4
Parenteral Products
Parenteral drug products with maximum daily volumes up to 2 liters may use the maximum daily
volume to calculate permissible concentrations from PDEs. For products whose daily volumes, as
specified by labeling and/or established by clinical practice, may exceed 2 liters (e.g., saline, dextrose,
total parenteral nutrition, solutions for irrigation), a 2-liter volume may be used to calculate
permissible concentrations from PDEs. (Ref. 4)
4.
ELEMENT CLASSIFICATION
The elements included in this guideline have been placed into three classes based on their toxicity
(PDE) and likelihood of occurrence in the drug product. The likelihood of occurrence is derived from
several factors including: probability of use in pharmaceutical processes, probability of being a coisolated impurity with other elemental impurities in materials used in pharmaceutical processes, and
the observed natural abundance and environmental distribution of the element. For the purposes of
this guideline, an element with low natural abundance refers to an element with a reported natural
abundance of < 1 atom/106 atoms of silicon (Ref. 5). The classification scheme is intended to focus
the risk assessment on those elements that are the most toxic but also have a reasonable probability of
inclusion in the drug product (see Table 5.1). The elemental impurity classes are:
Class 1: The elements, As, Cd, Hg, and Pb, are human toxicants that have limited or no use in the
manufacture of pharmaceuticals. Their presence in drug products typically comes from commonly
used materials (e.g., mined excipients). Because of their unique nature, these four elements require
evaluation during the risk assessment, across all potential sources of elemental impurities and routes of
administration. The outcome of the risk assessment will determine those components that may require
additional controls which may in some cases include testing for Class 1 elements. It is not expected
that all components will require testing for Class 1 elemental impurities; testing should only be applied
when the risk assessment identifies it as the appropriate control to ensure that the PDE will be met.
Class 2: Elements in this class are generally considered as route-dependent human toxicants. Class 2
elements are further divided in sub-classes 2A and 2B based on their relative likelihood of occurrence
in the drug product.
Class 2A elements have relatively high probability of occurrence in the drug product and thus
require risk assessment across all potential sources of elemental impurities and routes of
administration (as indicated). The class 2A elements are: Co, Ni and V.
Class 2B elements have a reduced probability of occurrence in the drug product related to their
low abundance and low potential to be co-isolated with other materials. As a result, they may
be excluded from the risk assessment unless they are intentionally added during the manufacture
of drug substances, excipients or other components of the drug product. The elemental
impurities in class 2B include: Ag, Au, Ir, Os, Pd, Pt, Rh, Ru, Se and Tl.
Class 3: The elements in this class have relatively low toxicities by the oral route of administration
(high PDEs, generally > 500 g/day) but may require consideration in the risk assessment for
inhalation and parenteral routes. For oral routes of administration, unless these elements are
intentionally added, they do not need to be considered during the risk assessment. For parenteral and
inhalation products, the potential for inclusion of these elemental impurities should be evaluated
during the risk assessment, unless the route specific PDE is above 500 g/day. The elements in this
class include: Ba, Cr, Cu, Li, Mo, Sb, and Sn.
Other elements: Some elemental impurities for which PDEs have not been established due to their
low inherent toxicity and/or differences in regional regulations are not addressed in this guideline. If
these elemental impurities are present or included in the drug product they are addressed by other
guidelines and/or regional regulations and practices that may be applicable for particular elements (e.g.,
Al for compromised renal function; Mn and Zn for patients with compromised hepatic function), or
quality considerations (e.g., presence of W impurities in therapeutic proteins) for the final drug product.
Some of the elements considered include: Al, B, Ca, Fe, K, Mg, Mn, Na, W and Zn.

5.
RISK ASSESSMENT AND CONTROL OF ELEMENTAL IMPURITIES
In developing controls for elemental impurities in drug products, the principles of quality risk
management, described in ICH Q9, should be considered. The risk assessment should be based on
scientific knowledge and principles. It should link to safety considerations for patients with an
understanding of the product and its manufacturing process (ICH Q8 and Q11). In the case of
elemental impurities, the product risk assessment would therefore be focused on assessing the levels of
elemental impurities in a drug product in relation to the PDEs presented in this guidance. Information
for this risk assessment includes but is not limited to: data generated by the applicant, information
supplied by drug substance and/or excipient manufacturers and/or data available in published literature.
The applicant should document the risk assessment and control approaches in an appropriate manner.
The level of effort and formality of the risk assessment should be proportional to the level of risk. It is
neither always appropriate nor always necessary to use a formal risk management process (using
recognized tools and/or formal procedures, e.g., standard operating procedures.) The use of informal
risk management processes (using empirical tools and/or internal procedures) may also be considered
acceptable. Tools to assist in the risk assessment are described in ICH Q8 and Q9 and will not be
presented in this guideline.
5.1
General Principles
For the purposes of this guideline, the risk assessment process can be described in three steps:
Identify known and potential sources of elemental impurities that may find their way into the
drug product.
Evaluate the presence of a particular elemental impurity in the drug product by determining the
observed or predicted level of the impurity and comparing with the established PDE.
Summarize and document the risk assessment. Identify if controls built into the process are
sufficient or identify additional controls to be considered to limit elemental impurities in the
drug product.
In many cases, the steps are considered simultaneously. The outcome of the risk assessment may be
the result of iterations to develop a final approach to ensure the potential elemental impurities do not
exceed the PDE.
5.2
Potential Sources of Elemental Impurities
In considering the production of a drug product, there are broad categories of potential sources of
elemental impurities.
Residual impurities resulting from elements intentionally added (e.g., catalysts) in the formation
of the drug substance, excipients or other drug product components. The risk assessment of the
drug substance should address the potential for inclusion of elemental impurities in the drug
product.
Elemental impurities that are not intentionally added and are potentially present in the drug
substance, water or excipients used in the preparation of the drug product.
Elemental impurities that are potentially introduced into the drug substance and/or drug product
from manufacturing equipment.
Elemental impurities that have the potential to be leached into the drug substance and drug
product from container closure systems.
The following diagram shows an example of typical materials, equipment and components used in the
production of a drug product. Each of these sources may contribute elemental impurities to the drug
product, through any individual or any combination of the potential sources listed above. During the
risk assessment, the potential contributions from each of these sources should be considered to
determine the overall contribution of elemental impurities to the drug product.

Manufacturing
equipment *
Drug
Substance
Elemental
impurities
in drug
Product
Water **
Container
Closure
System
Excipients
* The risk of inclusion of elemental impurities can be reduced through process understanding, equipment
selection, equipment qualification and Good Manufacturing Practice (GMP) processes.
** The risk of inclusion of elemental impurities from water can be reduced by complying with compendial (e.g.,
European Pharmacopoeia, Japanese Pharmacopoeia, US Pharmacopeial Convention) water quality requirements,
if purified water or water for injection is used in the manufacturing process(es).
5.3
Identification of Potential Elemental Impurities
Potential elemental impurities derived from intentionally added catalysts and inorganic
reagents: If any element listed in Table 5.1 is intentionally added, it should be considered in the risk
assessment. For this category, the identity of the potential impurities is known and techniques for
controlling the elemental impurities are easily characterized and defined.
Potential elemental impurities that may be present in drug substances and/or excipients: While
not intentionally added, some elemental impurities may be present in some drug substances and/or
excipients. The possibility for inclusion of these elements in the drug product should be reflected in
the risk assessment.
For the oral route of administration, the risk assessment should evaluate the possibility for inclusion of
Class 1 and Class 2A elemental impurities in the drug product. For parenteral and inhalation routes of
administration, the risk assessment should evaluate the possibility for inclusion of the Class 1, Class
2A and Class 3 elemental impurities as shown in Table 5.1.
Potential elemental impurities derived from manufacturing equipment: The contribution of
elemental impurities from this source may be limited and the subset of elemental impurities that should
be considered in the risk assessment will depend on the manufacturing equipment used in the
production of the drug product. Application of process knowledge, selection of equipment, equipment
qualification and GMP controls ensure a low contribution from manufacturing equipment. The
specific elemental impurities of concern should be assessed based on knowledge of the composition of
the components of the manufacturing equipment that come in contact with components of the drug
product. The risk assessment of this source of elemental impurities is one that can potentially be
utilized for many drug products using similar process trains and processes.
In general, the processes used to prepare a given drug substance are considerably more aggressive than
processes used in preparing the drug product when assessed relative to the potential to leach or remove
elemental impurities from manufacturing equipment. Contributions of elemental impurities from drug
product processing equipment would be expected to be lower than contributions observed for the drug
substance. However, when this is not the case based on process knowledge or understanding, the

applicant should consider the potential for incorporation of elemental impurities from the drug product
manufacturing equipment in the risk assessment (e.g., hot melt extrusion).
Elemental impurities leached from container closure systems: The identification of potential
elemental impurities that may be introduced from container closure systems should be based on a
scientific understanding of likely interactions between a particular drug product type and its packaging.
When a review of the materials of construction demonstrates that the container closure system does not
contain elemental impurities, no additional risk assessment needs to be performed. It is recognized
that the probability of elemental leaching into solid dosage forms is minimal and does not require
further consideration in the risk assessment. For liquid and semi-solid dosage forms there is a higher
probability that elemental impurities could leach from the container closure system during the shelflife of the product. Studies to understand potential leachables from the container closure system (after
washing, sterilization, irradiation, etc.) should be performed. This source of elemental impurities will
typically be addressed during evaluation of the container closure system for the drug product.
Factors that should be considered (for liquid and semi-solid dosage forms) include but are not limited
to:
Hydrophilicity/hydrophobicity;
Ionic content;
pH;
Temperature (cold chain vs room temperature and processing conditions);
Contact surface area;
Container/component composition;
Terminal sterilization;
Packaging process;
Component sterilization;
Duration of storage.
5.4
Recommendations for Elements to be Considered in the Risk Assessment
The following table provides recommendations for inclusion of elemental impurities in the risk
assessment. This table can be applied to all sources of elemental impurities in the drug product.
Table 5.1: Elements to be Considered in the Risk Assessment
Element
Cd
Pb
As
Hg
Co
V
Ni
Tl
Au
Pd
Ir
Os
Rh
Ru
Se
Class
If intentionally
added (all routes)
1
1
1
1
2A
2A
2A
2B
2B
2B
2B
2B
2B
2B
2B
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
If not intentionally added

Oral
yes
yes
yes
yes
yes
yes
yes
no
no
no
no
no
no
no
no
Parenteral
yes
yes
yes
yes
yes
yes
yes
no
no
no
no
no
no
no
no
Inhalation
yes
yes
yes
yes
yes
yes
yes
no
no
no
no
no
no
no
no

Ag
Pt
Li
Sb
Ba
Mo
Cu
Sn
Cr
2B
2B
3
3
3
3
3
3
3
5.5
Evaluation
yes
yes
yes
yes
yes
yes
yes
yes
yes
no
no
no
no
no
no
no
no
no
no
no
yes
yes
no
no
yes
no
no
no
no
yes
yes
yes
yes
yes
yes
yes
As the potential elemental impurity identification process is concluded, there are two possible
outcomes:
1) The risk assessment process does not identify any potential elemental impurities. The
conclusion of the risk assessment and supporting information and data should be documented.
2) The risk assessment process identifies one or more potential elemental impurities. For any
elemental impurities identified in the process, the risk assessment should consider if there are
multiple sources of the identified elemental impurity or impurities and document the conclusion
of the assessment and supporting information.
The applicants risk assessment can be facilitated with information about the potential elemental
impurities provided by suppliers of drug substances, excipients, container closure systems, and
manufacturing equipment. The data that support this risk assessment can come from a number of
sources that include, but are not limited to:
Prior knowledge;
Published literature;
Data generated from similar processes;
Supplier information or data;
Testing of the components of the drug product;
Testing of the drug product.
During the risk assessment, a number of factors that can influence the level of the potential impurity in
the drug product and should also have been considered in the risk assessment. These include but are
not limited to:
Efficiency of removal of elemental impurities during further processing;
Natural abundance of elements (especially important for the categories of elements which are
not intentionally added);

Prior knowledge of elemental impurity concentration ranges from specific sources;
The composition of the drug product.
5.6
Summary of Risk Assessment Process
The risk assessment is summarized by reviewing relevant product or component specific data
combined with information and knowledge gained across products or processes to identify the
significant probable elemental impurities that may be observed in the drug product.
The summary should consider the significance of the observed or predicted level of the elemental
impurity relative to the PDE of the elemental impurity. As a measure of the significance of the
observed elemental impurity level, a control threshold is defined as a level that is 30% of the
established PDE in the drug product. The control threshold may be used to determine if additional
controls may be required.

If the total elemental impurity level from all sources in the drug product is expected to be consistently
less than 30% of the PDE, then additional controls are not required, provided the applicant has
appropriately assessed the data and demonstrated adequate controls on elemental impurities.
If the risk assessment fails to demonstrate that an elemental impurity level is consistently less than the
control threshold, controls should be established to ensure that the elemental impurity level does not
exceed the PDE in the drug product. (See Section 6)
The variability of the level of an elemental impurity should be factored into the application of the
control threshold to drug products. Sources of variability may include:
Variability of the analytical method;
Variability of the elemental impurity level in the specific sources;
Variability of the elemental impurity level in the drug product.
At the time of submission, in the absence of other justification, the level and variability of an elemental
impurity can be established by providing the data from three (3) representative production scale lots or
six (6) representative pilot scale lots of the component or components or drug product. For some
components that have inherent variability (e.g., mined excipients), additional data may be needed to
apply the control threshold.
There are many acceptable approaches to summarizing and documenting the risk assessment that may
include: tables, written summaries of considerations and conclusions of the assessment. The summary
should identify the elemental impurities, their sources, and the controls and acceptance criteria as
needed.
5.7
Special Considerations for Biotechnologically-Derived Products
For biotechnology-derived products, the risks of elemental impurities being present at levels that raise
safety concerns at the drug substance stage are considered low. This is largely because: a) elements
are not typically used as catalysts or reagents in the manufacturing of biotech products; b) elements are
added at trace levels in media feeds during cell culture processes, without accumulation and with
significant dilution/removal during further processing; c) typical purification schemes used in biotech
manufacturing such as extraction, chromatography steps and dialysis or Ultrafiltration-Diafiltration
(UF/DF) have the capacity to clear elements introduced in cell culture/fermentation steps or from
contact with manufacturing equipment to negligible levels. As such, specific controls on elemental
impurities up to the biotech drug substance are generally not needed. In cases where the
biotechnology-derived drug substance contains synthetic structures (such as antibody-drug conjugates),
appropriate controls on the small molecule component for elemental impurities should be evaluated.
However, potential elemental impurity sources included in drug product manufacturing (e.g.,
excipients) and other environmental sources should be considered for biotechnologically-derived drug
products. The contribution of these sources to the finished product should be assessed because they
are typically introduced in the drug product manufacture at a step in the process where subsequent
elemental impurity removal is not generally performed. Risk factors that should be considered in this
assessment should include the type of excipients used, the processing conditions and their
susceptibility to contamination by environmental factors (e.g., controlled areas for sterile
manufacturing and use of purified water) and overall dosing frequency.
6.
CONTROL OF ELEMENTAL IMPURITIES
Control of elemental impurities is one part of the overall control strategy for a drug product that
assures that elemental impurities do not exceed the PDEs. When the level of an elemental impurity
may exceed the control threshold, additional measures should be implemented to assure that the level
does not exceed the PDE. Approaches that an applicant can pursue include but are not limited to:
Modification of the steps in the manufacturing process that result in the reduction of elemental
impurities below the control threshold through specific or non-specific purification steps;
Implementation of in-process or upstream controls, designed to limit the concentration of the

elemental impurity below the control threshold in the drug product;
Establishment of specification limits for excipients or materials (e.g., synthetic intermediates);
Establishment of specification limits for the drug substance;
Establishment of specification limits for the drug product;
Selection of appropriate container closure systems.
Periodic testing may be applied to elemental impurities according to the principles described in ICH
Q6A.
The information on the control of elemental impurities that is provided in a regulatory submission
includes, but is not limited to, a summary of the risk assessment, appropriate data as necessary, and a
description of the controls established to limit elemental impurities.
7.
CONVERTING BETWEEN PDES AND CONCENTRATION LIMITS
The PDEs, reported in micrograms per day (g/day) provided in this document give the maximum
permitted quantity of each element that may be contained in the maximum daily intake of a drug
product. Because the PDE reflects only total exposure from the drug product, it is useful to convert
the PDE, into concentrations as a tool in evaluating elemental impurities in drug products or their
components. The options listed in this section describe some acceptable approaches to establishing
concentrations of elemental impurities in drug products or components that would assure that the drug
product does not exceed the PDEs. The applicant may select any of these options as long as the
resulting permitted concentrations assure that the drug product does not exceed the PDEs. In the
choice of a specific option the applicant must have knowledge of, or make assumptions about, the
daily intake of the drug product. The permitted concentration limits may be used:
As a tool in the risk assessment to compare the observed or predicted levels to the PDE;
In discussions with suppliers to help establish upstream controls that would assure that the
product does not exceed the PDE;
To establish concentration targets when developing in-process controls on elemental impurities;
To convey information regarding the controls on elemental impurities in regulatory submissions.
As discussed in Section 5.2, there are multiple sources of elemental impurities in drug products. When
applying any of the options described below, elemental impurities from container closure systems and
manufacturing equipment should be taken into account before calculating the maximum permitted
concentration in the remaining components (excipients and drug substance). If it is determined during
the risk assessment that the container closure systems and manufacturing equipment do not contribute
to the elemental impurity level in the drug product, they do not need to be considered. Where
contributions from container closure systems and manufacturing equipment exist, these contributions
may be accounted for by subtracting the estimated daily intake from these sources from the PDE
before calculation of the allowed concentration in the excipients and drug substance.
Option 1: Common permitted concentration limits of elements across drug product components
for drug products with daily intakes of not more than 10 grams:
This option is not intended to imply that all elements are present at the same concentration, but rather
provides a simplified approach to the calculations.
The option assumes the daily intake (amount) of the drug product is 10 grams or less, and that
elemental impurities identified in the risk assessment (the target elements) are present in all
components of the drug product. Using Equation 1 below, and a daily intake of 10 grams of drug
product, this option calculates a common permissible target elemental concentration for each
component in the drug. This approach, for each target element, allows determination of a fixed
common maximum concentration in micrograms per gram in each component. The permitted
concentrations are provided in Appendix 2, Table A.2.2.
10
Concentrat ion ( g / g )
PDE ( g / day)
daily amount of drug product ( g / day )
(1)
If all the components in a drug product do not exceed the Option 1 concentrations for all target
elements identified in the risk assessment, then all these components may be used in any proportion in
the drug product. An example using this option is shown in Appendix 4, Table A.4.2. If the permitted
concentrations in Appendix 2, Table A.2.2 are not applied, Options 2a, 2b, or 3 should be followed.
Option 2a: Common permitted concentration limits across drug product components for a drug
product with a specified daily intake:
This option is similar to Option 1, except that the drug daily intake is not assumed to be 10 grams. The
common permitted concentration of each element is determined using Equation 1 and the actual
maximum daily intake.
This approach, for each target element, allows determination of a fixed common maximum
concentration in micrograms per gram in each component based on the actual daily intake provided.
An example using this option is provided in Appendix 4, Table A.4.3.
If all components in a drug product do not exceed the Option 2a concentrations for all target elements
identified in the risk assessment, then all these components may be used in any proportion in the drug
product.
Option 2b: Permitted concentration limits of elements in individual components of a product
with a specified daily intake:
This option requires additional information that the applicant may assemble regarding the potential for
specific elemental impurities to be present in specific drug product components. The applicant may
set permitted concentrations based on the distribution of elements in the components (e.g., higher
concentrations in components with the presence of an element in question). For each element
identified as potentially present in the components of the drug product, the maximum expected mass of
the elemental impurity in the final drug product can be calculated by multiplying the mass of each
component material times the permitted concentration established by the applicant in each material and
summing over all components in the drug product, as described in Equation 2. The total mass of the
elemental impurity in the drug product should comply with the PDEs given in Appendix 2, Table
A.2.1. unless justified according to other relevant sections of this guideline. If the risk assessment has
determined that a specific element is not a potential impurity in a specific component, there is no need
to establish a quantitative result for that element in that component. This approach allows that the
maximum permitted concentration of an element in certain components of the drug product may be
higher than the Option 1 or Option 2a limit, but this should then be compensated by lower allowable
concentrations in the other components of the drug product. Equation 2 may be used to demonstrate
that component-specific limits for each element in each component of a drug product assure that the
PDE will be met.
N
PDEg day C k M k
(2)
k 1
k=
Ck =
Mk =
an index for each of N components in the drug product

permitted concentration of the elemental impurity in component k (g/g)
mass of component k in the maximum daily intake of the drug product (g)
An example using this option is provided in Appendix 4 Tables A.4.4 A.4.5.

