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Extractables and Leachables


Challenges and Strategies in Biopharmaceutical Development

Anthony Mire-Sluis, Stacey Ma, and Ingrid Markovic, with Lorna McLeod

T
he 13th WCBP CMC Strategy product under actual conditions of
Forum on extractables and use. Thus, it is not currently possible
leachables was held in Bethesda, to definitively and quantitatively
MD, in January 2008. The establish without scientific
purpose of this forum, cosponsored by investigation which of those two cases
CASSS (an international separations will occur for a specific drug product/
society) and the FDA, was to discuss system. Therefore, a complete and
questions related to extractables and scientifically rigorous safety
leachables in the context of assessment must include data-based
biopharmaceutical manufacturing and evaluation of both direct and indirect
find consensus on some of those topics. contact components in both
Morning sessions began with immediate and remote contact
“Extractables and Leachables: situations.
Challenges and Strategies in Jim Castner discussed the values
Biopharmaceutical Development” with and challenges of an industry
program cochairs Stacey Ma of extractables/leachables database and
www.photos.com
Genentech, Inc., Ingrid Markovic of described materials in published
FDA CDER, Edwin Moore of Baxter and/or processing equipment under literature as well as software-based
Healthcare Corporation, and Susan Yu recommended or routine conditions of applications and analytical tools that
of FDA CBER, FDA. “Analytical use and storage. Leachables are often a are being used (or proposed for use) in
Tools for Testing Extractables and subset of extractables. such an endeavor. He stated that
Leachables” followed, with session chair In his presentation, Dennis Jenke during the early stages of a drug-
Edwin Moore. Presentations included pointed out that every packaging development program, the scope of
• “Extractables and Leachables: system should be suitable for its analytical methods for monitoring
CBER Perspective,” by Susan Yu intended use over its entire market impurities should not be limited to
• “General Concepts in Leachables lifetime. He also defined a contact formulation degradants, but extend
and Extractables,” by Dennis Jenke of system as any material or set of also to leachables. Additionally, a
Baxter Healthcare Corporation materials that contacts a final drug database containing the chemical,
• “A Strategy for Developing product or its associated precursors physical, and application properties of
Analytical Methods and a Database to during the product lifetime, including potential leachable compounds can be
Address the Questions of Extractables,” manufacturing (processing), storage, a valuable predictive and diagnostic
by Jim Castner of Bristol-Myers Squibb and administration (delivery). It has tool for developing a new drug under
Medical Imaging. been well established that some the quality by design (QbD)
Susan Yu defined extractables and extractables from indirect contact paradigm.
leachables. Extractables are chemicals materials, components, and systems
generated under exaggerated become leachables in a drug product Why Worry?
temperature and time conditions in the under actual conditions of use; and it Patient safety is the first concern in all
presence of an appropriate solvent. is well established that some biopharmaceutical endeavors.
Leachables are chemicals that migrate extractables from indirect contact Leachables in biological products can
spontaneously from a container– materials, components, and systems do affect patient safety by causing
closure system, packaging components, not become leachables in a drug toxicity, carcinogenicity, or (through

