Emea
Emea
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Section 2, paragraph 5, removes the ambiguity of the word “exempt” which was meant to refer to the
content of the ERA dossier and not to the legal requirement for an ERA dossier. Section 8, paragraph
2, addition of the word “studies” after ERA to clarify similarly that the guideline refers to the absence
of ERA studies, not to the absence of the ERA dossier itself (expert report as a minimum).
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GUIDELINE ON THE ENVIRONMENTAL RISK ASSESSMENT OF MEDICINAL
PRODUCTS FOR HUMAN USE
TABLE OF CONTENTS
1 INTRODUCTION....................................................................................................................... 3
9 NOTE ......................................................................................................................................... 11
10 LIST OF ABBREVIATIONS................................................................................................... 11
11 ANNEX ...................................................................................................................................... 12
The purpose of this guideline is to describe the assessment of potential environmental risks of human
medicinal products. It specifies the scope and legal basis for assessment. It outlines general
considerations and the recommended step-wise procedure of assessment. The general outline of the
Environmental Risk Assessment Report is given, and, when risks cannot be excluded, this guideline
outlines precautionary and safety measures to be considered.
1 INTRODUCTION
An Environmental Risk Assessment (ERA) shall accompany an application for a marketing
authorisation for a medicinal product for human use. This guideline describes how to evaluate
potential risks of the medicinal product to the environment. The guideline also includes considerations
for potential precautionary and safety measures to be taken, and recommendations for the
Environmental Risk Assessment Report.
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3 GENERAL PRINCIPLES
Assessment of the potential risks to the environment is a step-wise, phased procedure, consisting of
two phases. The first phase (Phase I) estimates the exposure of the environment to the drug substance.
Based on an action limit the assessment may be terminated. In the second phase (Phase II),
information about the fate and effects in the environment is obtained and assessed. Phase II is divided
in two parts, Tier A and B (see Table I).
Certain substances, such as highly lipophilic compounds and potential endocrine disruptors, may need
to be addressed irrespective of the quantity released into the environment.
Table 1: The phased approach in the environmental risk assessment
Stage in Stage in risk Objective Method TEST / DATA
regulatory assessment REQUIREMENT
evaluation
Phase II Tier A Screening Initial prediction of Risk Assessment Base set aquatic
risk toxicology and fate
Phase II Tier B Extended Substance and Risk Assessment Extended data set on
compartment-specific emission, fate and
refinement and risk effects
assessment
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European Chemicals Bureau (2003) Technical Guidance Document in support of Commission Directive
93/67/EEC on Risk Assessment for new notified substances, Commission Regulation (EC) No 1488/94 on Risk
Assessment for existing substances and Directive 98/8/EC of the European Parliament and of the Council
concerning the placing of biocidal products on the market.
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DOSEai * Fpen
PECSURFACEWATER = ------------------------------------------------------------------------------
WASTEWinhab * DILUTION
If the PECSURFACEWATER value is below 0.01 µg/L(3), and no other environmental concerns are apparent,
it is assumed that the medicinal product is unlikely to represent a risk for the environment following
its prescribed usage in patients.
If the PECSURFACEWATER value is equal to or above 0.01 µg/L, then a Phase II environmental fate and
effect analysis should be performed as described below (section 5).
In some cases, the action limit may not be applicable. Some drug substances may affect the
reproduction of vertebrate or lower animals at concentrations lower than 0.01 µg/L. These substances
should enter Phase II and a tailored risk assessment strategy should be followed that addresses its
specific mechanism of action. In these cases, the Applicant should justify all actions taken.
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The present action limit is based mainly on acute toxicity data and may therefore be revised in future versions
of the guideline when a sufficient amount of chronic data is available.
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5.1 Tier A: Initial environmental fate and effects analysis
The assessment in Tier A should be based on the drug substance unless otherwise justified, e.g. if the
drug substance is a pro-drug.
Blue-green algae (Cyanophyta) are recommended for effects testing of antimicrobials, as they are
more sensitive indicator organisms than green algae. Short-term testing is generally not applicable for
human pharmaceuticals since continuous exposure of the aquatic environment via STP effluents is
assumed.
Substances with anti-microbial activity may affect microbial communities. The microbial community
most likely exposed to the highest concentrations of the substance(s) is the activated sludge
community. In order to evaluate anti-microbial effects of anti-microbial substances, the activated
sludge respiration inhibition test (OECD 209) should be used.
