From Red to Green: Enhancing Decision-Making with Traffic Light Assessment
From Terminal Sterlization to Aseptic Manufacturing of Perentral Products: Gut Sound of Regulatory Sciences
1. From Terminal Sterilization to
Aseptic Manufacturing of Parenteral Products
Gut Sound of Regulatory Sciences
Obaid Ali
R.Ph., M. Phil., Ph. D.
Civil Services Officer
02 June 2016
Arena, Karachi
2.
3. Mr. Sultan Jawa (MD, Irza Pharma, Lahore) Last Sunday &
Mr. Masroor Hassan (Production Manager, Hudson Pharma, Karachi) Yesterday
May Allah give them
eternal success
4. Not the view of DRAP
Current judgment of speaker
No obligation on DRAP
Regulatory experience
It has nothing to do
with any specific
commercial product
or organization
It is just a knowledge
sharing exercise
nothing more than
that
D
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5. Machines are fast, accurate and dumb
People are slow, sloppy and brilliant
Albert Einstein
Opening Message
17. If something has not happened yet, it will likely not happen
Design may be flawed, but there is no evidence that there is
a problem
If something has not been identified by inspector, it is ok
Passing the media fill assures process control
Lets correct, it is misconception
18. Sterility test has not yet failed but reason of pass is not
defendable
We are complying and it is enough, no matter what you are
referring
Traditional approach is a good approach
Insulin was filled in an area under exhaust fans in history
Lets correct, it is misconception
23. Aseptic processing proven safe but not sterile
IncreasedseparationofPersonnel
Increased confidence in Sterility Assurance
Manual aseptic fill
Conventional aseptic fill
Barrier System
Open RABS
Closed RABS
Open Gloved Isolator
Closed Glove Isolator
Glove-less Isolator
24.
25. Freedom from Road Blocks
Come out from traditional
approach of intellectual block
Be proactive in using technical
knowledge
Live safe and keep moving
forward
26. What happens if there is fire ?
Alarm React
Glass
breaking
Etc. etc.
27. Have a Fundamental Stroke ….
“ Leadership is essential to establish and maintain a
company wide commitment to quality and for the
performance of the Pharmaceutical Quality System”
ICH Q10
28. So have an overview
“ An effective risk management program aids in the careful
control of process, reducing the risk of contamination as
well as wasted efforts in controlling insignificant risk”
Risk management of Aseptic Processing,
Ed White, 2009
30. Detection sensitivity (n = 20 samples)
Microorganism
Concentration
Probability of one Sterility
test positive (+)
1.0 1.0
0.1 0.88
0.01 0.18
0.001 0.02
10-6 1.9x10-5
18% of time, not 82% of time
31. Sterility is very difficult to prove
Microorganisms are not homogenously distributed over all units
Sample
Size
% Contamination
0.1 1 5 10 15
10 0.01 0.09 0.40 0.66 0.80
20 0.02 0.18 0.65 0.89 0.96
50 0.05 0.34 0.92 0.99
100 0.09 0.63 0.99
300 0.26 0.95
3000 0.95
33. • Protects body from pathogens
• Prevents loss of moisture
• Body temperature regulation
2m2
• Considerable diversity in species
• Variation b/w different locations on body
• Variation b/w individuals
Diversity
• Average person sheds 1 billion skin cells/ day
• 10% have micro-organisms on them30 million
Human Skin
Go in clean rooms They touch, shed, do things wrong sometimes
34. ORAL CAVITY
High population
High diversity
SKIN
Variable population
Low diversity
URETHRA/VAGINA
High population
Low diversity
GUT
High population
High diversity
People
Ecology
36. Clean room requirements are demanding when stringent
particulate control and aseptic conditions are required
during manufacturing
This requirement applies in particular to filling lines
located in HEPA filtered UDAF. In such cases, turbulent
regions and wakes can play critical roles by causing an
accumulation of contaminants
Bengt & Berit, 2004
Just for the sake of reference
37. Just for the sake of reference
Engineers design and install
Validation department executes validation
Production department performs production
Maintenance department performs maintenance
Quality Control performs tests
Quality Assurance reviews and approves
38. Just for the sake of reference
Microorganisms unique to your facility and operation
Personnel and material flow
Air flow pattern evaluations
Observation of aseptic filling operation
Environmental monitoring sample site selection
46. Lets be honest
Risk management encourages proactive rather than
reactive, management of product processing and is
a means to end itself
Quality Risk Management for Aseptic Processing
PDA Technical Report No. 22, Vol. 62, No. S-1, 2008
47. Lets be honest
Rigorous thinking is involved with logical,
systematic and science based approaches to
improve the effectiveness and efficiency of
decision making
Quality Risk Management for Aseptic Processing
PDA Technical Report No. 22, Vol. 62, No. S-1, 2008
48. Lets be honest
The goal of Quality Risk Management program
should be to better understand the process and
improve the process, thereby assuring patient
safety
Quality Risk Management for Aseptic Processing
PDA Technical Report No. 22, Vol. 62, No. S-1, 2008
49. Become wise and proactive
Don’t wait for any human tragedy
Read the wall ….
50. Good ideas are not adopted automatically.
They must be driven into practice with
courageous patience
Admiral H.G. Rickover
Closing Message