14 BioProcess International February 2011


interactions with the protein) the types of extracting solutions your The CMC Strategy
immunogenicity if administered to supplier uses and how relevant they Forum Series
patients. Materials leached from a are for your product. A contact
container or other contact surface component that does not pose a The purpose of the CMC Strategy Forum
series is to provide a venue for
during manufacturing into a product problem in one type of product (e.g., a
biotechnology/biological product
may cause chemical affects such as chemical drug) may react differently discussion. These meetings focus on
oxidation or aggregation. They may with a biological. relevant chemistry, manufacturing, and
affect the look of the formulation: its Drug manufacturers also need to controls (CMC) issues throughout the
color, for example. Leachables could take into account how they are using/ lifecycle of such products and thereby
affect product stability over time, lead processing materials they purchase from foster collaborative technical and
to immunogenicity caused by altering suppliers. If something is cleaned or regulatory interaction. The forum
the product, or change its potency. prewashed/pretreated, then extractables committee strives to share information
Leachables may also affect medical data provided by its vendor may no with regulatory agencies to assist them
diagnostic tests and assay results for a longer be applicable. A vendor also in merging good scientific and
drug substance or product. might be unaware of the composition of regulatory practices. Outcomes of the
forum meetings are published in this
Control of extractables and components it supplies if they come
peer-reviewed journal with the hope
leachables is also required by from other raw-materials manufacturers that they will help assure that
regulations. The US federal Food, and thus could miss some extractables biopharmaceutical products
Drug, and Cosmetic (FD&C) Act that might be present. manufactured in a regulated
refers to adulterated products. It is critical to analyze data available environment will continue to be safe and
Avoiding product contamination from for the composition of material efficacious. The CMC Strategy Forum is
equipment and contact surfaces is yourself. Analyze their manufacturing organized by CASSS, an International
required by 21 CFR 211.65 (a), 21 process and be aware of what goes into Separation Science Society (formerly the
CFR 600.11 (b), and ICH Q7 (1–3). each vessel or type of piping in California Separation Science Society),
Extractables and leachables from drug question, and determine whether it will and is cosponsored by the US Food and
product containers and closures are come into contact with your product. Drug Administration (FDA).
covered in 21 CFR 211.94 (a), 21 CFR For example, you can check existing
600.11 (h), and the FDA guidance on databases for materials information and technologies or those that can affect
container–closures (2, 4, 5). They are use risk assessment to determine what equipment (e.g., extremely acidic or
also mentioned in 21 CFR 600.3 (b) to analyze — whether in the materials highly volatile compounds affecting
(6). An understanding of extractables themselves or in your product. column resins). The length of
and control of leachables is expected A number of things should be taken exposure to an extracting solution also
as part of the filing package for a into account when developing an should be considered. Too short a
marketing application. Requirements extractables program. For example, duration might not extract everything
at earlier points (e.g., at IND filing) what extractable tests may be required? that is relevant; too long may induce
are less well-defined but should be The United States Pharmacopeia lists chemical reactions with materials that
risk based. Companies can rely on compendial tests in Chapters <1>, <87>, would not occur in real-life use and
prior knowledge and vendor supplied <88>, <381>, and <661>. Factor in your therefore produce irrelevant results.
data for the necessary information. own worst-case scenarios and specific There is no standard set of
Morning presentations were buffer programs. techniques for making these decisions.
followed by a panel discussion with When designing an extractables You need to understand the chemistry
the presenters talking about their program, be sure you have appropriate of the compounds with which you are
presentations and taking questions methods available to assess possible working to define their analysis. Keep
from the audience. extractables. Take a thorough but in mind that analytical methods for
What are the primary realistic approach. Consider testing at extractables should be comprehensive
considerations in analyzing pH extremes, with organic and water- rather than for organic compounds only.
extractables for disposable/in-process based solvents, and at appropriate Some available analytical tools include
systems and final container–closure temperatures. However, be careful not • For nonspecific tests, total organic
systems? It is important to ensure that to overdo extraction conditions that carbon (TOC) analysis, UV
the materials you will be working with may themselves affect the extractables, absorbance, pH and conductivity
during product manufacturing and particularly thermally labile or volatile measurement, and visual inspection
storage cannot pose a leachables compounds. Different conditions are • For specific testing, gas
problem. Information provided by appropriate for different extractables, chromatographic methods (GC/FID,
equipment suppliers may be valuable if such as volatile and nonvolatile GC/MS, GC/IR), liquid
used with caution. A supplier of compounds or thermally labile and chromatographies (LC/PDA, LC/
containers or product-contact stable compounds. MS, LC/NMR), Fourier-transform
components should be audited during Do not use solvents that can’t be infrared analysis (FTIR) and metals
routine vendor audits. Also, consider analyzed readily using available analysis (ICP/MS).

