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Risk Assessment for Intervention
Scoring in Relation to Aseptic
Processing | IVT
By
Tim Sandle, Ph.D.
Aseptic processing is arguably the most 'at risk' pharmaceutical process in terms of
microbiological contamination (1). This is because the final point in the production
process is during filling, stoppering and capping and oversealing. Because of the
nature of the product, after these activities have taken place the product cannot be
subjected to any sterilization process. Thus, excluding concerns with the sealed
container and container closure integrity issues, if microbial contamination enters at
the filling stage no other process steps can be undertaken to remove or destroy the
contaminant.
Product protection exists by using a sterile filtered product and the use of
depyrogenated glassware and sterile stoppers. In addition, the activity of filling takes
place within an ISO class 5 (EU GMP Grade A) localized airflow. With the clean air
zone, additional protection exists through the use of isolator technology, which adds
a complete barrier and stops the risks associated with personnel intervention from
occurring (2).
Each human intervention is a risk, because people are the primary source of
microbial contamination and personnel activities and behavior are the hardest to
control. No intervention carries a zero risk and it follows that interventions are not a
good thing; thus every opportunity, through good design, appropriate machine set-
up, and efficient machine running, should be taken to avoid them from happening
during a filling run (4).
While there are control mechanisms in place, most importantly the direction and
velocity of the airflow (which needs to be confirmed by an airflow visualization
study), together with personnel training (glove sanitization and using sterile
implements to avoid direct touching of components), risks from interventions will be
ever present. In assessing risks, the standard verification tool of environmental
monitoring is too limited to give complete assurance (due to the limitations
pertaining to the metrology of the methods) (5). There is a touch of irony that some
of the interventions are the very act of environmental monitoring.
While each aseptic intervention carries a risk, it is down to the aseptic processing
manager and the microbiologist to agree the level of risk. This requires three
questions to be addressed. First: are all interventions of equal risk?; secondly, how
can multiple interventions be evaluated? And thirdly, at what point does a further
intervention become one ingression into the aseptic core too many? Those tasked
with running aseptic filling lines or reviewing the filling runs for batch release need
to be confident that these questions have been posed and answered. This paper
presents one possible approach through which these questions can be answered. This
is through a risk scoring system.
Certain medicinal products need to be sterile at the point where they are introduced
to the patient by injection. This is because this mode of drug delivery bypasses the
body's natural defenses. Because of this, the administration of many biologics carries
a higher risk of infection being introduced to the patient compared with, say, an oral
drug product. Sterile drug products can be manufactured using two techniques:
terminal sterilization or aseptic processing. With terminal sterilization, the product
in its final container is subject to a final sterilization processes. This ordinarily
involves heat or irradiation.
Interventions
Interventions in any aseptic process should be far and few between. Quality Risk
Management (QRM) and Quality by Design (QbD), as two key regulatory initiatives,
should lead to the development of processing systems where interventions become a
rarity.
For other barrier systems, while gloveports are the norm, older style machines exist.
Even with gloveport equipped barrier systems, the need for an occasional
intervention arises (6). The risks associated with such interventions require
evaluating, through both airflow visualization studies (7) and media simulation fills
(8). In relation to this, the FDA aseptic filling guidance emphasizes that the
"evaluation of the impact of aseptic manipulations (e.g., interventions)" is required
(9).
"Any intervention or stoppage during an aseptic process can increase the risk of
contamination. The design of equipment used in aseptic processing should limit the
number and complexity of aseptic interventions by personnel."
Where interventions are required, the activity produces several factors that need to
be considered and evaluated:
b) Does the risk change should multiple interventions be performed in a given filling
run?
c) Ho many interventions can be performed before the risk becomes too great and
consideration needs to be given to terminating the filling run?
This paper presents an approach to evaluate the risks stemming from interventions.
Intervention risks
Microbial risks will arise from air (with microorganisms carried on particles, like skin
detritus) and from direct transfer (such as from the gloved hands of personnel). The
opportunities for microorganisms to enter a product vial or land onto a critical
surface relate to the factors of dispersion, transfer and deposition (11). To an extent,
such risk factors can be modeled and then designed out through assessing assess the
transfer of contamination from all of the sources within the cleanroom area that
could impact upon the aseptic zone; and then assessing both air and surface contact
contamination from these areas within the aseptic zone.