Option 3: Finished Product Analysis:
The concentration of each element may be measured in the final drug product. Equation 1 may be
used with the maximum total daily dose of the drug product to calculate a maximum permitted
concentration of the elemental impurity. An example using this option is provided in Appendix 4,
Table A.4.6.
11

8.
SPECIATION AND OTHER CONSIDERATIONS
Speciation is defined as the distribution of elements among chemical species including isotopic
composition, electronic or oxidation state, and/or complex or molecular structure. When the toxicities
of different species of the same element are known, the PDE has been established using the toxicity
information on the species expected to be in the drug product.
When elemental impurity measurements are used in the risk assessment, total elemental impurity
levels in drug products may be used to assess compliance with the PDEs. The applicant is not
expected to provide speciation information; however, such information could be used to justify lower
or higher levels when the identified species is more or less toxic, respectively, than the species used in
the monographs in Appendix 3.
When total elemental impurity levels in components are used in the risk assessment, the applicant is
not expected to provide information on release of an elemental impurity from the component in which
it is found. However, such information could be used to justify levels higher than those based on the
total elemental impurity content of the drug product.
9.
ANALYTICAL PROCEDURES
The determination of elemental impurities should be conducted using appropriate procedures suitable
for their intended purposes. Unless otherwise justified, the test should be specific for each elemental
impurity identified for control during the risk assessment. Pharmacopoeial procedures or suitable
alternative procedures for determining levels of elemental impurities should be used.
10.
LIFECYCLE MANAGEMENT
The quality systems and management responsibilities described in ICH Q10 are intended to encourage
the use of science-based and risk-based approaches at each lifecycle stage, thereby promoting
continual improvement across the entire product lifecycle. Product and process knowledge should be
managed from development through the commercial life of the product up to and including product
discontinuation.
Knowledge gained from development combined with commercial manufacturing experience and data
can be used to further improve process understanding and process performance. Such improvements
can enhance controls on elemental impurities. It is recognized that the elemental impurity data
available for some components is somewhat limited at the date of publication of this guideline, which
may direct the applicant to a specific set of controls. Additional data, if developed, may lead to
modifications of the controls.
If changes to the drug product or components have the potential to change the elemental impurity
content of the drug product, the risk assessment, including established controls for elemental
impurities, should be re-evaluated. Such changes could include, but are not limited to: changes in
synthetic routes, excipient suppliers, raw materials, processes, equipment, container closure systems or
facilities. All changes are subject to internal change management process (ICH Q10) and if needed
appropriate regional regulatory requirements.
12

GLOSSARY
ACGIH:
American Conference of Governmental Industrial Hygienists.
ATSDR:
Agency for Toxic Substances and Disease Registry.
CEC:
Commission of the European Community.
CFR:
Code of Federal Regulations. (USA)
Change Management:
A systematic approach to proposing, evaluating, approving, implementing and reviewing changes.
(ICH Q10)
CICAD:
Concise International Chemical Assessment Documents. (WHO)
Container Closure System:
The sum of packaging components that together contain and protect the dosage form. This includes
primary packaging components and secondary packaging components, if the latter are intended to
provide additional protection to the drug product. A packaging system is equivalent to a container
closure system. (ICH Q1A)
Control Strategy:
A planned set of controls, derived from current product and process understanding, that assures
process performance and product quality. The controls can include parameters and attributes related to
drug substance and drug product materials and components, facility and equipment operating
conditions, in-process controls, finished product specifications, and the associated methods and
frequency of monitoring and control. (ICH Q10)
Control Threshold:
A limit that is applied during the assessment of elemental impurities to determine if additional control
elements may be required to ensure that the PDE is not exceeded in the drug product. The limit is
defined as 30% of the PDE of the specific elemental impurity under consideration.
Daily Dose:
The total mass of drug product that is consumed by a patient on a daily basis.
EFSA:
European Food Safety Agency.
EHC:
Environmental Health Criteria. (IPCS, WHO)
EU SCOEL:
European Scientific Committee on Occupational Exposure Limits.
EU SEG:
European Union Scientific Expert Group.
Herbal Products:
Medicinal products containing, exclusively, plant material and/or vegetable drug preparations as active
ingredients. In some traditions, materials of inorganic or animal origin can also be present.
13

IARC:
International Agency for Research on Cancer.
Inhalation Unit Risk:
The upper-bound excess lifetime cancer risk estimated to result from continuous exposure to an agent
at a concentration of 1 g/L in water, or 1 g/m3 in air. The interpretation of inhalation unit risk
would be as follows: if unit risk = 2 x 10-6 per g/L, 2 excess cancer cases (upper bound estimate) are
expected to develop per 1,000,000 people if exposed daily for a lifetime to 1 g of the chemical in 1
liter of drinking water. (US EPA)
IPCS:
International Programme for Chemical Safety.
IUPAC:
International Union of Pure and Applied Chemistry.
IRIS:
Integrated Risk Identification System, United States Environmental Protection Agency.
LOAEL:
Lowest-Observed-Adverse-Effect Level: Lowest concentration or amount of a substance (dose), found
by experiment or observation, that causes an adverse effect on morphology, functional capacity,
growth, development, or life span of a target organism distinguishable from normal (control)
organisms of the same species and strain under defined conditions of exposure. (IUPAC)
LoQ:
Limit of Quantitation: The quantitation limit of an individual analytical procedure is the lowest amount
of analyte in a sample which can be quantitatively determined with suitable precision and accuracy.
The quantitation limit is a parameter of quantitative assays for low levels of compounds in sample
matrices, and is used particularly for the determination of impurities and/or degradation products. (ICH
Q2)
LOEL:
Lowest-Observed-Effect Level: The lowest dose of substance in a study or group of studies that
produces biologically significant increases in frequency or severity of any effects in the exposed
humans or animals.
Modifying Factor:
An individual factor determined by professional judgment of a toxicologist and applied to bioassay
data to relate that data to human safety. (ICH Q3C) (See related term Safety Factor)
MRL:
Minimal Risk Level: An estimate of the daily human exposure to a hazardous substance that is likely
to be without appreciable risk. (ATSDR)
NAS:
National Academy of Science. (USA)
NOAEL:
No-Observed-Adverse-Effect Level: Greatest concentration or amount of a substance, found by
experiment or observation, that causes no detectable adverse alteration of morphology, functional
capacity, growth, development, or life span of the target organism under defined conditions of
exposure.
14

NOEL:
No-Observed-Effect Level: The highest dose of substance at which there are no biologically
significant increases in frequency or severity of any effects in the exposed humans or animals.
NTP:
National Toxicology Program. (USA)
OEHHA:
Office of Environmental Health Hazard Assessment. (California, USA)
OELV:
Occupational Exposure Limit Value.
OSHA:
Occupational Safety and Health Administration. (USA)
PEL:
Permitted Exposure Limit.
PDE:
Permitted Daily Exposure: The maximum acceptable intake of elemental impurity in pharmaceutical
products per day.
Product Lifecycle:
All phases in the life of the product from the initial development through marketing until the products
discontinuation. (ICH Q9)
Quality:
The degree to which a set of inherent properties of a product, system, or process fulfills requirements
(see ICH Q6A definition specifically for quality of drug substance and drug products). (ICH Q9)
Quality Risk Management:
A systematic process for the assessment, control, communication, and review of risks to the quality of
the drug product across the product lifecycle. (ICH Q9)
Quality System:
The sum of all aspects of a system that implements quality policy and ensures that quality objectives
are met. (ICH Q10)
Risk:
The combination of the probability of occurrence of harm and the severity of that harm. (ISO/IEC
Guide 51, ICH Q9)
Risk Acceptance:
The decision to accept risk. (ISO Guide 73)
Risk Analysis:
The estimation of the risk associated with the identified hazards. (ICH Q9)
Risk Assessment:
A systematic process of organizing information to support a risk decision to be made within a risk
management process. It consists of the identification of hazards and the analysis and evaluation of
risks associated with exposure to those hazards. (ICH Q9)
Risk Control:
Actions implementing risk management decisions. (ISO Guide 73)
15

Risk Identification:
The systematic use of information to identify potential sources of harm (hazards) referring to the risk
question or problem description. (ICH Q9)
Risk Management:
The systematic application of quality management policies, procedures, and practices to the tasks of
assessing, controlling, communicating, and reviewing risk. (ICH Q9)
Safety:
Practical certainty that adverse effects will not result from exposure to an agent under defined
circumstances. (Ref. 2)
Safety Assessment:
An approach that focuses on the scientific understanding and measurement of chemical hazards as well
as chemical exposures, and ultimately the risks associated with them. This term is often (and in this
guideline) used synonymously with risk assessment. (Ref. 2)
Safety Factor:
A composite (reductive) factor applied by the risk assessment experts to the NOAEL or other reference
point, such as the benchmark dose or benchmark dose lower confidence limit, to derive a reference
dose that is considered safe or without appreciable risk, such as an acceptable daily intake or tolerable
daily intake (the NOAEL or other reference point is divided by the safety factor to calculate the
reference dose). The value of the safety factor depends on the nature of the toxic effect, the size and
type of population to be protected, and the quality of the toxicological information available. See
related terms: Assessment factor, Uncertainty factor. (Ref. 2)
Severity:
A measure of the possible consequences of a hazard. (ICH Q9)
TLV:
Threshold Limit Value: The concentration in air to which it is believed that most workers can be
exposed daily without an adverse effect (i.e., effectively, the threshold between safe and dangerous
concentrations). The values were established (and are revised annually) by the ACGIH and are timeweighted concentrations (TWA) for a 7- or 8-hour workday and 40-hour workweek, and thus related to
chronic effects. (IUPAC
TWA:
Time Weighted Average: As defined by ACGIH, time-weighted average concentration for a
conventional 8-hour workday and a 40-hour workweek. (IUPAC)
URF:
Unit Risk Factor.
US DoL:
United States Department of Labor.
US EPA:
United States Environmental Protection Agency.
WHO:
World Health Organization.
16

REFERENCES
1. Ball D, Blanchard J, Jacobson-Kram D, McClellan R, McGovern T, Norwood DL et al.
Development of safety qualification thresholds and their use in orally inhaled and nasal drug
product evaluation. Toxicol Sci 2007;97(2):226-36.
2. IPCS. Principles and methods for the risk assessment of chemicals in food, chapter 5: doseresponse assessment and derivation of health based guidance values. Environmental Health
Criteria 240. International Programme on Chemical Safety. World Health Organization,
Geneva. 2009;Table 5.5.
3. US EPA. 0410 Boron and Compounds. Integrated Risk Management System (IRIS). 2004.
4. Holliday MA, Segar WE. The maintenance need for water in parenteral fluid therapy.
Pediatrics 1957;19:823-32.
5. Haxel GB, Hedrick JB, Orris GJ. Rare earth elements-critical resources for high technology.
US Geological Survey 2005;Fact Sheet 087-02.
17

Appendix 1: Method for Establishing Exposure Limits
For most elements, acceptable exposure levels for elemental impurities in this guideline were
established by calculation of PDE values according to the procedures for setting exposure limits in
pharmaceuticals (Ref. 1), and the method adopted by International Programme for Chemical Safety
(IPCS) for Assessing Human Health Risk of Chemicals (Ref. 2). These methods are similar to those
used by the United States Environmental Protection Agency (US EPA) Integrated Risk Information
System, the United States Food and Drug Administration (US FDA) (Ref. 3) and others. The method
is outlined here to give a better understanding of the origin of the PDE values. When an MRL was
used to set the PDE, no additional modifying factors were used as they are incorporated into the
derivation of the MRL. For carcinogenic elements unit risk factors were used to set the PDE using a
1:100000 risk level; these are described in the individual monographs in Appendix 3. Some PDEs for
inhalation were derived using occupational exposure limits, applying modifying factors, and
considering any specific effects to the respiratory system.
The PDE is derived from the No-Observed-Effect Level (NO[A]EL), or the Lowest-Observed-Effect
Level (LO[A]EL) in the most relevant animal study as follows:
PDE = NO(A)EL x Mass Adjustment/[F1 x F2 x F3 x F4 x F5] (A.1.1)
The PDE is derived preferably from a NO(A)EL. If no NO(A)EL is obtained, the LO(A)EL may be
used. Modifying factors proposed here, for relating the data to humans, are the same kind of
"uncertainty factors" used in Environmental Health Criteria (Ref. 2), and "modifying factors" or
"safety factors" in Pharmacopeial Forum.
The modifying factors are as follows:
F1 = A factor to account for extrapolation between species
F1 = 1 for human data
F1 = 5 for extrapolation from rats to humans
F1 = 12 for extrapolation from mice to humans
F1 = 2 for extrapolation from dogs to humans
F1 = 2.5 for extrapolation from rabbits to humans
F1 = 3 for extrapolation from monkeys to humans
F1 = 10 for extrapolation from other animals to humans
F1 takes into account the comparative surface area: body mass ratios for the species concerned and for
man. Surface area (S) is calculated as:
S = kM0.67
(A.1.2)
in which M = body mass, and the constant k has been taken to be 10. The body masses used in
Equation A.1.2 are those shown below in Table A.1.1.
F2 = A factor of 10 to account for variability between individuals
A factor of 10 is generally given for all elemental impurities, and 10 is used consistently in this
guideline
F3 = A variable factor to account for toxicity studies of short-term exposure
F3 = 1 for studies that last at least one half lifetime (1 year for rodents or rabbits; 7 years for cats, dogs
and monkeys)
F3 = 1 for reproductive studies in which the whole period of organogenesis is covered
F3 = 2 for a 6-month study in rodents, or a 3.5-year study in non-rodents
F3 = 5 for a 3-month study in rodents, or a 2-year study in non-rodents
18

F3 = 10 for studies of a shorter duration
In all cases, the higher factor has been used for study durations between the time points, e.g., a factor
of 2 for a 9-month rodent study.
F4 = A factor that may be applied in cases of severe toxicity, e.g., non-genotoxic carcinogenicity,
neurotoxicity or teratogenicity. In studies of reproductive toxicity, the following factors are used:
F4 = 1 for fetal toxicity associated with maternal toxicity
F4 = 5 for fetal toxicity without maternal toxicity
F4 = 5 for a teratogenic effect with maternal toxicity
F4 = 10 for a teratogenic effect without maternal toxicity
F5 = A variable factor that may be applied if the NOEL was not established
F5 = 1 for a NOEL
F5 = 1-5 for a NOAEL
F5 = 5-10 for a LOEL
F5 = 10 for a Lowest-Observed-Adverse-Effect Level (LOAEL)
For most elements the NOAEL was used to set the oral PDE, using a F5 of 1, as the studies did not
investigate the difference between a NOAEL and NOEL and the toxicities were not considered
adverse at the dose selected for determining the PDE.
The mass adjustment assumes an arbitrary adult human body mass for either sex of 50 kg. This
relatively low mass provides an additional safety factor against the standard masses of 60 kg or 70 kg
that are often used in this type of calculation. It is recognized that some patients weigh less than 50
kg; these patients are considered to be accommodated by the built-in safety factors used to determine a
PDE and that lifetime studies were often used. For lead, the pediatric population is considered the
most sensitive population, and data from this population were used to set the PDE. Therefore, the
PDEs are considered appropriate for pharmaceuticals intended for pediatric populations.
As an example of the application of Equation A.1.1, consider a toxicity study of cobalt in human
volunteers as summarized in Tvermoes (Ref. 4). The NOAEL for polycythemia is 1 mg/day. The PDE
for cobalt in this study is calculated as follows:
PDE = 1 mg/day /[1 x 10 x 2 x 1 x 1] = 0.05 mg/day= 50 g/day
In this example,
F1 = 1 study in humans
F2 = 10 to account for differences between individual humans
F3 = 2 because the duration of the study was 90 days
F4 = 1 because no severe toxicity was encountered
F5 = 1 because a NOAEL was used
Table A.1.1: Values Used in the Calculations in this Document
Rat body weight
425 g
Mouse respiratory volume
Pregnant rat body weight
330 g
Rabbit respiratory volume
Mouse body weight
28 g
Guinea pig respiratory volume
Pregnant mouse body weight
30 g
Human respiratory volume
Guinea pig body weight
500 g
Dog respiratory volume
Rhesus monkey body weight
2.5 kg
Monkey respiratory volume
Rabbit body weight
4 kg
Mouse water consumption
(pregnant or not)
Beagle dog body weight
11.5 kg
Rat water consumption
Rat respiratory volume
290 L/day Rat food consumption
19
43 L/day
1440 L/day
430 L/day
28,800 L/day
9,000 L/day
1,150 L/day
5 mL/day
30 mL/day
30 g/day

References
1. United States Pharmacopeial Convention, Pharmacopeial Forum, Nov-Dec 1989.
2. IPCS. Assessing Human Health Risks of Chemicals: Derivation of Guidance Values for
Health-based Exposure Limits, Environmental Health Criteria 170. International Programme
on Chemical Safety. World Health Organization, Geneva. 1994.
3. US FDA, Guidance for Industry and Other Stakeholders: Toxicological Principles for the
Safety
Assessment
of
Food
Ingredients
(Redbook
2000),
available
at
http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/In
gredientsAdditivesGRASPackaging/ucm2006826.htm.
4. Tvermoes BE, Unice KM, Paustenbach DJ, Finley BL, Otani JM, Galbraith DA. Effects and
blood concentrations of cobalt after ingestion of 1 mg/d by human volunteers for 90 d. Am J
Clin Nutr 2014;99:632-46.
20

Appendix 2: Established PDEs for Elemental Impurities
Table A.2.1: Permitted Daily Exposures for Elemental Impurities1
Element
Class2
Oral PDE
Parenteral PDE,
Inhalation PDE,
g/day
g/day
g/day
Cd
1
5
2
2
Pb
1
5
5
5
As
1
15
15
2
Hg
1
30
3
1
Co
2A
50
5
3
V
2A
100
10
1
Ni
2A
200
20
5
Tl
2B
8
8
8
Au
2B
100
100
1
Pd
2B
100
10
1
Ir
2B
100
10
1
Os
2B
100
10
1
Rh
2B
100
10
1
Ru
2B
100
10
1
Se
2B
150
80
130
Ag
2B
150
10
7
Pt
2B
100
10
1
Li
3
550
250
25
Sb
3
1200
90
20
Ba
3
1400
700
300
Mo
3
3000
1500
10
Cu
3
3000
300
30
Sn
3
6000
600
60
Cr
3
11000
1100
3
1
PDEs reported in this table (g/day) have been established on the basis of safety data described in
the monographs in Appendix 3, and apply to new drug products. The PDEs in the monographs are
not rounded. For practical purposes the PDEs in this table have been rounded to 1 or 2 significant
figures. PDEs less than 10 have 1 significant figure and are rounded to the nearest unit. PDEs
greater than 10 are rounded to 1 or 2 significant figures as appropriate. The principles applied to
rounding in this table may be applied to PDEs derived for other routes of administration.
2
Classification as defined in Section 4.
21

Table A.2.2: Permitted Concentrations of Elemental Impurities for Option 1
The values presented in this table represent permitted concentrations in micrograms per gram for
elemental impurities in drug products, drug substances and excipients. These concentration limits are
intended to be used when Option 1 is selected to assess the elemental impurity content in drug
products with daily doses of not more than 10 grams per day. The numbers in this table are based on
Table A.2.1.
Element
Cd
Pb
As
Hg
Co
V
Ni
Tl
Au
Pd
Ir
Os
Rh
Ru
Se
Ag
Pt
Li
Sb
Ba
Mo
Cu
Sn
Cr
Class
Oral Concentration
g/g
1
1
1
1
2A
2A
2A
2B
2B
2B
2B
2B
2B
2B
2B
2B
2B
3
3
3
3
3
3
3
0.5
0.5
1.5
3
5
10
20
0.8
10
10
10
10
10
10
15
15
10
55
120
140
300
300
600
1100
Parenteral
Concentration
g/g
0.2
0.5
1.5
0.3
0.5
1
2
0.8
10
1
1
1
1
1
8
1
1
25
9
70
150
30
60
110
22
Inhalation
Concentration
g/g
0.2
0.5
0.2
0.1
0.3
0.1
0.5
0.8
0.1
0.1
0.1
0.1
0.1
0.1
13
0.7
0.1
2.5
2
30
1
3
6
0.3

