This document discusses cleaning validation requirements from a regulatory perspective. It provides an overview of key concepts in cleaning validation including establishing health-based exposure limits and determining maximum allowable carryover levels. A risk-based approach using bracketing and worst-case determination is recommended. Common deficiencies observed include inadequate hazard assessment, lack of justification for cleaning approaches, and failure to revalidate cleaning when processes change. International GMPs are incorporating guidelines for setting health-based exposure limits to ensure contamination risks are properly managed.
The presentation was an overview of the GMP regulations specific to cleaning validation for medicine manufacturers. New guidelines for Health Based Exposure Limits were discussed along with common GMP deficiencies observed during TGA inspections.
Validation: Validation is a documented program that provides high degree of assurance that a specific process, method or system consistently produces a result meeting pre-determined acceptance criteria.
The presentation was an overview of the GMP regulations specific to cleaning validation for medicine manufacturers. New guidelines for Health Based Exposure Limits were discussed along with common GMP deficiencies observed during TGA inspections.
Validation: Validation is a documented program that provides high degree of assurance that a specific process, method or system consistently produces a result meeting pre-determined acceptance criteria.
Webinar: Is Phase-Appropriate Validation the Right Choice for your Cell or Ge...Merck Life Sciences
Participate in the interactive webinar now: http://bit.ly/CGTWebinar
This webinar will introduce phase-appropriate validation and why it may be advantageous for cell and gene therapy development. We will also describe how validated platform assays can help you meet your critical development timelines.
Explore our webinar library: www.merckmillipore.com/webinars
Validation is the process of checking of the process, equipment and method whereas qualification is solely done for equipment and qualification of instrument helps in quality of pharmaceutical product.
This presentation covers the manufacture and testing of all sterile drug products, including drugs that are sterilized by filtration or other means and aseptically processed, and drug products that are terminally sterilized. The type of products covered include sterile bulk drugs, ophthalmic drugs, otic dosage forms, small volume parenteral (SVS) products for small molecule and licensed biological
therapeutic drug products, large volume parenteral (LVP) products, and any other drug products required to be sterile or labeled as sterile. Center for Biologics Evaluation and Research (CBER) regulated products and veterinary drug products are excluded from coverage under this program.
The guidance information is tailored to sterile manufacturing operations and should be used in conjunction with the Compliance Program for Drug Manufacturing Inspections (CP 7356.002).
In this presentation from CPhi 2014, Elise Gallais outlines the guidelines for cleaning validation: and focuses on analytical methods and their validation.
In this slide contains definition, importance, benefits of annual product review.
Presented by: Ravi Sanker babu .D.V (Department of pharmaceutical analysis and quality assurance).
RIPER, anantapur.
Bioburden Validation Strategy for Cleaning Validationangelsalaman
This presentation is based on the article published by Pharmaceutical Technology (USA) entitled “BIOBURDEN METHOD SUITABILITY FOR CLEANING AND SANITATION MONITORING: HOW FAR WE HAVE TO GO?”, Aug 2010. by Angel L. Salaman-Byron
This presentation consist a consolidated list all Regulatory Guidelines for Cleaning Validation. Hyperlink of the applicable guidelines are also given in the presentation.
Webinar: Is Phase-Appropriate Validation the Right Choice for your Cell or Ge...Merck Life Sciences
Participate in the interactive webinar now: http://bit.ly/CGTWebinar
This webinar will introduce phase-appropriate validation and why it may be advantageous for cell and gene therapy development. We will also describe how validated platform assays can help you meet your critical development timelines.
Explore our webinar library: www.merckmillipore.com/webinars
Validation is the process of checking of the process, equipment and method whereas qualification is solely done for equipment and qualification of instrument helps in quality of pharmaceutical product.