To help with post-filling evaluations, Whyte and Eaton have outlined a number of
useful equations. For example, to assess the overall risk of microbial contamination
of a product (12):
Where:
S = the quantity of surface material, or air, that is dispersed, from a source in a given
time (cm2 /s for surfaces, and cm3 /s for air dispersion); this can also be expressed
as the quantity dispersed per frequency of occurrence;
P = proportion of microorganisms in the adjacent area that are deposited per unit
a
T = time, during which transfers occur(s); this can also be expressed as frequency of
occurrence.
However, what about during the filling operation? When does the risk from
interventions present a problem for the continuation of filling? The paper presents
an intervention scoring approach.
Where filling machine doors are opened, the exposed vial(s) should be identified (or
marked up) and included in the sterility test set. Most sterility test failures are the
result of a personnel intervention (13).
Additionally, the operators should take finger plates, this allows an assessment to be
made of any contamination transfer from operator to critical surface to be made.
Importantly, all interventions mist documented. Such information is necessary for
the final batch review.
Intervention scoring
The use of a numerical score not only allows for a decision to be made as to the
relative and absolute risk of any intervention, it also allows different filling
operations to be compared and trended if necessary. The use of a numerical score
also allows a cut-off value to be applied. A cut-off value is a score which, when
exceeded during the filling runs, indicates to the filling team that a decision is
required whether filling should continue.
The first step in developing an intervention scoring system is to devise the numerical
ranges. Once developed, different types of interventions can be assigned.
The scoring system used in the example weights each intervention based on the
perceived contamination risk to product or product components. The greater the risk
then the higher the score assigned. The risk scores used are in multiples of 5, with 0
being of minimal risk, up to 30 for the highest risk. Of course, other scoring systems
can be selected. This is detailed in the table below:
Table 1: An example intervention scoring system
The above scoring system was based on accounting for three factors:
1. The location within the filling machine where the intervention takes place. Here it
is recognised that different parts of the filling machine pose different risks to exposed
vials.
The point of fill, for example, presents a bigger risk of contamination ingress than a
partially stoppered vial.
2. The height at which the intervention takes place relative to working height. Here,
working height, which is equivalent to the product vial, presents a bigger risk than a
height below the vial. This is because below the vial the unidirectional airflow is more
likely to sweep contamination away.
In relation to points '1' and '2' above, some aseptic processing managers adopt the
terms 'critical' and 'non-critical' interventions in relation to height and position. By
this, it can be inferred:
Critical intervention: when the body/ glove is exposed above (within vertical
unidirectional air- flow) open vials/ hopper / product contact surfaces and disrupts
unidirectional air flow. Actions in response may include line clearance.
Non-critical intervention: the gloves or body parts are not disrupting the
unidirectional air flow. It is performed with sterile tools above the open vials/ above
hopper/ product contact surfaces; stopper bag addition, bulk container addition.
While these differences are important, the phrases 'critical' and 'non-critical' can
detract from the potential risk that any intervention presents to the process.
3. Time and complexity taken to complete the intervention. This informs whether an
intervention is classed as a major (of more complexity or taking a relatively longer
time) or minor (undertaken within a short time or of a relatively less complex
nature).
In assigning scores, the use of tools, such as using or not using forceps to remove a
vial, is not addressed since such activities are undertaken by using gloveports and
they are classed as manipulations. With developing scores, especially in relation to
time and complexity, useful information can be obtained from media fills, such as
from the viewing of digitally recorded footage (14).
Following this, the scoring system can be matched up with different types of
interventions. This is presented in Table 2 below. Table 2 takes the intervention score
table and pairs the score options with common types of interventions. A rationale for
the score selection is also provided, in the end column.
Code
Justification
Intervention
type
Routine
task
Single
intervention score
of score
Placement of air A Y 0 This activity has not been
sampler assigned a score because it takes
place during every filling
operation (once or twice at
defined locations depending
upon the length of the fill). The
activity is practiced during each
media trial. Therefore, cters
pribus (Latin for other things
being equal); it is not
considered to be a variable risk.
Justification
Intervention
type
Routine
task
Single
intervention score
of score
a variable risk.
