Fundamental of cleaning validation

www.julphar.net Gulf Pharmaceutical Industrieswww.julphar.net Gulf Pharmaceutical Industries
CLEANING VALIDATION
Know – How of an Effective Cleaning Program
Quality Assurance
Presented By :
Vishal Katiyar

www.julphar.net Gulf Pharmaceutical Industries
Cleaning Validation……………. At a glance
After completing this session we’ll come to know :
 Definition
 Purpose
 Cleaning mechanisms
 Cleaning agents
 Cleaning Methods
 Cleaning parameters
 Cleaning continuum
 Grouping strategies
 Worst Case considerations
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Quality Assurance
 Acceptance criteria
 Sampling Methods
 Analytical Methods
 Hold time studies

Cleaning Validation………… The definition
The process of removing contaminants from
process equipment and monitoring the
condition of equipment such that the equipment
can be safely used for subsequent product
manufacturing.
Dustin A. Leblanc.
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Quality Assurance

Cleaning Validation…………........... Purpose
 Product integrity
Cross contamination
Microbial integrity
Product impurity
Batch integrity
Equipment reuse
Regulatory issues
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Quality Assurance

Cleaning Validation……Cleaning Mechanisms
The chemistry of contaminant removal :
Solubility
Wetting
Emulsification
Physical removal
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Quality Assurance

Solubility :
Solubility involves the dissolution of one chemical
(the contaminant) in a liquid solvent.
For example, salts may be soluble in water, and
certain organic actives may be soluble in acetone or
methanol.
One of the primary cleaning mechanisms to be
considered during design phase.
Rate of solubility, Insoluble form, Soluble –
Insoluble species
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Quality Assurance

Wetting :
Wetting involves the displacement of one fluid from a
solid surface by another fluid. Wetting can be improved
by the addition of surfactants.
It improve penetration of the cleaning solution into
cracks and crevices, which are usually difficult-to
clean locations.
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Courtesy: Validated Cleaning Technologies for Pharmaceutical Manufacturing, D. A. LeBlanc Quality Assurance

Emulsification :
Breaking up an insoluble liquid residue into smaller
droplets and then suspending those droplets throughout
the water.
Emulsion = Mechanical energy + Surfactants / Polymers.
Emulsions are thermodynamically unstable (say, 5 to 10
mins.).
Redeposition of the cleaned residue back onto the
equipment surfaces.
Agitation should be continued till the time to discharge
the cleaning solution to the drain.
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Quality Assurance

Physical Removal:
Cleaning by some mechanical force. the objective
is to physically displace the residue.
Pressurized water + Scrubbing
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In real life situation, more than
one cleaning mechanisms are
being used.
Quality Assurance

Cleaning Validation………….Cleaning Agents
Cleaning Agents
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Aqueous Cleaning Organic Solvents
Water Surfactants
Quality Assurance
Detergents (citrus terpenes)

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Cleaning Validation……….Cleaning Agents
Organic
Solvents
• Acetone
• Methanol
• Ethyl Acetate
Surfactants
• SLS
• Fatty acid salts
Solvents
(miscible)
• Glycol Ethers
Bases
• NaOH
• KOH
Acids
• Glycolic
Acid
• Citric Acid
Oxidants
• NaOCl
• H2O2
Quality Assurance

Cleaning Validation……….Cleaning Methods
Automated Cleaning:
o Fixed CIP
o Portable CIP
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Manual Cleaning:
Soak
Brush
Wipe
Spray
Extent of automation……………..Extent of disassembly
Quality Assurance

Fixed CIP :
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Quality Assurance

Cleaning Validation…….Cleaning Methods
Portable CIP :
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Quality Assurance

Parts Washer :
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Ultrasonic Washer :
Quality Assurance

Cleaning Validation……Cleaning Parameters
 Time
 Action
 Cleaning chemistry
 Concentration
 Temperature
 Mixing / flow / turbulence
 Water quality
 Rinsing
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Quality Assurance

Parameter interactions :
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Cleaning Validation……Cleaning Parameters
Time vs Concentration :
Temp. vs Concentration :
Courtesy: Validated Cleaning Technologies for
Pharmaceutical Manufacturing, D. A. LeBlanc
Quality Assurance

