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HEATING, VENTILATION, AND AIR cedures. It is important to collect data on the silicone used
CONDITIONING (HVAC) SYSTEMS for sealing penetrations, on the flooring material, and on the
paints that are used on the walls and ceiling. The cleanliness
INTRODUCTION of the job site during construction should be strictly en-
Whether a parenteral facility is designed for manual or forced and all ducts should be capped or sealed then cleaned
automated operation, environmental control is a critical fac- before being used.
tor in determining the successful operation of the facility.
The design and construction that relates to the clean room DESIGN QUALIFICATION
must include consideration for:
• Air Volume A facility’s room classification or design specification
• Air Velocity should be identified based on the product being manufac-
• Particulate Loading (especially viable organisms) tured and the processes being used. It is important that the
• Temperature HVAC system meets the required specifications based on
• Relative Humidity the needs or requirements of the products and processes. For
• Pressure Differentials example, one would not design a system to meet aseptic
conditions if the product to be produced was not meant to
There are many documents that are helpful guides in de- be sterile. Therefore, it is important to define your product
termining the requirements for the design and construction and process requirements before designing your HVAC sys-
of your controlled environmental system. The Federal Stan- tem. The clean room classification requirements found in
dard 209-E is a document intended to provide standardiza- Figure 1 should be considered when designing an HVAC
tion of definitions and air cleanliness classes for clean system.
rooms. The American Society of Heating, Refrigerating,
and Air-conditioning Engineers’ (ASHRAE) handbook is CONSTRUCTION QUALIFICATION (CQ)
another guide that also can be helpful.
During construction, documenting procurement and The construction of a pharmaceutical manufacturing fa-
verifying construction activities are critical components of cility requires strict adherence to the requirements outlined
successful Installation Qualification (IQ). It is important to in the Code of Federal Regulations (CFR) 21, Part 211.42,
witness certain tests, such as the Heating, Ventilation, and the current Good Manufacturing Practice regulations
Air Conditioning (HVAC) duct leak test, and cleaning pro- (cGMPs) for processing human drugs. A great deal of em-
Figure 1
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Airborne Particulate Cleanliness Classes (by cubic meter)
The larger, bolded font in ISO rows five through eight and in columns headed, 0.5 µm and 5.0 µm,
denotes classification and particle size usually used in the certification of clean rooms for the
Health Care Industries.
Note: The new FDA Guideline for Industry "Sterile Drug Products Produced by Aseptic Processing —
Current Good Manufacturing Practice," requires testing for only the 0.5 µm particles/m3 sizes during rou-
tine monitoring for aseptic processes
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David W. Vincent and Herbert Matheson
OPERATIONAL QUALIFICATION
Test, Balancing, and Adjustment
After the critical utilities IQ has been verified, it is im- Once the clean rooms have been certified, the next step
portant to conduct the next important step of the qualifica- of the validation process is the Operational Qualification
tion: Test, Balancing, and Adjustment (TBA). TBA is the (OQ).
culmination of the long and costly process of designing and During the execution of the OQ it is important to verify
constructing an HVAC environmental control system. TBA the following steps:
ensures that the completed installation will produce the en-
vironment intended by the original system design and con- 1. Review the HVAC IQ final report, instrument cali-
tributes to the continued efficient performance of the system bration, and operation and maintenance procedures.
after it is in operation. The TBA technician will verify hy- 2. Review the testing and balancing final report.
drostatic and HVAC balancing, along with air change rates 3. Review the clean room testing and certification
and volumes. Clean room velocities will also be verified dur- final report (HEPA filter certification).
ing the testing. 4. Verify HVAC control functions and alarms.
5. Verify Building Management System controls and
Clean Room Testing and Certification communication.
After the HVAC system has been balanced and accepted, 6. Verify pressure differentials and airflows between
it is now time to certify the clean rooms. This involves the clean rooms.
testing and certification of certain physical attributes of the 7. Complete shutdown and start-up tests to verify that
clean room. the HVAC systems return to normal conditions.
The clean room testing and certification contractor 8. Verify Environmental Control Functions
should perform the following tests:
It may be necessary to repeat the particle counts and
• DiOctyl Phthalate (DOP) Test of HEPA Filters temperature and humidity test after the shutdown and start-
• Noise Levels up procedure.
