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HomeGlossaryNitrosamines
Quality · The complete guide

Nitrosamines

In short

Following the 2018 sartan recall, EMA Article 5(3) and FDA's 2020/2021 guidances require every marketed drug-product holder to (1) perform a nitrosamine risk assessment, (2) confirm by testing where risk is identified, and (3) implement control — against Acceptable Intakes derived under ICH M7 for the named N-nitrosamines.

1,322 words · ~7 min read
On this page
  1. 01Why this whole programme exists
  2. 02The regulatory framework — EMA, FDA, ICH M7
  3. 03How nitrosamines get into drug products — the four-source taxonomy
  4. 04Control options — prevention, mitigation, replacement
  5. 05Common findings on the post-2020 nitrosamine programme
  6. 06How V5 Ultimate supports the nitrosamine programme
On this page · 6 sections
  1. 1Why this whole programme exists
  2. 2The regulatory framework — EMA, FDA, ICH M7
  3. 3How nitrosamines get into drug products — the four-source taxonomy
  4. 4Control options — prevention, mitigation, replacement
  5. 5Common findings on the post-2020 nitrosamine programme
  6. 6How V5 Ultimate supports the nitrosamine programme
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01Why this whole programme exists

In July 2018, valsartan API from Zhejiang Huahai Pharmaceutical was found to contain N-nitrosodimethylamine (NDMA), a probable human carcinogen, at levels well above any safe threshold. Investigation traced the impurity to a 2012 change in synthetic route that introduced tetrazole-forming conditions in the presence of nitrite. The recall expanded across the sartan class (irbesartan, losartan, olmesartan), then to ranitidine (NDMA in the molecule itself under typical storage), metformin (high-volume Type 2 diabetes drug, NDMA detected at levels exceeding the AI), and a long list of other products. The episode forced a wholesale rethink of impurity-control philosophy across pharma.

One-Sentence Summary

Nitrosamine controls became universal in 2020 because a 2018 catalyst-and-solvent change at one API site put a genotoxic impurity into 50+ globally registered products before anyone caught it.

02The regulatory framework — EMA, FDA, ICH M7

EMA Article 5(3) procedure (2019) and FDA's February 2021 guidance (with September 2024 revision) require every Marketing Authorisation Holder (MAH) to perform three steps for every chemical drug product:

  1. Step 1 — Risk assessment (deadline: 31 March 2021 for chemical APIs in EMA; 31 March 2021 for FDA chemical products). Assess each API + finished product against the known sources of N-nitrosamines (vulnerable APIs, manufacturing processes, materials, packaging, drug-substance impurities — NDSRIs).
  2. Step 2 — Confirmatory testing where risk is identified (deadline: 26 September 2022 originally for EMA, extended for NDSRIs). Validated LC-MS/MS or GC-MS/MS methods at the low ppb / ppt level.
  3. Step 3 — Risk-mitigation / control (variations and labelling changes as needed). Where exposure exceeds the AI, the product must be re-engineered, re-supplied or removed from market.

Acceptable Intakes (AIs) are calculated using the ICH M7 framework — TD50 from carcinogenicity bioassay divided by 50,000 (the standard 1-in-100,000 lifetime cancer-risk margin), or the threshold of toxicological concern (1.5 µg/day for non-cohort genotoxins) when no specific data exist. The FDA published recommended AIs for NDMA (96 ng/day), NDEA (26.5 ng/day), NMBA (96 ng/day), NMPA (26.5 ng/day), NIPEA (26.5 ng/day) and NDIPA (26.5 ng/day). NDSRI AIs (where the nitrosamine retains the API's structural fragment) are published in tranches as the agency works through them.