Appendix 3: Individual Safety Assessments
ANTIMONY
Summary of PDE for Antimony
PDE (g/day)
Oral
1200
Antimony (Sb)
Parenteral
94
Inhalation
22
Introduction
Antimony (Sb) is a silvery white naturally occurring metalloid element that is used in various
manufacturing processes. Small amounts of antimony are found in the earth's crust. It exists in of the
+3 and +5 oxidation states. Metallic antimony and a few trivalent antimony compounds are the most
significant regarding exposure potential and toxicity. Some antimonials, such as Antimony Potassium
Tartrate (APT), have been used medicinally as parasiticides. Antimony trioxide is being used as a
catalyst (e.g., in the manufacturing of Polyethylene Terephthalate [PET] used for container closure
system components). Antimony is nutritionally not essential and no metabolic function is known
(ATSDR, 1992). Antimony and antimony trioxide have low solubility in water whereas ATP is water
soluble (WHO, 2003).
Safety Limiting Toxicity
APT was negative for mutagenicity in Salmonella in the presence or absence of S9 (NTP, 1992). In a
review of genotoxicity data, conflicting results are obtained, although it appears that Sb(3+) may be
positive for clastogenicity (WHO, 2003). Available studies are considered inadequate to assess the
risk of carcinogenicity by the oral route (Lynch et al, 1999). In humans and animals, the
gastrointestinal tract appears to be the primary target organ after oral exposure and can result in
irritation, diarrhea and vomiting. Antimony is poorly absorbed after oral administration (NTP, 1992).
In subchronic studies in rats lower mean body weights and adverse liver findings were the most
sensitive endpoints. Inhalation of high levels of antimony over a long period can cause adverse
respiratory effects in both humans and animals, including carcinogenicity. In an inhalation
carcinogenicity study conducted by Newton et al. (1994), rats were exposed to antimony trioxide for
12 months, followed by a 12-month observation period. Neoplasms were observed with comparable
incidence among all groups. The authors conclude that Sb2O3 was not carcinogenic and propose that
in previous studies, positive for carcinogenicity, the tumors may be the result of overload with
insoluble particulates (Newton et al, 1994; WHO, 2003).
PDE Oral Exposure
Limited oral data on antimony exposure is available in mice and rats (Schroeder et al., 1968;
Schroeder et al, 1970; Poon et al, 1998). The National Toxicology Program (NTP) conducted a 14day study in rats and mice where APT was administered in the drinking water. In this study APT was
found to be relatively nontoxic by this route (NTP, 1992). Reevaluating the data of Poon et al. (1998),
Lynch et al. concluded that a NOAEL from a 90 day drinking water study in rats using 0.5 to 500 ppm
APT was 50 ppm based on lower mean body weight and reduced food consumption at the highest dose
(Lynch et al, 1999). This finding is consistent with the earlier reports from Schroeder et al. (1970).
Thus, the PDE for oral exposure was determined on the basis of the lowest NOAEL, i.e., 50 ppm
(equivalent to 6.0 mg Sb/kg/day).
Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the oral PDE is
calculated as below:
PDE = 6000 g/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 1200 g/day
PDE Parenteral Exposure
Adverse liver findings (liver capsule inflammation, liver cell necrosis, and liver degeneration.) were
the most sensitive endpoint in rats after repeated intraperitoneal administration. Thus, the parenteral
23

PDE was determined on the basis of the lowest NOAEL, i.e., 3.0 mg APT/kg/day (equivalent to 1.1
mg Sb/kg/d). This value was obtained from a 90-day study in rats (based on adverse liver findings at 6
mg/kg in male rats exposed to APT via intraperitoneal injection) (NTP, 1992). No systemic effects
were observed at this dose.
Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), and correcting for
continuous dosing from 3 days per week (factor of 3/7), the parenteral PDE is calculated as below:
PDE = 1100 g/kg/d x 3/7 x 50 kg / 5 x 10 x 5 x 1 x 1 = 94 g/day
PDE Inhalation Exposure
Sub chronic and chronic inhalation rat studies have been conducted. The lung effects observed across
these studies were consistent. Using the data from a 13-week inhalation rat study using antimony
trioxide dust at exposure levels of 0.25, 1.08, 4.92 and 23.46 mg/m3, (Newton et al, 1994), a NOAEL
of 1.08 mg/m3 was used to determine the inhalation PDE (~83% Sb). At higher dose levels an increase
in mean absolute and relative lung weights were observed, a finding not seen in the one year
oncogenicity study using exposure levels of 0.06, 0.51 and 4.5 mg/m3. Carcinogenicity was not
observed in this study. No adverse effects on hematology or clinical chemistry were seen in either
study.
Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the inhalation PDE is
calculated as:
For continuous dosing = 0.9 mg/m3 x 6 h/d x 5 d/wk = 0.16 mg/m3
24 h/d x 7 d/wk
1000 L/m3
Daily dose
0.00016 mg/L x 290 L/d =

0.425 kg bw
= 0.00016 mg/L
0.11 mg/kg/day
PDE = 0.11 mg/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 0.022 mg/d = 22 g/day

REFERENCES
ATSDR. Toxicological profile for antimony and compounds. Agency for Toxic Substances and
Disease Registry, Public Health Service, US Department of Health and Human Services, Atlanta, GA.
1992.
Lynch BS, Capen CC, Nestmann ER, Veenstra G, Deyo JA. Review of subchronic/chronic toxicity of
antimony potassium tartrate. Reg Toxicol Pharmacol 1999;30(1):9-17.
Newton PE, Bolte HF, Daly IW, Pillsbury BD, Terrill JB, Drew RT et al. Subchronic and chronic
inhalation toxicity of antimony trioxide in the rat. Fundam Appl Toxicol 1994;22:561-76.
NTP. Technical report on toxicity studies of antimony potassium tartrate in F344/N rats and B6C3F 1
mice (drinking water and intraperitoneal injection studies). National Toxicology Program, Public
Health Service, U.S. Department of Health and Human Services, Research Triangle Park, NC. 1992;
NTP Toxicity Report Series No. 11.
Poon R, Chu I, Lecavalier P, Valli VE, Foster W, Gupta S et al. Effects of antimony on rats following
90-day exposure via drinking water. Food Chem Toxicol 1998;36:20-35.
Schroeder HA, Mitchner M, Nasor AP, Balassa JJ, Kanisawa M. Zirconium, niobium, antimony and
fluorine in mice: effects on growth, survival and tissue levels. J Nutr 1968;95:95-101.
Schroeder HA, Mitchner M, Nasor AP. Zirconium, niobium, antimony, vanadium and lead in rats: life
term studies. J. Nutr 1970;100(1):59-68.
WHO. Antimony in drinking-water. Background document for development of WHO guidelines for
drinking-water quality. World Health Organization, Geneva. 2003. WHO/SDE/WSH/03.04/74.
24

ARSENIC
Summary of PDE for Arsenic
PDE (g/day)
Oral
15
Arsenic (As)
Parenteral
15
Inhalation
1.9
Introduction
Arsenic (As) is ubiquitous in the environment and present in food, soil, drinking water and in air.
Inorganic arsenic occurs in trivalent (e.g., arsenic trioxide, sodium arsenite) or pentavalent (e.g.,
sodium arsenate, arsenic pentoxide, arsenic acid) forms. Arsenic has no known useful biological
function in human or mammalian organisms. This assessment focuses on inorganic arsenic, because
this is most relevant for drug products.
Inorganic arsenic has shown to be genotoxic, but not mutagenic and has been acknowledged as a
human carcinogen (Group 1; IARC, 2012).
Due to its ubiquitous nature and toxicity profile, there have been many risk assessments conducted of
arsenic and arsenic compounds, which utilize non-threshold, linear dose response approaches (Meharg
and Raab, 2010).
For the most part the effects of arsenic in humans have not been reproduced in animals, so the risk
assessments have to rely heavily upon epidemiology data in populations with high exposure
concentrations (Schuhmacher-Wolz et al., 2009). In humans, both cancer and non-cancer effects have
been linked to arsenic exposure. Oral exposure has been linked to cancers of the skin, liver, lung,
kidney and bladder. Following inhalation exposure there is evidence for an increased risk of lung
cancer (ATSDR, 2007; IARC, 2012; EU EFSA, 2009; WHO, 2011; US EPA, 2010).
The skin (dyspigmentation, palmoplantar keratosis) and gastrointestinal tract (e.g., nausea) appear to
be the most sensitive targets for non-cancer adverse effects after oral ingestion while vascular disease,
reproductive effects and neurological effects are also reported as non-cancer endpoints (IARC, 2012;
Schuhmacher-Wolz et al., 2009; US EPA, 2007). Oral exposure studies suggest that skin lesions may
appear at levels above 0.02 mg As/kg/day; no effects were generally seen at levels from 0.0004 to 0.01
mg As/kg/day (ATSDR, 2007). There are insufficient epidemiological data to set a LOEL or NOEL
for other endpoints. The regions of hyperkeratosis may evolve into skin cancers (ATSDR, 2007) and
can possibly be considered predictive of skin and internal cancers and the non-cancer long-term
adverse health effects (Chen et al, 2005; Hsu et al., 2013; Ahsan and Steinmaus, 2013).
Studies of large populations (~40,000) exposed to arsenic concentrations in well water at 1000 g/L
and higher in southwestern Chinese Taipei have been the basis of risk assessments of skin cancer, and
more recently of bladder and lung cancer (US EPA, 2010). Recent meta-analyses of cancer risk have
indicated no additional bladder cancer risk at low dose exposure (<100200 g/L) (Chu and CrawfordBrown, 2006, 2007; Mink et al., 2008). This is consistent with the work of Schuhmacher-Wolz et al.,
(2009).
An inhalation unit risk for cancer of 0.0043 per g/m3 has been established by the US EPA based on
data from two US smelters (US EPA, 2007). The Texas Commission on Environmental Quality
provided an update to the US EPA Unit Risk Factor (URF), incorporating additional years of followup to the US EPA data and additional data on workers from the United Kingdom and Sweden. The
Commission calculated a URF of 0.0015 per g/m3. This URF translates to an air concentration of
0.067 g/m3 at a risk of 1 in 100,000 excess lung cancer mortality (Erraguntla et al., 2012).
PDE Oral Exposure
The oral PDE is based on the chronic effects of arsenic to skin and sets the limit at 15 g/day based on
Agency for Toxic Substances and Disease Registry (ATSDR) MRL and US EPA limit of 0.0003
25

mg/kg/day (ATSDR, 2007; US EPA 2007; EU EFSA, 2009). The PDE calculated based on the
ATSDR MRL is consistent with drinking water standards (WHO, 2011).
PDE = 0.0003 mg/kg/d x 50 kg = 0.015 mg/d = 15 g/day
No modifying factors were applied because they are incorporated into the derivation of the MRL.
The oral bioavailability of arsenic is ~95%. The most direct evidence is from a study that evaluated
the 6-day elimination of arsenic in healthy humans who were given water from a high-arsenic
sampling site (arsenic species not specified) and that reported approximately 95% absorption (Zheng et
al., 2002). Therefore the PDE is identical to the oral PDE.
PDE = 15 g/day
Increased risk of lung cancer and other respiratory disorders have been reported following inhalation
exposure to workers in the occupational setting. The rationale for using a cancer endpoint for
inhalation to set the PDE is the relative lack of information on linear-dose extrapolation, as compared
to the oral route. No modifying factors are needed as the URF were determined for the protection of
the general public. Based on the assessment conducted by Erraguntla et al. (2012), based on the risk
of 1:100.000, the inhalation PDE is:
PDE = 0.067 g/m3 / 1000 L/m3 x 28800 L/d = 1.9 g/day
No modifying factors were applied because the PDE is based on a URF derived from the multiplicate
relative risk model described by Erraguntla et al. (2012).
REFERENCES
Ahsan H, Steinmaus C. Invited commentary: use of arsenical skin lesions to predict risk of internal
cancer-implications for prevention and future research. Am J Epidemiol 2013;177:213-6.
ATSDR. Toxicological profile for arsenic. Agency for Toxic Substances and Disease Registry, Public
Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2007.
Chen CJ, Hsu LI, Wang CH, Shih WL, Hsu YH, Tseng MP et al. Biomarkers of exposure, effect, and
susceptibility of arsenic-induced health hazards in Taiwan. Toxicol Appl Pharmacol 2005;206:198-206.
Chu HA, Crawford-Brown DJ. Inorganic arsenic in drinking water and bladder cancer: a metaanalysis
for dose-response assessment. Int J Environ Res Public Health 2006;3:316-22.
Chu HA, Crawford-Brown DJ. Inorganic arsenic in drinking water and bladder cancer: a metaanalysis
for dose-response assessment. Int J Environ Res Public Health 2007;4:340-1.
Erraguntla NK, Sielken RL Jr, Valdez-Flores C, Grant RL. An updated inhalation unit risk factor for
arsenic and inorganic arsenic compounds based on a combined analysis of epidemiology studies.
Regul Toxicol Pharmacol 2012;64:329-41.
EU EFSA. Scientific opinion on arsenic in food. European Food Safety Authority. EFSA Journal
2009;7(10):1351.
Hsu LI, Chen GS, Lee CH, Yang TY, Chen YH, Wang YH et al. Use of arsenic-induced palmoplantar
hyperkeratosis and skin cancers to predict risk of subsequent internal malignancy. Am J Epidemiol
2013;173:202-12.
IARC. Arsenic, metals, fibres, and dusts: a review of human carcinogens. Monographs on the
Evaluation of Carcinogenic Risks to Humans. International Agency for Research on Cancer, World
Health Organization, Lyon. 2012;100C.
26

Meharg AA, Raab A. Getting to the bottom of arsenic standards and guidelines. Environ Sci Technol
2010;44:4395-9.
Mink PJ, Alexander DD, Barraj LM, Kelsh MA, Tsuji JS. Low-level arsenic exposure in drinking
water and bladder cancer: a review and meta-analysis. Regul Toxicol Pharmacol 2008;58:299-310.
Schuhmacher-Wolz U, Dieter HH, Klein D, Schneider K. Oral exposure to inorganic arsenic: and
evaluation of its carcinogenic and non-carcinogenic effects. Crit Rev Toxicol 2009;39:271-98.
US EPA. Arsenic, inorganic (CASRN 7440-38-2). Integrated Risk Information System (IRIS). 1998.
US EPA. Inorganic arsenic. TEACH Chemical Summary. 2007.
US EPA. Toxicological review of inorganic arsenic (CAS No. 7440-38-2). In support of summary
information on the Integrated Risk Information System (IRIS). 2010.
WHO. Arsenic in drinking-water. Background document of development of WHO Guidelines for
Drinking-water quality. World Health Organization, Geneva. 2011. WHO/SDE/WSH/03.04/75/Rev/1.
Zheng Y, Wu J, Ng JC, Wang G, Lian W. The absorption and excretion of fluoride and arsenic in
humans. Toxicol Lett 2002;133:77-82.
27

BARIUM
Summary of PDE for Barium
PDE (g/day)
Oral
1460
Barium (Ba)
Parenteral
730
Inhalation
343
Introduction
Barium (Ba) is a dense, silver-white, soft alkaline earth metal that oxidizes readily in moist air and
reacts with water. The Ba(2+) ion and the water soluble compounds of barium (chloride, nitrate,
hydroxide) are toxic. The insoluble compounds of barium, such as barium sulfate, do not generate free
Ba(2+) ions in the gastrointestinal tract and therefore are generally nontoxic to humans. Barium is
nutritionally not essential and no metabolic function is known. Barium sulfate has multiple uses e.g.,
as a radiocontrast medium, a colorant in paint and in the manufacture of glass and other products
(ATSDR, 2007).
In animals and humans, the kidney appears to be the most sensitive target of toxicity resulting from
repeated ingestion of soluble barium salts. Chronic rodent studies support the evidence for an
association between barium exposure and renal toxicity (NTP, 1994). The lesions were characterized
by tubule dilatation, renal tubule atrophy, tubule cell regeneration, hyaline cast formation, multifocal
interstitial fibrosis, and the presence of crystals, primarily in the lumen of the renal tubules. These
changes were characterized as morphologically distinct from the spontaneous degenerative renal
lesions commonly observed in aging mice. Effects on blood pressure may be the most sensitive
endpoint observed in humans after environmental exposure (WHO, 2004). Repeated exposure to
barium oxide via inhalation may cause bronchitis, including cough, phlegm, and/or shortness of breath
(CICAD, 2001).
PDE Oral Exposure
In an evaluation conducted in two towns in Illinois, no significant differences in blood pressure or in
the prevalence of cardiovascular or kidney disease was found between populations drinking water
containing a mean barium concentration of 7.3 mg/L or 0.1 mg/L (WHO, 2004). Using the NOAEL of
7.3 mg/L obtained from this study, and using 2 L/day as an estimation of water intake, the oral PDE
can be calculated as:
PDE = 14.6 mg/d / 1 x 10 x 1 x 1 x 1 = 1.46 mg/d =1460 g/day
No relevant data on parenteral exposure to barium compounds were found. The bioavailability of
barium is estimated to be 20-60% in adults and infants, respectively (ATSDR, 2007). Thus, the
parenteral PDE was calculated by dividing the oral PDE by a modifying factor of 2 (as described in
Section 3.1).
PDE = 1460 g/d / 2 = 730 g/day
No relevant data on inhalation exposure to barium compounds were found. United States Department
of Labor (US DoL, 2013) has a reported Time Weighted Average (TWA) of 0.5 mg/m3 based on
soluble barium salts.
calculated as:
28

For continuous dosing =
Daily dose =
500 g/ m3 x 8 hr/d x 5 d/wk = 119 g/ m3 = 0.119 g/L

24 hr/d x 7 d/wk
1000 L/m3
0.119 g/L x 28800 L = 68.6 g/kg
50 kg
PDE = 68.6 g/kg x 50 kg / 1 x 10 x 1 x 1 x 1 = 343 g/day

REFERENCES
ATSDR. Toxicological profile for barium and barium compounds. Agency for Toxic Substances and
Disease Registry, Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA.
2007.
CICAD. Barium and barium compounds. Concise International Chemical Assessment Document 33.
World Health Organization, Geneva. 2001.
NTP. Technical report on the toxicology and carcinogenesis studies of barium chloride dihydrate
(CAS No. 10326-27-9) in F344/N rats and B6C3F1 mice (drinking water studies). National
Toxicology Program, Public Health Service, U.S. Department of Health and Human Services,
Research Triangle Park, NC. 1994;NTP TR 432.
US DoL (OHSA). 29 CRF 1910.1000 Table Z-1. Limits for air contaminants. U.S. Department of
Labor. 2013.
WHO. Barium in drinking-water: Background document for development of WHO guidelines for
drinking-water quality. World Health Organization, Geneva. 2004. WHO/SDE/WSH/03.04/76.
29

