Turnaround, cost and accreditation across the services this trade relies on

Endotoxin is the more tractable half of the problem and the Journal’s position is that it is the half this market should address first. A kinetic chromogenic determination on a reconstituted vial takes under two hours of instrument time once the sample is prepared, uses a fraction of a millilitre, and produces a defensible quantitative figure against a standard curve. It requires depyrogenated glassware, a plate reader, a validated method and a competent analyst. It does not require a fortnight or a cleanroom.

Sterile is a claim about a process

In ordinary speech, calling something sterile describes a state. In pharmaceutical manufacture it describes a provenance. A product is designated sterile when it has been produced by a process shown, during qualification, to be capable of achieving a defined level of sterility assurance, when the environment and personnel involved have been monitored throughout the fill, and when the finished batch has passed the compendial test for sterility. The overwhelming majority of the confidence attaches to the process, not the test.

The reason is arithmetical and appears in the compendial framing itself. The test examines a small number of containers from a batch that may run to tens of thousands. Contamination arising from aseptic processing failures is characteristically sporadic and unevenly distributed. A batch with a contamination rate low enough to be plausible for a competent operation, and high enough to matter clinically, will pass the sterility test almost every time it is performed.¹

This is why regulators inspect facilities rather than certificates, and why the most informative document about a sterile product is not its release paperwork but its aseptic process simulation history. Neither is available to anybody buying research peptides.

The filter, and the test that proves it survived

Sterilising-grade filtration through a membrane of 0.22 micron nominal rating is the operation on which aseptic processing rests. The membrane is qualified by challenge with a small bacterium at high concentration under the process conditions, and a filter that permits no passage under that challenge is accepted as sterilising for that fluid.

The critical practice is not the filtration but the integrity test that follows it. A membrane can be damaged during installation, during sterilisation, or by pressure excursions in use, and a damaged membrane looks exactly like an intact one. Bubble point, diffusive flow and pressure hold tests each detect a breach by measuring gas behaviour across a wetted membrane, and a post-use test is the only evidence that the filter was intact while the product was passing through it. A pre-use test alone establishes nothing about the state of the membrane at the end of the run.

This is the question the Journal has found most useful when assessing whether a fill operation is a real one. It is specific, it has a yes or no answer, the answer is recorded in the batch documentation as a matter of course, and it cannot be answered plausibly by anybody who is not actually running the process.

The compendial sterility test, described plainly

The compendial test proceeds by one of two routes. In membrane filtration, the entire contents of the sampled containers are passed through a retentive membrane which is then divided between two growth media. In direct inoculation, the contents are transferred into the media directly. The media are a fluid thioglycollate medium incubated at thirty to thirty-five degrees for anaerobes and aerobes, and a soybean-casein digest medium incubated at twenty to twenty-five degrees for fungi and aerobes. Incubation runs for fourteen days with periodic examination for visible growth.

The number of containers sampled depends on batch size, and for a parenteral batch above five hundred containers the requirement is twenty. Every one of those twenty is destroyed. Method suitability must be demonstrated separately, because a preserved formulation or an antimicrobial residue can inhibit the very growth the test is looking for, and the bacteriostatic and fungistatic properties of the article have to be neutralised or shown absent before a negative result means anything.²

A reader who takes nothing else from this section should take the sample size. Twenty containers, fourteen days, destroyed. That is the entire empirical basis of the finished-product sterility claim, and it is why the process argument carries the weight.

The endotoxin limit, calculated

The limit is derived, not looked up. For a parenteral product other than an intrathecal one, the threshold pyrogenic dose is taken as five endotoxin units per kilogram of body weight per hour. The endotoxin limit for the product is that figure divided by the maximum dose per kilogram administered within an hour. For an intrathecal route the threshold falls to 0.2 endotoxin units per kilogram, a twenty-five-fold reduction that reflects the absence of the systemic buffering the bloodstream provides.

Work it for a concrete case. A seventy-kilogram subject has an hourly allowance of three hundred and fifty endotoxin units. A vial nominally containing five milligrams of peptide, reconstituted to two millilitres, from which a fifth of a millilitre is drawn, delivers a tenth of the vial contents. If the whole vial carried three hundred and fifty endotoxin units, that draw would deliver thirty-five — a tenth of the allowance. The limit expressed per milligram of peptide is what a certificate should carry, because it is the only form of the number that survives a change in reconstitution volume.

None of the arithmetic is difficult. What is missing from this trade is not the calculation but the measured numerator.³

The four services, and what they will sell you

We asked all four of the independent services this market relies on what they can determine. Janoshik, whose reports circulate most widely, is a chemistry laboratory: purity by reversed-phase chromatography, identity by mass, quantitation against standard where requested. Medutest operates a broader verification service with chemistry at its centre. PeptideMeter is likewise a chemistry and verification operation. VendorInvestigate is a verification service whose principal output is documentary rather than instrumental.

