Understand the Evolving Regulations for Aseptic Cleaning and Environmental Monitoring


Published on

This session from the Institute of Validation Technology's Contamination and Control Week discusses regulatory expectations and industry drivers for aseptic cleaning and environmental monitoring, regulatory expectations for cleanrooms, and current FDA and EU expectations during inspection of sterile and aseptic operations.

Published in: Health & Medicine

Understand the Evolving Regulations for Aseptic Cleaning and Environmental Monitoring

  1. 1. Session 5 • Understand the EvolvingRegulations for Aseptic Cleaning and Environmental Monitoring IVT’s Contamination Control Week June 25-27, 2012 Boston, Massachusetts
  2. 2. For more information on aseptic cleaning and environmental monitoring, please visit www.ivtnetwork.com. Use the promo code SLIDE1 for a 10% discount on a membership!
  3. 3. CONTACT INFORMATIONfor Course Leader: David Vincent, CEO Validation Technologies, Inc. San Diego, CA Office: 800-930-9222 Fax: 858-638-5532 Email: davidv@validation.org
  4. 4. Topics Addressed§  Regulatory requirements & expectations§  Potential sources and types of microbial contamination§  Implementation of microbial control measures§  Disinfection/Sanitization§  Environmental monitoring
  5. 5. Part 1:Microbiological control is aregulatory requirement
  6. 6. CFR 21- 211.113 (a) Control of Microbiological Contamination Microbial “Appropriate written procedures, designed to prevent objectionable organisms in drug products not required to be sterile, shall be established.” §  Control of bioburden §  Absence of objectionable organisms
  7. 7. WHAT ISCONTAMINATION?§  There are two types of contamination. Non-viable (Particulate) –  Air Filtration –  Materials shedding Viable (Microbiological or Bioburden) –  Molds –  Bacteria –  Viruses 7
  8. 8. Viable Contaminants §  Viruses §  TSEs (transmissible Spongiform encephalopathies §  Fungi §  Bacterial §  Pyrogens (Endotoxin) §  Mycoplasma §  Biological Based Components (DNA, foreign proteins, etc.)
  9. 9. NONVIABLECONTAMINATION§  This is any type of contamination that is not viable. It is usually filterable. For example: §  Dirt, sand, powders, etc. §  Particulate §  Debris §  Molding flash §  Chemical contamination such as crystals, etc. §  Oils and Mold Release agents §  Insect parts§  Controlled room classifications are defined by particulate contamination sizes and numbers. 9
  10. 10. What is ContaminationControl? §  Contamination control is not simply a task or function. It is a science and applied technology that interacts continuously with all products, processes, materials, equipment, and personnel entering the manufacturing areas.
  11. 11. MicrobiologicalControl §  Identify possible sources of contamination §  Identify possible types of contamination likely to occur §  Implement and validate/qualify preventative and control measures
  12. 12. Possible Sources ofContamination§  Raw Materials/Excipients§  Equipment and Process§  Environment/Facility§  Personnel
  13. 13. Raw Materials/Excipients §  Bioburden in raw materials and excipients v  natural vs synthetic products v  water activity level §  Bioburden in water systems v  potable water, purified water, WFI v  biofilm
  14. 14. Equipment and Process §  Process and Equipment §  Carbon filters/DI Design resins/membrane §  Material/Surface filters §  Unprotected storage tanks §  Sampling/transfer hoses §  Back flow §  Valves §  Perforated heat exchangers §  Dead legs
  15. 15. Facility§  Facility design§  Air handling system§  Construction materials§  Finish materials
  16. 16. Personnel§  Major potential source of microbial contamination v  Exposed skin (flakes, oils) v  Hair v  Clothing fibers v  Dirt v  Cosmetics v  Tobacco smoke v  Behavior
  17. 17. Part 2:Regulatory ExpectationsRelated to Cleanroom Operations
  18. 18. Facilities: CleanroomClassification FS209 ISO 14644-1 Viable Ave Airflow Cleanroom Cleanroom ≥0.5um Microbes Velocity Air classification classification particles/m3 (cfu/m3) (fpm) changes/hr 100,000 8 3,520,000 100 5-10 5-48 10,000 7 352,000 10 10-15 60-90 1000 6 35,200 7 25-40 150-240 100 5 3,520 1 40-80 240-480 §  a- All classifications based on data measured in the vicinity of exposed materials/articles during periods of activity. §  b- ISO 14644-1 designations provide uniform particle concentration values for cleanrooms in multiple industries. An ISO 5 particle concentration is equal to Class 100 and approximately equals EU Grade A. §  c- Values represent recommended levels of environmental quality. You may find it appropriate to establish alternate microbiological action levels due to the nature of the operation or method of analysis. §  d- The additional use of settling plates is optional. §  e- Samples from Class 100 (ISO 5) environments should normally yield no microbiological contaminants.