CADMIUM
Summary of PDE for Cadmium
PDE (g/day)
Oral
5.0
Cadmium (Cd)
Parenteral
1.7
Inhalation
1.7
Introduction
Cadmium (Cd) is a transition metal whose most abundant naturally-occurring isotope is nonradioactive. It is found in nature in mineral forms and is obtained for commercial uses principally
from cadmium ore (ATSDR, 2012). Cadmium exists as a salt form in the +2 oxidation state only.
Some cadmium salts such as cadmium chloride, cadmium sulfate and cadmium nitrate are water
soluble; other insoluble salts can become more soluble by interaction with acids, light or oxygen.
Cadmium, cadmium oxide, cadmium salts on borosilicate carrier are used as catalysts in organic
synthesis. Silver cadmium alloy is used in the selective hydrogenation of carbonyl compounds.
Cadmium has shown to be genotoxic, but not mutagenic and has been acknowledged as a human
carcinogen (Group 1; IARC, 2012). Cadmium and cadmium compounds cause cancer of the lung.
Also, positive associations have been observed between exposure to cadmium and cadmium
compounds and cancer of the kidney and of the prostate.
A sensitive endpoint for oral exposure to cadmium and cadmium salts is renal toxicity (Buchet et al.
1990). Skeletal and renal effects are observed at similar exposure levels and are a sensitive marker of
cadmium exposure (ATSDR, 2012).
Evidence from numerous epidemiologic studies assessing inhalation exposures to cadmium via both
occupational and environmental routes has demonstrated an increased risk of developing cancer
(primarily lung) that correlates with inhalation exposure to cadmium (IARC, 2012; NTP, 1995). An
inhalation unit risk of 0.0018/g/m3 has been derived by the US EPA (1992).
PDE Oral Exposure
A sensitive endpoint for oral exposure to cadmium and cadmium salts is renal toxicity (Buchet et al,
1990). Skeletal and renal effects are observed at similar exposure levels and are a sensitive marker of
cadmium exposure (ATSDR, 2012). A number of oral exposure studies of cadmium in rats and mice
showed no evidence of carcinogenicity. Therefore the renal toxicity endpoint was used to establish the
oral PDE for cadmium, following the recommendations of ATSDR, an MRL of 0.1 g/kg for chronic
exposure is used to set the oral PDE. This is consistent with the WHO drinking water limit of 0.003
mg/L/day (WHO, 2011).
PDE = 0.1 g/kg/d x 50 kg = 5.0 g/day
A 12-week study in rats given daily subcutaneous injections of 0.6 mg/kg Cd, 5 days per week showed
renal damage at week 7 and later (Prozialeck et al, 2009). A single dose level was used in this study.
The LOAEL of this study is 0.6 mg/kg based on decreased body weight, increased urine volume and
urinary biomarkers seen at this dose level. This study was used to set the parenteral PDE. In a
separate single dose study where rats were administered a 0, 1, 2, 4, 8, 16 or 32 mol/kg cadmium
chloride by the subcutaneous route, sarcomas were noted at the injection site at the two highest doses
at the end of the 72 week observation period (Waalkes et al, 1999). It is uncertain whether the
granulomas at the sites of injection over time trap an unspecified amount of the administered cadmium
dose at the injection site. This phenomenon may decrease the actual parenteral cadmium dose,
30

compared with the calculated parenteral cadmium dose. Taking into account the modifying factors
(F1-F5 as discussed in Appendix 1), and correcting for continuous dosing from 5 days to 7 days per
week (factor of 5/7), the parenteral PDE is calculated as:
PDE = 0.6 mg/kg x 5/7 x 50 kg / 5 x 10 x 5 x 5 x 10 = 1.7 g/day
A factor of 5 was chosen for F4 because cadmium is carcinogenic by the inhalation route and
granulomas were observed by the subcutaneous route. These findings are of uncertain relevance. A
factor of 10 was chosen for F5 because a LOAEL was used to set the PDE.
Using the inhalation unit risk of 0.0018/g/m3 that has been derived for cadmium and a risk level of
1:100000, the inhalation PDE can be calculated as:
Inhalation PDE
1x10-5
1.8 x10-3 /g/m3
= 5.55 x 10-2 g/m3
PDE = 0.056 g/m3 / 1000 L/m3 x 28800 L/d = 1.7 g/day

No modifying factors are used to adjust a PDE derived by the unit risk approach.
REFERENCES
ATSDR. Toxicological profile of cadmium. Agency for Toxic Substances and Disease Registry,
Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2012.
Buchet JP, Lauwerys R, Roels H, Bernard A, Bruaux P, Claeys F et al. Renal effects of cadmium body
burden of the general population. Lancet 1990;336:699-702.
NTP. Technical report on toxicity studies of cadmium oxide (CAS No. 1306-19-0) administered by
inhalation to F344/N Rats and B6C3F1 mice. National Toxicology Program, Public Health Service,
U.S. Department of Health and Human Services. 1995.
Prozialeck WC, Edwards JR, Vaidya VS, Bonventre JV. Preclinical evaluation of novel urinary
biomarkers of cadmium nephrotoxicity. Toxicol Appl Pharmacol 2009;238:301-305.
US EPA. Cadmium. Integrated Risk Information System (IRIS). 1992.
Labor. 2013.
Waalkes MP, Anver M, Diwan BA. Carcinogenic effects of cadmium in the Noble (NBL/Cr) rat:
induction of pituitary, testicular, and injection site tumors and intraepithelial proliferative lesions of the
dorsolateral prostate. Toxicol Sci 1999;52:154-161.
WHO. Cadmium in drinking-water. Background document for development of WHO Guidelines for
drinking-water quality. World Health Organization. 2011;WHO/SDE/WSH/03.04/80/Rev/1.
31

CHROMIUM
Summary of PDE for Chromium
PDE (g/day)
Oral
10700
Chromium (Cr)
Parenteral
1070
Inhalation
2.9
Introduction
Chromium (Cr) is found in a variety of oxidation states, the most important being Cr(0) (in stainless
steel) Cr(2+), Cr(3+) and Cr(6+). Cr (2+) is readily oxidized and is used as a reducing agent in
chemical synthesis. Cr(6+) is a powerful oxidant, chromate, CrO42-, and dichromate, Cr2O72-, being the
best known oxyanions. Cr(3+), the most abundant environmental form, is an essential element that
plays a role in glucose metabolism. Chromium deficiency causes changes in the metabolism of
glucose and lipids and may be associated with maturity-onset diabetes, cardiovascular diseases, and
nervous system disorders (Anderson, 1993, 1995). Sources of chromium in pharmaceuticals may
include colorants, leaching from equipment or container closure systems, and catalysts. Except when
it is used as a catalyst, intake of chromium from pharmaceuticals will be in the form of metallic
chromium (Cr(0)) or Cr(3+) rather than the more toxic Cr(6+); therefore, for drug products, this safety
assessment is based on the known toxicity of Cr(3+) and Cr(6+) is excluded from this assessment. If
Cr(6+) is used as a catalyst, then the assessment should incorporate this form. Chromium present as a
colorant (e.g., chromium oxide green, chromium hydroxide green) is intentionally added and thus
beyond the scope of this guidance.
Rats fed diets containing up to 5% Cr2O3 (equivalent to 1468 mg Cr/kg/day) for a lifetime showed no
adverse effects. In a more recent dietary rat study (Anderson et al, 1997), no adverse effects were
detected at 15 mg Cr(3+)/kg/day. No specific target organ toxicities have been identified for the oral
intake of chromium. Generally oral intake of 1.5 mg/kg/day Cr(3+) (US EPA, 1998) is not expected to
be associated with adverse health.
The data was reviewed to identify the safety limiting toxicities based on routes of administration.
PDE Oral Exposure
The 2-year NTP studies (2010) on the carcinogenicity of Cr(3+) picolinate administered in feed to rats
and mice at 2000, 10000 and 50000 ppm provided the most relevant safety information for chromium
as present in drug products. The NOAEL was the low dose of 90 mg/kg Cr(3+) picolinate (11.9
weight %; 10.7 mg/kg/day Cr(3+)) in rats based on increase in the incidence of preputial gland
adenoma in male rats at 460 mg/kg. This finding was not dose-dependent and was considered an
equivocal finding by the study authors. This finding was not observed male mice or in the female
counterpart in either species (clitoral gland). Taking into account the modifying factors (F1-F5 as
discussed in Appendix 1), the oral PDE is calculated as:
PDE = 10.7 mg/kg/d x 50 kg / 5 x 10 x 1 x 1 x 1 = 10.7 mg/day
Recommendation for the nutritional intravenous administration of Cr(3+) vary per age group between
0.05 g/kg/day in preterm infants and 15 g/kg in adults (Moukazel, 2009). There is insufficient
information to assess if exceeding these recommended daily doses may lead to adverse responses e.g.,
for the kidney especially in newborns and preterm infants.
The safety review for chromium was unable to identify any significant assessments upon which to
calculate a PDE for parenteral routes of exposure. On the basis of an oral bioavailability of about 10%
for chromium and inorganic chromium compounds (ATSDR, 2012), the parenteral PDE was
32

calculated by dividing the oral PDE by a modifying factor of 10 (as described in Section 3.1). The
recommended PDE for chromium for parenteral exposure is:
PDE = 10700 g/d / 10 = 1070 g/day
The study by Derelenko et al. (1999) used inhalation of Cr(3+) sulfate particles during 13 weeks
(6h/day and 5 days per week), and the predominant observed effects were chronic inflammation of the
airways (mononuclear infiltrate, particular material) and local thickening of alveolar walls. The effect
was observed at all doses. The LOAEL is 17 mg/m3 (3 mg Cr(3+)/m3). A lack of systemic toxicity
was noted in a 13-week inhalation study in rats administered soluble or insoluble Cr(3+). Based on
these data, the inhalation MRL of 0.1g/m3 was used to set the PDE (ATSDR, 2012).
PDE =0.0001 mg/m3 / 1000 m3/L x 28800 L/day = 2.9 g/day
REFERENCES
Anderson RA. Recent advances in the clinical and biochemical effects of chromium deficiency. Prog
Clin Biol Res 1993;380:221-34.
Anderson RA. Chromium and parenteral nutrition. Nutr 1995;11(1 suppl.):83-6.
ATSDR. Toxicological profile of chromium. Agency for Toxic Substances and Disease Registry,
Derelanko MJ, Rinehart WE, Hilaski RJ, Thompson RB, Lser E. Thirteen week subchronic rat
inhalation toxicity study with a recovery phase of trivalent chromium compounds, chromic oxide, and
basic chromium sulfate. Toxicol Sci 1999;52:278-88.
Glaser U, Hochrainer D, Klppel H, Oldiges H. Carcinogenicity of sodium dichromate and chromium
(VI/III) oxide aerosols inhaled by male Wistar rats. Toxicology. 1986;42(2-3):219-32.
Moukarzel A. Chromium in parenteral nutrition: too little or too much. Gastroenterology
2009;137:S18-S28.
NTP. Technical report on the toxicology and carcinogenesis studies of chromium picolinate
monohydrate (CAS NO. 27882-76-4) in F344/N rats and B6C3F1 mice (feed studies). National
Toxicology Program, Public Health Service, U.S. Department of Health and Human Services.
2010;NTP TR 556.
Labor. 2013.
US EPA. Chromium (III), insoluble salts. Integrated Risk Information System (IRIS). 1998.
33

COBALT
Summary of PDE for Cobalt
PDE (g/day)
Oral
50
Cobalt (Co)
Parenteral
5.0
Inhalation
2.9
Introduction
Cobalt (Co) is a naturally-occurring element, often combined with other elements such as oxygen,
sulfur, and arsenic. Cobalt is essential in the human body because it is an integral component of
Vitamin B12 and functions as a co-enzyme for several enzymes critical in the synthesis of hemoglobin
and the prevention of pernicious anemia. The average person receives about 11 g Co/day in the diet
(ATSDR, 2004). The Recommended Dietary Allowance of Vitamin B12 ranges from 0.7 to 2.4
g/day (NAS, 2010), which corresponds to 0.03 to 0.1 g of cobalt. No essential biological function
of inorganic cobalt in the human body has been identified. Cobalt compounds (e.g., cobalt octanoate)
are being used as catalysts in selective hydrogenation.
The International Agency for Research on Cancer (IARC, 2006) concluded that Cobalt sulfate and
other soluble Co(2+) salts are possible human carcinogens (Group 2B). The data indicate the location
of tumors is limited to the lung in rats and humans. Cobalt metal was positive for mutagenicity in
vitro but negative for clastogenicity in vivo. The NTP concluded that there was clear evidence of
carcinogenicity in male and female mice and rats (NTP, 2013). Human studies for carcinogenicity by
inhalation are inconclusive and not classified for carcinogenicity (US EPA, 2000). Polycythemia is
considered to be the most sensitive finding after repeated oral exposure to humans (ATSDR, 2004).
Inhalation exposure of humans to cobalt has been associated with a severe and progressive respiratory
disease known as hard-metal pneumoconiosis, as well as asthma and contact dermatitis (ATSDR,
2004; IARC, 2006).
PDE Oral Exposure
The oral PDE is based on the available human data. Polycythemia was a sensitive endpoint in humans
after repeated oral exposure to 150 mg of cobalt chloride for 22 days (~1 mg Co/kg/day; WHO, 2006;
ATSDR, 2004). Polycythemia or other effects were not observed in a study of 10 human volunteers (5
men and 5 women) ingesting 1 mg/Co per day as CoCl2 for 88-90 days (Tvermoes et al, 2014). The
oral PDE was determined on the basis of the NOAEL of 1 mg/day. Taking into account the modifying
factors (F1-F5 as discussed in Appendix 1), the oral PDE is calculated as below:
PDE = 1 mg/d / 1 x 10 x 2 x 1 x 1 = 0.05 mg/d = 50 g/day
A factor of 2 was chosen for F3 because a short term human study was used to set the PDE.
No relevant data on parenteral exposure to cobalt compounds were found. The oral bioavailability of
cobalt and inorganic cobalt compounds ranges from 18-97% (ATSDR, 2004). To account for the low
oral bioavailability, the parenteral PDE was calculated by dividing the oral PDE by a modifying factor
of 10 (as described in Section 3.1). The PDE for cobalt for parenteral exposure is:
PDE = 50 g/d / 10 = 5.0 g/day
Cobalt sulfate and other soluble Co(2+) salts are possible human carcinogens (Group 2B) that can
induce lung tumors.
34

Pneumoconiosis, asthma and contact dermatitis were the principal non-carcinogenic effects in humans
after chronic inhalation. The MRL approach was considered acceptable for cobalt as the data are
considered more reliable and the lack of human data for carcinogenicity cobalt sulfate. The best
estimate of human cancer risk is approximately the same as the PDE derived using the MRL (WHO,
2006). For the calculation of the inhalation PDE, the chronic inhalation MRL of 0.1 g/ m3 was used
(ATSDR, 2004).
PDE = 0.0001 mg/ m3 /1000 m3/L x 28800 L/d = 2.9 g/day
REFERENCES
ATSDR. Toxicological profile for cobalt. Agency for Toxic Substances and Disease Registry, Public
IARC. Cobalt in hard metals and cobalt sulfate, gallium arsenide, indium phosphide and vanadium
pentoxide. International Agency for Research on Cancer, World Health Organization, Lyon. 2003;86,
updated in 2006.
NAS.IOM. Food and Nutrition Board. Dietary Reference Intakes: RDA and AI for vitamins and
elemnets. Institute of Medicine National Academies. Summary Tables, 2010. (available online at
http://fnic.nal.usda.gov/dietary-guidance/dietary-reference-intakes/dri-tables; accessed May 27, 2014)
NTP. Technical report on the toxicology studies of cobalt metal (CAS No. 7440-48-4) in F344/N rats
and B6C3F1/N mice and toxicology and carcinogenesis studies of cobalt metal in F344/NTac rats and
B6C3F1/N mice (inhalation studies). National Toxicology Program, Public Health Service, U.S.
Department of Health and Human Services, Research Triangle Park, NC. 2013;NTP TR 581.
Tvermoes BE, Unice KM, Paustenbach DJ, Finley BL, Otani JM, Galbraith DA. Effects and blood
concentrations of cobalt after ingestion of 1 mg/day by human volunteers for 90 d. Am J Clin Nutr
2014;99:632-646.
US EPA. Cobalt compounds: technology transfer network air toxics web site: Hazard summary. 2000
(http://www.epa.gov/ttn/atw/hlthef/cobalt.html; accessed April 23, 2014).
WHO. Cobalt and inorganic cobalt compounds. Concise International Chemical Assessment
Document. Inter-Organization Programme for the Sound Management of Chemicals (IOMC). World
Health Organization. 2006;69.
35

COPPER
Summary of PDE for Copper
PDE (g/day)
Oral
3400
Copper (Cu)
Parenteral
340
Inhalation
34
Introduction
Copper (Cu) is a Group 11 element of the first transition series and has two main oxidation states,
Cu(1+) and Cu(2+). It is an essential trace element in both animals and humans. Copper plays a vital
role in a number of critical enzyme systems and is closely linked with normal hematopoiesis and
cellular metabolism. Copper compounds (e.g., copper chromite) are being used as catalysts in
hydrogenolysis and decarboxylation reactions.
A general review of relevant safety data for animals and humans indicates that copper can produce
adverse effects to the gastrointestinal tract, liver, and kidney upon ingestion of toxic doses (Araya et al,
2003).
PDE Oral Exposure
Studies on cupric sulfate and copper 8-quinolinolate have been conducted in mice, rats and dogs (IPCS,
1998). Rats were determined to be the most sensitive of these species to effects on liver and kidney.
In a 13-week study in which rats were fed 500 to 8000 ppm cupric sulfate pentahydrate, the NOEL for
hyperplasia and hyperkeratosis of the forestomach mucosa was 1000 ppm. Hepatic and renal toxicity
was observed from doses equal to and greater than 2000 ppm. The NOEL was 1000 ppm, equivalent
to 64 mg CuSO4/kg/day (17 mg Cu/kg/day). (Hbert et al, 1993; IPCS, 1998). Taking into account
the modifying factors (F1-F5 as discussed in Appendix 1), the oral PDE is calculated as:
PDE = 17 mg/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 3400 g/day
The safety review for copper was unable to identify any significant assessments upon which to
calculate a PDE for parenteral routes of exposure. The human gastrointestinal system can absorb 3040% of ingested copper from the typical diets consumed in industrialised countries (Wapnir, 1998).
On the basis of limited oral bioavailability of 30-40% for copper and inorganic copper salts, the
Section 3.1). The recommended PDE for copper for parenteral exposure is:
PDE = 3400 g/d / 10 = 340 g/day
The available data on the toxicity of inhaled copper were considered inadequate for derivation of
acute-, intermediate-, or chronic-duration inhalation MRLs (ATSDR, 2004). The inhalation PDE was
calculated by dividing the oral PDE by a modifying factor of 100 (as described in Section 3.1).
PDE = 3400 g/day / 100 = 34 g/day
REFERENCES
Araya M, Olivares M, Pizarro F, Gonzlez M, Speisky H, Uauy R. Gastrointestinal symptoms and
blood indicators of copper load in apparently healthy adults undergoing controlled copper exposure.
Am J Clin Nutr 2003;77(3):646-50.
36

ATSDR. Profile for copper. Agency for Toxic Substances and Disease Registry, Public Health Service,
U.S. Department of Health and Human Services, Atlanta, GA. 2004.
Hbert CD, Elwell MR, Travlos GS, Fitz CJ, Bucher JR. Subchronic toxicity of cupric sulfate
administered in drinking water and feed to rats and mice. Fundam Appl Toxicol 1993;21:461-475.
IPCS. Copper. Environmental Health Criteria 200. International Programme on Chemical Safety.
Wapnir RA. Copper absorption and bioavailability. Am J Clin Nutr 1998;67(suppl):1054S-60S.
37

GOLD
Summary of PDE for Gold
PDE (g/day)
Oral
134
Gold (Au)
Parenteral
134
Inhalation
1.3
Introduction
Gold (Au) exists in metallic form and in oxidation states of +1 to +5, the monovalent and trivalent
forms being the most common. Elemental gold is poorly absorbed and consequently is not considered
biologically active. Gold is being used on a carrier or in complexes like gold chloride and L-Au+
(where L is a phosphane, phosphite, or an arsine; Telles, 1998), as catalysts in organic synthesis. The
only source for gold in drug products comes from the use as catalyst. Au(1+) salts are used
therapeutically.
Most knowledge of gold toxicity is based on therapeutic uses of gold. Currently available therapies
are gold salts of monovalent Au(1+) with a sulfur ligand (Au-S), but metallic gold has also been
studied. No toxicity was seen in 10 patients administered colloidal metallic gold (monoatomic gold) at
30 mg/day for one week followed by 60 mg/day the second week or the reverse schedule. The patients
were continued on the trial for an additional 2 years at 30 mg/day. There was no evidence of
hematologic, renal or hepatic cytotoxicity but some improvement in clinical symptoms of rheumatoid
arthritis and in cytokine parameters were noted (Abraham and Himmel, 1997).
Long term animal and human data are available with gold compounds. Toxicities include renal lesions
in rats administered gold compounds by injection (Payne and Saunders, 1978) and humans (Lee et al,
1965) and gastrointestinal toxicity in dogs (Payne and Arena, 1978). However, these studies have
been performed with monovalent gold (Au(1+)) or forms of gold not present as pharmaceutical
impurities and thus are not considered sufficiently relevant to derive a PDE for gold in pharmaceutical
products.
There are no relevant toxicology studies in humans or animals by the oral route of a form of gold
likely to be in a pharmaceutical product to set an oral PDE of gold. Au(3+) is thought to be the more
toxic form and is used in catalysis, e.g., as gold trichloride. There is only limited data on Au(3+)
complexes. In one study, the Au(3+) compound [Au(en)Cl2]Cl (dichloro(ethylenediamine-aurate3+
ion) caused minimal histological changes in the kidney and liver of rats, and no renal tubular necrosis,
at a dose of 32.2 mg/kg in mice administered the compound intra peritoneal for 14 days (Ahmed et al,
2012).
PDE Oral Exposure
The toxicologically significant endpoint for gold exposures is renal toxicity. The study in mice
administered Au(3+) by the intra peritoneal route was considered acceptable in setting the oral PDE
because the renal endpoint of toxicity is a sensitive endpoint of gold toxicity. Taking into account the
modifying factors (F1-F5 as discussed in Appendix 1), the oral PDE is calculated as:
PDE = 32.2 mg/kg x 50 kg / 12 x 10 x 10 x 1 x 10 = 134 g/day
A factor of 10 for F5 was chosen because the LOAEL is used to establish the PDE and the
toxicological assessment was not complete.
In humans, 50 mg intramuscular injections of gold sodium thiomalate resulted in >95% bioavailability
(Blocka et al, 1986). In rabbits, approximately 70% of the gold sodium thiomalate was absorbed after
an intramuscular injection of 2/mg/kg (Melethil and Schoepp, 1987). Based on high bioavailability,
38

and that a study by the intra peritoneal route was used to set the oral PDE, the parenteral PDE is equal
to the oral PDE.
PDE = 134 g/day
In the absence of relevant inhalation and parenteral data, including the potential local tissue toxicity of
the effects of gold in lungs, the parenteral PDE was calculated by dividing the oral PDE by a
modifying factor of 100 (as described in Section 3.1).
PDE = 134 g/d / 100 = 1.34 g/day
REFERENCES
Abraham GE, Himmel PB. Management of rheumatoid arthritis: rationale for the use of colloidal
metallic gold. J Nutr Environ Med 1997;7:295-305.
Ahmed A, Al Tamimi DM, Isab AA, Alkhawajah AMM, Shawarby MA. Histological changes in
kidney and liver of rats due to gold (III) compound [Au(en)Cl2]Cl. PLoS ONE 2012;7(12):1-11.
Blocka KL, Paulus HE, Furst DE. Clinical pharmacokinetics of oral and injectable gold compounds.
Clin Pharmacokinet 1986;11:133-43.
Lee JC, Dushkin M, Eyring EJ, Engleman EP, Hopper J Jr. Renal Lesions Associated with Gold
Therapy: Light and Electron Microscopic Studies. Arthr Rheum 1965;8(5):1-13.
Melethil S, Schoepp D. Pharmacokinetics of gold sodium thiomalate in rabbits. Pharm Res
1987;4(4):332-6.
Payne BJ, Arena E. The subacute and chronic toxicity of SK&F 36914 and SK&F D-39162 in dogs.
Vet Pathol 1978;15(suppl 5): 9-12.
Payne BJ, Saunders LZ. Heavy metal nephropathy of rodents. Vet Pathol 1978;15(suppl 5):51-87.
Telles JH, Brode S, Chabanas M. Cationic gold (I) complexes: highly efficient catalysts for the
addition of alcohols to alkynes. Angew Chem Int Ed 1998;37:1415-18.
39

