Professional Documents
Culture Documents
Cleaning Validation
Beth Kroeger
Technical Services
Specialist
STERIS Life Sciences
&
Amanda Deal
Senior Technical
Services Associate
STERIS Life Sciences
1/
Agenda
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Parameters and attributes
of cleaning processes
• Critical Performance Parameters (CPPs)
– Process times (includes Dirty-hold)
– Turbulence or flow
– Cleaning agent concentration
– Temperature
• Critical Quality Attributes
– Visual Inspection
– Analytical residue limits (HPLC or TOC)
– Microbial (Bioburden/Endotoxin)
– Conductivity/pH
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Cleaning parameters
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Cleaning Chemistry –
Process parameters
• Cleaning also depends on cleaning
conditions…
– Water Quality – Which glass is cleaner?
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Cleaning Chemistry –
Process parameters
• Cleaning also depends on cleaning
conditions…
– Individual Performing Cleaning (especially in
manual cleaning)
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Manual Cleaning Process
Variation
• Variation sources
– Different persons
– Different motivation
– Different physical strength
– Day shift, 2nd shift, 3rd shift, weekend differences
– On and on…..
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Cleaning Chemistry
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Cleaning Chemistry
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Cleaning Chemistry
• Cleaning also depends on cleaning
conditions…
– Nature of Soil
• Slip agents: commonly used in the manufacture of plastics
• Insoluble in water and most buffers.
– Tend to float at air/liquid interface
– Deposit on side wall of tanks at the meniscus levels
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Identifying Risk in
Cleaning Validation
• Need to know and
understand:
– Process flow
– Equipment
– Process soils
– Components of cleaning
• Where to start?
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Performing a risk
assessment
• Risk based Scientific
Rationale are needed for
the following:
– Equipment Grouping
– Soil Selection
– Product Grouping
– Sampling method selection
– Sampling site selection
– Limit selection & calculation
– Analytical Approach
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Equipment Grouping
Criteria
• Must be same type
– Size
• Same equipment of different sizes
– Example: 50L, 100L, 300L, 500L and 1000L tanks
– Same materials of construction
– Configuration
• Equivalent geometries/design risks
• Must have same cleaning process
– Cleaning agent
– TACT
– Frequency of cleaning
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Equipment Grouping
Criteria
• Must have same manufacturing
process/soil characteristics
– Role/position in process
– Campaign length/dirty hold time
• Alternatives --
– Validate separately largest /smallest sizes
– Validate together testing extremes
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Types of Soils
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Risk Ranking Specific
Soils
Risk Level
Parameter Risk Level 1 Risk Level 2 Risk Level 3 Risk Level 4 Risk Level 5
0
Moderately Very Difficult
Product Moderately hard to clean Difficult to to clean such
Easy to clean
Difficulty to Very easy to easy to clean – Thicker clean oily as denatured
•
clean - lab clean – water
and highly
mobile in
– some products, substance, protein,
study or effective viscosity some builder or dyes,
liquid state
subjective issues insoluble excipient titanium
ingredients dioxide
>1250 mg/kg >250 mg/kg
≥ 2500 > 2500 >500 mg/kg
Toxicity – and ≤ 500 and ≤ 25
mg/kg mg/kg and ≤ and ≤ 250 ≥ 25 mg/kg
LD50 (oral rat) mg/kg mg/kg
1250 mg/kg mg/kg
Slightly
Freely Practically
Solubility - Very soluble Soluble Very Slightly
Soluble Soluble Insoluble
g/100mL of 100% in >10% but Soluble <
99.9 % in 99% in water < 0.01% in
water water <90% in 10% in water
water water
water
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Example (Dietary
Supplements)
Cleanability in
Potency - RDA Toxicity Total RPN
Oral Dosage Form Solubility (active) Alkaline
(mg) Oral LD50 (mg/kg) (S×P×T×C)
Detergent
Practically
Calcium 7 1 800-1200 1 6450 2 14
insoluble
0.050-
Chromium 4 Not specified 5 2 100-400 2 80
0.200
Slightly
Magnesium 5 3 270-400 1 4722 2 30
soluble
Not
Potassium 3 soluble 3 1 7200 2 18
specified
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Grouping for a Contract
Manufacturing Facility
• Facility may not know next product
• Want to avoid frequent re-validation of
cleaning processes. How?
