Diethylene Glycol Contamination in Cough Syrups
Introduction:
Cough syrups have long been trusted as a remedy for relieving symptoms associated with respiratory illnesses, providing comfort during cold and flu seasons. However, the discovery of diethylene glycol (DEG) contamination in certain cough syrups has raised serious concerns about the safety and quality of these products. DEG, a toxic substance primarily used in industrial applications, poses significant health risks when ingested or absorbed by the human body. This article explores the issue of DEG contamination in cough syrups, its implications for public health, and the measures which should be taken to address this alarming problem.
Understanding Diethylene Glycol Contamination:
Diethylene glycol is an organic compound primarily used as an industrial solvent, particularly in the production of polymers, resins, and antifreeze. It is significantly cheaper than other common solvents and additives used in pharmaceutical dosage forms such as Propylene glycol and Glycerine. Unfortunately, its chemical properties and low manufacturing costs have led to instances of DEG being fraudulently or unintentionally used as a substitute or adulterant in the additives such as Propylene glycol and Glycerine used in pharmaceuticals including cough syrups.
Health Risks Associated with DEG:
The ingestion or absorption of diethylene glycol can have severe consequences for human health. It can cause kidney failure, damage the liver, affect the central nervous system, and even lead to death in extreme cases. Symptoms of DEG poisoning include nausea, vomiting, abdominal pain, dizziness, seizures, and respiratory issues. Children, due to their smaller body size, are particularly vulnerable to the toxic effects of DEG
Cases of DEG Contamination in Pharmaceuticals-
Over
the years, several incidents of DEG contamination in cough syrups and other
pharmaceuticals have come to light, causing significant harm and loss of life.
The
first and one of the largest outbreaks, which resulted in 105 deaths, occurred
in the United States of America (USA) in 1937. In this case DEG was used by
development scientist as solvent for formulating sulphanilamide elixir due to
lack of knowledge about it’s toxicity. This incident led to the passing of the
1938 Federal Food, Drug and Cosmetic Act. The Act requires manufacturers to
establish safety and efficacy of the drugs before they are introduced into the
marketplace. Since that time, there have been no DEG mass
poisonings in the USA, but many have occurred in the developing world.
Cough
syrup contaminated with DEG led to the deaths of 33 of 36 children known to be
affected in India in 1998 and 85 of 109 children known to be affected in Haiti
in 1995–1996. In both outbreaks, patients had unexplained acute
renal failure, a characteristic of moderate-to-severe DEG poisoning. In 1995, an American Physician volunteering in
Bangladesh reported deaths in children due to Government issued cough syrup. Although
the government denied that anything was wrong with the syrup, but the sample
when tested in US was found to be contaminated with DEG. No specific actions to
prevent recurrence were taken post these incidences.
A
case of cough syrup containing DEG resulting in the deaths of 365 people,
mostly children was reported in Panama in 2006-07. The diethylene glycol used
in the contaminated syrup originated from a Chinese manufacturer, which
exported it as industrial "TD glycerine" with a shelf life of one
year. The letters "TD" were short for "substitute" in
Chinese. When Panama-based company received the material from a
Spanish trader, it changed the name to "glycerine" and the expiration
date to four years before selling it to the government of Panama. Neither
the trading companies involved nor the government lab in Panama that processed
the ingredient tested the substance for verification. Responsible people
were severely punished including death penalty to seniormost person involved.
In 2020-21, another 12 children died in India (J&K) after consuming cough syrups.
In death of more than 100 children were reported in Indonesia due to acute
kidney injuries after consuming cough syrup contaminated with DEG and ethylene
glycol.
Recently
WHO reported deaths in more than 100 children in Marshall island, Gambia and
Uzbekistan due to consumption of cough syrups made by three different drug
manufacturers from India. After initial denial and attempts to prove that
nothing was wrong in the cough syrups, CDSCO conducted audits at the
manufacturing sites and eventually suspended their manufacturing licences due
to lapses seen during the audits. Pharmexcil suspended the membership of one of
the company and Commerce ministry issued notice that all the cough syrups need
to be tested at government laboratories before export.