LEAD
Summary of PDE for Lead
PDE (g/day)
Oral
5.0
Lead (Pb)
Parenteral
5.0
Inhalation
5.0
Introduction
Lead (Pb) occurs in organic and inorganic forms. The generally bivalent lead compounds include
water-soluble salts such as lead acetate as well as insoluble salts such as lead oxides. Organic lead
compounds include the gasoline additives tetramethyl- and tetraethyl-lead. Organic lead compounds
undergo fairly rapid degradation in the atmosphere and form persistent inorganic lead compounds in
water and soil. Lead has no known biological function in human or mammalian organisms (ATSDR,
2007).
In humans and animals, exposure to lead may cause neurological, reproductive, developmental,
immune, cardiovascular and renal health effects. In general, sensitivity to lead toxicity is greater when
there is exposure in utero and in children compared to adults. A target blood level of 1-2 g/dL was
set, and using modelling programs (US EPA, 2009) that assumed 100% bioavailability and no other
exposure, a PDE was obtained. For this reason, the PDEs are the same regardless of the route of
administration.
PDE Oral Exposure
Adverse neurobehavioral effects are considered to be the most sensitive and most relevant endpoint in
humans after oral exposure. Data from epidemiological studies show that blood lead levels <5 g/dL
may be associated with neurobehavioral deficits in children (NTP, 2011).
According to the US EPA model (Integrated Exposure Uptake Biokinetic (IEUBK) Model, 1994)
(100% absorption, no other sources of lead), oral intake of 5 g/day translates into a blood level of 1-2
g/dL for children age 0-7 years (0-82 months) (US EPA, 2007, 2009).
PDE = 5.0 g/day
The oral effects of Pb are based on blood levels. Therefore, the parenteral PDE is equal to the oral
PDE.
PDE = 5.0 g/day
The oral effects of Pb are based on blood levels. Therefore, the inhalation PDE is equal to the oral
PDE.
PDE = 5.0 g/day
REFERENCES
ATSDR. Toxicological profile for lead. Agency for Toxic Substances and Disease Registry, Public
NTP. Monograph on health effects of low-level lead. National Toxicology Program, U.S. Department
of Health and Human Services. 2012.
40

US EPA. Users Guide for the Integrated Exposure Uptake Biokinetic Model for Lead in Children
(IEUBK) Windows. 2007.
US EPA. Integrated Exposure Uptake Biokinetic (IEUBK) Model for Lead. 1994, updated 2009.
(http://www.epa.gov/superfund//health/contaminants/lead/products.htm; Accessed March 25, 2014)
41

LITHIUM
Summary of PDE for Lithium
PDE (g/day)
Oral
560
Lithium (Li)
Parenteral
280
Inhalation
25
Introduction
Lithium (Li) is a common metal that is present in plant and animal tissues. Lithium is being used
alone or in combination with other metals as catalyst. Lithium compounds (e.g., lithium aluminum
hydride) are being used as reagents in organic synthesis. Lithium exists commonly as a salt in the +1
oxidation state only.
Lithium is used as a human therapeutic, and extensive human data exists in the administration of
lithium salts in the treatment of mania, bipolar disorder, and recurrent unipolar depression. Treatment
with lithium salts requires frequent controls by the treating physician, including measurement of
lithium concentrations. The therapeutic range for lithium has been established at 0.6-1 mmol/L in
serum, depending upon the formulation administered (Grandjean and Aubry, 2009). The therapeutic
margin is narrow and Li toxicity can occur at therapeutic exposures. Lithium treatment in humans is
mainly associated with an increased risk of reduced urinary concentrating ability, hypothyroidism,
hyperparathyroidism, and weight gain (McKnight et al, 2012). The usual recommended dose is 300600 mg three to four times a day (US FDA, 2011). The data was reviewed to identify the safety
limiting toxicities based on routes of administration.
PDE Oral Exposure
Human experience with lithium was used as the point of departure for this PDE. When using the
lowest human single oral dose of 300 mg lithium carbonate (56 mg Li), the oral PDE is calculated as
follows:
PDE = 56 mg/d / 1 x 10 x 1 x 1 x 10 = 0.56 mg/d = 560 g/day
A factor of 10 was chosen for F5 because a LOAEL (one-third the recommended daily dose) was used
to set the PDE.
There are no adequate data to develop a parenteral PDE. However, based on oral bioavailability of
85% (Grandjean and Aubry, 2009), the parenteral PDE was calculated by dividing the oral PDE by a
PDE = 560 g/d / 2 = 280 /day
Rabbits were exposed to lithium chloride at 0.6 and1.9 mg/m3 for 4-8 weeks, 5 days/week for 6
hours/d (Johansson et al. 1988). Lungs were studied by light and electron microscopy with focus on
inflammatory changes. No significant effects were reported, so the highest dose was used to set the
PDE. Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the inhalation
PDE is calculated as:
For continuous dosing = 1.9 mg/m3 x 6 h/d x 5 d/wk = 0.34 mg/m3 = 0.00034 mg/L
24 h/d x 7d/wk
1000 L/m3
42

Daily dose =
0.00034 mg/L x 1440 L/d =

4 kg
122.04 g/kg/day
PDE = 122.04 g/kg/d x 50 kg / 2.5 x 10 x 10 x 1 x 1 = 25 g/day

REFERENCES
Grandjean EM, Aubry JM. Lithium: updated human knowledge using an evidence-based approach.
Part II: Clinical pharmacology and therapeutic monitoring. CNS Drugs 2009;23(4):331-49.
Johansson A, Camner P, Curstedt T, Jarstrand C, Robertson B, Urban T. Rabbit lung after inhalation
of lithium chloride. J Appl Toxicol 1988;8:373-5.
McKnight RF, Adida M, Budge K, Stockton S, Goodwin GM, Geddes JR. Lithium toxicity profile: a
systematic review and meta-analysis. Lancet 2012;379:721-728.
US FDA. Lithium carbonate product label, 2011. (available at drugs@fda; accessed May 1, 2014)
43

MERCURY
Summary of PDE for Mercury
PDE (g/day)
Oral
30
Mercury (Hg)
Parenteral
3.0
Inhalation
1.2
Introduction
Mercury (Hg) is widely distributed in the global environment. Mercury exists in three forms:
elemental mercury, inorganic mercury and organic mercury. The most likely form of residual mercury
in drug products is the inorganic form. Therefore, this safety assessment is based on the relevant
toxicological data of elemental or inorganic mercury. This safety assessment and derived PDEs do not
apply to organic mercury.
There is no data to indicate that inorganic mercury is carcinogenic in human. There is limited
evidence in experimental animals for the carcinogenicity of mercuric chloride. The International
Agency for Research on Cancer (IARC) concluded that inorganic mercury compounds are not
classifiable as to their carcinogenicity to humans (Group 3; IARC, 1997).
Inorganic mercury compounds show significantly lower oral bioavailability compared to organic
mercury and induce different toxicological effects including neurological, corrosive, hematopoietic,
and renal effects and cutaneous disease (acrodynia). The safety limiting toxicity for inorganic mercury
and salts is renal toxicity. Direct absorption to the brain via the olfactory pathway has been reported
(Shimada et al, 2005).
PDE Oral Exposure
There were well designed NTP studies in rats and mice of HgCl2 of up to 2 years duration. The 6month gavage study in rats was selected because it had more detailed clinical pathology assessment
and a wider range of doses (0.312 to 5 mg HgCl2/kg/5d per week) than the 2-year study. Absolute and
relative (to body weight) kidney weights were increased from 0.625 mg/kg. Some changes in clinical
chemistry parameters (decreased creatinine, potassium, alanine aminotransferase and aspartate
aminotransferase) were noted in all dosed males. The findings did not appear dose-dependent. An
increase in the incidence and severity (minimal to mild) in nephropathy was noted from 0.625 mg
HgCl2. In a Joint Expert Committee for Food Additives (JECFA) assessment (JECFA, 2011) a
BMDL10 of 0.06 mg Hg/kg/day (adjusted from 5 days/week dosing) was derived based on adverse
renal effects (weight increase) from the 6-month rat study (NTP, 1993). Using the modifying factors
(F1-F5 as discussed in Appendix 1) the oral PDE is calculated as:
F4 was set to 1 as the findings in the 6-month and 2-year studies were not considered significant at the
lowest dose, and F5 was set to 1 as the BMDL10 can be considered a NOAEL (Sargent et al, 2013).
Animal studies indicate that the oral bioavailability of inorganic mercury is in the 10-30% range
(ATSDR, 1999). Therefore, the parenteral PDE was calculated by dividing the oral PDE by a
PDE = 30 g/d / 10 = 3.0 g/day
44

Neurobehavioral effects are considered to be the most sensitive endpoint following inhalation
exposure in humans as shown in occupational studies at the range of air TWA levels between 14 and
20 g/m3 (US EPA, 1995; EU SCOEL, 2007). The presence of neurobehavioral effects at low-level
mercury exposures (14 g/m3) in dentists (Ngim et al. 1992) indicates that the TWA needs to be
considered as a LOAEL. Taking into account the modifying factors (F1-F5 as discussed in Appendix
1), the inhalation PDE is calculated based on the long-term inhalation exposure to elemental mercury
vapor:
For continuous dosing = 14 g/m3 x 8 hr/d x 6 d/wk =
24 hr/d x 7 d/wk
Daily dose =
4 g/m3 = 0.004 g/L

1000 L/m3
0.004 g/L x 28800 L = 2.30 g/kg

50 kg
PDE = 2.30 g/kg x 50 kg / 1 x 10 x 1 x 1 x 10 = 1.2 g/day

A factor of 10 for F5 was chosen because a LOAEL was used to set the PDE and to account for the
possible direct transfer of mercury to the brain through the olfactory pathway.
REFERENCES
ATSDR. Toxicological profile for mercury. Agency for Toxic Substances and Disease Registry, Public
EU SCOEL. Recommendation from the scientific committee on occupational exposure limits for
elemental mercury and inorganic divalent mercury compounds. European Union Scientific Committee
on Occupational Exposure Limits. 2007;SCOEL/SUM/84.
IARC. Beryllium, cadmium, mercury, and exposures in the glass manufacturing industry. Monographs
on the Evaluation of Carcinogenic Risks to Humans. International Agency for Research on Cancer,
World Health Organization, Lyon. 1993;58, updated in 1997.
JECFA. Safety evaluation of certain contaminants in food. WHO Food Additive Series 63. Joint
Expert Committee on Food Additives. Rome, 2011.
Ngim CH, Foo SC, Boey KW, and Jeyaratnam J. Chronic neurobehavioural effects of elemental
mercury in dentists. Br J Ind Med 1992;49(11):782-90.
NTP. Technical report on the toxicology and carcinogenesis studies of mercuric chloride (CAS No.
7487-94-7) in F344 rats and B6C3F1 mice (gavage studies). National Toxicology Program, Public
Health Service, U.S. Department of Health and Human Services, Research Triangle Park, NC.
1993;NTP TR 408.
Sargent EV, Faria E, Pfister T, Sussman RG. Guidance on the establishment of daily exposure limits
(ADE) to support risk-based manufacture of pharmaceutical products. Reg Toxicol Pharmacol
2013;65:242-250.
Shimada A, Nagayama Y, Morita T et al. Localization and role of metallothioneins in the olfactory
pathway after exposure to mercury vapor. Exp Toxicol Pathol 2005;57:117-125.
US EPA. Mercuric chloride (HgCl2) (CASRN 7487-94-7). Integrated Risk Information System (IRIS).
1995.
45

MOLYBDENUM
Summary of PDE for Molybdenum
PDE (g/day)
Oral
3400
Molybdenum (Mo)
Parenteral
1700
Inhalation
11
Introduction
The main oxidation states for Mo are +4 and +6, the most common forms of which are oxyanions.
The predominant form of Mo occurring in soils and natural waters is the molybdate ion, MoO42- which
forms soluble compounds with a variety of cations including K +, NH4 + and Ca2+. Mo exists in soil in
various forms at concentration of 0.1-10 mg/kg. MoO2 and MoS2 are insoluble in water. It is widely
present in vegetables, dairy products and meats. Mo combinations (e.g., Bi-Mo, Fe-Mo, molybdenum
oxide and Mo-complexes) are being used as catalysts in organic synthesis.
Molybdenum is an essential element with an estimated upper level intake range of 100-600 g/day for
infants to adults, respectively (EC Scientific Committee on Food, 2000). Molybdenum deficiency is
characterized by night blindness, nausea, disorientation, coma, tachycardia and tachypnea and
associated with various biochemical abnormalities including high plasma methionine. In addition an
almost undetectable serum uric acid concentration has been reported in a patient receiving total
parenteral nutrition (Abumrad et al, 1981).
Molybdenum as the trioxide was not mutagenic (NTP, 1997) and a Ruksinstutuut Voor
Volksgezondheid En Milieu (RIVM) assessment concluded that molybdenum is not genotoxic (RIVM,
2001). Carcinogenicity has not been evaluated by IARC or US EPA. Molybdenum by the oral route
has low toxicity. There is some evidence of carcinogenicity in the mouse when molybdenum is
administered by the inhalation route. The possible carcinogenic effects were considered the endpoint
of greatest toxicological relevance for this route of exposure.
PDE Oral Exposure
A good laboratory practice compliant 90-day toxicology study that investigated the toxicity of sodium
molybdate dehydrate administered in the diet of rats demonstrated effects at 60 mg Mo/kg/day,
including effects on body weight, weight gain, food conversion efficiency, some organ weights
(absolute and relative to body weight) and renal histopathology (slight diffuse hyperplasia in the
proximal tubules in 2 females) (Murray et al, 2014). No adverse effects were noted after a 60-day
recovery period, with the exception of reduced body weights in male rats. No adverse effects on
reproductive organs, estrus cycles, or sperm parameters were noted. The authors conclude that the
NOAEL for this study was 17 mg Mo/kg/day. No treatment-related toxicity was seen at this dose.
Using modifying factors (F1-F5 as discussed in Appendix 1) the oral PDE is:
PDE = 17 mg/kg x 50 kg / 5 x 10 x 5 x 1 x 1 = 3.4 mg/d = 3400 g/day
In Vyskocil and Viau (1999), it was reported that oral bioavailability in humans ranged from 28-77%.
Turnland et al. (2005) report that molybdenum absorption was about 90% in healthy men. Therefore,
the parenteral PDE is divided by a modifying factor of 2 (as described in Section 3.1).
PDE= 3400 g/day / 2 = 1700 g/day
Inhaled molybdenum trioxide was carcinogenic in male and female mice (NTP, 1997) and the weight
of evidence suggests that calcium and zinc molybdates may be carcinogenic to humans (NAS, 2000).
46

Modeling was conducted using the adenoma/carcinoma incidence data (combined) in female mice
(3/50, 6/50, 8/49, and 15/49 for the 0, 10, 30 and 100 mg/m3 exposure groups, respectively) to
determine a linear extrapolation, the unit risk of lung cancer is less than 2.610 5/g/m3 (NAS, 2000).
Using a risk level of 1:100000, the inhalation PDE is calculated as follows:
Inhalation PDE =
1x10-5
2.6 x10-5 /g/m3
= 0.38 g/m3
PDE = 0.38 g/m3 / 1000 L/m3 x 28800 L/d = 10.9 g/day

No modifying factors are used to adjust a PDE derived by the unit risk approach.
REFERENCES
Abumrad NN, Schneider AJ, Steel D, Rogers LS. Amino acid intolerance during prolonged total
parenteral nutrition reversed by molybdate therapy. Am J Clin Nutr 1981;34(11):2551-9.
EC Scientific Committee on Food. Opinion of the Scientific Committee on Food on the tolerable upper
intake level of molybdenum. European Commission Committee on Food, 2000 (available at
ec.europa.eu/food/fs/sc/scf/out80h_en.pdf; accessed March 21, 2014).
Miller RF, Price NO, Engel RW. Added dietary inorganic sulfate and its effect upon rats fed
molybdenum. J Nutr 1956;60(4):539-47.
Murray FJ, Sullivan FM, Tiwary AK, Carey S. 90-Day subchronic toxicity study of sodium molybdate
dihydrate in rats. Regul Toxicol Pharmacol 2013: http://dx.doi.org/10.1016/j.yrtph.2013.09.003
(accessed September 29, 2014).
NAS. Toxicological risks of selected flame-retardant chemicals: Subcommittee on Flame-Retardant
Chemicals, Committee on Toxicology, Board on Environmental Studies and Toxicology, National
Academy
of
Sciences
National
Research
Council.
2000.
(available
at
http://www.nap.edu/catalog/9841.html; accessed March 21, 2014).
NTP. Toxicology and carcinogenesis studies of molybdenum trioxide (CAS No. 1313-27-5) in F344
rats and B6C3F1 mice (inhalation studies). National Toxicology Program, Public Health Service, U.S.
Department of Health and Human Services. 1997.
RIVM. RIVM Report 711701025: Re-evaluation of human-toxicological maximum permissible risk
levels. Ruksinstutuut Voor Volksgezondheid En Milieu (National Institute of Public Health and the
Environment). 2001.
Turnland JR, Keyes WR, Peiffer GL. Molybdenum absorption, excretion, and retention studied with
stable isotopes in young men at five intakes of dietary molybdenum. Am J Clin Nutr 1995;62:790-796.
Vyskocil A, Viau C. Assessment of molybdenum toxicity in humans. J Appl Toxicol 1999;19:185192.
47