– Develop cleaning matrix for products currently
produced in facility
– Identify worst case soil, and validate the cleaning
process
• When new products are introduced into facility, add it to
matrix and determine if re-validation is required.
• During original cleaning validation, adjust limits to be low
enough that the potential for re-validation is reduced
(based on historical manufacturing trends)
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Sampling
Bottom Outlet
5 3 3 1 1 13
Valve
Dome Lid 1 1 1 1 5 9
Instrument
1 5 3 1 5 15
Port
Sampling Port 5 5 3 1 1 15
Agitator 1 1 1 1 3 7
1 = Low Risk
3 = Moderate Risk
5 = High Risk
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Sources of Guidance for Limits
• US FDA, Guide to Inspections of Validation of
Cleaning Processes (1993)
• Pharmaceutical Inspection Convention (PIC),
Recommendations on…Cleaning Validation (2001)
• Canadian HPFB, Cleaning Validation Guidelines
(2001)
• EC Guide to Good Manufacturing Practice – Annex 15
(Paragraph 36) (2006) & GMP Part II (formerly
Appendix18) (2005)
• WHO Technical Report No. 937: WHO
Supplementary Guidelines on GMP (Annex 4):
Validation (2006)
• European Medicines Agency EMA/CHMP/CVMP/
SWP/169430/2012. Guideline on setting health
based exposure limits for use in risk identification…
November 2014 (effective June 2015)
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Interesting Agreement….
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Background
• Limits timeline:
Fourman, G., and Mullin, M., ISPE Baseline® Guide:
“Determining Cleaning Validation Risk-Based Manufacture
Acceptance Limits for of Pharmaceutical
Pharmaceutical Manufacturing Products
Operations,” Pharmaceutical (Risk-MaPP), September,
Technology, April 1993 2010
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Sources of Guidance for
Limits
• European Medicines Agency
EMA/CHMP/CVMP/ SWP/169430/2012.
– Guideline on setting health based exposure limits
for use in risk identification
– November 2014 (effective June 2015)
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Residue Limits
1 Fourman, Gary L., and Michael V. Mullen, “Determining Cleaning Validation Acceptance Limits for
Pharmaceutical Manufacturing Operations,” Pharmaceutical Technology, Vol.17, No. 4, April, pages 54 -
60, 1993.
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Residue Limits
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Residue Limits – In
Layman’s Terms….
• Need to determine how much of the product we just
cleaned will be administered to each patient taking the
next product.
But in order to make this number useful….
• Need to determine how much that will represent in the
next batch and translate that number to a value in terms
of how much that might represent on the surface to
measure.
• Need the residual amount to be “safe”, add safety factor.
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Nature Term
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Daily amount allowed –
Product A
• Assume tablet Product A:
50 mg active per tablet, 1 tablet per dose, 2-4
doses/day
• Minimum daily dose of active is:
50mg/tablet x 1 tablet/dose x 2 doses/day = 100
mg/day
• Daily amount allowed:
– Acceptable Daily Intake (ADI)
– Acceptable Daily Exposure (ADE)
– Based on Safety/toxicity evaluation
(Or) 0.001 of a minimum daily dose of an active.
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Safety Factor Term
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Safety Factor Term
(Continued)
• Common practice is to apply safety factors
uniformly within a plant
– Topical Products: 10 to 100*
– Oral Dosage Products: 100 to 1000*
– Parenteral/Opthalmic Products: 1,000 to 10,000
– Research/Investigational Products: 10,000 to
100,000
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Dose Term
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Concentration in next
product - Product B
• Assume Product B:
1,000 mg tablets, 1 tablet per dose, 2-4 doses per
day
• Maximum daily dose of Product B is:
1,000 mg/tablet x 1 tablet/dose x 4 doses/day =
4000 mg/day or 4 gm/day
• Concentration in next product:
(100 mg/day)(0.001 safety factor) = 0.025 mg/g
4 gm/day
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MAC
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Size Term
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Limit per surface area
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Putting the Terms Together
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Limit per swab
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Limit in swab extract
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Leveraging sampling
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Leveraging sampling
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Limits for Cleaning Agents
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Things to Avoid in Setting
Limits
• Limits based on analytical assay
• Limits based on compendial water specs
• Limit unrelated to target residue
• Limits selected arbitrarily
• No documentation of rationale or risk ranking
for how selected
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Recent Approaches –
ISPE Risk MaPP
• Risk based approach for determining the
ADE (acceptable daily exposure)
• Typically established by trained toxicologist
• Focuses limit on “how” the carryover might
cause harm
• Would be used in place of 1/1000th
therapeutic dose approach
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Calculating the Safety
Threshold Value (STV)
(ISPE)
Batch Size
ADE STV
Maximum DailyDose
Rather than:
NOAEL BW
ADE (mg/day)
UFC MF PK
• Where:
– ADE = Acceptable daily exposure
– NOAEL = No observed adverse effect level
– BW = Body weight
– UFc = Composite uncertainty factor
– MF = Modifying factor (professional judgment)
– PK = Pharmacokinetic adjustments (route to route
adjustments)
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Calculation of ADE Value
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“New” Approach: EMA
Guidance
• Why?