03How nitrosamines get into drug products — the four-source taxonomy

  • Source 1 — API synthesis. Secondary or tertiary amines + a nitrosating agent (nitrite, nitrous acid, nitrogen oxides, certain catalysts) under acidic conditions form nitrosamines. The classic sartan failure mode (tetrazole-forming step + recovered DMF solvent + acidic conditions = NDMA). Process risk assessment should be element-by-element for every step.
  • Source 2 — Cross-contamination from previous products on shared equipment. Especially relevant in multi-product API plants and CMOs.
  • Source 3 — Raw materials / starting materials carrying nitrosamines or precursors. Recovered solvents (DMF, DMA, NMP), nitrite-containing salts, amine reagents.
  • Source 4 — NDSRIs (Nitrosamine Drug Substance-Related Impurities) — formed in the finished drug product from secondary-amine-containing APIs reacting with trace nitrite from excipients (typically <1 ppm in many common excipients) under typical formulation/storage conditions. The hardest source to engineer out, because nitrite is everywhere at trace levels.

04Control options — prevention, mitigation, replacement

When risk is confirmed, the available controls form a hierarchy:

  1. Eliminate the precursor — change the synthetic route to avoid the nitrosating step, use a non-nitrite-bearing reagent, change the solvent (avoid recovered DMF in nitrite-containing process). The strongest control, requires variation.
  2. Process change to suppress formation — add nitrite scavenger (ascorbic acid, gallic acid, vitamin E), lower the temperature, shorten the hold time at risk, change pH, add a downstream purification step.
  3. Excipient change — switch to a low-nitrite excipient grade (when justified for the formulation), control nitrite spec on the excipient at the supplier level, change excipient supplier.
  4. Drug-substance specification — set a nitrosamine impurity limit at the API level (with associated method validation, OOS workflow, change-control discipline).
  5. Finished-product testing per batch — least efficient (testing in is harder than designing in) but sometimes the only option for legacy products under transition.
  6. Withdraw from market — when re-engineering is infeasible and the AI cannot be met, products have been (and continue to be) recalled.

05Common findings on the post-2020 nitrosamine programme

  1. Risk assessment treated as a one-off — not re-opened when the API supplier, excipient grade or finished-product formulation changes.
  2. Step 2 (confirmatory testing) delayed past the deadline without a documented justification — a frequent EMA variation finding.
  3. Test method validated for one matrix (API) but applied to a different matrix (finished tablet) without re-validation — sensitivity collapses.
  4. AI calculated against the wrong daily dose — the AI is the absolute µg/day, not a percentage of the spec.
  5. NDSRI not even considered for secondary-amine APIs — only the named nitrosamines (NDMA, NDEA) tested.
  6. Excipient nitrite content not characterised — supplier hasn't been asked, and the formulator's risk assessment assumes nitrite-free.
  7. Cross-contamination risk from shared API equipment not assessed — the equipment-history file shows a nitrite-process campaign immediately before the at-risk product.

06How V5 Ultimate supports the nitrosamine programme

  • Nitrosamine-risk-assessment register per product holds the four-source assessment, the assumptions, the supporting data and the current status (initial / under confirmatory testing / mitigated / recalled). The register is a controlled record under change control, not a Word file.
  • Change-control workflow auto-routes API-source changes, synthetic-route changes, excipient-grade changes, formulation changes and equipment-history events (previous campaigns on shared API equipment) to the nitrosamine assessment owner.
  • LC-MS/MS or GC-MS/MS test data integrate with LIMS as critical release attributes; the method is held as a validated Q2(R2) procedure with documented sensitivity to the low-ppb level.
  • AI tracking — the platform holds the regulatory AI per nitrosamine and product, and computes the percent-of-AI for every batch's measured (or estimated) content. Drift toward the AI is visible before exceedance.
  • Recall-readiness — if a batch exceeds the AI, the platform's recall workflow uses the genealogy and shipping data to identify all affected lots and downstream consignees within minutes, not days.
  • Supplier portal includes a nitrite spec on excipient CoAs where required — the data lives on the same record the formulator's risk assessment cites.
The Honest Version

V5 will not perform the toxicology, validate the LC-MS method or design the synthetic route — that's analytical-chemistry + CMC + RA work. It will make sure the risk assessment is a living controlled record, that the right changes re-open it, that every batch's nitrosamine result is tied to the regulatory AI, and that recall execution is minutes not days when a batch fails.