Parameter interactions :
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Cleaning Validation….……Cleaning Parameters
Time vs Temperature :
Time (min)
Courtesy: Validated Cleaning Technologies for
Pharmaceutical Manufacturing, D. A. LeBlanc
Quality Assurance

Cleaning Validation.……Cleaning Continuum
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Continuum represent the extremes in the range of operating
differences found within the industry.
The continuum should be used during the initial phases of
defining a cleaning validation program or during new
product development.
Manual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Automated Cleaning
COP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..CIP
Dedicated Equipment . . . . . . . . . . . . . Non-Dedicated Equipment
Product Contact Surfaces . . . . . . . Non-Product Contact Surfaces
Non-Critical Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Critical Site
Minor Equipment . . . . . . . . . . . . . . . . . . . . . . . . Major Equipment
Quality Assurance

Cleaning Validation……Cleaning Continuum
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Sterile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Non-Sterile
Solid Formulations . . . . . . . . . . . . . . . . . . . . . Liquid Formulations
Soluble . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Insoluble
Single Product Facility . . . . . . . . . . . . . . . Multiple Product Facility
Campaigned Production . . . . . . . . . Non-Campaigned Production
Simple Equipment Train . . . . . . . . . . . Complex Equipment Train
Quality Assurance

Cleaning Validation……Grouping Strategies
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"Grouping" is the concept of demonstrating that certain elements
of cleaning are of a similar type, and selecting one (or more)
representative object(s) on which to conduct the Cleaning
Validation (Cleaning Process Qualification).
Product grouping :
 Same manufacturing equipments being used.
 Same cleaning SOPs being followed.
 Similar formulations.
 Similar risk / therapeutic group.
Equipment grouping, Cleaning method grouping, Cleaning
agent grouping, …………….., etc.
Quality Assurance

Cleaning Validation.……Grouping Strategies
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Sr. No. Name of product Formulation
Cleaning
methods
Equipment
train
Risk /
Therap. class
1 Product A Tablet (FC) Method 1 Train A General
2 Product B Tablet Method 1 Train B General
3 Product C Parenteral Method 2 Train C Cytotoxic
4 Product D Tablet Method 3 Train B General
5 Product E Tablet (EC) Method 4 Train A General
6 Product F Parenteral Method 2 Train C Cytotoxic
7 Product G Tablet (FC) Method 1 Train A Cytotoxic
8 Product H Tablet Method 3 Train B General
9 Product I Tablet (EC) Method 4 Train A General
10 Product J Parenteral Method 2 Train C Cytotoxic
All products in a facility (hypothetical):
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Cleaning Validation……Grouping Strategies
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Cleaning
methods
Equipment
train
Risk /
Therap. class
Before Grouping :
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Cleaning Validation…….Grouping Strategies
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Cleaning
methods
Equipment
train
Risk /
Therap. class
After Grouping :
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Cleaning Validation…..Worst Case considerations
Once the product groups have been established, the next step is to
determine the so-called “worst case” representative of each group.
It is that member(s) who shows the highest challenge on
cleaning program.
Worst case product : Toxicity / solubility / Single Therapeutic
Dosage.
Worst case eq. train : Longest train.
Worst case equipment : Larger size equipment (identical design).
Worst case acc. criteria: Stringent acceptance criteria.
Hold time studies : Longest possible duration.
Campaign Mfg. : Highest possible nos. of batches.
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Quality Assurance

Cleaning Validation…..Worst Case considerations
There is no ‘hard & fast’ rule on worst case selection.
A good logic and science should always be used.
Grouping and worst case selection help to demonstrate
cleaning method robustness.
It smartly reduces the load from cleaning validation
program.
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Quality Assurance

Cleaning Validation……...Acceptance criteria
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How clean is clean ?
What are the bases of defining limits ?
What are the impacts of after cleaned residue ?
Human Drug CGMP Notes, 9:2, 2Q 2001 :
“Should equipment be as clean as the best possible method
of residue detection or quantification?”
Answer: “No,……absolute cleanliness is neither valuable
nor feasible…. It should be as clean as can be reasonably be
achieved, to a residue limit that is medically safe and that
causes no product quality concerns…………….” Quality Assurance