This presentation covers the manufacture and testing of all sterile drug products, including drugs that are sterilized by filtration or other means and aseptically processed, and drug products that are terminally sterilized. The type of products covered include sterile bulk drugs, ophthalmic drugs, otic dosage forms, small volume parenteral (SVS) products for small molecule and licensed biological
therapeutic drug products, large volume parenteral (LVP) products, and any other drug products required to be sterile or labeled as sterile. Center for Biologics Evaluation and Research (CBER) regulated products and veterinary drug products are excluded from coverage under this program.
The guidance information is tailored to sterile manufacturing operations and should be used in conjunction with the Compliance Program for Drug Manufacturing Inspections (CP 7356.002).
In this presentation from CPhi 2014, Elise Gallais outlines the guidelines for cleaning validation: and focuses on analytical methods and their validation.
In this slide contains definition, importance, benefits of annual product review.
Presented by: Ravi Sanker babu .D.V (Department of pharmaceutical analysis and quality assurance).
RIPER, anantapur.
Bioburden Validation Strategy for Cleaning Validationangelsalaman
This presentation is based on the article published by Pharmaceutical Technology (USA) entitled “BIOBURDEN METHOD SUITABILITY FOR CLEANING AND SANITATION MONITORING: HOW FAR WE HAVE TO GO?”, Aug 2010. by Angel L. Salaman-Byron
This presentation consist a consolidated list all Regulatory Guidelines for Cleaning Validation. Hyperlink of the applicable guidelines are also given in the presentation.
Cleaning validation for the 21 th century pharmaceutical onlineEmma Aguinaga
This eBook is a collection of articles written from May of 2017 through August 2018 and are part of the cleaning validation for the "Cleaning Validation for teh 21 st Century" series.
Challenges using Multiple Single-use Systems: Functionality versus Extractabl...MilliporeSigma
As single-use technologies continue to expand in pharmaceutical manufacturing processes, the risk assessment for extractables and leachables becomes increasingly complex. Join this webinar to obtain guidance on how to perform risk evaluation on a process with multiple single-use components.
A Single-Use System (SUS) is typically designed for a specific process step. In many cases, single-use components are chosen based on their functionality. The challenge arises when there are multiple processing steps-- as the different applications and product matrices are evaluated, the complexity of the risk assessment increases. Complexity includes component evaluation, process conditions, and model solvents streams which ultimately relates to the patient safety risk.
This webinar will evaluate the different single-use components with respect to compatibility and extractables and leachables. A case study will be used to demonstrate the complexity and potential concerns when performing a risk evaluation on the manufacturing process.
In this webinar, you will learn:
- Risk assessment of extractables
- Single-use component evaluation
- Complexity when evaluating multiple assemblies
Challenges using Multiple Single-use Systems: Functionality versus Extractabl...Merck Life Sciences
As single-use technologies continue to expand in pharmaceutical manufacturing processes, the risk assessment for extractables and leachables becomes increasingly complex. Join this webinar to obtain guidance on how to perform risk evaluation on a process with multiple single-use components.
A Single-Use System (SUS) is typically designed for a specific process step. In many cases, single-use components are chosen based on their functionality. The challenge arises when there are multiple processing steps-- as the different applications and product matrices are evaluated, the complexity of the risk assessment increases. Complexity includes component evaluation, process conditions, and model solvents streams which ultimately relates to the patient safety risk.
This webinar will evaluate the different single-use components with respect to compatibility and extractables and leachables. A case study will be used to demonstrate the complexity and potential concerns when performing a risk evaluation on the manufacturing process.
In this webinar, you will learn:
- Risk assessment of extractables
- Single-use component evaluation
- Complexity when evaluating multiple assemblies
this presentation contains information about HACCP implementation in food industry. with example, easy to understand comment below how is this presentation
Title: Sense of Taste
Presenter: Dr. Faiza, Assistant Professor of Physiology
Qualifications:
MBBS (Best Graduate, AIMC Lahore)
FCPS Physiology
ICMT, CHPE, DHPE (STMU)
MPH (GC University, Faisalabad)
MBA (Virtual University of Pakistan)
Learning Objectives:
Describe the structure and function of taste buds.