Frequently asked questions

Q.Does the nitrosamine programme apply to biologics?+

Generally no — the EMA and FDA programmes apply to chemical drug products. Biologics rarely contain the structural motifs that lead to N-nitrosamine formation. However, biological products using small-molecule excipients/buffers that themselves carry nitrosamine risk may need a targeted assessment.

Q.What's an NDSRI?+

An NDSRI — Nitrosamine Drug Substance-Related Impurity — is an N-nitrosamine formed by nitrosation of a secondary-amine fragment of the drug substance itself, so the impurity retains the API's structural backbone (e.g. N-nitroso-varenicline, N-nitroso-rasagiline). NDSRIs are the hardest class to manage because (a) the parent amine is in the drug by design, (b) nitrite is ubiquitous in excipients at trace levels, and (c) each NDSRI requires its own AI determination (some are far stricter than the named-nitrosamine 96 ng/day default).

Q.Is the 1.5 µg/day TTC always usable for nitrosamines?+

No. The ICH M7 TTC of 1.5 µg/day applies to non-cohort-of-concern mutagens. N-nitrosamines are a 'cohort of concern' under M7 because of their potency; the default for cohort-of-concern impurities is much lower (typically calculated from compound-specific data, often in the tens to low-hundreds of ng/day). The published per-nitrosamine AIs reflect this.

Q.Do I need to test every batch?+

Not necessarily. If the risk assessment plus a robust upstream control (synthetic-route prevention, validated nitrite scavenger, low-nitrite excipient spec, equipment-cleaning verification) consistently delivers nitrosamine below the control threshold (typically 30 % of AI), routine batch-level finished-product testing can be replaced by periodic confirmatory testing and on-change re-evaluation. EMA expects the rationale in the dossier.

Q.Can the AI change?+

Yes — agencies update the AI as new toxicology data emerge or as the inventory of new NDSRIs grows. The Sep 2024 FDA revision is one such update. The risk assessment should include a procedure for monitoring the regulatory landscape and re-evaluating the AI when published values move.

Primary sources

  • EMA Q&A on Nitrosamine impurities (latest revision)
  • FDA Guidance: Control of Nitrosamine Impurities in Human Drugs (Feb 2021, rev. Sep 2024)
  • FDA Recommended Acceptable Intake Limits for Nitrosamine Drug Substance-Related Impurities (NDSRIs) — Aug 2023
  • ICH M7(R2) Assessment and Control of DNA Reactive (Mutagenic) Impurities
  • EU GMP Annex 15 / Chapter 5 (cleaning + cross-contamination)

Further reading

  • ICH Q3D
    The sister-framework — elemental impurities, different chemistry, same risk philosophy.
  • Control strategy
    Nitrosamine controls live in the impurity-control section of the strategy.
  • Certificate of Analysis
    Nitrosamine results, when on a CoA, are treated as critical release data.
  • Out-of-Specification
    Nitrosamine exceedances trigger an immediate OOS + recall-readiness review.
  • Data Integrity
    The risk assessment is a regulated record under ALCOA+.
Software that covers Nitrosamines
V5 Ultimate Batch Genealogy Software
Input lots, intermediates from linked sub-jobs, finished lots and shipments are linked as work is recorded, so a lot trace runs…
V5 Ultimate (FDA Compliance)
V5 Ultimate is a single-platform FDA compliance system for US manufacturers regulated under 21 CFR — pharma (210/211), medical…
Talk to us about Nitrosamines

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Inside V5
  • → 21 CFR Part 11 — signatures and audit history your team can validate.
Example reports
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Regulatory anchors
  • EMA Article 5(3) Q&A
  • FDA Nitrosamine Guidance 2021 (rev. 2024)
  • ICH M7(R2)
Related terms
  • → ICH Q3D
  • → Control strategy
  • → CoA
  • → OOS
  • → Data Integrity

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