  19. 19. Equipmentand Process §  CFR 211.63, “Equipment used in the manufacture, processing, packing, or holding of a drug product shall be of appropriate design, adequate size and suitably located to facilitate operations for its intended use and for its cleaning and maintenance.” §  Q7A, 5.15, “Closed or contained equipment should be used whenever appropriate. Where open equipment is used, or equipment is opened, appropriate precautions should be taken to minimize the risk of contamination.”
  20. 20. Equipment and Process §  Equipment v  easily disassembled and cleaned v  use sanitary fittings and valves/avoid dead legs v  product contact surfaces resistant to corrosion v  store cleaned equipment in a sanitary condition
  21. 21. Equipmentand Process§  Equipment flow and location v  no cross flow of clean and dirty and contaminated equipment/materials§  Process v  evaluate each step in a process for the potential of microbial contamination v  use closed systems whenever possible v  open operations should be contained within HEPA stations
  22. 22. Environment & Facility §  Flooring and wall materials must be easily cleaned §  Surfaces must be resistant to chemicals, abrasion, and flaking §  Ensure concave coving at the junction of walls and floors §  Floors must be sloped toward the drain §  Clean/sanitize floors daily §  Cover floor drains when not in use §  Avoid standing water
  23. 23. Environment & Facility §  Evaluate traffic patterns and room capacity §  Production and packaging areas need to be under positive pressure §  Establish and monitor operating parameters and environmental controls §  Use HEPA filtration systems §  Clean up spills immediately §  Cover air ducts, pipes, and light fixtures §  Avoid build-up of dust and moisture accumulation
  24. 24. Part 3:Cleaning and Disinfection
  25. 25. Disinfection/SanitizationProgram •  Cleaning/Sanitization is a regulatory requirement •  Cleaning should not be confused with disinfection •  A cleaning program is not complete without contamination control
  26. 26. Disinfection/SanitizationProgram §  CFR211.56 (b) “ There shall be written procedures assigning responsibilities for sanitation and describing in sufficient detail the cleaning schedules, methods, equipment, and materials to be used in cleaning the buildings and facilities; such written procedures shall be followed.”
  27. 27. Preparation and Use ofDisinfectants Preparation and Storage •  EC Guide, Annex 1, “Disinfectants and detergents should be monitored for microbial contamination: dilutions should be kept in previously cleaned containers and should only be stored for defined periods unless sterilised. Disinfectants and detergents used in grade A and B areas should be sterile prior to use.”
  28. 28. Current regulatory expectationsfor use of disinfectants Rotation •  EC Guide, Annex 1, 37 “Where disinfectants are used, more than one type should be employed. Monitoring should be undertaken regularly in order to detect the development of resistant strains.” •  ISO Recommendation •  Industry Practice
  29. 29. Product Classification§  Sanitizers v  proper use results in 99.9% (3 log) reduction of bacteria v  cannot handle soil; use on pre-cleaned surfaces§  Disinfectants v  proper use results in 100% (> 4 log) reduction of bacteria and yeast. Limited reduction for mold. v  most have surfactants/cleaning ability§  Sterilants v  proper use results in 100% (> 6-7 log) reduction of all microorganisms, including bacterial spores. v  require application on pre-cleaned surfaces
  30. 30. Disinfection efficacy §  Suitability, efficacy & limitations of disinfectant agents and procedures should be assessed. §  The disinfection program should include the use of a sporicidal agent used according to a written schedule and when environmental data suggests presence of spore forming agents (Baccilus spp.).
  31. 31. Disinfectant Efficiency Most Resistant Endospores Mycobacteria Fungal Spores Small Non-enveloped viruses (polio, rotavirus, rabies) Vegetative Fungal Cells Enveloped Viruses (Herpes, Hepatitis B, Hepatitis C, HIV) Vegetative Bacteria Least Resistant
  32. 32. Equipment and bacteria Even seemingly smooth surfaces can harbor bacteria ! Scanning electron micrograph of Listeria monocytogenes forming a biofilm in soy on a stainless steel chip. Courtesy of Professor Amy Wong.
  33. 33. Cleaning/SanitizationProgram An effective cleaning and sanitization process is attained by: §  Treatment with strong acids and bases §  Use of high velocity hot water or steam §  Use of detergents and/or sanitizers §  Rinsing with high quality water (Purified or WFI) §  Use of solvent rinses §  Drying at elevated temperatures
  34. 34. Disinfectant Selection §  Population and types of organisms §  Spectrum of activity of disinfectant §  EPA registrations §  Method of application §  Contact time §  Nature and surface to be disinfected §  Compatibility of surface with disinfectant
  35. 35. Disinfectant Selection §  Corrosiveness of disinfectant §  Organic compounds present on surface §  Operator safety §  Compatibility with cleaning agents §  Planned rotation of disinfectants §  Needed steps to avoid contamination of pharmaceutical products by disinfectant §  Need for residual bactericidal activity