NICKEL
Summary of PDE for Nickel
PDE (g/day)
Oral
220
Nickel (Ni)
Parenteral
22
Inhalation
6.0
Introduction
Nickel (Ni) is a Group 10 element of the first transition series. Although nickel may exist in the 0, +1,
+2 and +3 oxidation states, its main oxidation state is +2. Nickel is a naturally occurring metal
existing in various mineral forms. In general, nickel compounds are grouped based on solubility in
water, and the more soluble nickel compounds, including nickel chloride, nickel sulfate, and nickel
nitrate, tend to be more toxic than less soluble forms, such as nickel oxide and nickel subsulfide
(ATSDR, 2005). Nickel is nutritionally not essential for humans, but nickel deficiency may cause
adverse effects in animals. Nickel as Ni-Al alloys is being used as catalyst in hydrogenation reactions.
Stainless steel, which may be used in metered-dose inhaler components, is an iron-based alloy
containing chromium and may also contain <1-38% nickel as an oxide (Stockmann-Juvala et al, 2013;
NTP, 2006). Daily intake of nickel ranges from 100-300 g/day (US EPA, 1996).
Nickel is genotoxic, but not mutagenic (IARC 2012). There is no indication of carcinogenicity of Ni
salts after oral administration (Heim et al, 2007). Depending on the type of salt there was an increase
in tumors in some rodent inhalation studies (ATSDR, 2005; EU EFSA, 2005). The US EPA has
concluded that there is sufficient evidence of carcinogenicity of nickel refinery dust (US EPA, 2012).
In contrast to nickel refinery dust, no significant increase in cancer risk was found in workers in nickel
alloy or stainless steel production (ATSDR, 2005). Combining all forms of nickel, IARC (2012)
classified nickel as a human carcinogen (Group 1).
In humans and animals, ingestion of large amounts of nickel may cause stomach pain, depression of
body weight and adverse effects on blood and kidneys. Humans generally become sensitized to nickel
after prolonged contact with the skin. Human data show that an oral challenge to a single dose of
nickel administered in drinking water can induce dermatitis in nickel-sensitized individuals (Nielsen et
al, 1999). In the derivation of the oral reference dose (US EPA, 1996) for soluble salts of nickel,
individuals with nickel hypersensitivity were not taken into account. Chronic inhalation may produce
adverse changes such as inflammation in lung and nasal cavity in both humans and animals; bronchitis,
emphysema, fibrosis and impaired lung function have been reported in nickel welders and foundry
workers (ATSDR, 2005). The inflammatory lung lesions which developed in rats administered the
soluble NiSO4 were qualitatively similar, but less severe than those occurring in rats administered the
insoluble NiO (Benson, 1995). The toxicity of nickel appears greater for soluble forms, which are
more rapidly absorbed from the lung (Schaumlffel, 2012).
PDE Oral Exposure
In a 2-year carcinogenicity study in rats administered nickel sulfate hexahydrate at 10, 30 or 50
mg/kg/day, no treatment-related tumors were observed. There was a significant exposure-response in
mortality in females during weeks 0-105 at all dose levels, and a dose-dependent decrease in body
weights in both sexes at week 103 that reach significance in the 30 and 50 mg/kg/day groups (Heim et
al, 2007). Using the LOAEL of 10 mg/kg/day (2.2 mg Ni/kg/d), and taking into account the
modifying factors (F1-F5 as discussed in Appendix 1), the oral PDE is:
A factor of 10 was chosen for F5 because a LOAEL was used to set the PDE.
48

A human study using a stable nickel isotope estimated that 29-40% of the ingested label was absorbed
(based on fecal excretion data) (Patriarca et al. 1997). In another study assessing the effect of food on
nickel absorption, between 2-23% of an administered dose was absorbed (Nielsen et al, 1999).
Therefore, on the basis of limited oral bioavailability of nickel and water-soluble nickel compounds,
the parenteral PDE was calculated by dividing the oral PDE by a modifying factor of 10 (as described
in Section 3.1).
PDE = 220 g/d / 10 = 22 g/day
For calculation of the inhalation PDE, a relevant form of nickel was selected from the available data.
In 2-year studies with nickel oxide, no tumors were observed in hamsters (Wehner et al. 1984) or mice
(NTP, 2006). There was some evidence of carcinogenicity in rats (NTP, 2006) but no evidence of
carcinogenicity with inhalation of metallic nickel (Oller et al, 2008). For nickel, the modifying factor
approach was considered acceptable because the forms and levels likely to be in inhalation drug
products have not shown evidence of carcinogenicity. Taking into account the modifying factors (F1F5 as discussed in Appendix 1), the inhalation PDE is calculated based on the NOAEL in the rat study
of 0.5 mg Ni/m3 /day.
For continuous dosing = 0.5 mg/m3 x 6 hr/d x 5 d/wk = 0.089 mg/m3 = 0.000089 mg/L
24 hr/d x 7 d/wk
1000L/m3
Daily dose
= 0.000089 mg/L x 290 L/d

0.425 kg bw
0.060 mg/kg
PDE = 0.060 mg/kg x 50 kg / 5 x 10 x 1 x 10 x 1 = 6.0 g/day

A factor of 10 was chosen for F4 because of the potential of relatively insoluble forms of Ni to
accumulate in the lungs and that inflammation was observed in the lungs upon histopathology after
inhalation of all forms of Ni.
REFERENCES
ATSDR. Toxicological profile for nickel. Agency for Toxic Substances and Disease Registry, Public
Benson J, Chang I-Y, Cheny YS, Hahn FF, Kennedy CH et al. Fundam Appl Toxicol 1995;28:232-244.
EU EFSA. Opinion of the scientific panel on dietetic products, nutrition and allergies on a request
from the Commission related to the tolerable upper intake level of nickel. European Food Safety
Authority. EFSA Journal 2005;146:1-21.
Haney JY, McCant DD, Sielken RL, Valdez-Flores C, Grant RL. Development of a unit risk factor for
nickel and inorganic nickel compounds based on an updated carcinogenicity toxicity assessment. Reg
Toxicol Pharmacol 2012;62:191-201.
Heim KE, Bates HK, Rush RE, Oller AR. Oral carcinogenicity study with nickel sulphate hexahydrate
in Fischer 344 rats. Toxicol Sci 2007;224:126-37.
Nielsen GD, Sderberg U, Jrgensen PJ, Templeton DM, Rasmussen SN, Andersen KE et al.
Absorption and retention of nickel from drinking water in relation to food intake and nickel sensitivity.
Toxicol Appl Pharmacol 1999;154:67-75.
49

NTP. Toxicology and carcinogenesis studies of nickel oxide (CAS NO. 1313-99-1) in F344/N rats and
B6C3F1 mice (inhalation studies). National Toxicology Program, U.S. Department of Health and
Human Services. 2006;Technical Report Series No. 451.
Oller AR, Kirkpatrick DT, Radovsky A, Bates HK. Inhalation carcinogenicity study with nickel metal
powder in Wistar rats. Toxicol Appl Pharmacol 2008;233:262-75.
Ottolenghi AD, Haseman JK, Payne WW, Falk HL, MacFarland HN. Inhalation studies of nickel
sulfide in pulmonary carcinogenesis of rats. J Natl Cancer Inst 1974;54:1165-72.
Patriarca M, Lyon TD, Fell GS. Nickel metabolism in humans investigated with an oral stable isotope.
Am J Clin Nutr 1997;66:616-21.
Schaumlffel D. Nickel species:analysis and toxic effects. J Trace Elements Med Biol 2012;26:1-6.
Stockmann-Juvala H, Hedberg Y, Dhinsa NK, Griffiths DR, Brooks PN et al. Inhalation toxicity of
316L stainless steel powder in relation to bioaccessibility. Human Exp Toxicol 2013;32(11):11371154.
US EPA. Nickel, soluble salts (CASRN various). Integrated Risk Information System (IRIS). 1996.
US EPA. Nickel refinery dust (no CASRN). Integrated Risk Information System (IRIS). 2012.
Wehner AP, Dagle GE, Busch RH. Pathogenicity of inhaled nickel compounds in hamsters. IARC Sci
Publ 1984;(53):143-51.
50

PALLADIUM
Summary of PDE for Palladium
PDE (g/day)
Oral
100
Palladium (Pd)
Parenteral
10
Inhalation
1.0
Introduction
Palladium (Pd) is a steel-white, ductile metallic element resembling and occurring with the other
platinum group metals and nickel. It exists in three states: Pd(0) (metallic), Pd(2+) and Pd(4+). It can
form organometallic compounds, only few of which have found industrial uses. Palladium (on various
supports) is being used as catalyst in hydrogenation reactions. Palladium metal is stable in air and
resistant to attack by most reagents except aqua regia and nitric acid.
In a 90-day study in male rats administered 10, 100 and 250 ng/mL palladium in drinking water,
palladium was found to accumulate in the kidney but not liver, lung, spleen or bones. Elimination was
primarily through the fecal route (Iavicoli et al, 2010). Several in vitro mutagenicity tests of different
palladium compounds with bacterial or mammalian cells (Ames test with Salmonella typhimurium;
SOS chromotest with Escherichia coli; micronucleus test with human lymphocytes) gave negative
results (IPCS, 2002; Kielhorn et al, 2002). The data was reviewed to identify the safety limiting
toxicities based on routes of administration.
PDE Oral Exposure
Several long-term animal studies have been conducted exploring the toxicity and carcinogenicity of
palladium salts. However, none to date have been executed in accordance with current guidelines for
toxicological studies. The available data suggest potential NOAELs for palladium in the range of 0.81.5 mg/kg. A lifetime study with mice given Pd(2+) chloride in drinking-water at a dose of about 1.2
mg Pd/kg/day found a significantly higher incidence of amyloidosis in several inner organs of males
and females and suppressed growth in males, but not in females (Schroeder and Mitchener, 1971;
IPCS, 2002). This study also contained a signal that suggested a possible carcinogenic endpoint;
however, the design of the study (single dose level, pooling of the tumor rates from male and female
animals, and a significant increase in the age of the treated vs control animals) limited the utility of the
data to assess the carcinogenic potential. Taking into account the modifying factors (F1-F5 as
discussed in Appendix 1), the oral PDE is calculated based on the LOEL of 1.2 mg/kg/day.
A factor of 5 was chosen for F5 because a LOEL was used in deriving the PDE.
The safety review for palladium was unable to identify any significant assessments upon which to
calculate a PDE for parenteral routes of exposure. Pd(2+) chloride (PdCl2) was poorly absorbed from
the digestive tract (<0.5% of the initial oral dose in adult rats or about 5% in suckling rats after 3-4
days). Absorption/retention in adult rats was higher following intratracheal or intravenous exposure,
resulting in total body burdens of 5% or 20%, respectively, of the dose administered, 40 days after
dosing (IPCS, 2002). On the basis of limited oral bioavailability of palladium, the parenteral PDE was
calculated by dividing the oral PDE by a modifying factor of 10 (as described in Section 3.1).
PDE = 100 g/d / 10 = 10 g/day
51

There are no adequate inhalation data on Pd. Therefore, the inhalation PDE was calculated by
dividing the oral PDE by a modifying factor of 100 (as described in Section 3.1).
PDE = 100 g/d / 100 = 1.0 g/day
REFERENCES
Iavicoli I, Bocca B, Fontana L, Caimi S, Bergamaschi A, Alimonti A. Distribution and elimination of
palladium in rats after 90-day oral administration. Toxicol Ind Health 2010;26.
IPCS. Palladium. Environmental Health Criteria 226. International Programme on Chemical Safety.
Kielhorn J, Melver C, Keller D, Mangelsdorf I. Palladium a review of exposure and effects to human
health. Int J Hyg Environ Health 2002;205:417-432.
Schroeder HA, Mitchener M. Scandium, chromium (VI), gallium, yttrium, rhodium, palladium, indium
in mice: Effects on growth and life span. J Nutr 1971;101:1431-8.
52

PLATINUM
Summary of PDE for Platinum
PDE (g/day)
Oral
108
Platinum (Pt)
Parenteral
10.8
Inhalation
1.4
Introduction
Platinum (Pt) is a Group 8 element of the third transition series. It is the most important of the six
heaviest of the Group 8 elements, collectively called the platinum group metals or platinoids,
including palladium, osmium, rhodium, ruthenium and iridium. Metallic platinum has been shown to
catalyze many oxidation-reduction and decomposition reactions and the major industrial use of
platinum is as a catalyst. Platinum complexes exhibiting a range of oxidation states are known,
although the principal oxidation states are +2 and +4. Pt(2+) forms a tetra-coordinate aqua ion [Pt
(H2O)4]2+. The most common Pt IV catalysts are chloroplatinate salts such as tetra and
hexachloroplatinate ions.
No experimental data are available on the carcinogenicity of platinum and platinum compounds forms
likely to be present in pharmaceuticals as impurities, and toxicology data are limited (US EPA, 2009).
Chlorinated salts of platinum are responsible for platinum related hypersensitivity and are a major
occupational health concern (US EPA, 2009). The hypersensitivity appears to be the most sensitive
endpoint of chloroplatinate exposure, at least by the inhalation route. Signs include urticaria, contact
dermatitis of the skin, and respiratory disorders ranging from sneezing, shortness of breath, and
cyanosis to severe asthma (IPCS, 1991). Exposure reduction was effective in resolving symptoms
(Merget et al, 2001). Neutral complexes and complexes without halogenated ligands do not appear
allergenic (US EPA, 2009; EU SCOEL, 2011). The risk of hypersensitivity appears to be related to
sensitizing dose and dose and length of exposure (IPCS, 1991; US EPA, 2009; Arts et al, 2006) and
cigarette smoking (US EPA, 2009; Merget et al, 2000; Caverley et al, 1995). The data was reviewed
to identify the safety limiting toxicities based on routes of administration
PDE Oral Exposure
In a study in male rats administered PtCl2 (relatively insoluble) and PtCl4 (soluble) in the diet for 4
weeks, no effects were observed on hematological and clinical chemistry parameters for PtCl 2. Plasma
creatinine was increased and a reduction in hematocrit and erythrocyte parameters was observed in
animals dosed with 50 mg Pt/kg diet for four weeks in the form of PtCl 4, the highest dose tested.
Platinum concentrations increased in tissues in animals dosed with either compound, particularly the
kidney (Reichlmayr-Lais et al, 1992). This study was used in the determination of the PDE because
toxicity is observed in the kidney with platinum compounds and was a main site of accumulation in
this study. Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the oral
PDE is calculated based on the NOAEL of 10 mg Pt/kg diet (4.1 mg Pt taken over 28 days; 0.146
mg/d). The body weight of the rats was 35 g at the beginning of the study and the average weight gain
over the course of the study was 235 g. A mean body weight of 135 g was used in the calculation.
0.146 mg/d / 0.135 kg = 1.08 mg/kg/day
The safety review for platinum identified limited assessments of platinum salt toxicity for parenteral
routes of administration. The oral absorption of platinum salts is very low in rats (<1% when
53

administered by gavage) and higher in humans (42-60% of dietary Pt; US EPA, 2009). Therefore, the
oral PDE is divided by a factor of 10 (as described in Section 3.1) to obtain the parenteral PDE.
PDE = 108 g/d / 10 = 10.8 g/day
Due to the use of the chloroplatinates in catalytic converters, numerous animal (Biagini et al, 1983)
and human (Pepys et al, 1972; Pickering 1972; Merget et al, 2000; Cristaudo et al., 2007) studies have
been conducted. The US EPA (1977; 2009) and the European Scientific Committee on Occupational
Exposure Limits (EU SCOEL, 2011) have also examined the safety of chloroplatinates based on
sensitization. The European Scientific Committee on Occupational Exposure Limits (EU SCOEL)
concluded that the database does not allow for setting an occupational limit for soluble platinum salts.
The US DoL (2013) has established an occupational limit for soluble platinum salts at 2 g/m3.
calculated as:
For continuous dosing = 2 g/m3 x 8 hr/d x 5 d/wk = 0.48 g/m3 = 0.00048 g/L
24 hr/d x 7 d/wk
1000 m3/L
Daily dose
= 0.00048 g/L x 28800 L/d = 0.27 g/kg/day

50 kg
PDE = 0.27 g/kg/d x 50 kg / 1 x 10 x 1 x 1 x 1 = 1.4 g/d

REFERENCES
Arts JHE, Mommers C, de Heer C. Dose-response relationships and threshold levels in skin and
respiratory allergy. Crit Rev Toxicol 2006;36:219-51.
Biagini RE, Moorman WJ, Smith RJ, Lewis TR, Bernstein IL. Pulmonary hyperreactivity in
cynomolgus monkeys (Macaca fasicularis) from nose-only inhalation exposure to disodium
hexachloroplatinate, Na2PtCl6. Toxicol Appl Pharmacol 1983;69:377-84.
Caverley AE, Rees D, Dowdeswell RJ, Linnett PJ, Kielkowski D. Platinum salt sensitivity in refinery
workers: incidence and effects of smoking and exposure. Int J Occup Environ Med 1995;52:661-66.
Cristaudo A, Picardo M, Petrucci F, Forte G, Violante N, Senofonte O et al. Clinical and allergological
biomonitoring of occupational hypersensitivity to platinum group elements. Anal Lett 2007;40:334359.
EU SCOEL. Recommendation from the scientific committee on occupational exposure limits for
platinum and platinum compounds. European Union Scientific Committee on Occupational Exposure
Limits. 2011;SCOEL/SUM/150.
IPCS. Platinum. Environmental Health Criteria 125. International Programme on Chemical Safety.
Merget R; Kulzer R; Dierkes-Globisch A, Breitstadt R, Gebler A, Kniffka A, Artelt S, Koenig HP, Alt
F, Vormberg R, Baur X, Schultze-Werninghaus G. Exposure-effect relationship of platinum salt
allergy in a catalyst production plant: conclusions from a 5-year prospective cohort study. J Allergy
Clin Immunol 2000;105:364-370.
Merget R, Caspari C, Kulzer SA, Dierkes-Globisch R, Kniffka A, Degens P et al. Effectiveness of a
medical surveillance program for the prevention of occupational asthma caused by platinum salts: a
nested case control study. J Allergy Clin Immunol 2001;107:707-12.
Pepys J, Pickering CAC, Hughes EG. Asthma due to inhaled chemical agents--complex salts of
platinum. Clin Exp Allergy 1972;2:391-96.
54

Pickering CAC. Inhalation tests with chemical allergens: complex salts of platinum. Proc R Soc Med
1972;65:2-4.
Reichlmayr-Lais AM, Kirchgessner M, Bader R. Dose-response relationships of alimentary PtCl2 and
PtCl4 in growing rats. J Trace Elem Electrolytes Health Dis 1992;6(3):183-7.
Labor. 2013.
US EPA. Platinum-group metals. Environmental Health Effects Research Series 1977;EPA-600/1-77040.
US EPA. Toxicological review of halogenated platinum salts and platinum compounds. In support of
summary information on the Integrated Risk Information System (IRIS). 2009. EPA/635/R-08/018
55