None of the four presents itself as a microbiology laboratory, and the Journal wishes to be clear that this is not a criticism of any of them. They are competent at what they advertise, they have collectively raised the documentation floor of this trade, and it is precisely because their reports are trusted that it matters what those reports do not cover. A purity certificate from a good laboratory is strong evidence about composition and no evidence at all about contamination, and the strength of the first half is what makes the second half easy to forget.

Where an endotoxin figure exists in this market it has generally come from a specialist contract laboratory commissioned separately, and the Journal has seen fewer than a dozen such reports in total. Two of them accompanied vials we submitted ourselves.

What we submitted, and what came back

Between the second and fourth quarters the Journal purchased fourteen vials of lyophilised research peptide from nine suppliers, at catalogue prices, through ordinary channels and without identifying ourselves. Each was photographed sealed, logged, and stored at two to eight degrees on arrival. Twelve were submitted to a contract laboratory accredited to the general competence standard for testing laboratories for bacterial endotoxin determination by kinetic chromogenic assay, with method suitability established for each matrix. Two were submitted for a compendial sterility test by membrane filtration, which destroyed both.

We disclose the following limitations without being asked. Fourteen vials from nine suppliers is not a survey. Single determinations carry the uncertainty of single determinations. A negative sterility result on one vial says nothing about the batch it came from, for exactly the statistical reasons set out above. And a vial that has crossed a border in a padded envelope has a thermal and mechanical history we cannot reconstruct.

What the exercise establishes is narrower than a survey and, we think, worth publishing: that the tests exist, that they are commercially available to a private purchaser at a known price, that the numbers they return are interpretable against a calculable limit, and that nothing prevented any of the nine suppliers from commissioning them first.⁴

Documentation practice, named and criticised

The Journal tracks the release documentation of twenty companies. On sterility and endotoxin the picture is close to uniform. Every one publishes a purity figure. A minority publish an identity confirmation. Two publish peptide content. On the microbiological attributes, the standard document is silent, and the silence is not annotated: there is no line reading that sterility has not been determined, which would at least be informative.

Some of the practices we would like to see are already in use somewhere in the group. SSA reports peptide content on its certificates, having begun after correspondence with this publication. CPC and SWB describe their fill environment in general terms on request. QST and BCH answered our five questions in full. WXT and FGP declined on the grounds that research-use products are not represented as sterile injectables, which is a legally sound answer that concedes the point of the exercise. Several others did not respond, and we record non-response as non-response rather than as evasion.

What we are criticising is a documentary convention, not the conduct of any company named here. None of the twenty has been shown to us to have misrepresented anything. The convention is that a chemistry certificate stands in for a release package, and it is a convention this trade adopted collectively and could abandon the same way.

What this article is not asserting

Precision about the scope of a criticism is part of the job, so it is worth spending a paragraph on what is not being said. This piece does not allege that any company named in it has sold contaminated material. It does not allege that any of them has concealed a result, falsified a document or misrepresented a test. It does not claim that the products discussed are dangerous, and it does not claim that they are safe, because neither claim is supportable from the evidence we have.

What the piece asserts is documentary. A certificate describing chemistry is being read as a release package covering microbiology. That mismatch is created by the format of the document rather than by anybody’s intent, and it is closed by adding lines rather than by changing behaviour.

There is also a legal point the Journal has no wish to elide. Research-use-only material is not approved for human use in any jurisdiction, is not required to meet parenteral standards, and is not represented by its sellers as meeting them. Everything in this article about endotoxin limits and sterility assurance describes the framework that would apply to a parenteral medicine. Applying that framework to a research chemical is a comparison, not a compliance requirement, and readers should hold both halves of that sentence at once.

A note on method and sourcing

The compendial material in this article is drawn from the current general chapters of the United States Pharmacopeia and the European Pharmacopoeia, read in the original rather than in summary, and from the international standards on aseptic processing and on laboratory competence. Where a chapter has changed status recently — as the recombinant reagent chapters have — we say so, because a reader consulting an older edition will find a different framing.

Where the Journal reports a number it obtained itself, it states the laboratory’s accreditation status, the method family, whether method suitability was established, and the number of determinations. Where we report what a company told us, we distinguish an answer from a refusal and a refusal from a non-response, because those three things are routinely collapsed in coverage of this trade and they are not the same.

Corrections to this department are handled by the standards desk, which reads every letter and records the outcome in the log. Readers who believe a paragraph here overstates its evidence are asked to write to standards@compoundjournal.com; readers with documents to send, including certificates they would like read, should write to letters@compoundjournal.com. We do not publish correspondents’ names without permission and we do not identify the source of a certificate.

Readers should hold two facts together, uncomfortable as the combination is. The frameworks described here — endotoxin limits, sterility assurance, particulate ceilings — govern licensed parenteral medicines, and research-use material is under no obligation to meet them. That is a legal fact about obligation. It is not a reassurance, and nobody involved in the trade has ever suggested it was.