Thermal Excursion Qualification for Clinical Trial Supplies: A GMP-Centric Guide

Clinical trial supplies—including investigational medicinal products (IMPs), comparators, and reference drugs—must remain within their labeled storage conditions to ensure patient safety and data integrity. However, real-world logistics often expose these supplies to temperature excursions. Proactively qualifying these excursions through stability data and predictive analysis enables risk-based decisions on product usability post-deviation. This guide provides an expert walkthrough of how pharmaceutical professionals can qualify and manage thermal excursions in clinical trial supplies across diverse geographies and regulatory environments.

1. What Is Thermal Excursion Qualification?

Definition:

Thermal excursion qualification refers to the systematic process of using stability data, degradation profiles, and validated models to determine whether a drug product remains within specification after temporary exposure to temperatures outside its labeled range.

Application in Clinical Trials:

• Used when IMPs deviate from storage limits (e.g., 2–8°C) at depots, sites, or in transit
• Forms the basis for QA decision-making on release or quarantine
• Supports temperature deviation justification in audit and regulatory submissions

2. Regulatory and Quality Expectations

ICH Q1A(R2):

• Mandates stress testing and long-term stability data to support labeled storage
• Permits data-supported excursion assessment if degradation pathways are known

FDA and EMA Guidance:

• Expect robust excursion management during clinical supply chain operations
• Excursion risk must be addressed in GMP documentation and clinical SOPs

WHO PQ and GCP Interfaces:

• Stability data must justify continued use of IMPs after deviation
• Temperature-controlled logistics are critical for comparator and vaccine studies

3. Types of Excursions Encountered in Clinical Supply Chains

Sites of Occurrence:

• Depot and site storage refrigerators
• IRT-managed shipments and relabeling depots
• Courier delays, customs holds, airport tarmacs

4. Designing a Thermal Excursion Qualification Program

Step 1: Gather Product-Specific Stability Data

• Pull ICH stability study reports and stress testing profiles
• Include both long-term and accelerated condition results
• Retrieve impurity limits, degradation kinetics, and aggregation data

Step 2: Define Excursion Acceptance Criteria

• Based on assay, impurity levels, physical attributes (color, pH, clarity)
• Include sterility/preservation testing for multidose products
• Model excursion duration, MKT, and degradation margin

Step 3: Develop Excursion Qualification Matrix

Step 4: Integrate into SOPs and Clinical Logistics

• Create a thermal excursion SOP linked to your QMS
• Train QA, depot, courier, and site personnel on excursion response
• Embed matrix and limits into IRT (Interactive Response Technology)

5. Analytical Support for Qualification Decisions

Recommended Testing Parameters:

• HPLC/UPLC: Assay, related substances
• pH, Osmolality: For aqueous injectables
• Visual Inspection: Clarity, discoloration, precipitate
• Container Closure Integrity: Post temperature stress
• Protein Aggregation: SEC, DLS for biologics

6. Case Studies in Clinical Excursion Qualification

Case 1: Comparator Tablet Shipment Exceeded 25°C

Tablet batch exceeded 25°C for 72 hours at the airport. Based on stability data showing no impurity growth up to 30°C for 7 days, the product was released with a deviation report logged.

Case 2: Freeze Exposure of Ophthalmic Dropper

Multidose eye drop frozen at depot due to power failure. QA quarantined the batch. Follow-up testing showed phase separation and pH drift. Batch was discarded, and stability SOP was updated to flag freezing as critical excursion.

Case 3: mAb Shipment Exposed to 35°C

Protein-based injectable exposed to 35°C for 12 hours in courier vehicle. MKT was calculated as 27°C. Based on known aggregation threshold and SEC data, batch was cleared for site use.

7. Tools, Documentation, and Templates

Include in Clinical Documentation:

• Thermal Excursion Qualification Matrix
• Deviation Reports and QA Justification Memos
• Excursion Tracker in Clinical Supply Chain Dashboard

Available from Pharma SOP:

• Thermal Excursion Handling SOP (Clinical Supplies)
• Excursion Qualification Template
• Excursion Impact Risk Assessment Form
• CTD Module 3.2.P.8.3 Summary Template for IMPs

Further insights available at Stability Studies.

Conclusion

Thermal excursion qualification is a cornerstone of modern clinical trial supply management. With rising global studies, strict GMP oversight, and complex logistics, having predefined excursion thresholds and a scientifically justified framework ensures that clinical products maintain safety, efficacy, and regulatory integrity even when deviations occur. Predictive risk matrices, analytical validation, and proper SOP integration are key to successful implementation.