• Light Levels After the environmental controls have been tested and
• Air Patterns: Parallelism and Unidirectional tests in accepted, the clean rooms are ready for the Performance
the aseptic fill area Qualification (PQ) study.
• Induction Testing
• Humidity and Temperature
• Room Non-Viable Particulate Counts using PERFORMANCE QUALIFICATION
209-E calculations (Clean Room Classification)
• Recovery Time Testing Microbiological validation of any facility should be ex-
• Room Air Change Rates ecuted in three phases, with varying degrees of severity. The
• Differential Pressure initial protocol should cover the baseline environmental
• Air Flows Direction sampling plus installation and initial operational qualifica-
tion of critical systems, beginning just after construction
The clean room must meet all the design criteria before clean-up. The second stage involves the actual validation of
the next stage of the validation can be performed. The cer- systems and equipment, including both static and dynamic
tifying contractor must formalize all results obtained during environmental testing, once all air-handling systems are bal-
the certification process in an official report. anced and fully qualified. The third and final stage covers
the routine Environmental Monitoring Program; Standard
Operating Procedures (SOPs), such as, gowning, mainte-
nance, and cleaning procedures; operation limits of test
methods; plus any follow-up items generated from the first
two stages.
The overall intent of the first two phases is to determine
the limits and capabilities of the facility and to get a general
profile of the resident population of organisms. The infor-
Figure 2
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Air Classificationsa
a- All classifications based on data measured in the vicinity of exposed materials or articles dur-
ing periods of activity.
b- ISO 14644-1 designations provide uniform particle concentration values for cleanrooms in mul-
tiple industries. An ISO 5 particle concentration is equal to Class 100 and approximately
equals EU Grade A.
c- Values represent recommended levels of environmental quality. You may find it appropriate to
establish alternate microbiological action levels due to the nature of the operation or method
of analysis.
d- The additional use of settling plates is optional.
e- Samples from Class 100 (ISO 5) environments should normally yield no microbiological conta-
minants.
Figure 3
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USP 1116: Microbial Levels for Surface Monitoring
The microbial levels for surfaces samplings are detailed in the following table and are based on
USP <1116> requirements.
1
Adjacent to critical area, 2
Support Areas - Product
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David W. Vincent and Herbert Matheson
mation for these studies can then be used to develop a rou- After the PQ study is completed, the data is reviewed
tine environmental monitoring program that provides the and a final report is written summarizing the results. The in-
highest probability of detecting any failure or problems, formation from the PQ final report is than used to establish
while still being manageable for operating and testing per- a routine environmental monitoring program.
sonnel. The data in Figure 2 is based on the new FDA
Guideline for Industry “Sterile Drug Products Produced by
Aseptic Processing — current Good Manufacturing Prac- PHARMACEUTICAL GAS SYSTEMS
tice,” for routine monitoring of aseptic processes. INTRODUCTION
Baseline Sampling Since gases are used in the application and production of
The initial sampling for the baseline is intended to get a pharmaceutical drugs and can have a direct impact on prod-
general profile of the microbial population before cleaning. uct quality, they are considered critical systems. Gases are
This sampling usually involves taking random sampling used in various manufacturing processes. Gases are typi-
throughout the clean rooms. The sampling of the controlled cally used to transfer fluid products from one location to an-
environments involves high levels of samples and sampling other and in the manufacturing processes.
frequencies, often using two selective growth media for both The most commonly used gases in the pharmaceutical
surface and air monitoring, (Sabouraud Dextrose Agar industry are the following:
(SDA): for molds and yeast and Tryptic Soy Agar (TSA): for • Carbon Dioxide
bacteria). This is done to check the sub-population of organ- • Nitrogen
isms and to determine which sample sites are the “hot-spots.” • Clean, Dry Compressed Air
Static and Dynamic Sampling Other gases such as helium, oxygen, and argon may also
This stage of the validation involves performing three be used. This article will discuss only those gases most
static and dynamic state studies. The sample locations are commonly used in the Pharmaceutical Industry that may
pre-determined based on the clean room particle count stud- come in contact with the product.