16 BioProcess International February 2011


Quality Concerns polyurethane adhesives. Silicone oil is regulatory bodies, and nongovernment
The afternoon session was titled polydimethylsiloxane, for example. organizations.
“Impact of Extractables and Organic solvents include acetone, Next, the presenters made up a
Leachables on Product Quality and isopropanol, and others. Accelerators panel to discuss their presentations
Clinical Performance (Safety and include thiuram, sulfenamide, and questions along with the audience.
Efficacy),” with session chair Edwin guanidine, and dithiocarbamate. What are the primary considerations
Moore. Presentations included Antioxidants include butylated for analyzing leachables — analytical
• “Relevant Case Studies hydroxytoluene (BHT), Irganox, and stability studies — and assessing
Illustrating the Safety and Quality Irgafos, and so on. Phthalates such as their impact on product quality? Before
Considerations for Extractables and di(2-ethylhexyl) phthalate (DEHP) are initiating a leachables program,
Leachables in Therapeutic Biologics: a separate group unto themselves, as companies can use toxicologists to help
A CMC Perspective,” by Ingrid are nitrosamines (e.g., define which extractables identified
Markovic diphenylnitrosamines and vulcanizing may be important to consider during
• “Case Examples of Qualification agents (e.g., Vultac 2). Other groups leachables studies. Based on risk
of Extractables and Leachables in include polycyclic aromatic assessment, leachables studies may be
Therapeutic Biologic Products: A hydrocarbons, antistatic agents, and performed at any stage of
Toxicological Perspective,” by residual cleaning agents. Timothy manufacturing (e.g., upstream
Timothy Robison of FDA CDER Robison highlighted the scope of this production, downstream processing,
• “Role of Elastomeric Closures in problem when he pointed out that intermediate and/or final storage, and
the Degradation of a Lyophilized available scientific literature indicates so on). Contaminants are evaluated in
Product: A Case Study,” by Munir many hundreds, if not thousands, of process raw material(s), product
Nassar of Bristol-Myers Squibb individual chemical entities that can intermediate(s), drug substance, and/or
• “A Strategy for Developing appear as extractables/leachables and drug products.
Analytical Methods and a Database to could be detected, identified, and In designing leachable studies,
Address the Question of Extractables,” quantified at similar levels. companies should consider using the
by Jim Castner Munir Nassar presented a case actual drug product vehicle whenever
• “Extractables and Leachables study: A degradant in a lyophilized possible. In addition, because a protein
from Single-Use Systems: BPSA product was attributed to a leachable can mask and/or interfere with
Perspective,” by Jerold Martin of Pall from the vial stopper that was not part leachables detection, analysis of
Life Sciences. of the rubber formulation itself, but leachables also should include a
Ingrid Markovic pointed out the likely part of the stopper’s reinforcing placebo as an additional extraction
many sources of extractables and structure. The chemical that was not medium. Specifically for final dosage
leachables. In-process single-use initially identified as a leachable forms, consider exposing the
systems include bioreactors, containers migrated out of the stopper as a container–closure system with placebo
and storage bags for product volatile compound and interacted with alone as well as with the protein
intermediates, intravenous (IV) bags, the product to form adducts. This product throughout the dating period,
carboys, filters, tubing, gaskets, valves, incident showed that a company both inverted and upright. It is
rings, purification resins, and so on. should work with its suppliers to becoming an expectation that several
Even stainless steel bioreactors and understand the full composition of stability time points (including end-
storage tanks can contribute. Primary their materials because not all of-expiry material) be analyzed for
packaging components that come into compounds used during material leachables and the results provided as
direct contact with a drug include vials, manufacture may be identified easily part of the stability section in a
syringes (prefilled or not), ampules, and as potential leachables. marketing application.
bottles. Closures include screw caps and Jerold Martin introduced the Bio- Some other materials have limited
rubber stoppers. Container liners are Process Systems Alliance (BPSA), an contact periods with a component
also of concern. Secondary packaging organization representing suppliers of material (e.g., tubing, filters, and
components (not necessarily in direct disposable process components, single- storage bags). The length of contact
contact with the product) include use systems, and related services to the time with the product, intermediate(s),
cardboard containers, overwraps/ biopharmaceutical industry. The and/or process raw material(s) should
overseals, and container labels. organization’s primary objectives are to be accounted for in design of
Extractables and leachables can be encourage and facilitate adoption of leachables studies. For all component
grouped into several groups of single-use systems in biopharmaceutical materials, take into consideration the
compounds. Metals include zinc (Zn), manufacturing, establish industry appropriate sample size (>1) in light of
iron (Fe), barium (Ba), cadmium (Ca), consensus guides for the manufacture intralot and lot-to-lot variability. For
aluminum (Al), nickel (Ni), and so on. and use of disposable process leachables from component materials,
Fatty acids include stearic acid, components and systems, and specifically, evaluate leachables in
palmitic acid, and myristic acid, just to communicate industry best practices to material reuse studies to ensure that
name a few. Cyclic esters come from biopharmaceutical manufacturers, your program monitors whether