Except
for the first incident which occurred in US, no comprehensive measures have
been taken to ensure that such incidences don’t get repeated. For the
incidences which occurred in India or related to products manufactured in
India, I haven’t seen any comprehensive investigation conducted by regulatory
agency to understand the root cause/s and taking concrete actions to ensure
that all medicines manufactured and distributed in India are safe.
Potential causes for DEG contamination
Based
on limited information available in public domain related to these incidences
and the knowledge of Pharmaceutical quality systems, following are likely
causes for DEG contamination in cough syrups and other pharmaceutical preparations
–
1.
Intentional use of diethylene glycol by the manufacturer to save
cost. This is highly unlikely because the toxic effects of DEG are now well
known and no manufacturer with sane mind will intentionally add toxic chemical which
can result in death, in their products, as it will damage their reputation and destroy
their business.
2.
Contamination of commonly used pharmaceutical ingredients such
as Propylene glycol and Glycerine with DEG. Such contamination can occur due to
intentional adulteration by manufacturer or the trader to reduce cost or
accidental contamination due to mix-up or wrong labelling of containers if
these chemicals are manufactured or handled in common facility.
3. Present in the
ingredients, being by-product of manufacturing process.
Manufacturing processes of Glycerine & Propylene glycol
To understand what impurities can come from the manufacturing
processes, we need to first understand various paths by which Glycerine and Propylene
glycol are manufactured. Various commonly used manufacturing processes for the
two ingredients and likely by-products by these routes are summarized below –
Ingredient |
Method of production |
Potential contaminants |
Glycerine |
Hydrolysis, saponification, alcoholysis of animal fats and vegetable
oils |
Tri methylene glycol, Formic acid, Various aldehydes, ketones, sulphur compounds, etc |
From petrochemicals (synthetic glycerine) |
Acrolein, Methanol & Di chlorohydrin / Epichlorohydrin |
|
Microbial fermentation of sugars followed by purification using
solvents |
Residual solvents such as dioxane, ether, butanol By-products such as polyols and polyhydroxy alcohols. |
|
Propylene glycol |
Hydration of Propylene oxide |
Di & Tri-propylene glycols along with other glycols, Chlorohydrin, Hypochlorous acid & Propylene oxide |
Review of manufacturing processes and likely
by-products did not indicate possibility of DEG contamination in these
ingredients during manufacturing although there is possibility of formation of
other toxic contaminants.
Based on above information the most likely cause
for DEG contamination in Glycerine or Propylene glycol appears to be intentional
adulteration for profiteering or un-intentional mix-up or wrong labelling.
While above are the technical causes for the
contamination, the major underlying root cause for such repeated issues and
poor quality of drugs in India is outdated drug laws and regulatory system. Some
of the major flaws in our drug laws which have resulted in such incidences are –
1.
The Central drug control
organization does not have direct control over the state FDAs which work as
parallel controlling agencies.
2.
Lack of scientific evaluation of
drug applications. After initial 4 years, state licensing authority can grant
product permission. Each state follows different process for granting manufacturing
licenses and many states grant such licences based on review of just limited
administrative information without doing any technical evaluation to ensure safety
and efficacy of the drugs.
3. There is no procedure for
controlling changes to the process and product, So the manufacturers are at
liberty to make any changes including changes in formulation, changes in vendors,
changes in process etc without even informing to regulatory agency.
4.
Recall process is extremely
ineffective in India due to loose regulations.
5.
There is no regulation for
control of vendors and supply chain.
Corrective and Preventive actions required
Based on the potential causes identified earlier
following controls need to be established to prevent recurrence of issues like
DEG contamination and preventing occurrence of other serious contamination
issues –
1. Vendor
Qualification
The ingredients should be sourced only from approved
vendor. Sourcing should be done directly from the manufacturer or their
authorized distributor.
The vendor qualification should not be restricted
to just review of self-assessment questionnaires and the data sheets provided
by the vendor but should also include the audit of manufacturing site. The
manufacturer as well as the distributor should be covered in vendor
qualification process. Apart from reviewing the systems & processes and
compliance to them, the audit should focus on understanding the manufacturing
process to evaluate adequacy of process controls and specifications to effectively
control the quality of the ingredients.
2. Quality agreement
Quality agreement should be signed with the vendor,
clearly defining the terms and conditions, responsibilities and specifications.
