There are different ways to define the concept of 'low levels' of extraneous agents in vaccines and vaccine starting materials, based on the amount of extraneous agents as such, the sensitivity of the detection method and the probability approach linked to the sampling method. None of these approaches, however, is entirely satisfactory--a general definition of a 'low level' cannot be provided. Since the main point is the safety of medicinal products, the risk analysis approach to 'low level' contaminations can be considered as a way to overcome the above mentioned deadlock. But as too many variables impact the risk analysis, it cannot be properly performed either. In practice, seeds are tested to show freedom from extraneous agents, the other raw materials are inactivated through a validated method. However, there are technical and regulatory limits in both cases, and neither testing nor inactivation entirely guarantees freedom from extraneous agents. Despite this unsatisfactory situation, it should be acknowledged that no truly significant disease outbreak linked to an extraneous agent has been identified until today. Regulatory actions are mainly undertaken when a sanitary problem occurs. In the end, companies remain responsible for their products.
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