Three criteria :
 It should be scientifically justifiable.
 Pacifically achievable.
 Methodically verifiable.
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Possible types of limits :
 Visual
 Chemical
 Microbiological
 Endotoxin
Quality Assurance

Visual clean criteria :
GMPs require inspection for visual cleanness before manufacture.
Key items to consider :
o Angle of view
o Distance from equipment surface
o Lighting conditions
o Viewer’s knowledge
o Surface usually must be dry
Visual aids :
Additional lighting / Magnifying glass / Mirror / Fiber-optic
scope / UV light
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Quality Assurance

Application for visual limits :
A typical visual limit is NLT 4 μg / cm2.
“Visually clean” may not be enough by itself
 Potent drugs
 Microbial contamination
 Endotoxin
More suitable method for non-potent drug products and APIs.
PIC/S advocates spiked coupon study for determination
of visual inspection limits (and for training of
inspectors
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Quality Assurance

Chemical residue limits (Therapeutically or Toxicologically
safe criteria) :
 Therapeutic dose based criteria
Most suitable for drug product (finished product)
manufacturing facility.
 Toxicological criteria (Where Api STD Not Available)
Most suitable for active drug (API) manufacturing facility.
Where cleaning agents are used (other than water).
 10 PPM criteria
CGMP requirement widely applicable.
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Quality Assurance

Therapeutic dose based criteria :
Based on the assumption that 1/1000 part of therapeutic dose
does not have any clinical impact on human (animal) body.
Determination of MACO (Maximum Allowable Carryover) of
Product A (Previous) to Product B (Next)
STD (A) × BS (B) × SF
MACO = (unit of mass)
LDD (B)
Where, STD = Single Therapeutic Daily Dose (Product A – ACTIVE CONTENT),
BS = batch size (Product B), SF = safety factor and LDD and LRDD = Largest Daily
Dose (Product B – DRUG PRODUCT)
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Step 1
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Determination of Surface contamination (Shared Equipment)
MACO
L1 = (mass / surface area)
TSA
Where, TSA = Shared Equipment Total Surface Area (for both products)
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Step 2
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Step 3
Determination of Sampled residue (for swab sample)
L2 = L1 × Swab Area (mass / swab)
 STD value represents the ACTIVE drug content only.
e.g. 10 mg, the dose strength.
 LDD value represents the mass or volume of entire dose.
e.g. 250 mg three times a day.
 BS = batch size (Product B).
e.g. 150 kg. Quality Assurance

Safety Factors :
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Approach Approach Typically Applicable To
0.1 to 0.01 Topical products
0.01 to 0.001 Oral products
0.001 to 0.0001 Parenterals products
0.0001 to 0.00001 Research, investigational products
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Step 1
Therapeutic dose based criteria (an example) :
Determination of Maximum Allowable Carryover
10 mg × 150 kg × 0.001 × 1000000
(250 mg × 3)
= 2000 mg (MACO value)
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Step 2
Determination of Surface contamination level
2000 mg
3170 cm2
= 0.63 mg / cm2 (L1 value)
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Step 3
Determination of Swab residue
0.63 mg / cm2 × 100 cm2
= 63.00 mg / swab (L2 value)
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10 PPM criteria :
Based on the hypothesis that 10 parts of previous product is
therapeutically ineffective if presents in million parts of next
product.
Determination of MACO
10 × BS
MACO = (unit of mass)
1000000
Where, BS = batch size (smallest available batch size)
Then use and to derive final swab residue
limit. 45
Step 1
Step 3Step 2
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Cleaning Validation…………...Acceptance criteria
Step 1
10 PPM criteria (an example) :
Determination of MAC
10 × 150 kg × 1000000
MAC = = 1500 mg
1000000
The final Swab residue (L2) :
1500 mg × 25 cm2
3170 cm2
= 11.83 mg/swab
Quality Assurance

