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Topic · Toxicology

“QA wants an ICH M7 classification this week, with a written rationale.”

ICH M7 assessment of impurities

What ICH M7 (R2) requires for mutagenic impurities and how CovaSyn delivers the groundwork: both assessment methods in one run, the applicability domain checked per prediction, a table ready for review by your experts.

Result · reportPurity by HPLC
V1V2API ↑V3V4mAU0246810t (min)
Peakt (min)Area %
V12.10.09
V23.40.24
API6.299.15
V37.80.38
V49.10.14
Example data, UV 254 nm. Area percentages computed from the peaks shown; main peak off scale, solvent front (0.8 min) not integrated.

Regulation

Obligations and deadlines

What the guideline sets out, as stated in our Insights articles and the ICH M7 guide. The final classification remains the job of your experts.

Obligations and deadlines
FrameworkWhat appliesThreshold or deadline
ICH M7 (R2), assessmentFor bacterial mutagenicity, two complementary (Q)SAR methods: one expert rule-based and one statistical. If both are negative, class 5 is possible without further testing.Two methods, both documented
ICH M7 (R2), class 1Known mutagenic carcinogen: control at or below the compound-specific acceptable intake.Compound-specific, e.g. NDMA with a published limit of 96 ng/day
ICH M7 (R2), class 2Known mutagen with unknown carcinogenic potential: control at or below the acceptable limit.TTC-based, except for the cohort of concern
ICH M7 (R2), class 3Alerting structure unrelated to the drug substance, no mutagenicity data: control at the TTC limit or a bacterial mutagenicity test to reclassify to 5 or 2.TTC or Ames test
ICH M7 (R2), classes 4 and 5Alert shared with the drug substance or a tested non-mutagenic relative (4), or no alert or an alert with data showing no mutagenicity (5): treat as non-mutagenic.ICH Q3A/Q3B applies
ICH M7 (R2), TTCThreshold of toxicological concern for controlling mutagenic impurities at lifetime exposure.1.5 µg/day
ICH M7 (R2), cohort of concernN-nitroso compounds, aflatoxin-like and alkyl-azoxy structures: the general TTC does not apply. A compound-specific acceptable intake from carcinogenicity data, read-across or a framework such as CPCA is required.Not 1.5 µg/day
ICH M7 (R2), prediction without dataA prediction alone gives class 3 or 5 at most. Classes 1, 2 and 4 require data or comparison with the drug substance.

Sources: our articles on ICH M7 classification and nitrosamine risk assessment and the ICH M7 guide, linked below.

CovaSyn

How CovaSyn does it

CovaSyn makes the groundwork reproducible and traceable. The classification, control strategy and filing are owned by your experts in toxicology, QA and regulatory affairs.

  • Both methods in one run

    Rule-based structural alerts with mechanism and literature reference, and a statistical Ames probability with confidence. Both results come back separately, not as a merged verdict.

  • Many impurities against the API

    Up to 50 impurities in one run, with class per impurity, class distribution, worst case and similarity to the drug substance. That separates drug-related from process impurities.

  • Applicability domain per prediction

    If a structure lies outside the model space, the result says so. The expert rule then carries the rationale, not the statistical score.

  • Audit trail from the first call

    Timestamp, tool, version, result status and key ID per call, outputs with a SHA-256 checksum, export as CSV or JSON.

  • GAMP 5 category 4

    A configured product, no custom code at your site. Validation takes place in your organisation.

  • Your experts decide

    Class 3 still needs review by qualified toxicologists. Classes 1 and 2 are reported, not blocked automatically.

What the computation does not replace

  • The tool does not replace qualified toxicology experts. The final classification and filing strategy remain with QA and regulatory affairs.
  • A statistical score outside the applicability domain is not evidence but a directional signal.
  • Listing nitrosatable amines in the drug substance, the route and the formulation is chemistry, not software.

Questions

Common questions

Does the 1.5 µg/day TTC apply to nitrosamines?

No. N-nitroso compounds belong to the ICH M7 cohort of concern. A compound-specific acceptable intake is required, derived from carcinogenicity data, read-across or a framework such as CPCA.

Why does ICH M7 require two methods?

The rule set captures mechanisms that a model trained on Ames data cannot express traceably. The statistical model catches structures no rule covers. Both must be allowed to disagree.

Next step

Assess your own impurities.

Create an account, get your API key, use the tools in Claude, ChatGPT or Cursor.