A vial can be 99.4 per cent pure and not sterile in the same afternoon

A certificate of analysis for a research peptide is, in the overwhelming majority of cases, a document about chemistry. It reports a chromatographic purity figure, sometimes a mass, occasionally a water content, and it is generated from a few milligrams of powder dissolved in a vial of mobile phase. Nothing in that procedure has any bearing on whether the sealed container it came from holds viable microorganisms, whether the powder carries pyrogenic material from an upstream water system, or whether the stopper has maintained a seal since the day it was crimped. The document is accurate and it is answering a different question.

Two questions that share a piece of paper

Consider what happens physically when a certificate is produced. A few milligrams of lyophilised powder are weighed, dissolved in an aqueous mobile phase with an organic modifier, injected onto a reversed-phase column and separated over a programmed gradient while an ultraviolet detector records absorbance. The output is a trace. Software integrates the areas beneath its features, and the main peak area as a proportion of the total becomes the purity figure.

Every step of that procedure is blind to microbial contamination. A bacterial cell contributes no ultraviolet-absorbing peak at any retention time a peptide method would record. Endotoxin, a lipopolysaccharide, is not usefully detected at the wavelengths used for peptide bond absorbance and would in any case be present at a mass fraction several orders of magnitude below any integration threshold in commercial use. A vial holding a hundred colony-forming units and a vial holding none produce chromatograms that no analyst could distinguish.

This is not a defect of the method. Reversed-phase chromatography is an excellent way of determining what proportion of the chromatographically visible material is the intended species, and that is what it is being asked. The defect is in the reading. A document answering one question is being filed as evidence about five.

Bioburden, and why the number before the filter matters

A sterilising filter is not an unlimited barrier. Its qualification is expressed as a retention capability under a defined challenge — conventionally a high titre of a small bacterial species per square centimetre of membrane — and its performance in use depends on the load presented to it. A bulk solution carrying a heavy microbial burden presents a filter with a harder problem than one carrying a light burden, and it presents a second problem the filter cannot address at all: the endotoxin released by organisms that die upstream passes through the membrane unimpeded.

Regulated manufacture therefore specifies a pre-filtration bioburden limit, tests against it on every batch, and treats an excursion as an investigation rather than a curiosity. The specification is usually expressed in colony-forming units per hundred millilitres, and a well-controlled process runs far below it.

Of the twenty companies the Journal wrote to, four stated that pre-filtration bioburden is determined on every batch, three stated that it is determined periodically, and the remainder did not answer the question. We regard that distribution as the single most informative result of the correspondence, because bioburden testing is inexpensive, is performed on the bulk rather than the finished container, and is the earliest point at which a problem is cheap to fix.

Media fills, and proving that a rare thing is rare

An aseptic process simulation, generally called a media fill, replaces the product with a sterile growth medium and runs the line exactly as it would run for a real batch: same components, same interventions, same operators, same duration. Every filled unit is then incubated and examined for growth. The purpose is to estimate the contamination rate of the process itself.

The arithmetic constrains the design. To support a claim that the contamination rate is below one unit in a thousand with reasonable statistical confidence, several thousand units must be filled with no contaminated unit recovered. Contemporary practice runs simulations of five to ten thousand units and treats a single positive as a signal requiring investigation rather than as an acceptable rate. The simulations are repeated at defined intervals and after any significant change to the line, and they are the closest thing in manufacturing to a direct measurement of aseptic capability.

One company in the Journal’s correspondence provided media fill records. They covered three simulations across eighteen months, at scales between four and six thousand units, with no recovered contamination. We report that because it is the only such record we have seen from this trade, and because it demonstrates that the documentation exists and can be shared when a company chooses to.

What endotoxin is, and why sterility does not address it

Endotoxin is a structural component of the outer membrane of Gram-negative bacteria: a lipopolysaccharide with a lipid A anchor that is the pyrogenic moiety, a core oligosaccharide, and a variable O-antigen chain. It is shed during growth and released in quantity on cell lysis, which means that killing a bacterial population does not remove its endotoxin and may increase the free concentration.

Three physical properties make it a separate discipline. It is thermally robust, surviving autoclave conditions with little loss of pyrogenicity, so terminal sterilisation is not a depyrogenation step. It is small and amphipathic, forming aggregates that pass a 0.22 micron membrane without difficulty, so sterilising filtration is not a depyrogenation step either. And it is active in humans at very low mass — the threshold pyrogenic dose corresponds to something in the region of a nanogram per kilogram of body weight.

The practical consequence is stark. A vial can pass a sterility test, contain no viable organism of any kind, and carry an endotoxin burden many times a defensible parenteral limit, because the organisms responsible died somewhere upstream in a water system, a holding tank or a poorly stored component.¹

Depyrogenation, and the step that gets skipped

Because endotoxin survives sterilisation, glass components require a separate treatment. The standard is dry heat: a tunnel or oven cycle at two hundred and fifty degrees or above, validated to achieve at least a three-log reduction in a deliberately applied endotoxin challenge. Vials emerging from a qualified depyrogenation tunnel are both sterile and pyrogen-free, and they remain so only if the subsequent handling maintains it.

Elastomeric closures cannot take that treatment and are instead washed, siliconised and steam-sterilised by a validated cycle, with endotoxin control achieved by the washing step and specified as a limit per stopper. Water for injection is controlled at source, with a compendial endotoxin specification, and a water system is the commonest origin of a pyrogen problem in an otherwise competent facility.

Depyrogenation is also, in the Journal’s experience of asking, the step most frequently absent from descriptions of small fill operations. Autoclaved vials are sterile. Autoclaved vials are not depyrogenated, and an operation that describes its glass preparation solely in terms of autoclaving has told you something specific about what it has not done. We put this point to eleven correspondents; two said their glass is depyrogenated by dry heat with a validated cycle, and one asked us what depyrogenation was, which we took as a straight answer and a useful one.

Particulate matter, visible and subvisible

Injectable products are required to be essentially free of visible particulates, and every container in a regulated batch is inspected against dark and light backgrounds under defined illumination. The detection threshold for a trained inspector is somewhere near fifty microns for a contrasting particle, and the inspection is a hundred per cent operation rather than a sample-based one, which makes it unusual among quality tests.

Subvisible particles are counted instrumentally. Light obscuration is the primary compendial method, with microscopic membrane counting as the alternative when the sample defeats it. For a small-volume injection the limits are six thousand particles at or above ten microns and six hundred at or above twenty-five microns per container. Products that are themselves proteinaceous get a distinct chapter, because inherent aggregates complicate the counting and the method has to distinguish them from extrinsic contamination.

For a private buyer, visible inspection is the one quality operation available without instrumentation, and it is worth doing carefully: a lyophilised cake that has collapsed to a glassy disc, a reconstituted solution showing a faint tyndall haze on rotation, a fibre against a dark card. None of those is a sterility finding. All of them are evidence about how the product was made and how it has travelled.²³

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.

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.