Toxicological criteria :
Based on the toxicological information available in Material Safety
Data Sheets.
Determination of NOEL (No Observed Effect Level)
NOEL = LD50 × Emperical Factor
(unit of mass/kg of body weight)
Where, LD50 = lethal dose for 50% of animal population in study (mg/kg/day),
Emperical Factor = derived from animal model developed by Layton, et.al : 0.001*
* Used by expert panel of WHO (10-3).
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Step 1A
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Determination of ADI (Acceptable Daily Intake)
ADI = NOEL × AAW × SF
(unit of mass)
Where, AAW = average adult weight : 70 kg,
SF = safety factor (0.01)
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Step 1B
 Consider average body weight of child where there is any
pediatric dose available.
 Use LD50 value of mice.
Quality Assurance

Determination of MAC (Maximum Allowable Carryover)
ADI × BS
MAC =
LRDD (any next product) (unit of mass)
Then use and to derive final swab residue
limit.
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Step 1C
Step 2 Step 3
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Step 1A
Toxicological criteria (an example) :
Determination of NOEL
(1750 mg /kg/day) × 0.001 = 1.75 mg/kg
(NOEL value)
Determination of ADI
(1.75 mg/kg) × 70 kg × 0.01 = 1.225 mg
(ADI value)
Step 1B
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Step 1C
Toxicological criteria (an example) :
Determination of MAC
1.225 mg × 150 kg × 1000000
(250 mg × 3)
= 245000 mg
The final Swab residue (L2) :
245000 mg × 25 cm2
3170 cm2
= 1932 mg/swab
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The most stringent acceptance criteria shall be chosen for
cleaning validation study (The worst case approach).
11.831932 63.00
mg / swab
In real life cases, therapeutic or 10 PPM criteria become final
acceptance criterion for cleaning validation. Quality Assurance

Microbiological criteria :
 Internal specifications
 Official specifications: e.g. USP <1111>, “Microbial
Examination of nonsterile Products: Acceptance criteria for
Pharmaceutical Preparations and Substances for Pharmaceutical
Use”
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Adminstration route TAMC Endotoxin
Oral 100 CFU/mL -
Liquid 20 CFU/mL -
Injectables 10 CFU/mL 0.25 Unit/mL
Quality Assurance

Determining acceptance criteria with more than one next
products (The Matrix approach):
52Quality Assurance
Product Name Active Ingredient STD[mg]
Toxicity
LD50 in mg/kg
Solubility In Water
PRODUCTS IN AMPOULES
Scopinal 20mg/mL
Hyoscine-N-
Butylbromide 20mg 18 mg/kg I.V. rat Freely Soluble
Premosan 10mg/2mL
Metoclopramide HCl
10mg 50 mg/kg I.V. rat Very Soluble
Cynovit Injection
1mg/mL
B12 –
Cyanocobalamin
(Code #1013012)
1mg 2000 mg/kg I.V. mouse Sparingly Soluble
Mikacin 100 mg/2 ml
Injection
Amikacin Sulphate
1mg
(Code#0101057)
210mg 4000 mg/kg I.V. rat Freely Soluble
Salurin Injection
20mg/2mL
Furosamide
(Code# 0106008)
20mg 800 mg/kg I.V. rat Not soluble
Rantag 50 mg/2 ml
Injection
Ranitidine HCL
(Code# 0118014)
25mg 85 mg/kg I.V. rat Very soluble

The sampling procedure refers to the method of collecting the
residues from the surface so that they can be measured.
Cleaning Validation…......Sampling Methods
Types Advantages Limitations
Swabs & Wipes
Dissolves & physically removes
sample, adaptable to wide variety
of area
May introduce fibers,
technique dependent, hard-to-
reach areas
Rinse
Easy, quick, non-intrusive, large
surface area
Limited information about
actual surface cleanliness
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Quality Assurance

 Swab sampling techniques:
(1) One of the most widely used technique for chemical and
microbial sampling.
(2) Swabs are being wet with solvent aiding solubilization and
physical removal of surface residues.
(3) Results are technique dependent.
Cleaning Validation…......Sampling Methods
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Microbial swab (sterile) Chemical swabs (Texwipe) Cotton wipes
Quality Assurance