  36. 36. Disinfectant Selection -Other Factors to Consider §  Quality, sterility, and stability of product §  Ease of application §  Cleaning ability §  Supporting vendor documentation §  Cost and availability §  Factors that may affect performance (temp., organic matter, contact time, pH, etc…) §  Regulatory expectations/regulations
  37. 37. Current regulatory expectationsfor use of disinfectants §  Disinfectants Qualification v  Studies to evaluate the effectiveness of the disinfectants as they are used and prepared v  Studies to evaluate the storage conditions of disinfectants for possible loss of efficacy v  Use of environmental isolates in the qualification studies v  Neutralization studies
  38. 38. Disinfectant Qualification- Studies In-Situ §  Use actually cleaning procedures §  Monitoring pre and post cleaning at worst-case conditions/ document activities §  Increased number of sample sites §  Compare EM data before & after In-Vitro §  Surface Tests (use of coupons or pieces of equipment/ material) §  Carrier Tests (AOAC method) §  Use-Dilution Tests (modified AET )
  39. 39. Disinfectant Qualification -Studies Typical Test Organisms §  Escherichia coli - ATCC 8739 §  Pseudomonas aeruginosa - ATCC 9027 §  Staphylococcus aureus - ATCC 6538 §  Bacillus subtilis - ATCC 6633 §  Candida albicans - ATCC 10231 §  Aspergillus niger - ATCC 16404 §  Environmental isolates
  40. 40. Disinfectant Qualification Surface Test §  Preferred method by inspectors §  No guidance document available §  Must select types of surfaces (coupons) §  Variable microbial challenge level §  Quantitative method §  Must select contact times (1-5-10 minutes) §  Variable test conditions (wet vs dry) §  Sampling/recovery technique (swab, rinse, contact plate) §  Need neutralization studies
  41. 41. Disinfectant Qualification -User’s Approach/Decisions §  Type of agent and materials/surfaces and sites to be evaluated. §  Testing protocol (In-vitro vs In-situ) §  Types of challenge organisms §  Contact times §  Sampling methods (swab, rinse, or contact plate)
  42. 42. Disinfectant Qualification -Acceptance Criteria §  Surface Tests v  ≥ 3-log reduction vegetative bacteria and fungi v  ≥ 2-log reduction spore-forming bacteria §  Use-Dilution Tests v  ≥ 4-log reduction (disinfectant properties) v  ≥ 6-log reduction (sporicidal properties) §  Carrier Test v  AOAC criteria §  In-situ Test v  counts not to exceed alert levels
  43. 43. Part 4:Environmental MonitoringProgram
  44. 44. Monitoring andTrending §  Establish an EM program §  Employee training and monitoring §  Enforce personal hygiene §  Enforce cGMPs §  Schedule regular PMs §  Product bioburden testing/trending §  Re-qualification vs on-going verification of cleaning (bioburden and endotoxin) §  Change control
  45. 45. EM Program§  Regulatory requirement§  Must be tailored to a facility§  Must be manageable and efficient§  Must be well documented§  Must be defendable§  Must not add possible sources of contamination into the environment§  Do not rely solely on EM data for assurance of product quality
  46. 46. EM Program EM is a tool to assist a company manage the microbiological control program
  47. 47. EM Program Choice of Equipment§  Active vs passive§  Air and surface monitoring devices§  Detection of potential problems must be done in a timely manner§  Sampling activities should not contribute to contamination of the process
  48. 48. EM Program Test Methods §  EM procedures must be qualified §  Use same methods used during qualification studies §  Viable and non-viable monitoring §  Use of specific media for fungi: is it really needed? §  Monitoring for anaerobes: is it really needed? §  Levels are established based on industry guidelines and/or historical data
  49. 49. EM Program Frequency and Sites §  Depends on area being monitored §  More intensive monitoring for “cleaner” areas §  Usually frequency is reduced once qualification is complete §  Trend towards continuous monitoring §  Site selection: depends on room design, activities, equipment and personnel flow
  50. 50. EM Program Data Management §  Results are retrospective §  Useful information can be obtained by trending data §  Evaluate data based on Alert and Action Levels §  Identify isolates §  Frequent isolates should be maintained and used in challenge studies
  51. 51. EM Program - Hot Topics §  EM data linked to batch release EC Annex 1, 5 “Where aseptic operations are performed, monitoring should be frequent… Results from monitoring should be considered when reviewing batch documentation for finish product release…” §  EM requirements for non-sterile operations §  Use of PAT and Rapid Methods
  52. 52. EM Program – Focus ofRegulatory Inspections §  Create presentation describing program v  area classifications v  methods v  frequency v  rationale for choice of sites v  rationale for setting alert and action levels v  describe data management and trending §  Create trend reports for each area v  tabular and graphical format v  trend by values and organisms §  Create executive summary reports v  address deviations, adverse trends, CAPA
  53. 53. Thank You!! 53