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​Non-Pharmaceutical Grade Substances in Laboratory Animals

Purpose

This policy describes the conditions under which non-pharmaceutical grade substances may be used in laboratory animals. It also covers preparation, storage and labeling of drug formulations.

Definitions

Pharmaceutical grade compound:
A drug, biologic, or reagent that is approved by the Food and Drug Administration (FDA). A listing of pharmaceutical grade drugs and biologics is available through the FDA database (Drugs@FDA​ and Animal Drug​s@FDA​ databases). The Orange Book is the reference for FDA-approved human drugs. The Green Book is the reference for FDA-approved veterinary drugs.
Non-pharmaceutical grade compound:
Analytical grade, reagent ACS, or reagent grade are not pharmaceutical grade but when a pharmaceutical agent is not available, they are listed in the preferred order.
New investigational compound:
A compound produced by a laboratory or supplied by a manufacturer for testing in an experimental setting only and for this reason would not have chemical purity standards established and by default is considered a non-pharmaceutical-grade compound.
Solvent:
A substance that dissolves other substances to create a solution

Background

Guidance from the National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW), USDA and the 8th Ed. of the Guide for the Care and Use of Laboratory Animals (“The Guide”) require that preference be given to pharmaceutical grade chemicals and other substances when selecting compounds for use in laboratory animals. The use of non-pharmaceutical grade chemicals or substances should be described and justified in an animal use protocol and be approved by the IACUC (Wolff et al. 2003). Scientific justification may include:

  • A pharmaceutical grade is not available; this includes new investigational compounds.
  • A pharmaceutical grade is not available in the appropriate concentration, formulation, or vehicle.
  • The non-pharmaceutical grade is required to generate data that are part of an ongoing study or are comparable to previous work.

Cost savings alone is not an adequate justification for the use of non-pharmaceutical grade compounds. However, unavailability or shortages of pharmaceutical grade compound may lead to cost increases and necessitate that the IACUC determine whether this justifies the use of the non-pharmaceutical grade compound substitution.

Policy

Any drug used for clinical purposes must be an FDA-approved pharmaceutical grade product for use in humans or animals. This includes all anesthetics, analgesics, euthanasia agents, and antibiotics as well as controlled or legend (prescription) drugs used in veterinary care. Investigators are expected to use pharmaceutical-grade compounds whenever they are available, even in non-survival procedures.

Investigators must use pharmaceutical grade drugs when they are available in the proper formulation for the proposed work. The use of a non-pharmaceutical grade formulation when an appropriate pharmaceutical grade formulation is available may be considered in certain special situations on a case-by-case basis by the IACUC. These need to be clearly listed on the IACUC protocol and approved by the IACUC.

New investigational compounds are considered to be non-pharmaceutical grade with no available human or veterinary pharmaceutical grade equivalent or alternative.

Sterile diluents and non-toxic vehicles must be used in the preparation of all non-pharmaceutical grade compounds. Diluents or vehicles must be specified in the animal use protocol.

The UW IACUC expects researchers to have the expertise and professional judgment to determine the most appropriate formulation and route of administration for their research. For example, drugs that are formulated for oral administration should only be considered for oral administration, not altered for injectable administration. If the researcher determines that a non-pharmaceutical grade substance is needed, the researcher will obtain the highest quality/purity and will have the expertise, technical information, and laboratory resources for preparing a formulation that is most suitable for the planned route of administration. Researchers are expected to be aware of possible side effects and/or adverse reactions and state these, along with anticipated duration and/or need for treatment, in the protocol.

Use of non-pharmaceutical grade MS-222 (tricaine) and other compounds used for immersion of aquatic animals and Avertin (tribromoethanol)

  • MS-222 is used in an immersion bath for anesthesia and euthanasia of aquatic animals. The IACUC considers that either pharmaceutical grade or non-pharmaceutical grade formulations of MS-222 may be used for this purpose without additional justification in the protocol. Other compounds that are used to prepare immersion baths for aquatic animals may also be non-pharmaceutical grade.
  • As tribromoethanol is not available in a comparable pharmaceutical grade compound, its use as an anesthetic agent should be limited to non-survival procedures. The preparation and use of tribromoethanol for survival procedures must be scientifically necessary, appropriately justified and approved by the IACUC.