18 BioProcess International February 2011


cleaning affects the results. Cleaning Permanent Advisory regimen and method sensitivity. The
under harsh conditions (e.g., with Committee for These Forums LOD may not be suitable for certain
detergents or organic solvents) may toxic compounds.
over time alter a material’s surface and Siddharth Advant (Imclone) Consideration of a toxicological
make it more or less prone to leaching. John Dougherty (Eli Lilly and Company) safety threshold rarely takes into
You also need to justify which Christopher Joneckis (CBER, FDA) account nontoxic and/or weakly toxic
methods you will use for extractables Rohin Mhatre (Biogen Idec Inc.) leachables (e.g., certain inorganics),
and leachables studies. For example, to Anthony Mire-Sluis, chair (Amgen, Inc.) which can negatively affect product
select appropriate analytical methods, quality. Such leachables can exert their
Wassim Nashabeh (Genentech, Inc.)
you require an understanding from activity through different pathways
extractables studies to ensure that Anthony Ridgway (Health Canada) including protein aggregation, adduct
chosen methods are capable to assess Nadine Ritter (Biologics Consulting formation, and generation of clipped
leachables in your product. Those Group, Inc.) variants (e.g., by metalloprotease
studies should include an assessment Mark Schenerman (MedImmune) activation), all of which are likely to
of sensitivity (limit of detection, LOD Keith Webber (CDER, FDA) adversely affect drug safety and
and quantitation, LOQ ) and potential efficacy. Leachables threshold levels
interference, as well as selection of clearance processes, cleaning protocols, that trigger changes in product quality
specific tests for leachables. We and length-of-use studies. It could also may not correspond to the toxic
recommend qualifying the methods prevent reinventing the wheel and thresholds of such compounds, which
selected for extractables and leachables reduce extractable/leachable study emphasizes the need for well-designed
testing to ensure that they are fit for costs. A database could also assist in leachables studies.
their intended purpose. The panel of development of assays that can cover Assessments of safety are based on
methods as a whole should be able to both product and leachables (or a range systemic toxicity, route-specific
detect leachables in both drug thereof), ultimately saving time and toxicity (e.g., inhalation and skin
substance and drug product. Some costs. It would need to include injection), and mutagenic/carcinogenic
leachables may be masked by the chemical structure, Chemical Abstract potential, as well as ICHQ3
protein; thus, as noted above, we Service (CAS) number, partitioning, classification and limits (7–9), existing
recommend testing both in its materials that chemicals can come toxicology databases, structural
presence and absence. from, toxicology data, and spectral/ similarity to known molecules, and
During the meeting, some analytical properties. actual product/leachable toxicology
questioned why material before and The forum discussed whether the studies (minimally a 90-day duration
after product expiry should be analyzed industry should rely on vendors or for chronic administrations). Safety
for leachables — if product is tested collaborate as an industry and create a considerations must also take into
during clinical studies whether the database, indicating that the latter account the fact that many databases
risk:benefit ratio would account for the might be more realistic. Further, there are based on toxic thresholds that do
presence of leachables. However, others was discussion about where such a not include subchronic threshold
argued that it is rare to test material at database would reside and who would levels, which can affect patients, as
the end of expiry in a clinical trial, fund it. The Forum agreed that a could interaction of subthreshold
whereby leachables might account for consortium was most likely. The compounds. Therefore, understanding
some adverse events and thus should be database would need to have some sort the range and levels of leachable
studied. Also, the tests used to analyze of standardized conditions before it compounds present in a product at the
product on stability may not be such could be really useful, but current end of its dating period is critical.
that can identify leachables (especially information might be a good start. How can a risk assessment of
inorganics) or product interactions with Leachables that migrate into identified extractables and leachables be
them. And it is highly likely that formulations would need consideration, developed for different phases of drug
product interaction with contact as well as extractables extracted under development? It is important to
surfaces over time can influence specific, exaggerated conditions. develop a risk profile early in product
leachables profiles, increasing the What are the primary development. Define potential
number of leached chemicals and their considerations for setting acceptance extractables using existing knowledge
quantities as a product ages. limits? Defining a true “safety from material manufacturers,
Would a public database of common threshold” depends on many leveraging existing in house data, and
extractables and leachables be useful, variables. It often depends on patient taking advantage of chemical
and what information should it population and the amount of safety toxicology classifications (e.g., benzene
contain? A public database would data available for humans. It is is class I, acetic acid is class III).
allow for early risk assessments during affected by your ability to translate Consider patient factors such as disease
product development and improved animal data for your particular severity, treatment impact on disease,
selection of process materials, as well product if no human-exposure data dose and frequency of administration,
as help companies design appropriate exists. It also must consider dose and prior clinical exposure to

