FDA Issues Guidance on Nitrosamine Leachables in Infusion Bags: Risks, Root Causes, and Testing Requirements

Nitrosamines Leachables in Infusion Bags

Introduction

The U.S. Food and Drug Administration (FDA) has recently released new guidance on the risks associated with Nitrosamines Leachables in Infusion Bags, focusing especially on N-nitrosodibutylamine (NDBA). These impurities can migrate from packaging materials into drug solutions, raising major safety concerns as nitrosamines are considered probable human carcinogens. The FDA document highlights its findings, potential causes, required testing, and the impact on pharmaceutical companies.

This step continues the global efforts of regulatory agencies to strengthen nitrosamine risk control in all dosage forms. Infusion drugs are a critical concern since they are widely used for patients in hospitals and long-term therapies. Managing leachables at this stage is essential to ensure both patient safety and continuous drug availability.

At ResolveMass Laboratories Inc., we help pharmaceutical manufacturers adapt to these evolving regulations by offering validated nitrosamine testing, detailed risk assessments, and complete compliance solutions.

Have questions about nitrosamines testing or compliance?

Contact our experts today for guidance tailored to your needs.


🔎 Key Takeaways (Summary)

  • FDA has detected NDBA in infusion bag–packaged drug products.
  • Possible causes include inks, polymeric packaging, nitrocellulose binders, and overwrap processing.
  • Risk assessments, confirmatory testing, and reporting must be done within 90 days.
  • The FDA may allow higher acceptable intake (AI) levels for infusion therapies due to clinical need.
  • Testing must reach parts-per-billion (ppb) sensitivity using validated analytical methods.
  • Manufacturers need to balance safety requirements with continuous patient access to treatment.
  • ResolveMass Laboratories provides advanced nitrosamine impurity testing, submission support, and risk evaluations.

These key points highlight the urgency of compliance while stressing the need for practical solutions that avoid disrupting patient care. Drug makers should prepare now to meet the new requirements on time.


Background: FDA Findings on Nitrosamines Leachables in Infusion Bags

The FDA’s Center for Drug Evaluation and Research (CDER) confirmed the presence of NDBA in infusion bag–packaged drugs. The concern is that nitrosamines may leach from the packaging itself or form during interactions with inks, binders, or protective overwraps.

NDBA and other nitrosamines are recognized as probable human carcinogens, making their presence a high-risk issue. Infusion bags are widely used in emergency care, oncology, and critical care, increasing the potential for patient exposure.

The FDA noted that adjusted AI limits—sometimes 4–10 times higher—may be acceptable for infusion products due to their life-saving role. These findings are consistent with warnings from European and Canadian regulators, confirming that nitrosamine management has become a global regulatory priority.

👉 Learn more: Nitrosamine Impurity Limits for Health Canada Submissions


Potential Root Causes of Nitrosamines Leachables in Infusion Bags

The FDA identified packaging-related sources as key contributors to nitrosamine contamination in infusion therapies.

Source MaterialContribution to Nitrosamine Leachables
Polymeric raw materialsAct as precursors for nitrosamine formation
InksContain dialkylamines that may react into nitrosamines
Nitrocellulose bindersRelease reactive groups during breakdown
Overwrap manufacturingHeat and compression increase nitrosamine formation

Manufacturers are strongly advised to evaluate these risks early in the packaging design process. Strategies include material replacement, stronger supplier quality controls, and frequent extractable/leachable (E&L) testing.

👉 For details: Nitrosamine Impurities in Pharmaceuticals


FDA Guidance on Risk Assessment, Testing, and Reporting

The FDA requires companies to follow a structured three-step process:

Step 1: Risk Assessment

Identify all possible sources of Nitrosamines Leachables in Infusion Bags and packaging systems.

Step 2: Confirmatory Testing

Conduct validated testing methods capable of detecting nitrosamines at ppb sensitivity.

Step 3: Reporting

Submit results to the FDA within 90 days, including risk details and method validation.

If testing cannot be completed within the timeframe, companies must provide a clear plan and timeline for review. This ensures monitoring of high-risk products while avoiding unnecessary supply shortages.

👉 Explore our services: Nitrosamine CRO Support for Effective Risk Evaluation


Implications for Drug Manufacturers and Applicants

Drug makers now face the challenge of meeting compliance requirements while ensuring continuous supply of infusion therapies. The FDA has confirmed it will not immediately block affected products but expects proactive action to reduce risks.

Applicants may request higher AI levels for large-volume parenterals, but this must be supported with solid scientific data. Timely reporting is crucial to maintain trust with regulators and avoid approval delays.

This guidance makes it clear that early compliance planning is key. Any delays or incomplete reporting could harm patients, disrupt supply chains, and affect company reputation.