Describe the relationship between the taste threshold and taste index of common substances.
Explain the chemical basis and signal transduction of taste perception for each type of primary taste sensation.
Recognize different abnormalities of taste perception and their causes.
Key Topics:
Significance of Taste Sensation:
Differentiation between pleasant and harmful food
Influence on behavior
Selection of food based on metabolic needs
Receptors of Taste:
Taste buds on the tongue
Influence of sense of smell, texture of food, and pain stimulation (e.g., by pepper)
Primary and Secondary Taste Sensations:
Primary taste sensations: Sweet, Sour, Salty, Bitter, Umami
Chemical basis and signal transduction mechanisms for each taste
Taste Threshold and Index:
Taste threshold values for Sweet (sucrose), Salty (NaCl), Sour (HCl), and Bitter (Quinine)
Taste index relationship: Inversely proportional to taste threshold
Taste Blindness:
Inability to taste certain substances, particularly thiourea compounds
Example: Phenylthiocarbamide
Structure and Function of Taste Buds:
Composition: Epithelial cells, Sustentacular/Supporting cells, Taste cells, Basal cells
Features: Taste pores, Taste hairs/microvilli, and Taste nerve fibers
Location of Taste Buds:
Found in papillae of the tongue (Fungiform, Circumvallate, Foliate)
Also present on the palate, tonsillar pillars, epiglottis, and proximal esophagus
Mechanism of Taste Stimulation:
Interaction of taste substances with receptors on microvilli
Signal transduction pathways for Umami, Sweet, Bitter, Sour, and Salty tastes
Taste Sensitivity and Adaptation:
Decrease in sensitivity with age
Rapid adaptation of taste sensation
Role of Saliva in Taste:
Dissolution of tastants to reach receptors
Washing away the stimulus
Taste Preferences and Aversions:
Mechanisms behind taste preference and aversion
Influence of receptors and neural pathways
Impact of Sensory Nerve Damage:
Degeneration of taste buds if the sensory nerve fiber is cut
Abnormalities of Taste Detection:
Conditions: Ageusia, Hypogeusia, Dysgeusia (parageusia)
Causes: Nerve damage, neurological disorders, infections, poor oral hygiene, adverse drug effects, deficiencies, aging, tobacco use, altered neurotransmitter levels
Neurotransmitters and Taste Threshold:
Effects of serotonin (5-HT) and norepinephrine (NE) on taste sensitivity
Supertasters:
25% of the population with heightened sensitivity to taste, especially bitterness
Increased number of fungiform papillae
New Directions in Targeted Therapeutic Approaches for Older Adults With Mantl...i3 Health
i3 Health is pleased to make the speaker slides from this activity available for use as a non-accredited self-study or teaching resource.
This slide deck presented by Dr. Kami Maddocks, Professor-Clinical in the Division of Hematology and
Associate Division Director for Ambulatory Operations
The Ohio State University Comprehensive Cancer Center, will provide insight into new directions in targeted therapeutic approaches for older adults with mantle cell lymphoma.
STATEMENT OF NEED
Mantle cell lymphoma (MCL) is a rare, aggressive B-cell non-Hodgkin lymphoma (NHL) accounting for 5% to 7% of all lymphomas. Its prognosis ranges from indolent disease that does not require treatment for years to very aggressive disease, which is associated with poor survival (Silkenstedt et al, 2021). Typically, MCL is diagnosed at advanced stage and in older patients who cannot tolerate intensive therapy (NCCN, 2022). Although recent advances have slightly increased remission rates, recurrence and relapse remain very common, leading to a median overall survival between 3 and 6 years (LLS, 2021). Though there are several effective options, progress is still needed towards establishing an accepted frontline approach for MCL (Castellino et al, 2022). Treatment selection and management of MCL are complicated by the heterogeneity of prognosis, advanced age and comorbidities of patients, and lack of an established standard approach for treatment, making it vital that clinicians be familiar with the latest research and advances in this area. In this activity chaired by Michael Wang, MD, Professor in the Department of Lymphoma & Myeloma at MD Anderson Cancer Center, expert faculty will discuss prognostic factors informing treatment, the promising results of recent trials in new therapeutic approaches, and the implications of treatment resistance in therapeutic selection for MCL.