(5) Generally 1 swab sample per location is adequate.
(6) Multiple swabs can be taken to improve surface recovery.
(7) Typical swabbed per site varies from 25 cm2 to 100 cm2. There
is no “magic” number.
(8) PTFE (chemically inert) templates may be used for accurate
swabbing area. e.g. (Teflon)
(9) “Difficult to clean” equipment surfaces
shall be identified and sampled.
(10) Representative surfaces of different
materials (MOCs) should be sampled.
Cleaning Validation……......Sampling Methods
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10 cm
10 cm
Swab area
templates
Quality Assurance

(11)10 Nos. Wiping should be unidirectional at a time. Parallel
strokes should be employed to cover entire swab area.
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Courtesy: Validated Cleaning Technologies for Pharmaceutical Manufacturing, D. A. LeBlanc
Quality Assurance

Example of “Difficult to clean” locations of an RMG:
57
Courtesy: Rapid mixer granulator, Kevin.
The design aspect of the equipment should be considered to
identify “difficult to clean” locations. Quality Assurance

 Rinse sampling techniques:
Rinse sampling involves using a liquid to cover the surfaces to be
sampled.
(1) One of the easy and widely used sampling method.
(2) Most preferable liquid for rinsing is water.
58Quality Assurance

 Specific vs non-specific methods:
(1) A non-specific assay may detect a variety of residues.
(2) A specific assay may quantify any anticipated residue.
(3) It is essential to correlate the results from a specific method to
the results from other non-specific methods that might be
used for routine monitoring of cleaning effectiveness.
Cleaning Validation……Analytical Methods
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HPLC pH meter
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Specific Test Methods Non-Specific Test Methods
UV/Visible Spectrophotometry
Near Infrared Spectrophotometry
(NIR)
High Performance Liquid
Chromatography (HPLC)
Mid Infrared Spectrophotometry (MIR)
Atomic Absorption
Capillary Zone Electrophoresis
Enzyme Linked Immunosorbant Assay
(ELISA)
Total Organic Carbon (TOC)
pH
Titration
Conductivity
Gravimetric
Quality Assurance

The analytical methods used for testing cleaning samples
must be validated for [ICH Q2 (R1)]:
 Limit of Detection (LOD)
 Limit of Quantification (LOQ)
 Specificity
 Accuracy
 Repeatability
 Precision
 Range
 Linearity
 Recovery
63Quality Assurance

 The analytical method used for evaluation of cleaning sample is
different that used for product assay.
 If the target limit in the analytical sample were 5.2 μg / mL,
and a method was only able to detect down to 7.0 μg / mL,
that method would not be useful for cleaning validation
purposes.
 The target value should be within the linearity range
of the specific method.
What if the calculated acceptance value is
less than the detectable level of an
analytical method?
There may be two options available……….
64Quality Assurance

Choose more efficient analytical method !
Example:
Derived acceptance limit = NMT 4.0 μg / mL
Analytical LOQ = 5.5 μg / mL
Analytical Method = UV/Visible Spectrophotometry
New method adopted = Ion mobility spectrometry
New LOQ = 2.0 μg / mL
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Quality Assurance

Increase the sampling area to achieve at least LOQ
value!
Example:
Derived acceptance limit = NMT 4.0 μg / mL
Analytical LOQ = 5.5 μg / mL
Swab area = 25 cm2
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Revised swab area =
25 cm2
4.0 μg / mL
× 5.5 μg / mL
= 35 cm2 (7 cm × 5 cm)Quality Assurance

Recovery studies :
Procedure :
o Spike coupon with known amount
o Allow to dry
o Remove in swab or simulated rinse procedure
o For swab, desorb
o Analyze sample
o Compare to expected 100% value
This is done at surface acceptance (or below) limit.
Cleaning Validation………Analytical Methods
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Quality Assurance

Swab recovery schematic :
Cleaning Validation…………Analytical Methods
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1. Spike control diluent directly
Control
B μg/mL
Control
C μg/mL
Standard
solution
A μg/mL 2a. Spike
coupon
2b. Swab
coupon
2c. Extract swab
Quality Assurance