Preparation, Storage and Labeling of formulations

  • Diluents or vehicles must be specified in the animal use protocol. Use of solvents will be evaluated on a case-by-case basis. Use of such solvents may limit amounts, concentration and routes of administration. Where possible, prepared solutions that will be given parenterally must be passed through a syringe filter (0.22 um or finer) at the time of preparation. This can be done in the process of transfer to an injection vial. If there is any question about the sterility of a stored solution, it should also be filtered at the time of use. If filtering is not possible (e.g., nanoparticles), sterile components should be mixed using sterile technique (e.g., in a laminar flow hood or biosafety cabinet). Compounds for oral administration do not need to be sterile; however, sterility might be warranted depending on the type of solution and how long it will be stored to prevent degradation or contamination. Proper storage of agents is important. Solutions must not be used if they are cloudy, discolored, precipitated, etc.
  • The UW IACUC expects that the duration of storage and use of a non-pharmaceutical grade formulation will be compatible with the duration for which the formulation will remain potent, as per technical information available, and also sterile. Methods for preparing and storing formulations must prevent contamination that could adversely affect animal welfare or the interpretation of data. Storage in sterile injection vials is strongly recommended as the best option for storage of most injectable drugs. Storage of diluted drugs in 15 or 50 ml conical vials is not recommended, as it is extremely difficult to maintain sterility when they are repeatedly entered with a syringe and needle, outside of a biosafety cabinet. Sterile vials can be purchased from UW Drug Services (https://depts.washington.edu/drugsvcs/home/).
  • Formulations (including secondary containers) must be labeled with the following information: name of the compound, concentration, date of preparation and expiration date. The expiration date must meet the guidelines established in IACUC Policy: Expiration Date Management for Medical Supplies, Equipment, and Substances (generally requiring a month expiration date for dilutions and mixtures unless otherwise approved by IACUC).

Resources

Some examples of pharmaceutical grade agents that can be purchased from UW Drug Services

Note: In order to purchase either pharmaceutical legend (prescription) OR controlled drugs from UW Drug Services, one must have a research drug license from the state of WA, see: Pharmacy Professions Licensing Information

  • sterile water in a vial, fluid bags (e.g., lactated Ringer’s solution, 0.9% NaCl)
  • 10% dextrose solution
  • buprenorphine (controlled drug)
  • euthanasia solution containing pentobarbital and phenytoin (controlled drug)
  • pharmaceutical grade corn oil (commonly used for tamoxifen preparation, or a vehicle for other drugs)
  • Ibuprofen
  • penicillin (legend drug)
  • lidocaine, bupivacaine (legend drugs)

Some examples of non-pharmaceutical grade agents that would be considered unacceptable, due to the availability of a pharmaceutical grade form:

  • laboratory water that has been autoclaved
  • glucose powder from Sigma dissolved in sterile water, PBS or saline
  • xylazine, meloxicam, and other drugs from Sigma which are available as veterinary and/or human medical products

Some examples of non-pharmaceutical grade agents that would generally be considered acceptable:

  • tamoxifen prepared in oil for injection (since the pharmaceutical grade formulation used in human medicine is an oral tablet). Note: The use of pharmaceutical grade oil for preparation of tamoxifen is expected. UW Drug Services is one resource for pharmaceutical grade oil.
  • a novel research compound prepared in a sterile manner (not available in pharmaceutical grade formulation)
  • cells and infectious agents that are administered to animals
  • PBS (purchased and endotoxin-free, not prepared by the laboratory)

In addition to UW Drug Services, the following companies may provide veterinary grade agents to researchers who are able to supply a DEA Researcher License in lieu of a veterinary license. The IACUC cannot endorse these pharmaceutical firms, nor can it guarantee that these firms will continue to supply these pharmaceuticals in forms suitable for animal studies.

References

  1. Guide for the Care and Use of Laboratory Animals (8th Ed.), published 2011. Adopted as an extension of PHS Policy by OLAW December 1, 2011.
  2. NIH, 2016. Guidelines for the Use of Non-Pharmaceutical-Grade Chemicals/Compounds in Laboratory Animals. Animal Research Advisory Committee, Office of Animal Care and Use, NIH. Available at Guidelines for the Use of Non-Pharmaceutical Grade Compounds in Laboratory Animals (PDF) accessed December 17, 2020.
  3. Human pharmaceutical grade drugs are listed in the FDA Orange book: Approved Drug Products with Therapeutic Equivalence Evaluations | Orange Book
  4. Veterinary pharmaceutical grade drugs are listed in the FDA Green book: Approved Animal Drug Products (Green Book)
  5. Wolff A, Garnet N, Potkay S, Wigglesworth C, Doyle D, Thornton D. 2003. Frequently asked questions about the Public Health Service Policy on Humane Care and Use of Laboratory Animals. Lab Anim 32(9): 33-36.
  6. 4/30/2012 Statement by Susan Silk, M.S., Director of the Division of Policy and Education, OLAW: “AAALAC and OLAW Implementation and Recommendations Regarding the New Guide…” (Scientists Center for Animal Welfare IACUC Training Workshop, Baltimore, MD, April 30, 2012) in relation to the virtual unavailability of pentobarbital sodium except at a cost of $1000 for 50 ml of 50 mg/ml solution from very limited sources.

Approval/Review Dates

Originally A​​​pproved: 12/17/2015
Last Reviewed/Revised by the IACUC: 09/21/2023

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