Platinum-Group Elements
Summary of PDE for Platinum-Group Elements
Iridium (Ir), Osmium (Os), Rhodium (Rh), Ruthenium (Ru)
Oral
Parenteral
Inhalation
PDE (g/day)
100
10
1.0
Introduction
There is limited toxicological data for the Platinum-Group Elements (PGE) other than platinum, and,
to a lesser extent, palladium. Occupational exposure to the PGE may cause hypersensitivity with
respiratory symptoms and contact dermatitis (Goossens et al, 2011). Acute LD50s are available for
some of the platinum-group elements but this information was not sufficient for setting a PDE; longer
term toxicology studies are not available. RuO4 appears to be a stronger oxidizing agent than OsO4, at
least when used in fixing tissues (Gaylarde and Sarkany, 1968; Swartzendruber et al, 1995). It appears
that the soluble salts of the PGE are more toxic than the metal (Wiseman and Zereini, 2009).
Based on the lack of information on toxicity of the PGE, the PDEs for all routes of administration are
based on the palladium PDEs rather than platinum as the more conservative approach. The limited
safety information for the PGE is described below.
Safety Evaluation
There are very few published data on the safety of Iridium, Osmium, Rhodium and Ruthenium.
Iridium
o Iridium induced DNA single strand breaks in rat fibroblasts as measured in a Comet assay
when fibroblasts were incubated with Ir(3+) chloride hydrate for 24 hours No strand
breaks were seen after a 2 hour incubation (Iavicoli et al, 2012).
o Groups of Wistar rats were administered Ir(3+) chloride hydrate in drinking water (0,
0.019, 0.19, 1.9, 9.5 and 19 g Ir/d) for 90 days to assess nephrotoxicity Iavicoli et al,
2011). While there may have been some indication of renal toxicity from 0.19 g/d, this
study was not adequate to set an oral PDE.
Osmium
o Osmium tetroxide is not very soluble in water (Luttrell and Giles, 2007). Metallic osmium
is not toxic (McLaughlin et al, 1946).
o Osmium tetroxide has been used as a treatment for arthritis. As a vapor, OsO 4 can cause
severe eye damage and irritation to the eye, nose, throat and bronchial tubes, lung, skin,
liver and kidney damage (USDoL, 1978; Luttrell and Giles, 2007).
o The Permitted Exposure Limit (PEL) TWA for osmium tetroxide (as osmium) is 0.002
mg/m3 (UsD0L, 2013).
Rhodium
o Rh salts (K2RhCl5, (NH4)3RhCl6) were genotoxic in Salmonella typhimurium (Bnger et
al, 1996). In this assay, rhodium was similar to palladium in terms of cytotoxicity and
genotoxicity and much less toxic than platinum. Rhodium induced DNA single strand
breaks in rat fibroblasts as measured in a Comet assay when fibroblasts were incubated
with Rh(3+) chloride hydrate for 2 or 24 hours (Iavicoli et al, 2012). RhCl3 was genotoxic
in the human lymphocyte micronucleus assay and increased DNA migration (Comet
assay) in white blood cells (Migliore et al, 2002).
o In a lifetime carcinogenicity bioassay in mice administered rhodium chloride, a higher
incidence of tumors in treated animals compared to controls was noted at a dose of 5 ppm
in drinking water. The data on tumors were too limited to allow a conclusion of
carcinogenicity, a, similar to palladium (Schroeder and Mitchener, 1971).
56

o The PEL TWA for rhodium (as Rh) metal fume and insoluble compounds is 0.1 mg/m3.
The PEL TWA for soluble compounds of Rh is 0.001 mg/m3 (UsD0L, 2013).
Ruthenium
o Several Ru complexes cause genotoxic responses in vitro in Salmonella typhimurium
strains TA98 and TA100 (Monti-Bragadin et al, 1975; Yasbin et al, 1980; Benkli et al,
2009).
o Oral absorption of Ru is low (about 4%); the half-life of a parenteral dose is about 200
days. Ingested ruthenium compounds are retained in bones (Furchner et al, 1971).
REFERENCES
Benkli K, Tunali Y, Cantrk S, Artagan O, Alanyali F. Cytotoxic and genotoxic effects of [Ru(phi)3]2+
evaluated by Ames/Salmonella and MTT methods. Europ J Medic Chem 2009;44:2601-5.
Bnger J, Stork J, Stalder K. Cyto- and genotoxic effects of coordination complexes of platinum,
palladium and rhodium in vitro. Int Arch Occup Environ Health 1996;69(1):33-8.
Furchner JE, Richmond CR, Drake GA. Comparative Metabolism of Radionuclides in Mammals VII. Retention of 106Ru in the Mouse, Rat, Monkey and Dog. Health Phuysics 1971;21(3):355-65.
Gaylarde P, Sarkany I. Ruthenium tetroxide for fixing and staining cytoplasmic membranes. Science
1968;161(3846):1157-8.
Goossens A, Cattaert N, Nemery B, Boey L, De Graef E. Occupational allergic contact dermatitis
caused by rhodium solutions. Contact dermatitis 2011;64:158-61.
Iavicoli I, Fontana L, Marinaccio A, Calabrese EJ, Alimonti M, Pino A et al. The effects of iridium on
the renal function of female Wistar rats. Ecotoxicol Environ Safety 2011;74:1795-9.
Iavicoli I, Cufino V, Corbi M, Goracci M, Caredda E, Cittadini A et al. Rhodium and iridium salts
inhibit proliferation and induce DNA damage in rat fibroblasts in vitro. Toxicol in vitro
2012;26(6):963-9.
Luttrell WE, Giles CB. Toxic tips: Osmium tetroxide. J Chemical Health Safety 2007;Sept/Oct:40-1.
McLaughlin AIG, Milton R, Perry KMA. Toxic manifestations of osmium tetroxide. Brit J Ind Med
1946;3:183-6.
Migliore L, Frenzilli G, Nesti C, Fortaner S, Sabbioni E. Cytogenic and oxidative damage induced in
human lymphocytes by platinum, rhodium and palladium compounds. Mutagenesis 2002;17:411-7.
Monti-Bragadin C, Tamaro M, Banfi E. Mtuagenic activity of platinum and tuthenium complexes.
Chem Biol Interact 1975;11:469-72.
Schroeder HA, Mitchener M. Scandium, chromium (VI), gallium, yttrium, rhodium, palladium, indium
in mice: Effects on growth and life span. J Nutr 1971;101:1431-8.
Swartzendruber DC, Burnett IH, Wertz PW, Madison KC, Squier CA. Osmium tetroxide and
ruthenium tetroxide are complementary reagents for the preparation of epidermal samples for
transmission electron microscopy. J Invest Dermatol 1995;104(3):417-20.
USDoL (OHSA). Occupational health guideline for osmium tetroxide. U.S. Department of Labor.
1978.
USDoL (OHSA). 29 CRF 1910.1000 Table Z-1. Limits for air contaminants. U.S. Department of
Labor. 2013
Wiseman CLS, Sereini F. Airborne particulate matter, platinum group elements and human health: A
review of recent evidence. Sci Total Environ 20009;407:2493-500.
Yasbin RE, Matthews CR, Clarke MJ. Mutagenic and toxic effects of ruthenium. Chem Biol Interact
1980:31:355-65.
57

SELENIUM
Summary of PDE for Selenium
PDE (g/day)
Oral
170
Selenium (Se)
Parenteral
85
Inhalation
135
Introduction
Selenium (Se) is present in the earth's crust, often in association with sulfur-containing minerals. It can
assume four oxidation states (-2, 0, +4, +6) and occurs in many forms, including elemental selenium,
selenites and selenates. Selenium is an essential trace element for many species, including humans.
Selenium is incorporated into proteins via a specific selenocysteine tRNA. Selenium is being used as a
catalyst in the manufacture of rubber. Ru-Se catalysts are used in oxygen reduction. Aryl- and alkylSelenium reagents have various applications in organic synthesis.
Selenium was listed as a Group 3 compound (not classifiable for carcinogenesis) by IARC (1987).
The only selenium compound that has been shown to be carcinogenic in animals is selenium sulfide
(NTP, 1980). According to the US EPA, selenium sulfide is in Group B2 (probable human
carcinogen) (US EPA, 2002). Other selenium compounds are classified as D; not classifiable as to
carcinogenicity in humans.
The most significant toxicity observed with excessive exposure in humans to Se is selenosis,
characterized primarily by dermal and neurological effects, including unsteady gait and paralysis
(ATSDR, 2003). There is some concern over exposure to excessive levels of selenium in the diet; to
limit the total exposure to Se, various organizations have set an upper tolerable limit at 400 g/day
(WHO, 2011). Occupational studies describe respiratory effects such as irritation of the nose,
respiratory tract, and lungs, bronchial spasms, and coughing following chronic exposure to selenium
dioxide or elemental selenium as dust. Respiratory symptoms similar to those reported for
occupationally-exposed humans have been seen in animals inhaling high doses of elemental selenium
fumes or dust, and studies of animals with acute inhalation exposure to hydrogen selenide or elemental
selenium fumes or dust have reported hepatocellular degeneration and atrophy of the liver. Absorption
after inhalation exposure is uncertain (ATSDR, 2003).
PDE Oral Exposure
In a rat carcinogenicity study of selenium sulfide, the NOAEL for hepatocellular carcinoma was 3
mg/kg/day (1.7 mg Se/kg/day) (NTP, 1980). Although, there is insufficient data to assess carcinogenicity of
other forms of selenium, and the human relevance of the rodent liver tumors has been questioned (IARC,
1999), this is the best available study. Some human data are available but only in a limited number of
subjects (ATSDR, 2003). The calculated PDE is in line with the MRL of 5 g/kg/day for Se (ATSDR,
2003). Taking into account the modifying factors (F1-F5 as discussed in Appendix 1), the oral PDE is
calculated as below.
A factor of 10 was chosen for F4 because of the risk of selenosis.
Studies in humans and experimental animals indicate that, when ingested, several selenium
compounds including selenite, selenate, and selenomethionine are readily absorbed, often to greater
than 80% of the administered dose (ATSDR, 2003). On the basis of oral bioavailability of ~80%, the
Section 3.1).
58
PDE = 170 g/d / 2 = 85 g/day

Respiratory endpoints are the most sensitive markers for inhalation exposure in occupational studies.
Occupational limits have established time weighted averages for selenium exposures of 0.2 mg/m3 (US
DoL, 2013) and 0.07 by the European Union Scientific Expert Group (EU SEG, 1992). However, the
EU SEG Occupation Exposure Limits (OEL) was based on hydrogen selenide, a form not likely to be
present in inhalation products. Thus, using the OEL derived by US DoL, and taking into account the
modifying factors (F1-F5 as discussed in Appendix 1), the inhalation PDE is calculated as below.
For continuous dosing = 0.2 mg/m3 8 hr/d x 5 d/wk = 0.048 mg/m3 = 0.000048 mg/L
24 hr/d x 7 d/wk
1000 L/m3
Daily dose =
0.000048 mg/L x 28800 L = 0.027 mg/kg

50 kg
PDE = 0.027 mg/kg x 50 kg / 1 x 10 x 1 x 1 x 1= 0.135 mg/day =135 g/day

REFERENCES
ATSDR. Toxicological profile for selenium. Agency for Toxic Substances and Disease Registry,
EU SEG. Recommendation from the Scientific Expert Group on Occupation Exposure Limits for
Hydrogen selenide. European Union Scientific Expert Group. 1992;SEG/SUM/22C
IARC. Overall evaluations of carcinogenicity: An update of IARC monographs volumes 1 to 42.
Monographs on the Evaluation of the Carcinogenic Risks to Humans. International Agency for
Research on Cancer, World Health Organization, Lyon. 1987;Suppl 7.
IARC. Some aziridines, N-, S- and O-mustards and selenium. Summary of data reported and
evaluation. Monographs on the Evaluation of Carcinogenic Risks to Humans. International Agency for
Research on Cancer, World Health Organization, Lyon. 1999.
NTP. Bioassay of selenium sulfide (gavage) for possible carcinogenicity. National Toxicology
Program, US Department of Health and Human Services. 1980;Technical Report Series No 194.
Labor. 2013.
US EPA. Selenium and compounds (CAS No. 7782-49-2). Integrated Risk Information System (IRIS).
2002.
WHO. Selenium in Drinking-water; Background document for development of WHO Guidelines for
Drinking-water Quality. World Health Organization, Geneva. 2011. WHO/HSE/WSH/10.01/14
59

SILVER
Summary of PDE for Silver
PDE (g/day)
Oral
167
Silver (Ag)
Parenteral
14
Inhalation
7.0
Introduction
Silver (Ag) is present in silver compounds primarily in the +1 oxidation state and less frequently in the
+2 oxidation state. Silver occurs naturally mainly in the form of very insoluble and immobile oxides,
sulfides and some salts. The most important silver compounds in drinking-water are silver nitrate and
silver chloride. Most foods contain traces of silver in the 10100 g/kg range. Silver is nutritionally
not essential and no metabolic function is known. Silver is being used as a catalyst in the oxidation of
ethylene to ethylene oxide. Silver-Cadmium alloy is used in selective hydrogenation of unsaturated
carbonyl compounds. Silver oxide is used as a mild oxidizing agent in organic synthesis.
Silver is not mutagenic. Animal toxicity studies and human occupational studies have not provided
sufficient evidence of carcinogenicity. Based on these data silver is not expected to be carcinogenic in
humans (ATSDR, 1990).
Argyria appears to be the most sensitive clinical effect in response to human Ag intake. Silver acetate
lozenges are used in smoking cessation (Hymowitz and Eckholdt, 1996). Argyria, a permanent bluishgray discoloration of the skin, results from the deposition of Ag in the dermis combined with an silverinduced production of melanin. Inhalation of high levels of silver can result in lung and throat
irritation and stomach pains (ATSDR, 1990).
PDE Oral Exposure
Silver nitrate was added at 0.015% to the drinking water of female mice (0.9 g/mouse; 32.14 mg/kg
silver nitrate; 64% silver) for 125 days to examine neurobehavioral activity of the animals based on
potential neurotoxicity of silver (Rungby and Danscher, 1984). Treated animals were hypoactive
relative to controls; other clinical signs were not noted. In a separate study, silver was shown to be
present in the brain after mice were injected with 1 mg/kg intra peritoneal silver lactate (Rungby and
Danscher, 1983). The oral PDE is consistent with the reference dose of 5 g/kg/day (US EPA, 2003).
PDE = 20 mg/kg x 50 kg / 12 x 10 x 5 x 1 x 10 = 167 g/day
A factor 10 was chosen for F5 because the LOAEL was used to set the PDE as few toxicological
endpoints were examined.
US EPA (2003) identified a LOAEL of 0.014 mg/kg Ag/day using long-term (2 to 9 years) human
intravenous data based on argyria following colloidal and organic silver medication. Taking into
account the modifying factors (F1-F5 as discussed in Appendix 1), the parenteral PDE is calculated as
below.
A factor of 5 was chosen for F5 as the finding of argyria was considered a LOEL because
accumulation of silver in the skin is not considered adverse.
60

Lung and throat irritation and stomach pains were the principal effects in humans after inhalation of
high Ag levels. Using the Threshold Limit Value (TLV) of 0.01 mg/m3 for silver metal and soluble
compounds (US DoL, 2013), and taking into account the modifying factors (F1-F5 as discussed in
Appendix 1), the inhalation PDE is calculated as:
For continuous dosing = 0.01 mg/m3 8 hr/d x 5 d/wk = 0.0024 mg/m3 =0.00000238 mg/L
24 hr/d x 7 d/wk
1000 L/m3
Daily dose =
0.0000024 mg/L x 28800 L/d = 0.0014 mg/kg/day

50 kg
PDE = 0.0014 mg/kg x 50 kg / 1 x 10 x 1 x 1 x 1= 0.007 mg/d = 7.0 g/day

REFERENCES
ATSDR. Toxicological Profile for Silver. Agency for Toxic Substances and Disease Registry, Public
Hymowitz N, Eckholt H. Effects of a 2.5-mg silver acetate lozenge on initial and long-term smoking
cessation. Prev Med 1996;25:537-46.
Rungby J, Danscher G. Hypoactivity in silver exposed mice. Acta Pharmacol Toxicol 1984;55:398401.
Rungby J, Danscher G. Localization of exogenous silver in brain and spinal cord of silver exposed rats.
Acta Neuropathol 1983;60(1-2):92-8.
Labor. 2013.
US EPA. Silver (CASRN 7440-22-4). Integrated Risk Information System (IRIS). 2003.
61

THALLIUM
Summary of PDE for Thallium
PDE (g/day)
Oral
8.0
Thallium (Tl)
Parenteral
8.0
Inhalation
8.0
Introduction
Pure thallium (Tl) is a bluish-white metal. It exists primarily in two oxidation states: +1 and +3.
Monovalent thallium is similar to potassium (K+) in ionic radius and electrical charge, which
contributes to its toxic nature. Many of the thallium salts are soluble in water with the exception of the
insoluble Tl(3+) oxide. Thallium sulfate has been used in medicine, primarily as a depilatory agent,
but also to treat infections, such as venereal diseases, ringworm of the scalp, typhus, tuberculosis, and
malaria. Tl(3+) salts are being used in organic synthesis. Thallium is nutritionally not essential and
no metabolic function is known (ATSDR, 1992).
In humans and animals, the skin, especially the hair follicles, appears to be the most sensitive target of
toxicity from repeated oral exposure to thallium (US EPA, 1992; US EPA, 2009). Water soluble salts
(sulphate, acetate, or carbonate) have higher toxicity than other forms (Moore et al, 1993).
PDE Oral Exposure
The primary target organ for oral exposure to thallium in humans and animals appears to be the skin,
especially the hair follicles, as shown in a 90-day toxicity rat study with thallium sulfate. The NOAEL
was defined at 0.04 mg Tl/kg on the basis of an increased incidence of alopecia at the higher doses
(OEHHA, 1999; US EPA, 2009). Thus, the oral PDE was determined on the basis of the NOAEL of
0.04 mg Tl/kg in rat.
PDE = 0.04 mg/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 0.008 mg/day = 8.0 g/day
No relevant data on parenteral exposure to thallium compounds were found. The bioavailability of
soluble thallium salts is high (> 80%) (US EPA, 2009). Therefore, the parenteral PDE is the same as
the oral PDE.
PDE = 8.0 g/day
No relevant data on inhalation exposure to thallium compounds were found. The US EPA concluded
that information on the inhalation toxicity of thallium is insufficient to derive an inhalation reference
concentration. Occupational epidemiology studies involving possible inhalation exposures to thallium
were limited and inconclusive (US EPA, 2009). The major toxicity identified in humans and animals
is alopecia, and absorption and toxicity is considered high by the inhalation route (IPCS, 1996).
Similar findings may be expected by Tl exposure via oral and respiratory routes. For this reason, the
inhalation PDE is set at the parenteral PDE.
PDE = 8.0 g/day
62

REFERENCES
ATSDR. Toxicological profile for thallium. Agency for Toxic Substances and Disease Registry, Public
IPCS. Thallium and thallium salts: health and safety guide. International Programme on Chemical
Safety, World Health Organization, Geneva, 1996. Health and Safety Guide No. 102.
Moore D, House I, Dixon A. Thallium poisoning. Br Med J 1993;306:1527-9.
OEHHA. Public health goal for thallium in drinking water. Office of Environmental Health Hazard
Assessment, Berkeley and Sacramento, CA. 1999.
US EPA. Drinking water criteria document for thallium. Health and Ecological Criteria Division;
Office of Science and Technology; Office of Water; U.S. Environmental Protection Agency,
Washington DC, 1992.
US EPA. Toxicological review of thallium and compounds (CAS No. 7440-28-0). Integrated Risk
Information System (IRIS). 2009. EPA/635/R-08/001F
63

TIN
Summary of PDE for Tin
PDE (g/day)
Oral
6400
Tin (Sn)
Parenteral
640
Inhalation
64
Introduction
Tin (Sn) is a silvery-white metal that exists in +2 and +4 oxidation states. The most important
inorganic compounds of tin are its oxides, chlorides, fluorides and halogenated sodium stannates and
stannites. Tin is present in some multi-vitamin and mineral food supplements (at levels up to 10 g
Sn/tablet). Tin is possibly nutritionally essential for some animals, but it has not been shown to be
essential for humans. Tin(2+) chloride is being used as a reducing agent, and as a stabilizer of
polyvinylchloride (PVC). This safety assessment focuses on inorganic tin considering that the more
frequent occurrence of inorganic tin is more relevant with respect to metal impurities in drug products
than organic tin compounds.
There is no indication of in vivo genotoxicity or carcinogenicity for tin and tin salts. In several studies
in rats, a decrease in hemoglobin as an early sign for anemia was the most sensitive endpoint. In
general, in in vitro assays tin and tin salts were negative for mutagenicity but some forms were
positive for chromosomal damage (CICAD, 2005). Stannous chloride was not carcinogenic in the two
year assay in mice or rats (NTP, 1982).
PDE Oral Exposure
Anemia was the most sensitive endpoint in rats after repeated oral administration. Thus, the PDE for
oral exposure was determined on the basis of the lowest NOAEL, i.e., 150 ppm (equivalent to 32 mg
Sn/kg/day; ATSDR, 2005). This value was obtained from a 90-day study in rats based on signs of
anemia starting at 500 ppm in rats exposed to stannous chloride via diet (de Groot et al, 1973). This
study was considered more relevant than the NTP study (NTP, 1982) in determining the oral PDE
because in the 13-week NTP dose range finding study, the toxicological evaluation was more limited
(e.g., no clinical chemistry, including effects on hemoglobin) than in the study by de Groot et al.
PDE = 32 mg/kg/d x 50 kg / 5 x 10 x 5 x 1 x 1 = 6.4 mg/d = 6400 g/day
The safety review for tin was unable to identify any significant assessments upon which to calculate a
PDE for parenteral routes of exposure. On the basis of an oral bioavailability of about 5% for tin and
inorganic tin compounds (ATSDR, 2005), the parenteral PDE was calculated by dividing the oral PDE
by a modifying factor of 10 (as described in Section 3.1).
PDE = 6400 g/d / 10 = 640 g/day
The safety review for tin was unable to identify any significant assessments on inorganic tin upon
which to calculate a PDE for inhalation routes of exposure. Although a TLV is available for tin (2
mg/m3; US DoL, 2013), there is insufficient data to set a MRL (ATSDR 2005; EU SCOEL 2003).
Therefore, the PDE for tin is calculated by using a factor of 100 to convert the oral PDE to the
inhalation PDE (as described in Section 3.1).
64

PDE = 6400 g/d / 100 = 64 g/day
REFERENCES
ATSDR. Toxicological profile for tin and tin compounds. Agency for Toxic Substances and Disease
Registry, Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2005.
CICAD. Tin and inorganic compounds. Concise International Chemical Assessment Document.
World Health Organization, Geneva, 2005. Document 65.
De Groot AP, Feron V, Til H. Short-term toxicity studies on some salts and oxides of tin in rats. Food
Cos Toxicol 1973;11:19-30.
EU SCOEL. Recommendation from the scientific committee on occupational exposure limits for tin
and inorganic tin compounds. European Union Scientific Committee on Occupational Exposure Limits.
2003;SCOEL/SUM/97.
NTP. Technical report on the carcinogenesis bioassay of stannous chloride (CAS NO. 7772-99-8) in
F344/N and B6C3F1/N mice (feed study). National Toxicology Program. U.S. Department of Health
and Human Services. 1982; Technical Report Series No. 231.
Labor. 2013.
65

