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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
Mr. Sultan Jawa (MD, Irza Pharma, Lahore) Last Sunday &
Mr. Masroor Hassan (Production Manager, Hudson Pharma, Karachi) Yesterday
May Allah give them
eternal success
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
I
S
C
L
A
I
M
E
R
Machines are fast, accurate and dumb
People are slow, sloppy and brilliant
Albert Einstein
Opening Message
P A R E N T E R A L S
IV
IM
IG
SC
.
.
.
When life is everything
Risk
Horrible sometimes …
Good Luck
Cannot swim itself
Cannot move itself
Good Luck
Sensitive to heat
Sensitive to radiation
Sensitive to chemicals
Challenges
Aerobe
Facultative aerobe
Anaerobe
Challenges
Spore formation
Thermophilic
Mesophilic
Challenges
Water borne
Air borne
Human
Challenges
Skill to handle
Knowledge
Ability
Way to kill
Approach to kill
When calculated risk is the only option
Each and every caution is indispensible
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
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
Heat
sensitive
Unstable to
temperature
Towards stringent control, not otherwise
Compendial requirements are the minimum standards
Where we have an option to choose
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
Freedom from Road Blocks
Come out from traditional
approach of intellectual block
Be proactive in using technical
knowledge
Live safe and keep moving
forward
What happens if there is fire ?
Alarm React
Glass
breaking
Etc. etc.
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
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
Sample Limitations
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
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
Take an area as an example of challenge
• 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
ORAL CAVITY
High population
High diversity
SKIN
Variable population
Low diversity
URETHRA/VAGINA
High population
Low diversity
GUT
High population
High diversity
People
Ecology
Others that contribute a lot
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
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
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
Diclofenac Sodium Injection
Diclofenac Sodium Injection
Innovator uses terminal sterilization
Diclofenac Sodium Injection
Innovator uses terminal sterilization
Generic ????????
A
Is it consistent with science to opt aseptic filling ?
1 2 3 4 5 6 7 8 9 10
Yes No
B
Is impurity not the subject of interest ?
1 2 3 4 5 6 7 8 9 10
Yes No
C
Should impurity be included in release specifications ?
1 2 3 4 5 6 7 8 9 10
Yes No
D
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
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
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
Become wise and proactive
Don’t wait for any human tragedy
Read the wall ….
Good ideas are not adopted automatically.
They must be driven into practice with
courageous patience
Admiral H.G. Rickover
Closing Message
Thanks
oarohama@gmail.com

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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 I S C L A I M E R
  • 5. Machines are fast, accurate and dumb People are slow, sloppy and brilliant Albert Einstein Opening Message
  • 6. P A R E N T E R A L S IV IM IG SC . . .
  • 7. When life is everything Risk
  • 9. Good Luck Cannot swim itself Cannot move itself
  • 10. Good Luck Sensitive to heat Sensitive to radiation Sensitive to chemicals
  • 16. When calculated risk is the only option Each and every caution is indispensible
  • 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
  • 20. Towards stringent control, not otherwise
  • 21. Compendial requirements are the minimum standards
  • 22. Where we have an option to choose
  • 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
  • 32. Take an area as an example of challenge
  • 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
  • 40. Diclofenac Sodium Injection Innovator uses terminal sterilization
  • 41. Diclofenac Sodium Injection Innovator uses terminal sterilization Generic ????????
  • 42. A Is it consistent with science to opt aseptic filling ? 1 2 3 4 5 6 7 8 9 10 Yes No
  • 43. B Is impurity not the subject of interest ? 1 2 3 4 5 6 7 8 9 10 Yes No
  • 44. C Should impurity be included in release specifications ? 1 2 3 4 5 6 7 8 9 10 Yes No
  • 45. D
  • 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