ies and results from the baseline study (hot-spots). Again,
duplicate samples with different media and incubation tem- VALIDATION OF GASES SYSTEM
peratures and times should be used. This stage of the vali-
dation is also used to qualify the cleaning procedures based Gas System Design
on the data from both the baseline (before cleaning) and the Since gas systems can be used for various manufacturing
static and dynamic states studies. It is important to maintain processes, the design of the system can be considered
accurate facility maintenance and cleaning logs. The infor- straightforward. The application for which these gases will
mation from these logs will be compared with the environ- be used should be the major consideration during the design
mental results to determine whether the cleaning and main- phase.
tenance procedures are acceptable. The personal gowning The following are some considerations for the design of
and operator aseptic technique should also be validated dur- gas systems:
ing the PQ study.
The following conditions should be tested and moni- • Safety Issues (Oxygen)
tored during the Performance Qualification Study: • Materials of Design
• Fabrication
• Viable and Non-Viable Airborne Particulates • Code Requirements
• Viable Surface Samples • Product or Process Demands
• Temperature and Relative Humidity • Testing Requirements
• Magnehelic Gauge Readings • Installation Requirements
• Manufacturing Personnel Gowning • Functional and Control Requirements
• Aseptic Media Fills • Gas Purity
• Building Management System Trending Data
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David W. Vincent and Herbert Matheson
Gas System
During the execution of the IQ for gas systems, the fol- PERFORMANCE QUALIFICATION
lowing installation attributes should be verified:
The PQ is performed to verify that the gas systems de-
• Utility Connections liver high quality gas that will meet the manufacturing qual-
• Drawings (“as-built”) ity specifications and to establish the baseline information
• Materials of Construction on the performance of the gas systems used in the manufac-
• Distribution Systems turing areas. This study will also include qualifying three
• In-line Filters lots of gas supplied by the vendor and thirty consecutive
• Storage Tank days of testing to qualify the compressed gas system.
• Systems Design and Safety Codes
• Valves Acceptance Criteria
• Alarms and Control Devices The performance qualification testing shall be per-
• Backup System formed on three lots of nitrogen supplied by the vendor.
• Major Components Thirty consecutive days of testing will be completed to
• Point of Use Filters qualify the compressed gas system.
• Components, Tagged and Labeled Gas and Compressed Air samples collected during the
PQ test period shall meet the criteria detailed in Figure 5.
Figure 5
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Test Criteria for Gases Samples
Item Criteria
˚C
3
See
Figure 6
______________________________________________________________________________
Clean Room Classification of Particle Sizes
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David W. Vincent and Herbert Matheson
5. Perform viable and nonviable particulate testing at Routine Environmental Monitoring Program
worst-case sampling point, usually the point far- When establishing a routine environmental monitoring
thest away from the source. program, the data for the PQ study should include the start-
ing point for determining the sampling sites and frequencies
Data Analysis of testing. It is also important to have an accurate drawing
The testing of gas systems for microbial count may not indicating the sampling sites. The program should also in-
give any beneficial information if certain environmental con- clude environmental worksheets to record the test results.
ditions for the systems are not recreated during incubation. The worksheet data can be entered into a computer-aided
For example, if a sample from a nitrogen gas system is taken software program, which can be used to trend and perform
and incubated aerobically, certain organisms may not grow queries on environmental data.
in those conditions (oxygen environment). It would be more
logical to incubate the growth media in the same environ- Establishment of Alert and Action Limits
mental conditions to which the organism is accustomed. Alert Limits - The concentration of viable and non-vi-
Therefore, under certain conditions, anaerobic monitoring able particulate in a controlled environ-
may be acceptable for monitoring certain types of gases. ment that, when exceeded, signals a poten-
Most companies test for microbial contaminants using tial drift from normal operating conditions.