– Some felt that “traditional” method was not “risk-
based”
– Use of 1/1000th daily dose of active seen by some
to be “arbitrary”
– Some questioned the use of 10 ppm as the
“default” value as arbitrary and possibly not
reflective of potential risks
– Current approach could lead to either overly
prescriptive limits or inadequate limits
– Desire to update the approach to validation –
requires a toxicological assessment of product
residues.
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PDE Value
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Uncertainty factors
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Case Study: CIP®100
detergent
• The traditional method…
LD 50 BW M BS
M AC
M F1 M F2 LDD
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Case Study: CIP 100 detergent
• EMA Method:
– NOAEL = 120mg/kg/day
– F1 = 10
– F2 = 10 As determined
– F3 = 3 by toxicologist
– F4 = 1
– F5 = 3
120 mg/kg/day 60 kg
PDE (mg/day) 8 mg/day
10 10 3 1 3
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Case Study: CIP 100 detergent
MBS
STV PDE
LDD
10 kg 1000000 mg
STV 8 mg/day x 100,000 mg/day
800 mg 1 kg
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Process Capability and Limits
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Best Practices for successful
Cleaning Validation
• A Manufacturing perspective…..
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Best Practices for successful
Cleaning Validation
• Don’t work in a vacuum.
– Involve every group that will be involved with
Validation
• Quality Assurance
• QC Chemistry and Micro
• Manufacturing: Usually will execute the PQ. (Most likely be
pulling samples and will disassemble equipment).
• Process Engineers: (Fix equipment after bullet point #2).
• Facilities and Engineer: May have to re-engineer and
involved in facility effluent.
• EH&S:
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Best Practices for successful
Cleaning Validation
• Come to the manufacturing area and look at
the equipment, not just the P&ID…..
– Look for possible problems areas BEFORE you
start.
• Corners, crevices, deadlegs, valves, seals,
• Sample locations
– Consider where can contamination occur?
– Where can problems be fixed by re-engineering?
– What portions of the process can be cleaned in
place?
– Do sections need to be removed for cleaning?
COP or use of jumpers/manifolds?
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Best Practices for successful
Cleaning Validation
• Work with Process Development,
Manufacturing and Technical Services to
establish Design Space.
– MOR: Manufacturing Operating Ranges
– PAR: Proven Acceptable Ranges.
• The information and knowledge gained from
pharmaceutical development studies and
manufacturing experience provide scientific
understanding to support the establishment of
the design space, specifications and
manufacturing controls
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Best Practices for successful
Cleaning Validation
• Design space: Defined in ICH Q8 as
– The multi-dimensional combination and interaction of input
variables (e.g. material attributes) and process parameters
that have been demonstrated to provide an assurance of
quality.
MOR
Area of
Control PAR
pH 7.0 ± 0.5
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Most Frequent form 483
observations – FY2014
Top 10 FDA form 483 observations
(21 CFR 211) for FY2014
160
140 145
120
100 109
94
80 87
72 72
60 64 63
54
51
40
20
0
22(d) 160(b) 192 100(a) 67(b) 113(b) 165(a) 67(a) 68(a) 110(a)
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Cleaning procedure exercise
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Best Practices for successful
Cleaning Validation
• TWO WORDS: Experimental Protocol (or
significant pilot work)
– Confirms lab performance of cleaning agents
– Tests critical process parameters
– Tests engineering design and controls
– Determines rinse conditions and acceptance levels
(both active and cleaning agents) to ensure they
are achievable
– Test hold times
– Optimize conditions
– ID sampling locations
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Best Practices for successful
Cleaning Validation
• Clear and concise procedures:
– ID all pieces of equipment: use checklists, tables
or pictures for clarity. (tools may be equipment
specific and not have “universal” names).