20 BioProcess International February 2011


leachables. Also take into account your with appropriate specifications to dramatically between glass vendors.
previous manufacturing and clinical control levels of leachables. Those are particularly an issue for vials
experiences with similar materials. Are biologic therapeutics at a because syringe internal surfaces are
When deciding whether you need to greater risk regarding the impact of coated in silicon oil, which protects the
investigate an extractable identified chemical leaching? Some factors can inner glass surface from interacting
from a particular material, consider both decrease the potential for with formulations inside.
where in the process it could be released leachables to occur and increase their Prefilled syringes, however, can
as a leachable (e.g., upstream or impact on a protein product. In contain multiple surfaces with
downstream). Also important is the general, proteins are more likely to be exposure to leachables (e.g., silicon,
ability of purification to remove affected chemically by leachables than tungsten, glue, rubber, plastic, or
chemical contaminants and the are small molecules, but protein stainless steel). What might be a
composition of buffers that could manufacturing processes (that is, the nontoxic leachable (e.g., silicon,
induce leaching from contact materials chemical nature of buffers and tungsten, and ethylene oxide) in its
(e.g., high or low pH, organic content, temperatures involved) tend to be own right, either directly or by
and surfactants). Other considerations milder than those for small molecules. amount, can affect the quality of a
include contact time and temperature Several protein attributes increase biological product. Lot release and
and whether an accelerated stability the potential impact of leachables. stability assays are highly product
study can help identify product impact Proteins are susceptible to focused and not usually developed to
leachables early on. Worse-case safety environmental changes due to weak identify leachables. Manufacturers
assessments should be carried out for all noncovalent interactions that stabilize must consider within-lot and lot-to-lot
extractables unless there is absolute them in part. They are large and thus variability in container–closure
assurance that leaching could not occur. present potential surface/attribute leachable levels, especially for trace
Developing a risk-based profile exposure to chemicals. Most biologics components that depend highly on
later in product development involves are injectable products that go directly process operations and raw materials.
defining actual extractables that can into a patient’s bloodstream or through In some ways, biological products
be extracted from contact components, skin without passing through the gut. have a reduced risk of inducing
depending on the level of prior Many are dosed in high quantity (mg/ leaching compared with classical
knowledge and data as well as its mL). Also, liquid drug substances and/ pharmaceuticals. The industry has a
applicability to actual manufacturing or products can be stored for extensive lot of clinical experience with liquid
conditions. Extraction procedures periods, offering more potential for formulations. Most modern
should be carried out and those leaching than chemical drugs that are formulations are at neutral or near
extractables above safety/risk levels usually dry powders and tablets. neutral pH, which eliminates the
focused on for investigation as part of What are the challenges in selecting levels of salts and buffers known to
a leachables study. However, as container–closure and packaging induce leaching from glass (e.g.,
mentioned above, all potential systems, formulation ingredients, and citrate). Although therapeutic biologics
leachables should be investigated on storage conditions to minimize rarely contain organic solvents, they
stability, not just those indicated by leaching? Biological products pose a do often contain detergents (e.g.,
the extractable studies. It is still number of challenges to leaching from polysorbate 20 or 80) used as
unclear how extractable studies can be their primary containers. Protein stabilizers, and those may enhance the
translated into actual leaching that can formulations are limited by the nature risk of leaching. Storage of these
occur over time in the presence of a of delivery — mostly liquid injectables products is usually either in frozen
product, especially at the boundaries — suitable to keep proteins in solution form (for drug substances) or at
of recommended conditions for storage and stable. Liquid formulations are 2–8 °C (for drug products). Higher
and use. most able to induce leaching from temperatures and light exposure
To reduce risk, you can use container–closures; lyophilized usually should be avoided at all costs.
extractables data to create injectable products may be more stable
preextraction procedures (e.g., rinsing) and less likely to induce leachables, but Start Early for Success
in manufacturing processes to lessen they are often seen as a competitive Leachables can negatively affect
the possibility of leaching. You can disadvantage. Glass is the most biological products at various steps
develop alternatives to treatments common storage container material for during production and/or downstream
known to induce leachables (e.g., drug products and stainless steel or processing, both at the drug substance
irradiation and ethylene oxide) and plastic (e.g., polycarbonate) for drug and drug product stages. A process
reduce risk by developing clearance substances. Each has a distinct altogether devoid of leachables is highly
mechanisms within processes to lower leachable potential, which can be unlikely, so the goal of a well-planned
amounts of leachable (e.g., protein A surprisingly manufacturer-specific, program is to control leachables within
and other resins). Also reduce risk despite international pharmacopeial predefined limits to ensure that each
with a quality system focused on standards. Levels of alkalinity and product has desired quality, safety, and
vendors of product-contact materials surface components can vary efficacy. Address extractables and