Target Audience
Hematology/oncology fellows, attending faculty, and other health care professionals involved in the treatment of patients with mantle cell lymphoma (MCL).
Learning Objectives
1.) Identify clinical and biological prognostic factors that can guide treatment decision making for older adults with MCL
2.) Evaluate emerging data on targeted therapeutic approaches for treatment-naive and relapsed/refractory MCL and their applicability to older adults
3.) Assess mechanisms of resistance to targeted therapies for MCL and their implications for treatment selection
MANAGEMENT OF ATRIOVENTRICULAR CONDUCTION BLOCK.pdfJim Jacob Roy
Cardiac conduction defects can occur due to various causes.
Atrioventricular conduction blocks ( AV blocks ) are classified into 3 types.
This document describes the acute management of AV block.
Couples presenting to the infertility clinic- Do they really have infertility...Sujoy Dasgupta
Dr Sujoy Dasgupta presented the study on "Couples presenting to the infertility clinic- Do they really have infertility? – The unexplored stories of non-consummation" in the 13th Congress of the Asia Pacific Initiative on Reproduction (ASPIRE 2024) at Manila on 24 May, 2024.
Pulmonary Thromboembolism - etilogy, types, medical- Surgical and nursing man...VarunMahajani
Disruption of blood supply to lung alveoli due to blockage of one or more pulmonary blood vessels is called as Pulmonary thromboembolism. In this presentation we will discuss its causes, types and its management in depth.
Explore natural remedies for syphilis treatment in Singapore. Discover alternative therapies, herbal remedies, and lifestyle changes that may complement conventional treatments. Learn about holistic approaches to managing syphilis symptoms and supporting overall health.
Tom Selleck Health: A Comprehensive Look at the Iconic Actor’s Wellness Journeygreendigital
Tom Selleck, an enduring figure in Hollywood. has captivated audiences for decades with his rugged charm, iconic moustache. and memorable roles in television and film. From his breakout role as Thomas Magnum in Magnum P.I. to his current portrayal of Frank Reagan in Blue Bloods. Selleck's career has spanned over 50 years. But beyond his professional achievements. fans have often been curious about Tom Selleck Health. especially as he has aged in the public eye.
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Introduction
Many have been interested in Tom Selleck health. not only because of his enduring presence on screen but also because of the challenges. and lifestyle choices he has faced and made over the years. This article delves into the various aspects of Tom Selleck health. exploring his fitness regimen, diet, mental health. and the challenges he has encountered as he ages. We'll look at how he maintains his well-being. the health issues he has faced, and his approach to ageing .
Early Life and Career
Childhood and Athletic Beginnings
Tom Selleck was born on January 29, 1945, in Detroit, Michigan, and grew up in Sherman Oaks, California. From an early age, he was involved in sports, particularly basketball. which played a significant role in his physical development. His athletic pursuits continued into college. where he attended the University of Southern California (USC) on a basketball scholarship. This early involvement in sports laid a strong foundation for his physical health and disciplined lifestyle.
Transition to Acting
Selleck's transition from an athlete to an actor came with its physical demands. His first significant role in "Magnum P.I." required him to perform various stunts and maintain a fit appearance. This role, which he played from 1980 to 1988. necessitated a rigorous fitness routine to meet the show's demands. setting the stage for his long-term commitment to health and wellness.
Fitness Regimen
Workout Routine
Tom Selleck health and fitness regimen has evolved. adapting to his changing roles and age. During his "Magnum, P.I." days. Selleck's workouts were intense and focused on building and maintaining muscle mass. His routine included weightlifting, cardiovascular exercises. and specific training for the stunts he performed on the show.