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Best Practices for successful
Cleaning Validation
• Clear and concise procedures:
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Best Practices for successful
Cleaning Validation
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Information included in SOP
• Piece of equipment or system
• Frequency of visual inspections
• Department responsible for conducting the
visual inspection
• HOW to visually inspect
– Is extra light used? Scope? Camera??
• Follow-up actions defined
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And Finally…..
Perform a Lab-Scale cleaning study
• Optimize cleaning parameters using
beaker/coupon study
– Soiling is expensive large scale
– May not be feasible due to availability of
equipment
– Quantitative measurement of residue removal
easier at small scale
– “Laundry mat” approach: Run multiple conditions
at the same time.
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Why Perform a Lab-Scale Study
Run Cleaner Temperature Concentration 15 min
30 min
1 Cleaner A Ambient 1% v/v
45 min
2 Cleaner B Ambient 1% v/v
60 min
3 Cleaner C Ambient 1% v/v
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Where to start:
Cleaning Agent Selection
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Performing a Lab-Scale Cleaning
Study
• Coat coupon with 1-2 gms of soil
• Emulate process conditions and dirty hold
time
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Performing a Lab-Scale Cleaning
Study
• Use experimental design to vary parameters for
optimization
– Start with agitated immersion: Calibrated digital
stirplate
– Vary detergent concentration and temperature
• Check cleaning progress at specific time intervals.
1% 60 15
1% 80 15
Concentration
2% 60 15
2% 80 15
1% 60 30
1% 80 30
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Acceptance Criteria
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Advantages of Lab-Scale
Cleaning Study
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Advantages of Lab-Scale
Cleaning Study
• Residue build-up over time
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Advantages of Lab-Scale
Cleaning Study
Same coupon,
Same coupon, different angle.
different angle.
Residue visible
Residue visible on both angles,
in first angle, not 15 coating and
in second. cleaning cycles.
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Advantages of Lab-Scale
Cleaning Study
Same coupon,
different angle. Same coupon,
different angle.
Both coupons wet
Both coupons dry
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Best Practices for a Robust
Cleaning Validation
References & Additional Reading:
Fourman, G.L. and Mullen, M.V., “Determining Cleaning Validation Limits for Pharmaceutical
Manufacturing Operations,” Pharmaceutical Technology 17(4), 54-60 (1993).
FDA, 1993, Guide to inspections of validation of cleaning processes. Rockville, MD, USA: Food and
Drug Administration, Office of Regulatory Affairs.
Forsyth, R., O’Neill, J.C. and Hartman J.L. (2007) Materials of construction based on recovery data
for cleaning validation. Pharmaceutical Technology, Oct., pp. 103–116.
Thank you for your
LeBlanc, D.A. (2000) Validated Cleaning Technologies for Pharmaceutical Manufacturing. USA:
Interpharm Press. attention!
Verghese, G. and Lopolito, P. (2007) Process Analytical Technology and Cleaning. Contamination
Control, Fall 2007, pp. 22–26.
LeBlanc, Destin A. et al., Cleaning Technology for Pharmaceutical Manufacturing Pharmaceutical
Technology 17:7, 84-92 (1993).
Points to Consider for Cleaning Validation. PDA Technical Report No. 29. PDA. Bethesda, MD.March beth_kroeger@steris.com
30, 1998.
Forsyth, RJ. et al., Correlation of Visible-Residue Limits with Swab Results for leaning Validation.
Pharmaceutical Technology 30 (11), 90-100 (2006).
LeBlanc, Destin A., Issues in Setting Limits for Actives in Bulk Biotech Manufacture. Journal of
Validation Technology 15 (1), 71-76 (2009).
Pluta, P (editor). Cleaning and Cleaning Validation Volume I. PDA Books (2009). ISBN 1933722371.
Troy, F., Hold Time Studies: A Lost Parameter for Cleaning Validation. Journal of Validation
Technology 13 (3) 206-209 (2007).
86/