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3.

Is there information demonstrating that the method performs within the SMPR Method

Performance Requirements using the Reference Materials stated in the SMPR? If no, then

specify the what is missing and how this impacts demonstration of performance of the method.

n/a, no CRM's listed for the plant product. Standard's only. One source of a standard is

Chromadex.

4.

Is there information demonstrating that the method performs within the SMPR Method

Performance Requirements table specifications for all analytes in the SMPR applicability

statement? If no, please specify what is missing and whether or not the method’s applicability

should be modified.

No, the LIB does not cover the other ranges as far as repeatability and recovery.

IV.

GENERAL SUBMISSION PACKAGE:

1.

Based on the supporting information, were there any additional steps in the evaluation of the

method that indicated the need for any additional precautionary statements in the method?

Yes, there was no safety section.

2.

Does the method contain system suitability tests or controls as specified by the SMPR? If no,

please indicate if there is a need for such tests or controls and which ones.

No, only mitragynine was analyzed in the "in-house" reference material. The mitragynine was

quantitated by HPLC-DAD and not with the other techniques in the LIB. The material was not

fully characterized.

3.

Is there information demonstrating that the method system suitability tests and controls as

specified in the SMPR worked appropriately and as expected? If no, please specify.

Yes and no, mitragynine was used solely. 7-OH mitragynine was not quantitated in the

products.

4.

Based on the supporting information, is the method written clearly and concisely? If no, please

specify the needed revisions.

Yes, it is fairly straight forward

5.

Based on the supporting information, what are pros/strengths of the method?

Multiple techniques, GC-MS, HPLC-PDAD, and HPLC-MS/MS. Uses small sample size. With more

sensitive instruments that are now available, it would be possible to analyze at lower ranges.

6.

Based on the supporting information, what are cons/weaknesses of the method?

No data for the lower ranges. It is unsure if the LOD and LOQ have been met, since spikes were

not done.