Selleck adjusted his fitness routine as he aged to suit his body's needs. Today, his workouts focus on maintaining flexibility, strength, and cardiovascular health. He incorporates low-impact exercises such as swimming, walking, and light weightlifting. This balanced approach helps him stay fit without putting undue strain on his joints and muscles.
Importance of Flexibility and Mobility
In recent years, Selleck has emphasized the importance of flexibility and mobility in his fitness regimen. Understanding the natural decline in muscle mass and joint flexibility with age. he includes stretching and yoga in his routine. These practices help prevent injuries, improve posture, and maintain mobilit
These lecture slides, by Dr Sidra Arshad, offer a quick overview of physiological basis of a normal electrocardiogram.
Learning objectives:
1. Define an electrocardiogram (ECG) and electrocardiography
2. Describe how dipoles generated by the heart produce the waveforms of the ECG
3. Describe the components of a normal electrocardiogram of a typical bipolar leads (limb II)
4. Differentiate between intervals and segments
5. Enlist some common indications for obtaining an ECG
Study Resources:
1. Chapter 11, Guyton and Hall Textbook of Medical Physiology, 14th edition
2. Chapter 9, Human Physiology - From Cells to Systems, Lauralee Sherwood, 9th edition
3. Chapter 29, Ganong’s Review of Medical Physiology, 26th edition
4. Electrocardiogram, StatPearls - https://www.ncbi.nlm.nih.gov/books/NBK549803/
5. ECG in Medical Practice by ABM Abdullah, 4th edition
6. ECG Basics, http://www.nataliescasebook.com/tag/e-c-g-basics
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4. Cleaning validation
“Cleaning validation is documented evidence that an approved cleaning
procedure will reproducibly remove the previous product or cleaning
agents used in the equipment below the scientifically set maximum
allowable carryover level”
PIC/S Guide to GMP for Medicinal Products; Annex 15 Qualification & Validation
RACI & CAPSIG - August 2017 3
5. Current GMP requirements
– GMPs not prescriptive - allowing flexibility and adoption of
new technologies/science.
PE009-8 Section
Part I Personnel, Premises & Equipment,
Documentation, Production, Quality Control,
Contract Manufacture & Analysis
Part II Personnel, Buildings & Facilities, Process
equipment / cleaning, Materials management,
Production & Process controls, Packaging
Cleaning validation, Contract manufacturers,
Repackaging
APIs by cell culture/fermentation
Annexes 1, 2, 3, 6, 7, 8, 9, 10, 13, 15
RACI & CAPSIG - August 2017 4
6. GMP developments
• PIC/S cGMP – PE009-13
– Annex 15
– Annexes 2 & 3
– Part II - Implementation of QRM
– Part I Chapter 3
– Part I Chapter 5
– Annex 1
• PIC/S adoption of setting health
based exposure limit guidelines
(EMA)
RACI & CAPSIG - August 2017 5
7. Key concepts
Health Based Exposure Limits (HBELs)
• A daily dose of a substance below which no adverse effects are anticipated, by
any route, even if exposure occurs for a lifetime.
• Required for cleaning validation of hazardous products in shared facilities.
• Derived from a structured scientific evaluation of relevant data.
EMA/CHMP/CVMP/SWP/169430/2012
RACI & CAPSIG - August 2017 6
8. No Observable Adverse Effect Level (NOAEL)
• NOAEL must be established for all critical effects identified
• The NOAEL is the highest tested dose at which no adverse effect is observed
• If NOAEL is not calculable, the lowest-observed-effect level (LOEL) may be used
• Determined by toxicological expert
RACI & CAPSIG - August 2017 7
9. PDE or ADE?
• Permitted Daily Exposure (PDE) represents a substance-specific dose that is
unlikely to cause an adverse effect if an individual is exposed at or below this
dose every day for a lifetime
• Acceptable Daily Exposure (ADE) represents a dose that is unlikely to cause
an adverse effect if an individual is exposed, by any route, at or below this dose
every
PDE and ADE are effectively synonymous
RACI & CAPSIG - August 2017 8
10. MACO - Maximum Allowable Carryover
Mathematically calculated quantity of residue from a previous product when carried
over into a different product that CAN represent potential harm to the patient.
