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Barry A. Friedman, PhD LLC

FDA Regulatory Compliance for the Pharmaceutical, Biotechnology and Medical Device Arenas

Microbial Limits / Specified Microorganisms Rationale

September 13, 2015 By Barry Friedman Leave a Comment

As a “Frequently Asked Question”, the USP is often queried about the determination of microbial limits and specified microorganisms. The following, obtained from USP, provides a clarification for this commonly asked question.

In determining the appropriate microbial limit, the USP Microbiology Expert Committee considers such matters as the route of administration, the form of the product, and the source material. For example, it is never appropriate to have any microorganisms in a product intended for injection intravenously. Therefore, you will never see a microbial limit listed for such products. Instead, those products must meet the test for . Other products may be in a form possessing extremely low water activity, such that microbial growth could not occur. You may not see microbial limits provided for some of those products. Many other products, such as those intended for oral administration, will have limits provided. Those limits are selected such that the risk of harm to the consumer is extremely low, while being reasonable from a manufacturing and quality control perspective. Products from botanical sources may have higher limits due to the larger bioburden associated with the raw materials. Again, the limits are set such that consumer risk is minimized without creating an untenable situation for the manufacturer. Consideration is also given to the likelihood of product spoilage. Since some products are more prone to spoilage due to microbial contamination, limits may be set lower for these. The issues discussed above also influence which, if any, specific organisms must be tested.

 

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Filed Under: Compounding Pharmacy, Microbiological Issues, Microbiology Consulting, Regulatory Compliance Tagged With: microbial limits, Specified microorganisms, USP, water activity

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