Responsibility of the vendor should include providing timely information about
quality and process related changes to enable evaluation of the impact of those
changes on the quality of the material and the drug product.
3. Incoming material inspection
Indian drug laws require all the raw materials to
be used in Pharmaceuticals to be tested to ensure compliance to specifications.
The law and rules thereunder however are silent about sampling process. Most
companies collect sample from multiple containers selected from total
containers, following inhouse developed sampling plans and make pool sample for
performing the testing as per specifications which are largely derived based on
the Pharmacopoeial monographs. IP and USP monographs for Glycerine and
Propylene glycol have prescribed GC method for quantitative determination of Diethylene
glycol and Ethylene glycol with limit of not more than 0.1%.
Just relying on testing of pool sample however provide
very little assurance. For example, if out of total 10 containers received,
company samples 4 containers following commonly used formula of √n+1, remaining
6 containers will not be sampled at all and if one or more of those contain DEG
or EG fully or partially, it will go undetected. Similarly, if one of sampled
container contain DEG or EG up to 0.3%, the pooled sample will show result
below 0.1% and the material will get released. The syrup produced using one
contaminated drum will however have higher level of DEG and may result in
adverse event.
To address such issues following actions should be
implemented in addition to vendor qualification described earlier.
1. At the time of receipt, it
should be verified that the material is received in manufacturer’s original
container with manufacturers seal (preferably serialized).
2.
Unless the ingredient is manufactured
in a dedicated facility and the systems and processes including labelling process
has been validated, each drum should be sampled and subjected to ID test. Since
Identification tests for Glycerine and Propylene glycol in USP monograph
includes test for DEG and EG, contamination in any drum will get detected. Unfortunately,
the test for DEG and EG is not part of Identification test in IP monograph for
Glycerine. So apart from ID check on all individual containers, DEG/EG check
also needs to be conducted on individual samples.
3.
Rest of the tests may be done on
the pooled sample provided consistency in the supply has been assured based on audit
of manufacturing facility and results of past shipments. Number of containers
which can be pooled together should be based on the sensitivity of the method,
limits and the criticality of the test.
4. Regulatory changes
Many Indian companies, especially those who are
doing business in advanced countries have implemented all or some of above-mentioned
controls. To ensure that all the Pharma companies operating in India adopt these
controls, Indian regulatory agency need to overhaul the antiquated drug laws to
incorporate them in the law. The process for review of drug applications needs
to be strengthened to identify all possible contaminants and impurities and to
ensure that adequate controls are in place to ensure safety of the product. Drug
law should also include procedure for controlling changes to approved
application to ensure that manufacturer’s do appropriate risk assessment while
doing changes to the product and process. It is also necessary to revamp
Pharmacovigilance system in India. Most adverse events are not getting reported
due to lack of awareness or simple laziness. This may result in failure to
detect early warnings. Government should develop PV portal accessible to
everyone where, patients and healthcare givers can report any adverse events
noticed while using a drug. India currently has very low causality
determination rate in most states. Due to this many deaths occurring due to
such issues may go unreported and may not get investigated resulting in delay
in controlling further damage. Regulations need to make it mandatory to correctly
determine the cause of death and recording in national data base. Any abnormal
trends should be investigated. Government also need to develop effective recall
system in India so that in the event of any serious defect detected in the
distributed medicines, further distribution can be quickly stopped there by
preventing further damage.
4. Consumer
awareness
While regulatory measures are crucial, consumer
awareness is equally important in mitigating the risk associated with DEG
contamination and other serious quality defects. Consumers should be educated
and encouraged to report any suspected side effects (adverse events) immediately
to the healthcare professionals and also report to Pharmacovigilance cell of
manufacturer or government portal. Any abnormal trends should be detected and
investigated. AI could be good tool for such signal detection.
Conclusion:
The presence of diethylene glycol contamination in
cough syrups and other medications poses a significant threat to public health.
The ingestion or absorption of the toxic substance can lead to severe health
complications, making it imperative to address this issue effectively.
Governments, regulatory bodies, and pharmaceutical manufacturers must work
collaboratively to implement stringent quality control measures and raise
awareness among consumers. By ensuring the safety and integrity of medications,
we can safeguard the well-being of individuals and restore public confidence in
these essential medications.
-Ganadhish Kamat
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