👉 Learn more: Consequences of Nitrosamine Detection


Analytical Methods for Detecting Nitrosamines Leachables

The FDA underlined the need for advanced and validated analytical methods that detect nitrosamines in the ppb range.

Key Analytical Requirements

  • Must comply with ICH Q2(R1) validation standards.
  • Testing should include at least three representative batches within shelf-life.
  • High-risk strengths of drug products should be prioritized.

Advanced Techniques

  • LC-MS/MS (Liquid Chromatography – Tandem Mass Spectrometry)
  • GC-MS (Gas Chromatography – Mass Spectrometry)
  • High-resolution mass spectrometry

These methods ensure nitrosamines like NDBA can be reliably detected, giving manufacturers confidence in their quality control process.

👉 Read more: Emerging Tech in Nitrosamine Testing


Conclusion

The FDA’s guidance on Nitrosamines Leachables in Infusion Bags shows the urgent need for structured risk assessments, validated testing, and quick reporting. By understanding the causes—such as packaging materials, inks, and overwrap processing—companies can reduce risks before drugs reach patients.

Adopting strong testing systems not only keeps manufacturers compliant but also helps protect patient trust and market access. With regulators paying closer attention to nitrosamine impurities, proactive management is now a core part of pharmaceutical quality assurance.

At ResolveMass Laboratories Inc., we provide complete solutions, including advanced detection methods, AI-driven risk modeling, and regulatory support—helping your products stay compliant and safe.

👉 Contact our experts today: ResolveMass Contact Page

Most Asked FAQs on Nitrosamines Leachables in Infusion Bags

What are nitrosamines leachables in infusion bags?

Nitrosamines leachables are chemical impurities that move from packaging materials, inks, or protective layers into infusion drugs. Since infusion products are directly administered to patients, even trace amounts of nitrosamines raise serious health concerns. The FDA has already confirmed the presence of NDBA in certain infusion bag–packaged products.

Why are nitrosamines dangerous?

Nitrosamines are classified as probable human carcinogens. This means that consistent or long-term exposure, even at very low levels, can increase the risk of developing cancer. For infusion therapies, where drugs are given directly into the bloodstream, the safety concern becomes even more critical.

What did the FDA find in infusion bags?

The FDA discovered that NDBA, a type of nitrosamine, can leach from the packaging materials of infusion bags into drug solutions. This finding has raised alarms because these drugs are often used in life-saving treatments, making strict testing and monitoring essential for patient safety.

What are the main sources of nitrosamine leachables?

The primary sources include polymeric packaging materials, printing inks that contain amines, nitrocellulose binders, and manufacturing processes such as heating or compression of overwraps. Each of these materials or processes can contribute to the formation or release of nitrosamines into infusion solutions.

What is FDA recommending now?

The FDA is asking manufacturers to carry out structured risk assessments, conduct sensitive confirmatory testing, and submit findings within 90 days. If testing cannot be completed in time, a clear plan and timeline must be submitted. This ensures that risks are controlled while maintaining patient access to treatments.

What are the acceptable intake (AI) limits for nitrosamines?

For infusion therapies, the FDA may allow higher AI levels—sometimes 4 to 10 times above the standard limits—because these drugs are often critical in urgent care. However, manufacturers must provide strong scientific reasoning before such allowances can be approved.

What testing methods are acceptable?

Only validated and highly sensitive methods are considered acceptable by the FDA. Techniques such as LC-MS/MS, GC-MS, and high-resolution mass spectrometry can detect nitrosamines at parts-per-billion levels. These methods help ensure that impurities are identified long before reaching patients.

Will FDA allow continued distribution of affected drugs?

Yes, the FDA may temporarily allow the distribution of affected drugs to avoid supply shortages. However, this is only permitted while manufacturers are actively investigating the issue and implementing risk-mitigation strategies. The long-term goal remains complete compliance and patient safety.

What should manufacturers do if they can’t complete testing in time?

If confirmatory testing cannot be completed within the 90-day window, manufacturers are expected to submit a detailed plan outlining timelines and methods. This shows regulators that the company is taking the issue seriously while continuing to work toward full compliance.

References

  1. Food and Drug Administration. (2025, August 18). Emerging scientific and technical information on leachable NDBA and other small-molecule nitrosamines in infusion bags (FDA nonbinding recommendations). https://www.fda.gov/media/188238/download
  2. Food and Drug Administration. (n.d.). CDER nitrosamine impurity acceptable intake limits: Guidance for industry. U.S. Department of Health and Human Services. Retrieved [date you accessed it], from https://www.fda.gov/regulatory-information/search-fda-guidance-documents/cder-nitrosamine-impurity-acceptable-intake-limits

Have questions about nitrosamines testing or compliance?

Contact our experts today for guidance tailored to your needs.

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