Evaluating Freeze-Thaw Effects on Drug-Device Combination Products: A Regulatory and Functional Guide

Drug-device combination products—such as prefilled syringes, autoinjectors, insulin pens, and patch pumps—combine pharmaceutical and mechanical components into a single therapeutic system. These products face unique challenges under freeze-thaw and thermal cycling conditions. Regulatory authorities including the FDA and EMA now require that both the drug and the delivery mechanism retain integrity and functionality following temperature excursions. This tutorial offers pharmaceutical professionals a comprehensive guide to designing and conducting freeze-thaw testing for combination products, including key evaluation parameters, test methods, and regulatory reporting strategies.

1. Why Freeze-Thaw Testing Is Essential for Combination Products

Unique Vulnerabilities:

• Mechanical complexity: Moving parts like plungers, springs, and actuators can freeze or degrade
• Drug-device interface risks: Drug formulations may interact with device materials or seals under stress
• Packaging integrity: Container closure systems (CCS) and delivery interfaces may leak or crack when frozen

Common Excursion Scenarios:

• Refrigerated or room temperature-labeled products accidentally frozen during shipping
• Cold chain breaches in clinics, pharmacies, or patient homes
• Use in variable temperature zones without protective packaging

2. Regulatory Framework for Freeze-Thaw Testing of Combination Products

FDA Guidance:

• Freeze-thaw and stress testing must be part of combination product stability programs (21 CFR Part 4)
• Emphasizes function, CCI (container closure integrity), drug potency, and user safety

EMA Requirements:

• Stability testing of the integrated system under transport-simulated excursions
• Functional assessments of device post-cycling are mandatory

ICH Q1A/Q5C:

• Recommend freeze-thaw studies for stress condition analysis, particularly for biologics and devices with cold-chain needs

3. Designing Freeze-Thaw Studies for Combination Products

Study Parameters:

• Temperature Range: –20°C for freezing, 2–8°C or 25°C for thawing
• Cycles: 3–5 complete cycles (12–24 hours per phase)
• Test Configurations: Use final commercial packaging and shipping orientation

Sample Stratification:

• Test various device formats (e.g., PFS, autoinjectors)
• Include different batches and filling lines
• Store matched controls at standard conditions

4. Key Parameters to Evaluate Post Freeze-Thaw

A. Drug Product Stability:

• Assay and degradation profiling (HPLC)
• Appearance, particulate matter, and pH
• Viscosity changes (especially for biologics)
• Aggregation (SEC, DLS) and potency retention (bioassay)

B. Mechanical and Functional Testing:

Test	Purpose
Injection force	Detect freezing impact on delivery resistance
Dose accuracy	Ensure correct dose delivery after stress
Device actuation	Assess usability of buttons, plungers, and triggers
Delivery time	Compare consistency of dose administration pre/post stress
Container closure integrity (CCI)	Evaluate system for leakage or vacuum loss

5. Case Studies of Freeze-Thaw Effects in Combination Devices

Case 1: Autoinjector Spring Jamming Post-Freezing

After 4 cycles at –20°C and 25°C, an epinephrine autoinjector showed 30% failure in actuation due to spring compression inconsistency. Root cause: moisture condensation impacted lubricity. Packaging was improved to include moisture barrier.

Case 2: Protein Aggregation in Prefilled Syringe

A monoclonal antibody in a siliconized PFS aggregated post-thaw. SEC showed >5% high-molecular-weight species. Surfactant concentration was adjusted to reduce interfacial stress during thawing.

Case 3: Vial-Syringe Transfer System Failures

Freeze-thaw cycles caused plastic embrittlement in a dual-chamber syringe system, leading to breakage during reconstitution. Material selection was revised to include freeze-tolerant polymers.

6. Best Practices for Executing Freeze-Thaw Testing on Combination Products

Study Execution:

• Use calibrated thermal chambers with real-time monitoring
• Track each cycle phase with start/end timestamps
• Avoid rapid thawing unless intended for real-world simulation

Data Documentation:

• Use combination of raw data, visual observations, and video evidence
• Ensure traceability of sample IDs, device types, and stress durations
• Compare with baseline controls under standard storage

User Safety Assessment:

• Conduct usability testing post-cycling for autoinjectors and pen devices
• Ensure device functionality doesn’t compromise dose accuracy or cause injury

7. CTD Reporting of Freeze-Thaw Results

Submission Sections:

• Module 3.2.P.2.4: Justification for stress testing protocols
• Module 3.2.P.5.6: Analytical method validation for freeze-thaw conditions
• Module 3.2.P.8.3: Detailed stability data for drug and device functionality

Labeling Justifications:

• “Do Not Freeze. Freezing may impair device function or reduce drug efficacy.”
• “Product remains stable for up to 3 freeze-thaw cycles if stored at –20°C and thawed at 5°C.”

8. SOPs and Templates for Combination Product Freeze-Thaw Testing

Available from Pharma SOP:

• Combination Product Freeze-Thaw Testing SOP
• Device Functionality and Usability Checklist
• Stability Study Tracking Log for Devices
• Freeze-Thaw Excursion Investigation Form

More resources and case-specific guidance are available at Stability Studies.

Conclusion

Freeze-thaw testing is indispensable for ensuring the integrity and functionality of drug-device combination products in real-world conditions. With the increasing global distribution of temperature-sensitive therapies, pharmaceutical developers must rigorously evaluate both drug and device components under simulated stress. By aligning studies with regulatory guidance and incorporating functionality assessments, companies can ensure robust, patient-safe products that withstand thermal challenges and meet global compliance standards.