TSA, which is incubated aerobically and at 30˚ - 35˚C for Action Limits - The concentration of viable and non-vi-
48 - 72 hours. This may not be effective in isolating organ- able particulate in a controlled environ-
isms that may not survive under these environmental condi- ment that, when exceeded, signals a poten-
tions. When performing this test, consider what you are try- tial drift from normal operating conditions,
ing to accomplish. If it is to verify that the gas is free from and which requires an investigation and
microbial contaminants, then proper growth conditions corrective action.
should be simulated. Also, most organisms will not survive
in the harsh environments created by certain gas production Alert and action limits are usually derived statistically
and storage. Whatever test method is used to detect micro- from historical data. These limits are conservative measures
bial contaminants, it should be properly validated. designed to signal potential drift from historical or design
performance characteristics.
ROUTINE MONITORING PROGRAM The establishment of alert and action limits should be
FOR CRITICAL UTILITIES written and utilized in a consistent, non-arbitrary manner. It
is important to remember that alert and action levels should
Once the PQ is completed, the “real time” validation of not be extensions of the product specifications. If an alert
the critical utilities begins. Usually, the PQ study is per- level is exceeded, corrective action may not be required, but
formed over a short period of time and with intensive sam- records should show that the excursion was recognized. If
pling. But the routine environmental monitoring is per- the alert levels consistently exceed their set limits, an inves-
formed during the life of the facility and usually involves tigative action should be taken.
less intense sampling. The data collected from routine envi- If an excursion occurs above an action level, at mini-
ronmental monitoring programs includes: seasonal varia- mum, one should review the data. Additional action should
tions and manufacturing activities along with maintenance be taken in the form of an investigation, and corrective and
and cleaning activities. The most effective environmental alert notices to responsible parties and departments should
monitoring programs are the ones with clear and precise be completed and delivered to those parties.
procedures. When an action limit is exceeded, an investigation and
corrective action should be performed. A list of the types of
actions to be taken follows; actions should be appropriate to
the situation and should not necessarily be limited to these
suggestions:
• Generate an Environmental Deviation Report filled out under the following or similar circumstances:
(EDR) form. Water Systems
• Issue an Alert Notice. 1. When a QC sample consistently exceeds alert limits
• Investigate the Environmental Deviation. for all QC test results
• Perform Corrective Action. 2. When a QC sample of water exceeds the action
• Resample Out of Limit Locations. level for bacterial count
• Review maintenance and cleaning logs. 3. When a QC sample of water exceeds the action
• Perform gram stain/identification of isolated organ- level for endotoxin limits
ism(s). 4. When a QC sample of water exceeds the limit for
• Determine sensitivity of isolate to disinfectant USP chemistry
being used. 5. When a possible minor malfunction in the water
• Review risk of product contact. system is observed
When acceptable levels are re-attained, no further action Clean Steam Systems
is usually required. The results from the retest are recorded 1. When a QC sample consistently exceeds alert limits
on the Environmental Deviation Report form, disposition as for all QC test results
Pass, and filed for future reference. 2. When a QC sample of clean steam condensate ex-
If the retest indicates that acceptable levels have not ceeds the action limits for bacterial count
been met, the Quality Control (QC) Department will initiate 3. When a QC sample of clean steam condensate ex-
an Investigation Report to Directors of Quality Assurance ceeds the action limits for endotoxin levels
(QA) and Manufacturing with a description of the deviation. 4. When a QC sample of clean steam condensate ex-
It is the responsibility of the Manufacturing or Facility De- ceeds the action limits for USP chemistry
partment to conduct an immediate investigation and to initi- 5. When a possible minor malfunction in the water
ate corrective actions to restore the area to normal operating system is observed
conditions. QA is responsible for evaluating the impact of
the conditions on product quality. HVAC Systems
After corrective actions have been taken, the affected lo- 1. When a QC sample consistently exceeds alert limits
cation(s) should be retested at least three times. Acceptable for all QC test results
levels are re-attained if three consecutive re-tests meet ac- 2. When a questionable condition (such as sanitation,
ceptable levels. Once the system is again in compliance, QA or potential contamination) in the core and associ-
is responsible for releasing the system to Manufacturing. ated areas is observed
3. When an environmental monitoring sample exceeds
Corrective Action Program for Critical Utility Systems the action level for microbial or particulate counts
