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Session 8. Documentation - PDF
Session 8. Documentation - PDF
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OUTLINE
Documentation
SOP’s
-Cleaning Protocol Report
Process Cleaning Cleaning
- Cleaning Validation Validation
Validation
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Cleaning Process
Standard Operation Procedure
Cleaning Process SOP consists of :
• Materials List with part numbers and descriptions ( tools , cleaning
agents )
• Responsibilities List on the step of :
– Preparation
– Cleaning
– Inspection
• Procedures
– Specific for each or categories of equipment
– Step-wise and sequenced
– Concise, clearly written in simple language, yet detailed
– Include T.A.C.T. (Time, Action, Concentration/Chemistry, Temperature)
– Reference distinct measures or metrics to determine achievement of
T.A.C.T. parameters
– Include documentation requirements
– Include diagrams for clarity
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Cleaning Process
SOP’s should include
• Preparation • Preparation of area, tools & cleaning agent
• Documentation • Status Tags, Checklists , Cleaning & Use Log
• Disassembly • Exploded diagrams or digital photos
• Cleaning • Step-Wise, Tools, TACT, Measures
• Completion • Cleaning of Tools, Baskets, Carts
• Inspection • Methods & Tools, Locations for Inspection
• Drying • Environment / Controls
• Wrapping / • Materials, Handling, Location
Covering /
Storage
• Post-Cleaning • Re-Tagging, Cleaning & Use Log
Documentation
• Equipment • Dating Requirements, Re-Cleaning Requirements
Expiration
• Pre-Use • Verification of Expiration, Integrity of Wraps / Covers
Inspection
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Cleaning Process
SOP Contents Peculiar to Cleaning
Validation
• Time after use before cleaning
• Maximum interruption within a cleaning process
(such as hold times after a pre-rinse or time before a final rinse)
• Time after cleaning before use
• Cleaning Frequency
(if tied to levels of cleaning such as major clean and minor clean)
• Elements Affecting Cleaning That Would Be Included
in Batch Records or Master Cleaning Policy
• Maximum number of batches and/or days in a
campaign
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Cleaning Process
Records for cleaning
• Batch Record-Like Format is preferred
• Enables formal review of cleaning procedures
• Enforces consistency between operators
• Enforces sequence of activities
• Captures accomplishment of T.A.C.T. through documented
completion of key steps, including:
– Preparation of cleaning agent
– Disassembly checklist
– Pre-rinse, Wash, Final Rinse
– Drying
– Inspection
– Covering and Storage
– Cleaning and Storage of Tools
• Captures start / stop times and critical process parameter
achievement
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Cleaning Process
Special Considerations for Sanitization
Procedures
• Cleaning steps must be completed prior to the application of the
sanitant
– Contact time with chemical sanitant is critical
– Method of application may need to be demonstrated to reliably
leave sufficient “liquid” on the surface to effect the sanitization
– Expiration dates for formulated sanitizers are particularly
important
• Aseptic techniques should be taught and practiced
• Other validation considerations:
– Sanitant efficacy must be demonstrated in the presence of
known residues from processing or cleaning at the levels that
are typically present after an effective cleaning procedure;
ensure the cleaning agent residues don’t inactivate the
sanitant
– Re-use of a sanitizing solution must be validated as they often 7
Cleaning Process
Challenges in Creating Effective SOPs
• Too tight vs Too loose control limits
– Excessive investigations
– Limited reproducibility
• Too much vs Too little detail
– Using clockwise 50cm circular motions and the amount of
pressure that it takes to see if a pineapple is ripe, wipe the white,
lint-free wipe 25 times then reverse to a counter-clockwise
motion in the same position for an additional 25 circles. When
complete, move 50cm to the left, repeat, it will take 125 - 50cm
circles to clean the full circumference at the top level, when the
full circumference has been wiped in this manner, move down
50cm and repeat for the next row …
– Rinse, wash, rinse
• Defining scope and applicability of SOP
• Determining extent of cross-referencing vs including documents /
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Cleaning Process
Tips for Evaluating Existing SOPs
• Observe process
• Review the actual cleaning performed against the SOP
• Are all tools / steps identified ?
• Ensure critical process control steps have a measurable or
observable parameter
• Consider how the parameter is assured – is documentation the
answer?
• Observe several different operators performing the cleaning tasks -
look for variability in current practices
• Revise the SOP to reflect current practices
• Retrain all operators accordingly
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Cleaning Validation
Cleaning validation SOP -1
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Cleaning Validation
Cleaning validation SOP -2
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Cleaning Validation Protocols
Writing Protocols -1
Understand Your Objectives
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Worst-Case Conditions to
Challenge In Validation Studies
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What Worst Case Conditions
Should Be considered ?
Worst-Case Rationale
Hold times before cleaning Residues may dry on surfaces or, if
hygroscopic may pick up moisture
Starting soil conditions such as Will ensure that any condition that is less
maximum campaign length severe in terms of soil load will be
and/or maximum batch size successful
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Cleaning Validation Protocols
Typical Contents -1
• Scope / Purpose
– define the equipment, procedures, practices to be
challenged; be sure to include references to any
groupings / bracketing of equipment / products that
will also be considered validated based on a
successful outcome
• Responsibilities
– participants in the validation and their roles in the
studies
• Background
– optional section to describe any pre-work leading to
this point; references may be included to cycle
development, prior trials or linked validation studies
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Cleaning Validation Protocols
Typical Contents -2
• Experimental Design
– this section should define the key decisions and
rationales, such as:
• Equipment design or definition / boundaries
• Soil selection criteria
• Analytical method selection / sampling method
• Sampling site selection
• Worst-case conditions to be challenged (soil load,
hold times, cleaning parameters, etc.)
• Limits to be applied
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Cleaning Validation Protocols
Typical Contents -3
• References
– Include those documents that support the accomplishment of the
validation, avoid extraneous generic references
– Cleaning SOPs
– Training programs
– Rationales
– IQ / OQ performance of cleaning equipment and automation
– Analytical method / sampling method SOPs
– Analytical method validation summary report
– Recovery study summary report
– Failure Investigation / OOS procedure to be followed
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Cleaning Validation Protocols
Typical Contents -4
• Validation Procedure
– Details of each data sheet to be executed and
attached to the validation, including all
documentation to be completed and attached
• Acceptance Criteria
– Include limits (or their source) and all calculations
required for the interpretation of results
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Cleaning Validation Protocols
Typical Contents -5
• Revalidation conditions / parameters
• Monitoring conditions / parameters
• Data sheets for execution
– Common
• Visual Assessment
• Rinse Samples
• Swab Samples
• Deviation Summary
– Optional
• Instrument and Calibration Checklist
• Equipment Boundaries
• Personnel’s Training record
• Analytical Methods Validation / Recovery Studies
• Post-Sampling Activities 1 2
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Meaning of Consecutive Successful
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Storage of Clean Equipment
Could be a problem if :
• equipment stored in the production space
during other processing , or
• when the equipment is stored in same room as
cleaning takes place (dirty equipment is brought
in)
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Cleaning Validation
Reports
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Cleaning Validation
Reports
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Review and Approve Reports
• Ensure that all groups agree with the validity of the data
collected and the conclusions reached
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Maintenance of the Validated State
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Thank You
Terima Kasih
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