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The PNECWATER is based on the lowest NOEC result from the base set long-term toxicity tests. The
PNECMICROORGANISM is based on the NOEC result of the anti-microbial effect study. The
PNECGROUNDWATER is based on the NOEC result of the test with Daphnia sp.
To calculate the PNEC from the long-term toxicity tests and the anti-microbial effect study a default
AF of 10 is applied. This AF accounts for:
• inter-species variations of differences in sensitivity
• intra-species variability
• laboratory data to field impact extrapolation.
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excreted) metabolic fractions.
Refinement of the risk assessment using data on transformation of the substance within the
environment (i.e. the water/sediment systems) is not further considered here and is subject to expert
judgement.
A specific risk assessment should be conducted for a drug substance with a logKow > 4.5 (see section
4.1)
Table 4 summarises the parameters and default values recommended for the calculation of
PECSURFACEWATER in Phase II. Worst-case estimates should be used.
Table 4: Parameters and defaults for PECSURFACEWATER calculation in Phase II
Parameter Symbol Value Unit Origin Remarks
Input
• Amount of wastewater WASTEWinhab 200 [L.inh-1.d-1] D From TGD
per inhabitant per day
• Capacity of local CAPACITYstp 10000 [inh] D From TGD
sewage treatment plant
(STP)
• Fraction of emission Fstpwater [--] C Calculated by
directed to surface water SimpleTreat
• Dilution factor DILUTION 10 [--] D From TGD
• Factor taking the FACTOR [--] C From TGD
adsorption to suspended §2.3.8.3
matter into account
• Local emission to Elocalwater [mg d-1] A
wastewater of the
relevant residue
Output
• Local surface water
concentration PEClocalwater [mg.L-1] O
A = information from Applicant; D = Default, C = Calculated, O = Output
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5.3.2 Extended effects analysis
There may be cases in which the absence of ERA studies could be justified (e.g. marketing
authorisation applications for generic medicinal products or type II variations). In these cases, the
expert should provide a rationale for the absence of ERA studies, taking into consideration a possible
significant increase of environmental exposure to the drug substance.
The Expert Report should include an evaluation of the applicability of the environmental assessment
performed. In particular, the report should provide or justify the absence of:
1. An estimate of the potential environmental exposure (PEC) with an assessment of the underlying
assumptions.
2. An assessment of possible risks to the environment from the point of view of use, and a
presentation and evaluation of data in support of such risk evaluation,
3. An evaluation of precautionary and safety measures to be taken regarding the environmental
release from use in patients, and disposal of unused products or waste materials derived from such
products,
4. Proposals for labelling (SPC, PL) which give an outline of the information that applicants could
provide on precautionary and safety measures to be taken, for the purpose of reducing any risks to
the environment, with regard to the administration to patients and disposal of waste products.
The expert should sign the Expert Report and a curriculum vitae should be provided.
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9 Note
Fpen
A 95 percentile of 0.954 % was calculated as the default penetration factor (Fpen). It is proposed to
use an Fpen of 0.01 (1%) in the risk assessment.
The penetration factor (Fpen) represents the proportion of the population being treated daily with a
specific drug substance. The default penetration factor was derived from a wide range of individual
market penetration factors, which were calculated as follows:
10 LIST OF ABBREVIATIONS
AF Assessment Factor
CHMP Committee for Medicinal Products for Human Use
DDD Defined daily dose value(s)
DT90 Degradation Time for 90% of a substance to be degraded under laboratory conditions
EMEA European Medicines Agency
ERA Environmental Risk Assessment
EUSES European Union System for the Evaluation of Substances
Fpen (Market) Penetration Factor (see note 1)
GMOs Genetically Modified Organisms
ISO International Organization for Standardization
Koc Adsorption Coefficient
MAA Marketing Authorisation Application
NOEC No Observed Effect Concentration
OECD Organization for Economic Co-operation and Development
OPPTS US EPA Office of Prevention, Pesticides and Toxic Substances
OSPAR 1992 Convention for the Protection of the Marine Environment of the North-East
Atlantic (The “OSPAR Convention”)
PEC Predicted Environmental Concentration
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PNEC Predicted No Effect Concentration
PL Package Leaflet
SPC Summary of Product Characteristics
STP Sewage Treatment Plant
TGD EU Technical Guidance Document
WHO World Health Organization
11 ANNEX
Entry paths into the environment for most medicinal products when prescribed to patients
Air
Drinking water
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