The purpose of a corrective action program is to investi- 4. When a temperature or humidity reading is outside
gate critical system failures, to report and document these the specified range
failures, and to make the necessary corrective action to 5. When a pressure differential reading is outside the
bring the system into compliance. specified range
The following program is applicable to critical utility 6. When a possible minor malfunction in the HVAC
systems, which include: controlled environmental Heating, system is observed
Ventilation, Air Conditioning (HVAC), Purified Water,
Water-For-Injection (WFI), Process Gases, and Clean Gases Systems
Steam systems. 1. When a QC sample consistently exceeds alert limits
for all QC test results
Program Procedures 2. When gas system test results are outside the speci-
An environmental investigation applies to any situations fied range
not considered an immediate threat to a critical system, but 3. When a QC sample of gas exceeds the action level
which, if allowed to continue, may become serious. for bacterial count
An Environmental Deviation Report (EDR) must be 4. When dew point exceeds the action level
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David W. Vincent and Herbert Matheson
After the investigation is completed, any supporting doc- • Retrain clean room personnel on proper techniques
umentation should be included as a part of the final investi- • Check on possible unusual events during sampling
gation report. Maintain a history file on each system to de- or testing
termine whether there are any recurring failures that may re- • Review pressure differential information
quire modification or redesign of the system. • Review clean room and HEPA filter certification
data
Water Systems Corrective Action • Review maintenance and cleaning logs
Corrective actions for pretreatment water, Purified • Perform gram stain identification of isolated organ-
Water, and Water-For-Injection systems may be included, ism(s)
but are not limited to, the following: • Determine sensitivity of isolate to disinfectant
• Additional sampling and testing being used
• Review and repeat sanitization procedures • Review risk of product contact
• Review sampling and testing technique
• Review validation data Corrective Action For Gas Systems
• Check on possible unusual events during sampling Corrective actions for gas systems may include, but are
and testing not limited to, the following:
• Review 0.2mm filter and tank vent filter integrity • Additional sampling and testing
test results • Review sampling and testing technique
• Review maintenance and sanitization logs • Review validation data
• Perform gram stain identification of isolated organ- • Check on possible unusual events during sampling
ism(s) and testing
• Steam-In-Place (SIP) entire system • Review point of use filter integrity test results
• Inspect all major components on the pretreatment, • Review maintenance logs
purified, and WFI systems • Perform gram stain identification of isolated organ-
• Review risk of product contact ism(s)
• Review Certificate of Analysis from vendor
Corrective Action For Clean Steam System • Review risk of product contact
Corrective actions for clean steam systems may include,
but are not limited to, the following: No further action is required when acceptable levels are
• Additional sampling and testing re-attained. Record retest results on the Environmental De-
• Review sampling and testing techniques viation Report form, disposition as Pass, and file for future
• Review validation data reference.
• Check on possible unusual events during sampling If retest indicates that acceptable levels have not been
or testing met, initiate another Investigation Report to Directors of QA
• Review WFI test results and Manufacturing with the description of the deviation. It
• Review maintenance logs is the responsibility of Manufacturing to conduct an imme-
• Perform gram stain identification of isolated organ- diate investigation, and to initiate corrective actions to re-
ism(s) store the area to normal operating conditions. QA should be
• Check sampling condenser responsible for evaluating the impact of the conditions on
• Review risk of product contact product quality.
After corrective actions have been taken, the affected lo-
Corrective Action For HVAC System cation(s) will be retested at least three times. Acceptable
Corrective actions for controlled environments may in- levels are re-attained if three consecutive re-tests meet ac-
clude, but are not limited to, the following: ceptable levels.
• Additional sampling and testing
• Review and repeat sanitation procedures
• Review sampling and testing techniques
• Review validation data
N o v e m b e r 2 0 0 5 • Vo l u m e 1 2 , N u m b e r 1 19
David W. Vincent and Herbert Matheson
IVT is Currently
9. Graham C. Wrigley and Jan L. du Preez, Ph.D., “Facility
Validation: A Case Study for Integrating and Streamlining
Accepting Nominations
the Validation Approach to Reduce Project Resources”
Journal of Validation Technology Volume 8, Number 3, May
For This Year’s
2002, pp: 214-235.
* References noted above apply to the entire three-part arti-
cle and represent both specific references and suggested
reading.
N o v e m b e r 2 0 0 5 • Vo l u m e 1 2 , N u m b e r 1 21