Recovery calculation 1 (Spiked against Standard):
(C μg/mL) × (Conc. of standard mL)
% Recovery = × 100
(A μg/mL) × (Conc. of Sample mL)
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 Recovery depends on spiked standard of known concentration.
Recovery depends on material surface, sampling method and
some what on analytical method.
Quality Assurance

Recovery calculation 2 (Spiked against Positive control) :
(C μg/mL) × (mL)
% Recovery = × 100
(B μg/mL) × (mL)
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 More useful if defined standard is not readily available.
Swab recover study with multiple analysts :
 Usually 3 replicates by one sampler.
 Use lowest value of any one run.
Quality Assurance

Rinse recovery schematic :
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Pipette with
rinse solution
(known volume)
Spiked
coupon
Collection beaker
Spike bottom
of SS beaker
Lab shaker
Case 1 Case 2
Quality Assurance

Minimum acceptable recovery:
 Specify in cleaning validation master plan or master protocol.
 Minimum swab recovery of 70 % - 80 %.
 Carry out recovery study for different material surfaces
(Material Of Constructions).
 Chose right wetting solvent (soluble) and absorbent swab
material to improve recovery.
 May allow <50 % recovery with written justification.
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Quality Assurance

o DEHT = Max. allowed time, between end of usage and
employing cleaning
o CEHT = Max. allowed time, between end of cleaning and
further usage
Cleaning Validation………………Hold Times
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Hold Time studies
Cleaned Equipment
Hold Time (CEHT)
Dirty Equipment
Hold Time (DEHT)
Quality Assurance

Dirty equipment hold time study (DEHT) :
 Soils may become more difficult to clean over time.
 Maximum DEHT should be in SOPs.
 Maximum time shall be set in conjunction with production.
 Representative / worst case product can be selected for study.
 Equipments support wet processing can be selected.
 If extra cleaning is desirable, then it should be in SOP.
 May be expressed in days but preferably by hours.
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Cleaning Validation……………Hold Times
Quality Assurance

Dirty equipment hold time study (DEHT) :
Method
 Carry out microbiological sampling at 24 hr., 48 hr., 36 hr., …...
from the dirty equipments.
 Clean the equipments as per SOPs.
 Carry out chemical sampling after cleaning.
 Compile all results (chemical and microbial).
 Successful results shall standardize the maximum DEHT.
 Failure of any results shall reduce the max. DEHT followed by
another 3 verification runs.
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Quality Assurance

Cleaned equipment hold time study (CEHT) :
 Microbiological evaluation is the key focus area.
 Maximum CEHT should be in SOPs.
 Representative / worst case product can be selected for study.
 Vitamins, nutritional supplements, product containing Starch or
Gelatin may represent worst cases.
 Protection during storage of cleaned equipments should be as
per SOPs.
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Quality Assurance

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Cleaned equipment hold time study (CEHT) :
Method
 Clean the equipments as per SOPs.
 Store under protection (as per routine procedure).
 Carry out microbiological sampling at 24 hr., 48 hr., 36 hr., …...
 Verify the results against limit (less than validation limit).
 Successful results shall standardize the maximum CEHT.
 Failure of any results shall reduce the max. CEHT followed by
another 3 verification runs.
 Do not set max. CEHT on “until failure” basis.
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Campaign hold study (CHS) :
 Cleaning after production of definite number consecutive
batches.
 Negotiate with production related to number of batches.
 Simulate max. anticipated hours of campaign production.
 Cumulative deposition of residues may accelerate product
degredation.
 Perform cleaning and sampling at the end of campaign.
 Max. CHS (no. of batches + time) should be in SOPs.
 Batch to batch or lot to lot cleaning is advisable.
 More suitable for dedicated product equipments.
Quality Assurance

Cleaning Validation……....All aspects of CV
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Courtesy: Biopharm international
Quality Assurance

