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 MANUFACTURE AND TESTING OF SC-19192

MANUFACTURE AND TESTING OF SC-19192

Seven batches of SC-19192 (diketopiperazine) were used in this study.  All batches were manufactured in-house by Searle Chemist jack Drogt.  The lot numbers, analytical numbers, and quantities are as follows

Lot Number

Analytical Number

Quantity (After Milling)

1R

6906

This data removed in released report

2R

7274

This data removed in released report

3R

7273

This data removed in released report

4R

7291

This data removed in released report

5R (JDR-5-18A)

9129

This data removed in released report

6R (JDR-5-30A)

9805

This data removed in released report

7R (JDR-5-30B)

9829

This data removed in released report

Bach records covering the manufacture of lots 1R through 5R were reviewed.  Batch records for lot 6R and 7R could not be located by Searle personnel.  Analytical reports for all seven batches were reviewed.  Copies of the batch records and analytical records were obtained and are attached to this report, along with copies of pages from Jack Drogt's laboratory notebook, and other laboratory notebooks relating to the analysis of lots 1R through 7R of DKP. (See Exhibits 13-23.)

We obtained copies of three different specification sheets for DKP.  (See Exhibits 16-18.)  We could not determine with certainty which of the three specifications sheets was in effect at the time that the 7 lots of DKP used in this study were assayed, because only one of the three specification sheets was dated.  This resulted in ambiguities for two of the parameters measured: melting point and identity (IR Spectrum).  Specification memorandum dated Dec. 4, 1969 listed a melting range of 252-256 degrees C. Another specification sheet (not dated) entitled "Tentative Specification For SC-19192", listed a melting range of 241-246 degrees C.  A third specification sheet entitled "Specification for SC-19192,  Specification No. C 40606C" (not dated) listed a melting range "at about 243 degrees C.".

For identity (IR Spectrum) the first sheet (dated 12/4/69) specified that "The reference standard shall be considered to be TJT-12-32 until something better comes along".  The second and third sheets specify that the DKP "Conforms to IR #2358".

No data was made available as to dates, method of preparation and authentication of DKP references standards used.

Searle attorney Roger Thies was contacted about this point Aug. 1, 1977 and said he would attempt to obtain information regarding this point but later registered doubt as to whether anything would be found.

We asked Searle personnel to tell us which of the specification sheets was valid for the DKP used in study E-77/78.  We were told that the third sheet, identified with "No. C4060C", could not have been used since the number corresponded to a date in June, 1974.

It is not clear as to the exact date that the first sheet (dated 12/4/69) was superceded by the second one, identified "tentative specifications for SC-19192" because the second sheet was not dated or numbered.  However, Searle attorney Roger Thies told us that their "best guess" was that the sheet marked "tentative specifications for SC-19192" was the one used.

Accordingly, we have used the specifications from the sheet marked "tentative specifications" for the following chart, which compares the specifications with the actual results of analysis.

                    DKP LOTS

 Specifications  1R  2R  3R 4R  5R  6R  7R

Note... This entire table was expunged from the delivered document, by parties unknown.

-Specifications  1R  2R  3R 4R  5R  6R  7R

 Note... This entire table was expunged from the delivered document, by parties unknown.

The only discrepancy apparent in the above chart is in the criteria for identity.  The specification lists reference standard 1R #2358, while the analytical record for lots 1R through 5R refer to Reference #3701.

Examination of the laboratory notebooks referenced on the analytical records revealed other possible discrepancies.  For example, the analytical record A-9129 for DKP Lot 5R showed an assay (titration) of 100.0 percent.  The analytical record referenced two different lab notebooks assigned to two different analysts. Examination of lab notebook AR-68 assigned to Sandra Ann Carey revealed that she had analyzed 3 samples of lot 5R on 11/9/72. Results of the analysis showed that sample one had an assay (by titration) of 89.70 percent, sample two, 87.93 percent and sample three was discarded.

Apparently not satisfied with her results she repeated the assay on the same day (11/9/72) and obtain 93.23 percent (the average of 3 samples), still well below the specification of 99.0 percent.  The other lab notebook referenced was AR-57, assigned to E. Aranda.  This notebook showed that analyst Aranda performed an assay (titration) of lot 5R on 12/1/72 the results of which were 114.83 percent for 3 samples.  Apparently not satisfied with the results, he repeated the assay on 12/6/72 and obtained 100.4, 99.9 and 99.8 percent for an average of 100.0 percent.  This result (100.0 percent) was the only one reported on the analytical record A-9129.

The analytical record (A-7291) for DKP lot R shows a result of "less than 20 PPM" for the heavy metals test.  Two laboratory notebooks are referenced:  VSH-I, pages 260-263, and AR-23, page 269.  Examination of both of these books revealed no mention of a heavy metals test.

The analytical record (A-9805) for DKP lot 6R (JDR-5-30A) also showed a result of "less than 20 PPM" for heavy metals test. Examination of the referenced laboratory notebook (AR-77, page 83-86) revealed no evidence of a test for heavy metals.

The analytical record (A-9829) for DKP lot 7R (JDR-5-30B) again showed "less than 20 PPM" heavy metals.  Examination of the referenced lab notebook (AR-93) again showed no evidence of a heavy metals test.

The above discrepancies were the only ones noted with respect to lots 1R through 7R of DKP.  All other criteria for identity and purity of DKP as shown in the reports of analysis, conforms to Searle specification sheet marked "tentative specifications for SC-19192".  It should be noted however that none of the seven lots of DKP met the specifications on the sheet dated 12/4/69, with respect to melting range.