• toxicity/pharmacology
• mode of administration
• batch size
• shared equipment surface area plus a safety factor
RACI & CAPSIG - August 2017 9
11. Risk-based approach
• Health Based Exposure Limits
• Good knowledge management (ICH Q10)
• Risk based approach (ICH Q9)
Risk assessments for operations
Cross contamination strategy links to protection of patient
Shared facilities - scientific approach to ensure contamination risks are managed appropriately
RACI & CAPSIG - August 2017 10
12. Bracketing for cleaning validation
• Groups typically based on:
– Equipment train
– Cleaning procedure
– Dosage Form
• Rationale explained in SOP or Cleaning Validation document
• Groupings from which ‘worst-case’ will be selected
• Any product that does not conform to ‘bracket’ must be validated individually
RACI & CAPSIG - August 2017 11
14. Worst-case process conditions
• Campaign length (no. of batches or time elapsed)
• Dirty Hold Time
• Minimum limits for manual cleaning:
Time for Cleaning Steps
Temperature
• CIP programs
RACI & CAPSIG - August 2017 13
15. Establishing health based exposure limits
Step 1: Hazard Identification
Hazard
HLD50r
HCarcinogenicityr
HGenotoxicityr
HMechanism of
Action
HRepeat-dose
toxicityr
HReproductive
toxicityr
HDevelopmental toxicityr
RACI & CAPSIG - August 2017 14
16. Establishing health based exposure limits
Step 2: “Critical Effects”
• Clinical & non-clinical studies
• Therapeutic effects
• Adverse effects
Step 3: Determine NOAEL
• Based on Step 1 and 2 evaluation
• Requires toxicological expertise
• Defined as mg/kg/day
RACI & CAPSIG - August 2017 15
17. Establishing health based exposure limits
Step 4: Calculate PDE
NOAEL: Expressed as mg/kg/day
Weight Adjustment: 50 kg
F1: A factor (values between 2 and 12) to account for extrapolation between species
F2: A factor of 10 to account for variability between individuals
F3: A factor 10 to account for repeat-dose toxicity studies of short duration
F4: A factor (1-10) that may be applied in cases of severe toxicity
F5: A variable factor that may be applied if the no-effect level was not established.
PDE (mg/day) =
NOAEL x Weight Adjustment
F1 x F2 x F3 x F4 x F5
RACI & CAPSIG - August 2017 16
18. ADE approach
NOAEL: Expressed as mg/kg/day
Weight Adjustment: 50 kg - 60 kg
UFc: Composite Uncertainty Factor similar to F1-F5 in PDE formula
MF: Modifying Factor
PK: Pharmacokinetic Adjustments
ADE (mg/day) =
NOAEL x Weight Adjustment
UFc x MF x PK
RACI & CAPSIG - August 2017 17
19. MACO determination
PDE: Obtained in Step 4
MBSnext: Min. Batch Size
SF: Safety Factor
TDDnext: Standard Therapeutic Daily Dose (mg/day)
MACO (mg) =
PDE x MBSnext
SF x TDDnext
Safety factors:
Topicals 10 - 100
Oral products 100 - 1000
Parenterals 1000 - 10000
RACI & CAPSIG - August 2017 18
21. Revalidation requirements
• Introduction of new “worst-case” product
• Change in “product contact” equipment
• Change in bracketing approach
̵ Validation should be assessed for impact
• Annex 15 (PE009-13)
̵ Continuous process verification
̵ Effectiveness of manual cleaning should be confirmed at a justified frequency
RACI & CAPSIG - August 2017 20
22. Microbiological risks
• Annex 15 (PE009-13)
– More prescriptive clauses for cleaning validation
– Microbial and endotoxin contamination risks
• Appropriate sampling method
– Represents “worst-case” locations
– Trained personnel
– Sample handling before testing
• Validated Test Methods
– Acceptable recovery
– Objectionable organisms
RACI & CAPSIG - August 2017 21
23. Observed practices
Good Contamination Control Practices
• Documented Contamination Control Strategy
• Relies on good knowledge management (ICH Q10)
• Risk based approach (ICH Q9)
– Risk assessments for operations
– Cross contamination strategy links to protection of patient
– Shared facilities - methods follow scientific approach to ensure contaminants and contamination risks are
understood and managed appropriately.