Swab
Recovery
Study
Rinse
Recovery
StudyDeciding
Sampling
Points
Cleaning Limit
(Swab/Rinse)
Method
Validation
Swab Sample
Sampling
Rinse Sample
Hold
Time
Study
Clean Hold
Time
Dirty Hold
Time
MACO
Calculation
Dose Base
Criteria
10 ppm
Criteria
Testing
API Testing Microbial
Testing
Non-Specific
Testing
Single Therapeutic Dose
Toxicity
Solubility
Calculation Surface Area of
product contact equipment
Requirements
Conclusion
CLEANING VALIDATION
MASTER PLAN + SOP
Worst Case
Product Matrix approach
+
Equipment Train
Cleaning
Validation
Protocol
Product Identified
Cleaning
Validation
Report
Cleaning Validation....Julphar aspects of CV
Quality Assurance

Cleaning Validation……USFDA 483 Citations
Cleaning Parameters
“….. cleaning of ….. has not been validated, nor is the
spray temperature, volume or time defined.”
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Quality Assurance

Time of Cleaning
“Equipment cleaning is performed on a “clean until
clean” basis. There has been no determination of the
number of cleanings required to ensure the
cleanliness of the equipment.”
81Quality Assurance

Manual Cleaning
“Hands on training for equipment cleaning operations
is not provided and there is no program in place to
assure cleaning consistency between operators.”
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Quality Assurance

Cleaning Log
“There is no assurance that cleaning is conducted as
stated in their SOPs…… There are no cleaning
logs to indicate that this has been done.”
83Quality Assurance

Poor Cleaning
“….. we observed foreign material on the filter
grates….. Daily cleaning as per SOP…..failed to
remove the material. End of process cleaning as per
SOP…..failed to remove the material. Weekly
cleaning as per SOP……failed to remove the
material.”
84Quality Assurance

Detergent Concentration
“Detergent is dispensed into the ……Stopper Washer
reservoir every third cycle. No data has been
collected to determine the detergent concentration
each cycle…..”
85
Quality Assurance

Cleaning Agent Labeling
“The firm’s control over IPA 100% used to clean
equipment in production is inadequate. …..bottles
are not labeled…..with date, expiration or who
dispensed, ….no scientific information….which
would establish an expiration date…..”
86Quality Assurance

Acceptance Limit
“….. acceptance criteria….shall not exceed…..μg/cm2.
There is no data to justify this limit.”
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Quality Assurance

Sampling Locations
“Swabbing was performed on general contact areas
without taking into consideration area such as edges
and crevices.”
88Quality Assurance

Sampling Locations
“Exact / precise swab locations are not identified.”
89
Quality Assurance

Swab Sampling
“Swab samples collected…..from different locations
from each piece of equipment are combined into
one sample and tested such.”
90Quality Assurance

Rinse Sampling
“….firm’s validation…..is inadequate in that the rinse
solutions were not analyzed for the presence of the
active ingredient residues that might be present.”
91
Quality Assurance

Rinse Sampling
“There is not an exact sampling procedure for the
collection of rinse water samples which takes into
account the surface area involved, time of
contact….., volume of rinse, and temperature of
rinse, along with a formula to calculate the
amount of possible contamination based on
analysis.”
92
Quality Assurance

Dirty Equipment Hold Time
“No time frames / limitations have been established
for production equipment from end of use to start
cleaning.”
93
Quality Assurance

Cleaned Equipment Hold Time
“A time limit for the length of time allowed between
cleaning and the use of the manufacturing
equipment…..has not been established.”
94Quality Assurance

Recovery Studies
“Equipment cleaning validation studies for…..did not
include…..present recovery studies on rinse
samples.”
95Quality Assurance

Recovery Studies
“…..each drug’s recovery test was performed only
once, therefore there is no data to show
reproducibility.”
96
Quality Assurance

Recovery Studies
“Your firm is using the average of recovery results
(from different amounts of spiked solution) instead
of the worst case result. Using a value that
represents the average does not ensure that
contamination is not higher than calculated.”
97Quality Assurance

Change Control
“The SOP has been revised twice. No review was
performed to determine if a re-validation was
necessary for the changes……”
98
Quality Assurance

Cleaning Validation……….......................???
Quality Assurance

Cleaning Validation

Fundamental of cleaning validation

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