22 BioProcess International February 2011


leachables from a very early point in Administration: Rockville, MD, 1999; www. Stacey Ma is director of early stage
fda.gov/downloads/Drugs/ pharmaceutical development at Genentech,
drug development to ensure that all
GuidanceComplianceRegulatoryInformation/ ma.stacey@gene.com. Ingrid Markovic,
sources and causes are considered Guidances/UCM070551.pdf
throughout the process. This is vital to PhD, is an expert review scientist in the
6 Definitions. Code of Federal Regulations, Division of Therapeutic Proteins at the US
the success of every biopharmaceutical Title 21, Volume 7, Subchapter F, Part 600, FDA’s Center for Drug Evaluation and
drug manufacturing process. Subpart A, Section 600.3. US Food and Drug
Research; 1-301-827-1730, 1-301-480-3256;
Administration: Rockville, MD, 1 April 2010.
ingrid.markovic@fda.hhs.gov. And Lorna
References 7 ICH Q3A. Impurities in New Drug
McLeod is a contributing editor to
1 Equipment. Code of Federal Regulations, Substances. US Fed Reg. June 2008; www.ich.
org/fileadmin/Public_Web_Site/ICH_
BioProcess International.
Title 21, Volume 4, Subchapter C, Part 211,
Subpart D. US Food and Drug Administration: Products/Guidelines/Quality/Q3A_R2/Step4/
Rockville, MD, 1 April 2010. Q3A_R2__Guideline.pdf.
2 Biological Products: General. Code of 8 ICH Q3B. Impurities in New Drug Disclaimer
Federal Regulations, Title 21, Volume 7, Products. US Fed. Reg. 68(220) 2003: 64628–
The content of this manuscript reflects
Subchapter F, Part 600. US Food and Drug 64629; www.ich.org/fileadmin/Public_Web_
Site/ICH_Products/Guidelines/Quality/Q3B_
discussions that occurred during the
Administration: Rockville, MD, 1 April 2010.
R2/Step4/Q3B_R2__Guideline.pdf. CMC Forum workshop in addition to
3 ICH Q7: Good Manufacturing Practice the personal viewpoints and
Guide for Active Pharmaceutical Ingredients. 9 ICH Q3C. Guideline for Residual
Solvents. US Fed. Reg. 62(247) 1997: 67377 and experiences of the authors. This
US Fed. Reg. 66(186) 2001: 49028–49029;
www.ich.org/fileadmin/Public_Web_Site/ 68(219) 2003: 64352–64353; www.ich.org/ document does not represent officially
ICH_Products/Guidelines/Quality/Q7/Step4/ fileadmin/Public_Web_Site/ICH_Products/ sanctioned FDA policy or opinions and

Cumene/Q3C_R5__step_2.pdf. •
Q7_Guideline.pdf. Guidelines/Quality/Q3C_R5_PDE_for_ should not be used in lieu of
4 Drug Product Containers and Closures. published FDA guidance documents,
Code of Federal Regulations, Title 21, Volume 4, points-to-consider documents, or
Subchapter C, Part 211, Subpart E, Section direct discussions with the agency.
211.94. US Food and Drug Administration: Anthony Mire-Sluis is executive director of
Rockville, MD, 1 April 2010. global product quality and quality sciences
5 CDER/CBER. Guidance for Industry: for Amgen Inc. MS-36-2-B, One Amgen
Container Closure Systems for Packaging Human Center Drive, Thousand Oaks, CA 91320-
Drugs and Biologics. US Food and Drug 1799; 1-805-313-2415, fax 1-805-499-6843.

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