VANADIUM
Summary of PDE for Vanadium
PDE (g/day)
Oral
120
Vanadium (V)
Parenteral
12
Inhalation
1.2
Introduction
Vanadium (V) is present as a trace element in the earths crust and can exist in a variety of oxidation
states (-1, 0, +2, +3, +4 and +5). V is also present in trace quantities in most biological organisms with
the principal ions being vanadate, VO3- and vanadyl, VO2+. Absorption of vanadium from the
gastrointestinal tract is poor. Estimates of total dietary intake of vanadium in humans range from 10 to
60 g/day. Intake from drinking water depends on the water source and estimates are up to 140
g/day. Human populations have variable serum concentrations of vanadium, with 2 g/L being the
high end of the normal range. Despite its being ubiquitous in the body, an essential biological role for
vanadium in humans has not been established.
Vanadium is genotoxic, but not mutagenic (ATSDR, 2012). Vanadium pentoxide is classified as a
possible human carcinogen (Group 2B; IARC, 2012).
PDE Oral Exposure
Following oral administration to animals and humans the gastrointestinal tract, cardiovascular, and
hematological system are the primary targets of toxicity. The most appropriate study to assess
vanadium toxicity through oral administration was conducted in humans exposed to vanadium for 12
weeks. In this study, no significant alterations in hematological parameters, liver function (as
measured by serum enzymes), cholesterol and triglyceride levels, kidney function (as measured by
blood urea nitrogen), body weight, or blood pressure were observed in subjects administered via
capsule 0.12 or 0.19 mg vanadium as ammonium vanadyl tartrate or vanadyl sulfate for 612 weeks
(ATSDR, 2012). The oral NOAEL of 0.12 mg vanadium/kg/day for hematological and blood pressure
effects was used to calculate the oral PDE. Taking into account the modifying factors (F1-F5 as
discussed in Appendix 1), the oral PDE is calculated as below.
The safety review for vanadium was unable to identify any significant assessments upon which to
calculate a PDE for parenteral routes of exposure. On the basis of an approximate oral bioavailability
of <110% for vanadium and inorganic vanadium compounds (ATSDR, 2012), the parenteral PDE
was calculated by dividing the oral PDE by a modifying factor of 10 (as described in Section 3.1).
PDE = 120 g/day / 10 = 12 g/day
A two year chronic inhalation exposure study in rats was considered for use for the inhalation PDE for
vanadium. In this study, carcinogenic effects were observed to the lowest dose tested, 0.5 mg/m3
vanadium pentoxide (Ress et al. 2003). Vanadium pentoxide is a caustic agent and is not considered
to be present in drug products. Therefore, the inhalation PDE for vanadium was calculated by dividing
the oral PDE by a modifying factor of 100 (as described in Section 3.1).
PDE = 120 g/d / 100 = 1.2 g/day
66

REFERENCES
ATSDR. Toxicological profile for vanadium. Agency for Toxic Substances and Disease Registry,
Ress NB, Chou BJ, Renne RA, Dill JA, Miller RA, Roycroft JH et al. Carcinogenicity of inhaled
vanadium pentoxide in F344/N rats and B6C3F1 mice. Toxicol Sci 2003;74(2):287-96.
67

Appendix 4: Illustrative Examples
Examples for Converting PDEs into Permitted Elemental Impurity Concentrations
Option 1: Permitted common concentration limits of elemental impurities across drug product
component materials for products with daily intakes of not more than 10 grams.
For this example, consider a solid oral drug product with a maximum daily intake of 2.5 grams,
containing 9 components (1 drug substance and 8 excipients, see Table A.4.1). Because this drug
product does not exceed a maximum daily intake of 10 grams, the concentrations in Table A.2.2 may
be used. As Option 1 has a common permitted concentration, the 9 components can be used in any
proportion in the formulation. The drug substance synthesis uses Pd and Ni catalysts, and Pb, As, Cd,
Hg, and V are also of concern on the basis of the risk assessment. The maximum daily intake of each
elemental impurity in the drug product is given in Table A.4.2 assuming that each elemental impurity
is present at the concentration given in Table A.2.2. The maximum potential daily intake of an
elemental impurity is determined using the actual drug product daily intake and the concentration limit
for the elemental impurity in Table A.2.2 (concentration multiplied by the actual daily intake of the
drug product of 2.5 grams). The maximum daily intake given for each elemental impurity is not a
summation of values found in the individual columns of Table A.4.2.
This calculation demonstrates that no elemental impurities exceed their PDEs. Thus if these
concentrations in each component are not exceeded, the drug product is assured to not exceed the
PDEs for each identified elemental impurity.
Table A.4.1: Maximum Daily Intake of Components of the Drug Product
Component
Daily Intake, g
Drug Substance
0.200
Microcrystalline Cellulose (MCC)
1.100
Lactose
0.450
Ca Phosphate
0.350
Crospovidone
0.265
Mg Stearate
0.035
Hydroxypropylmethyl Cellulose (HPMC)
0.060
Titanium Dioxide
0.025
Iron Oxide
0.015
2.500
Drug Product
Table A.4.2: Permitted Concentrations from Table A.2.2 (assuming uniform concentrations and
10 grams daily intake)
Maximum Permitted Concentration (g/g)
Component
Pb
As
Cd
Hg
Pd
V
Ni
Drug Substance
0.5
1.5
0.5
3
10
10
20
MCC
0.5
1.5
0.5
3
10
10
20
Lactose
0.5
1.5
0.5
3
10
10
20
Ca Phosphate
0.5
1.5
0.5
3
10
10
20
Crospovidone
0.5
1.5
0.5
3
10
10
20
Mg Stearate
0.5
1.5
0.5
3
10
10
20
HPMC
0.5
1.5
0.5
3
10
10
20
Titanium Dioxide
0.5
1.5
0.5
3
10
10
20
Iron Oxide
0.5
1.5
0.5
3
10
10
20
Maximum Daily
1.25
3.75
1.25
7.5
25
25
50
intake (g)
PDE (g)
5
15
5
30
100
100
200
68

Option 2a: Permitted common concentration limits across drug product component materials for a
product with a specified daily intake:
For this example, consider the same solid oral drug product with a maximum daily intake of 2.5 grams,
containing 9 components (1 drug substance and 8 excipients, see Table A.4.1) used in Option 1. As
Option 2a has a common permitted concentration, the 9 components can be used in any proportion in
the formulation. The drug substance synthesis uses Pd and Ni catalysts, Pb, As, Cd, Hg, and V are
also of concern on the basis of the risk assessment. The maximum concentration of each elemental
impurity identified in the risk assessment can be calculated using the PDEs in Table A.2.1 and
Equation 1.
The maximum potential daily intake of an elemental impurity is determined using the actual drug
product daily intake and the concentration limit for the elemental impurity in Table A.4.3
(concentration multiplied by the actual daily intake of the drug product of 2.5 grams). The maximum
daily intake given for each elemental impurity is not a summation of values found in the individual
columns of Table A.4.3.
This calculation also demonstrates that no elemental impurities exceed their PDEs. Thus if these
concentrations in each component are not exceeded, the drug product is assured to not exceed the
PDEs for each identified elemental impurity.
The factor of 4 increase in Option 2a for permitted concentration seen when comparing Option 1 and
Option 2a concentration limits is due to the use of 10 grams and 2.5 grams, respectively, as daily
intake of the drug product.
Table A.4.3: Calculation of Maximum Permitted Concentrations Assuming Uniform
Concentrations in a Product with a Specified Daily Intake:
Component
Drug Substance
MCC
Lactose
Ca Phosphate
Crospovidone
Mg Stearate
HPMC
Titanium Dioxide
Iron Oxide
Maximum Daily
intake (g)
PDE (g)
Pb
2
As
6
Cd
2
Hg
12
Pd
40
V
40
Ni
80
2
2
2
2
2
2
2
2
6
6
6
6
6
6
6
6
2
2
2
2
2
2
2
2
12
12
12
12
12
12
12
12
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
80
80
80
80
80
80
80
80
15
30
100
100
200
15
30
100
100
200
Option 2b: Permitted concentration limits of elemental impurities across drug product component
materials for a product with a specified daily intake:
containing 9 components (1 drug substance and 8 excipients, see Table A.4.1) used in Option 1 and 2a.
The drug substance synthesis uses Pd and Ni catalysts, and Pb, As, Cd, Hg, and V are also of concern
on the basis of the risk assessment. To use Option 2b, the composition of the drug product and
additional knowledge regarding the content of each elemental impurity in the components of the drug
product are considered. The following table shows example data on elemental impurities that may be
derived from the sources described in Section 5.5:
69

Table A.4.4: Concentrations of Elemental Impurities (g/g) in the Components
Concentration (g/g)
Component
Pb
As
Cd
Hg
Pd
V
Ni
Drug Substance
<LoQ
0.5
<LoQ <LoQ
20
<LoQ
50
MCC
0.1
0.1
0.1
0.1
*
<LoQ
<LoQ
Lactose
0.1
0.1
0.1
0.1
*
<LoQ
<LoQ
Ca Phosphate
1
1
1
1
*
10
5
Crospovidone
0.1
0.1
0.1
0.1
*
<LoQ
<LoQ
Mg Stearate
0.5
0.5
0.5
0.5
*
<LoQ
0.5
HPMC
0.1
0.1
0.1
0.1
*
<LoQ
<LoQ
Titanium
20
1
1
1
*
1
<LoQ
Dioxide
Iron Oxide
10
10
10
10
*
2000
50
* = The risk assessment determined that Pd was not a potential elemental impurity; a quantitative
result was not obtained.
Using the information presented in Table A.4.4, one can evaluate different sets of potential
concentrations for each elemental impurity in each component. In table A.4.5, an example of one set
of these concentrations is displayed. In this case, a high concentration of lead has been allocated to
titanium dioxide and the PDE would not be exceeded due to the low proportion of this component in
the drug product, and the low concentrations of lead in the other components. Using these
concentrations and the component percent composition (Table A.4.1), levels of elemental impurities in
the drug product can be determined using Equation 2 and compared to the established PDE. The
concentrations given in Table A.4.5 are only suitable for the component proportions given in Table
A.4.1.
Table A.4.5: Example of Potential Concentrations of Elemental Impurities in the Components
Potential Concentration (g/g)
Component
Pb
As
Cd
Hg
Pd
V
Ni
Drug Substance
<LoQ
5
<LoQ
<LoQ
500
<LoQ
750
MCC
0.5
5
1
5
*
<LoQ
<LoQ
Lactose
0.5
5
1
5
*
<LoQ
<LoQ
Ca Phosphate
5
5
5
35
*
70
80
Crospovidone
0.5
5
1
5
*
<LoQ
<LoQ
Mg Stearate
5
10
5
125
*
<LoQ
100
HPMC
2.5
5
1
5
*
<LoQ
<LoQ
Titanium Dioxide
50
40
10
35
*
20
<LoQ
Iron Oxide
50
100
50
200
*
5000
1200
* The risk assessment determined that Pd was not a potential elemental impurity; a quantitative result
was not obtained.
Option 3: Finished Product Analysis
containing 9 components (1 drug substance and 8 excipients) used in Option 1, 2a and 2b. The drug
substance synthesis uses Pd and Ni catalysts, and Pb, As, Cd, Hg, and V are also of concern on the
basis of the risk assessment. The maximum concentration of each elemental impurity in the drug
product may be calculated using the daily intake of drug product and the PDE of the elemental
impurity using Equation 1. The total mass of each elemental impurity should be not more than the
PDE.
70

Table A.4.6: Calculation of Concentrations for the Finished Product
Drug Product
Daily
Intake (g)
Pb
As
Cd
Hg
Pd
Ni
2.5
12
40
40
80
15
30
100
100
200
Maximum Daily Intake (g)
Illustrative Example Elemental Impurities Assessment

The following example is intended as illustration of an elemental impurities risk assessment. This
example is intended for illustrative purposes and not as the only way to document the assessment.
There are many different ways to approach the risk assessment process and its documentation.
This example relies on the oral drug product described in Appendix 4. Consider a solid oral drug
product with a maximum daily intake of 2.5 grams, containing 9 components (1 drug substance and 8
excipients). The drug substance synthesis uses Pd and Ni catalysts.
The applicant conducts the risk assessment starting with the identification of potential elemental
impurities following the process described in Section 5. Because the applicant had limited historical
data for the excipients used in the drug product, the applicant determined that the Class 1 elements (As,
Cd, Hg, Pb) would be taken through the evaluation phase. The table below shows a summary of the
findings of the identification stage of the assessment.
Table A.4.7: Identification of Potential Elemental Impurities
Potential Elemental Impurities
Component
Intentionally
Potential
Potential
added
elemental
elemental
impurities with a
impurities from
relatively high
manufacturing
abundance and/or
equipment
are impurities in
excipients
Drug Substance
Pd, Ni
As
Ni
MCC
None
As, Cd, Hg, Pb
None
Lactose
None
As, Cd, Hg, Pb
None
Ca Phosphate
None
As, Cd, Hg, Pb
V, Ni
Crospovidone
None
As, Cd, Hg, Pb
None
Mg stearate
None
As, Cd, Hg, Pb
Ni
HPMC
None
As, Cd, Hg, Pb
None
Titanium Dioxide
None
As, Cd, Hg, Pb
V
Iron Oxide
None
As, Cd, Hg, Pb
V, Ni
Potential
elemental
impurities from
container
closure systems
None
None
None
None
None
None
None
None
None
The assessment identified seven potential elemental impurities requiring additional evaluation. Three
of the identified elements were found in multiple components. The applicant continued the risk
assessment by collecting information from vendors, published literature and data. The individual
component data in the risk assessment process is shown below in Table A.4.8. Total daily masses of
elemental impurities are calculated as the daily intake of the component times the concentration.
71
Table A.4.8: Elemental Impurity Assessment Evaluation of Daily Contribution to the Total Mass of Elemental Impurities in the Drug Product
Daily
intake, g
Component
Drug Substance
MCC
Lactose
Ca Phosphate
Crospovidone
Mg stearate
HPMC
Titanium Dioxide
Iron Oxide
0.2
1.1
0.45
0.35
0.265
0.035
0.06
0.025
0.015
Pb
<LoQ
0.1
0.1
1
0.1
0.5
0.1
20
10
TOTAL
2.5 g
Measured Concentration (g/g)

As
Cd
Hg
Pd
V
0.5
<LoQ <LoQ
20
<LoQ
0.1
0.1
0.1
*
<LoQ
0.1
0.1
0.1
*
<LoQ
1
1
1
*
10
0.1
0.1
0.1
*
<LoQ
0.5
0.5
0.5
*
<LoQ
0.1
0.1
0.1
*
<LoQ
1
1
1
*
1
10
10
10
*
400
-
Ni
50
<LoQ
<LoQ
5
<LoQ
0.5
<LoQ
<LoQ
50
Pb
0
0.11
0.045
0.35
0.0265
0.0175
0.006
0.5
0.15
1.2 g
Total Daily Mass of Elemental Impurity, g

As
Cd
Hg
Pd
V
0.1
0
0
4
0
0.11
0.11
0.11
0
0
0.045
0.045
0.045
0
0
0.35
0.35
0.35
0
3.5
0.0265 0.0265 0.0265
0
0
0.0175 0.0175 0.0175
0
0
0.006
0.006
0.006
0
0
0.025
0.025
0.025
0
0.025
0.15
0.15
0.15
0
6
0.8 g
0.7 g
0.7 g
4 g
9.5 g
Ni
10
0
0
1.75
0
0.0175
0
0
0.75
12.5 g
* The risk assessment determined that Pd was not a potential elemental impurity; a quantitative result was not obtained.
The next step in the risk assessment is to compare the measured or predicted levels in the drug product to the control threshold, using the information in Table
A.4.8, and determine appropriate actions.
Table A.4.9: Assessment Example Data Entry Descriptions
Column 1:
Review the components of drug product for any elements intentionally added in the production (the primary source is the drug substance).
For those used, record the elements for further consideration in the assessment.
Column 2:
Identify any potential elements or impurities that are associated with excipients used in the preparation of the drug product. Record the
source(s) for further consideration in the assessment.
Column 3:
Identify any elemental impurities known or expected to be leached from the manufacturing equipment. Record the specific elemental
impurities for further consideration in the assessment.
Column 4:
Identify any elemental impurities known or expected to be leached from the container closure system. Record the specific elemental
impurities for further consideration in the assessment.
72
Column 5:
Calculate the total contribution of the potential elemental impurity by summing the contributions across the components of the drug product.
Column 6:
Column 7:
Assess the variability of the elemental impurity level(s) in the components

Enter the control threshold of each potential elemental impurity identified. If the variability is known and it is within acceptable limits, the
control threshold (30% of the PDE) for each elemental impurity can be applied.
Column 8:
Describe action taken none if the value in column 5 is less than or equal to the control threshold (Column 7). Define control element if
material variability is high or control threshold is exceeded.
1
Intentionally
added
(if used in the
process)
Elemental impurities with a

relatively high abundance
and/or are impurities in
excipients
Manufacturing
equipment
As
No
Cd
No
Hg
No
Pb
No
Pd
API catalyst
Observed impurity in all

excipients and drug substance
excipients
excipients
excipients
No
Ni
API catalyst
No
Element
Total elemental
impurity
contribution
g/
No
4
Leached
from
container
closure
systems
No
Control
threshold
Action
0.8
6
Acceptable
variability of
elemental
impurity
contribution
yes
No
No
0.7
yes
1.5
No
No
0.7
yes
No
No
1.2
yes
1.5
No
No
4.0
yes
30
Observed in 3 excipients
No
No
12.5
yes
60
Observed in 3 excipients
No
No
9.5
yes
30
73
4.5
no further controls
required
no further controls
required
no further controls
required
no further controls
required
no further controls
required
no further controls
required
no further controls
required

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INTERNATIONAL CONFERENCE ON HARMONISATION OF TECHNICAL REQUIREMENTS

FOR REGISTRATION OF PHARMACEUTICALS FOR HUMAN USE

ICH HARMONISED GUIDELINE

GUIDELINE FOR ELEMENTAL IMPURITIES

Current Step 4 version

Approval by the Steering Committee under Step 2a.

Approval by the Steering Committee under Step 2b and

Post sign-off corrigendum in:

Post sign-off minor editorial corrections including: removal of

Addition of line numbers to facilitate the provision of

Approval by the Steering Committee under Step 4 and

Current Step 4 version

Corrigendum to correct: the modifying factor in the text of the

GUIDELINE FOR ELEMENTAL IMPURITIES

3. SAFETY ASSESSMENT OF POTENTIAL ELEMENTAL IMPURITIES ....................................................... 1

5.1 General Principles ........................................................................................................................5

CONTROL OF ELEMENTAL IMPURITIES .......................................................................................9

CONVERTING BETWEEN PDES AND CONCENTRATION LIMITS ...................................................10

SPECIATION AND OTHER CONSIDERATIONS ..................................................................................... 12

GUIDELINE FOR ELEMENTAL IMPURITIES

SAFETY ASSESSMENT OF POTENTIAL ELEMENTAL IMPURITIES

Guideline for Elemental Impurities

The likely oxidation state of the element in the drug product;

Oral bioavailability <1%: divide by a modifying factor of 100;

Other Routes of Administration

Guideline for Elemental Impurities

If local effects are expected, assess whether a modification to an established PDE is

Examples of justifying an increased level of an elemental impurity using a subfactor approach of a

Guideline for Elemental Impurities

Guideline for Elemental Impurities

RISK ASSESSMENT AND CONTROL OF ELEMENTAL IMPURITIES

Potential Sources of Elemental Impurities

Guideline for Elemental Impurities

Identification of Potential Elemental Impurities

Guideline for Elemental Impurities

Recommendations for Elements to be Considered in the Risk Assessment

If not intentionally added

Guideline for Elemental Impurities

not intentionally added);

Summary of Risk Assessment Process

Guideline for Elemental Impurities

Special Considerations for Biotechnologically-Derived Products

CONTROL OF ELEMENTAL IMPURITIES

Guideline for Elemental Impurities

Implementation of in-process or upstream controls, designed to limit the concentration of the

CONVERTING BETWEEN PDES AND CONCENTRATION LIMITS

Guideline for Elemental Impurities

an index for each of N components in the drug product

An example using this option is provided in Appendix 4 Tables A.4.4 A.4.5.

Guideline for Elemental Impurities

SPECIATION AND OTHER CONSIDERATIONS

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities

Guideline for Elemental Impurities