• Guidance documents:
– APIC “Guidance on Aspects of Cleaning Validation in API Plants” (2014)
– ISPE Baseline® Guide - Risk MaPP
– PDA TR 29 “Points to Consider for Cleaning Validation” (2009)
RACI & CAPSIG - August 2017 22
24. Common inspection deficiencies
Deficiency categorisation:
• Assessment of intrinsic hazards
presented by the products/processes
• Design of facilities, utilities, equipment
and processes
• Controls to address hazards
– Technical and organisational controls
• Periodic review
RACI & CAPSIG - August 2017 23
25. Assessment of intrinsic hazards - issues
Poor assessment of molecules handled by the
facility:
• Limited or no data from product sponsor
• No clear policies on what products are manufactured
in which areas
• Generic evaluation of risks presented by substances
Deficient assessment of processes:
• No risk assessment for new processes
• Campaign practices implemented without due
validation
RACI & CAPSIG - August 2017 24
26. Assessment of intrinsic hazards - issues
There was no completed risk assessment in place to justify the current operation of the facility
as a shared use, multi-product facility. It was noted that the lines and rooms used for the
production of XXXXX were also used for the production of other cytotoxics, steroids, analgesics
and non-β-lactam antibiotics in injectable forms. In addition, the site product range included
hormonal products, e.g. methyl progesterone.
RACI & CAPSIG - August 2017 25
27. Assessment of intrinsic hazards - issues
The validation of all cleaning processes for all products and equipment trains used by the
manufacturer was based on the cleaning validation of a single liquid product only, (“Product X”)
Product X is a flammable liquid product, and the applicability of this specific cleaning validation
exercise to the cleaning of powder, granule, tablet, cream, ointment and other liquid processes had
not been scientifically established, justified and documented by the manufacturer.
• The written instructions for the cleaning of equipment used in the liquids manufacturing areas, differed to that
in the solids manufacturing areas; the methods were not equivalent.
• The limits for allowable residues of Product X were based on a 10ppm carry over into the smallest flammable
liquids batch size. It was not possible to extrapolate this calculated limit to other product types or
equipment trains.
• Product X was a topical product, and the assessment of allowable carry over did not consider the route of
administration for other dosage forms or product types.
RACI & CAPSIG - August 2017 26
28. Design of processes - issues
In relation to cleaning validation:
• There was no risk assessment or justification available to outline the manufacturer’s current approach to
cleaning validation.
• The cleaning validation of the line 2 lyophiliser had been conducted based on the removal of sodium
chloride only; multiple active cytotoxic materials were processed in the common lyophilisers.
• For the cleaning validation of XXXX, the locations for residue swabbing in the mixing vessel were not
regarded as worst case or hard to clean surfaces. Other areas of the vessel, that were regarded by the
inspector as being more difficult to clean, such as inlet ports, sample valves and under the impellor were not
tested.
• Cleaning validation had not been performed on the glass “Schott” bottles used for API slurry formulation;
these bottles were not labelled as dedicated to a specific active.
RACI & CAPSIG - August 2017 27
29. Design of Processes - issues
In relation to the existing cleaning validation studies XX & YY:
• The existing cleaning validation for the facility was limited to the AAA and BBB machines only; it was not
apparent as to how the cleaning studies were applicable to other equipment trains
• There was no cleaning validation study available for liquids/creams
• There was no clearly defined cleaning method for the study; the cleaning SOP used at the time of the
validation (Version 1) did not contain sufficient details regarding the specific cleaning methods used.