Justification
Intervention
type
Routine
task
Single
intervention score
of score
settling of any viable particles.
To date both the finger plates and
the media trial settle plates have
been satisfactory and do not
suggest a significant risk from
this intervention.
A major
intervention may
require a re-set up
of the machine and
all of the
appropriate
environmental
monitoring to be
undertaken.
All interventions
will be assessed by
a review of
Code
Justification
Intervention
type
Routine
task
Single
intervention score
of score
microbiological
data post fill (a
review of
intervention finger
plates and exposed
settle plates)
Justification
Intervention
type
Routine
task
Single
intervention score
of score
Removal of H N 5 This intervention relates to a
jammed manual intervention into the
stoppered bottles filling machine. A member of
(outside of point- staff will use a sterile implement
of-fill area) (such as forceps) to make an
adjustment or to remove an
object (such as a vial).
Justification
Intervention
type
Routine
task
Single
intervention score
of score
Typically this activity would take
less than five minutes and the
line would be cleared. The
activity is also practiced during a
media trial (provided that the
activity has taken place within
the last six-months during the
filling run, in relation to the
specific filling line).
Justification
Intervention
type
Routine
task
Single
intervention score
of score
adjustment or to remove an
object (such as a vial).
Justification
Intervention
type
Routine
task
Single
intervention score
of score
component (such activity could potentially take
as a stopper place close to a critical product
bowl). surface, such as, the point of fill
or stopper bowl.
Justification
Intervention
type
Routine
task
Single
intervention score
of score
(intervention Q) a score of
twenty is given. This is a higher
score than intervention N
because of the long time taken to
complete this intervention
(typically longer than ten
minutes) and because the weights
used are not sterilised (although
they would be sanitised).
Justification
Intervention
type
Routine
task
Single
intervention score
of score
critical machine contact parts
(such as filling needles); because
the activity could potentially take
place close to a critical product
surface, such as, the point of fill
or stopper bowl; and because the
operator may need to work inside
the filling machine and could be
taking the machine apart, thereby
exposing additional surfaces.
Therefore, it was considered that
a score of twenty was of
insufficient proportion given the
nature of the task and thirty
points was awarded.
Justification
Intervention
type
Routine
task
Single
intervention score
of score
be opened to be changed. This is a relatively
low risk activity (due to this
activity being practiced for
media trials) and it is assigned a
score of 10.
Table 2 has presented the scoring system alongside different types of interventions.
The majority of these are corrective interventions, undertaken to allow the filling run
to continue. Such interventions will ideally have been practiced during media filling
trials and the way that each is performed should be described in an SOP and
appropriate training given to the operators (15).
With the above list, a cut-off value needs to be assigned. This is the total score from a
series of interventions taken to constitute a significant enough risk that filling should
be suspended. This is something that needs to be decided internally. Based on Table
2, a score of somewhere between 50 and 60 might be appropriate (although this
should not be taken as absolute),
Summary
Where possible interventions should be avoided and any intervention presents a risk.
While this paper presents a risk scoring system, the approach should not be used to
discuss away the fact that interventions should be avoided. Nor should the approach
be used to assume all interventions have been perfectly executed. All operators are
capable of carrying out the most basic intervention badly, and the lower scores
presented in the table should only be taken following a review of a video recording of
the operation (all aseptic filling operations should ideally be digitally captured).
These issues noted, the paper has considered interventions in relation to aseptic
filling. While all interventions carry risks, the risks will vary according to the nature
of the operation and where within the filling machine the intervention occurs.
Furthermore, the more interventions undertaken the greater the risk presented to
the filling operation. Here the idea of an accumulative score over time develops. To
add to this, it is sensible to have a cut-off value - a point where, if exceeded, a
decision should be made to continue filling. Exceeding the cut-off value should not
simply be accepted, even if the risk to filled product is considered to be low.
Mechanical problems with the operation of filling machines should be addressed,
through continuous improvement initiatives, and measures put in place to prevent
repeat occurrences.
The paper has illustrated this by way of a case study example. The example has been
prepared for illustrative purposes only and it is not applicable to every filling
operation (each filling operation differs and, more importantly, each ISO class 5 /
Grade A clean zone is not identical in its design, performance or capability).
However, it can provide the basis for others to construct their own intervention
scoring system along similar lines.
References