(Also Clause 4.4)
• The cleaning agent used at the time of the validation was “XXXX” but the manufacturer now uses “YYYY” it
was not clear as to whether these solutions were equivalent.
RACI & CAPSIG - August 2017 28
30. Design of processes - issues
In relation to the existing cleaning validation study:
• The surface area calculation was limited to the filling line equipment only, and did not include
the upstream of filling process (i.e. formulation) equipment train
• The study for the effective removal of detergent residues did not reflect the current practices used
in manufacturing as the concentration of the detergent was not defined in the cleaning process
RACI & CAPSIG - August 2017 29
31. Design of facility / processes - issues
In relation to the proposed cleaning validation study:
• The protocol did not include consideration of product contact parts used in the
manufacture of dosage forms, e.g. plastic jugs, bowls and sieves used in the manufacturing
area
• The cleaning method described in the procedure did not provide detail regarding the soak
times or method of mechanical removal of residues
• Specific swabbing locations (worst case) within equipment trains were not clearly defined
and justified; e.g. locations were identified as “hopper” or “perforated plate”
RACI & CAPSIG - August 2017 30
32. Lack of appropriate controls - issues
• The procedure for label issue (SOP 123) stated that labels for the powders batches
(penicillins) were to be placed in a grey box and secured. The majority of the boxes
used for label issue to the non-penicillin area were grey, and the mechanism to
ensure that boxes that had accessed the penicillin building were not used
in the general facility was not apparent
RACI & CAPSIG - August 2017 31
33. Lack of Appropriate Controls - issues
The cleaning record for the paclitaxel compounding area indicated that the room
was clean; however the inspector observed:
• A large pool of standing water was observed on the floor
• White powder residue was observed around the balances
• White residue was observed on the floor in the area
RACI & CAPSIG - August 2017 32
34. Lack of appropriate controls - issues
Re-usable equipment for CYTOTOXIC was stated to be dedicated, however the
inspector observed that:
• Although the filling needles and carboy siphon tubes were marked, these filling needles and carboy siphon
tubes were stored mixed up with needles and siphon tubes for other products
• Although the Equipment Preparation List for CYTOTOXIC stated “use CYTOTOXIC dedicated equipment” the
records available did not demonstrate that CYTOTOXIC dedicated equipment was used, and the system
in place did not clearly demonstrate that CYTOTOXIC dedicated equipment was controlled in a manner to
ensure that the dedicated equipment was not used for the manufacture of other products
• The flasks used for the collection of CYTOTOXIC flush and priming solutions were not dedicated to
CYTOTOXIC
RACI & CAPSIG - August 2017 33
35. Ineffective periodic reviews - issues
The (cleaning) studies were last performed in 2007 and were based on the cleaning and carry-over
from PROD A capsules. The cleaning validation had not been modified or reconsidered in light of
new products or equipment introduced to the site since the completion of the study in 2007.
There was no available risk assessment of the current cleaning practices in light of the changes to
the product range manufactured on site, i.e. the process ability to effectively clean residues from
those additional products introduced into manufacturing since the 2007 study. (Also clauses 1.5 &
1.6)
A 2009 review of the cleaning validation study identified several issues with the 2007 study; issues
were noted regarding the swabbing methods used, as well as the spiking of samples. However,
those recommendations had not yet been actioned.
RACI & CAPSIG - August 2017 34
36. Summary
• International GMPs have incorporated HBELs approach to cleaning validation
• Knowledge management and transfer of information is key
• Will need expert advice in establishing PDE limits - sponsors play key role
• This change is important to maintaining patient safety
• Manufacturers and Sponsors need to remain vigilant regarding cleaning
validation
RACI & CAPSIG - August 2017 35