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COMMENTARY
ABSTRACT: In multi-product biopharma facilities, the protection from product contamination due to the manufacture of
multiple products simultaneously is paramount to assure product quality. To that end, the use of traditional changeover
methods (elastomer change-out, full sampling, etc.) have been widely used within the industry and have been accepted by
regulatory agencies. However, with the endorsement of Quality Risk Management (1), the use of risk-based approaches
may be applied to assess and continuously improve established changeover processes. All processes, including changeover,
can be improved with investment (money/resources), parallel activities, equipment design improvements, and standard-
ization. However, processes can also be improved by eliminating waste. For product changeover, waste is any activity not
needed for the new process or that does not provide added assurance of the quality of the subsequent product. The
application of a risk-based approach to changeover aligns with the principles of Quality Risk Management. Through the
use of risk assessments, the appropriate changeover controls can be identified and controlled to assure product quality is
maintained. Likewise, the use of risk assessments and risk-based approaches may be used to improve operational efficiency,
reduce waste, and permit concurrent manufacturing of products.
must be avoided” (2). Additionally, “control measures This paper will discuss the optimization of changeover
to remove the organisms and spores before the subse- practices through the reduction of waste. Lean Six
quent manufacture of other products” (3) must be in Sigma identifies eight forms of waste (Figure 1).
place in a multi-product facility. These references Many, if not all, of these forms of waste may be
emphasize that preventing cross-contamination is par- present during traditional product changeover. In par-
amount in a robust changeover process so as not to ticular, this paper focuses on the elimination of waste
adversely affect the safety, identity, strength, purity, associated with cleaning and verification of equipment
or quality of the subsequent product. cleanliness during product changeovers. Table II uses
the lean forms of waste associated with changeover
The scope of changeover is typically limited to non- and identifies the benefits of applying risk-based
dedicated product contact equipment (e.g., cell cul- changeover approaches.
ture/fermentation, purification, and filling operations.)
Process support areas (media and buffer preparation) Optimization of a changeover practice is the process
may not be changed over, as this equipment does not of determining the most efficient and effective method
contact any product containing material that would to achieve the product changeover from Product A to
necessitate verification of removal. In addition, the Product B without adversely affecting the quality and
introduction of single-use equipment to the process safety of Product B. A robust risk program can be used
stream can also reduce the scope of changeover, as this to drive changeover optimization to assure the appro-
equipment is disposed of after use and does not require priate actions and controls have been established and
verification of cleanliness. executed to defend the quality and safety of Product B.
As a prelude to this article, an industry survey was The results in Table I show that there is variability in
conducted to assess the current practices and identify the changeover activities performed by survey respon-
the key areas deemed to be opportunities to improve dents, with “equipment cleaning” the only activity
changeover. Survey results were collected from 15 performed by all. So what actions are really needed
representative companies and included products man- and which are not?
ufactured both internally and externally (contract man-
ufacture). It also included manufacturing across the Risk assessments (RAs) are an industry-accepted tool
spectrum of potency from low-potency products (such to establish the changeover requirements. The RA
as monoclonal antibodies) through medium- and high- defines the criteria that need to be met during the
potency (cytokines and tumor necrosis factors). A changeover, the potential threats to meeting these cri-
summary of the survey results for the current change- teria, and the controls (design and procedures) needed
over practices and the percentage of companies cur- to mitigate, control, or detect these threats.
rently following each of the practices is shown in
Table I. The table shows the tasks associated with Cleaning and protection of the next process from
normal lot to lot (no product change) and the addi- contamination are major quality concerns during the
tional percentage of companies that perform the tasks changeover process. There are many potential contam-
during product changeover. The table is divided into ination threats to the coming product associated with
three sections: changeover.
● Changeover activities performed (lot to lot/addi- The RA allows a systematic assessment of each potential
tional at product changeover) threat and how each of these threats is mitigated/con-
trolled (design, cleaning, procedures, documentation)
● Release criteria (prior to starting the next lot/ and/or how the threat to quality is detected before it can
product) affect the marketed product (sampling, verification, in-
spection).
● Samples collected (during lot to lot/product
changeover) All of the items listed in Table I are types of
controls; the opportunity for optimization is to de-
The activities are ranked based on additional percent- fine— based on the quality threat—which of these
age performing each activity as part of product controls is actually needed to defend and demon-
changeover. strate that the quality of the next process will not be
TABLE I
Summary of Survey Practices
Note: The data was also analyzed to compare the differences in practices between manufacturers handling high- and
medium-potency products versus low-potency products but showed no significant differences and is not presented.
affected by the changeover processes. This also ● Elimination or reduction of changeover sampling
ensures that the changeover activities are commen-
surate with the threats to quality. ● Reduction of line clearance activities
With robust risk assessments, companies can provide a ● Concurrent manufacture of multiple products
solid defense that can support reduction in changeover within a single manufacturing area
activities. This may include the following:
It is important to realize that, if using risk assessment
● Elimination or reduction of elastomer change-out to justify a reduction in changeover, the risk assess-
TABLE II
Changeover Benefits
Figure 2
Figure 3
all risk assessments, risk tolerance will vary from representative materials of construction (MOC)
organization to organization and will result in differ- throughout the manufacturing process. These stud-
ing levels of potential benefits. Guidance for Quality ies can be used to support that the residues are
Risk Management and representative case studies can easily solubilized so if present within a system they
be found within PDA Technical Reports 54 (4) and will be present in rinse water samples collected at
54-4 (5). the system outlet or on swab samples of equipment
surfaces. These studies support the use of single-
New Product Introduction point sampling as well as the collection of swab
samples of the actual equipment surfaces. In addi-
The introduction of new products, or new product tion, the studies demonstrate that the residues are
introductions (NPIs), to a multi-product facility poses readily removed from elastomer and gasket materi-
unique challenges to existing changeover processes of als and are a critical element supporting a risk-based
validated products. As a result, more traditional approach to the change-out of elastomers (e.g., gas-
changeover activities may be required. Because the kets, o-rings, valve diaphragms, etc.).
validation of NPIs may be incomplete, the execution
of cleaning validation/verification is a major compo- When recovery studies have been conducted for all
nent of the NPI process. Small-scale studies are used products and MOC, a matrix can be created that ge-
to assess the product to be introduced into the manu- nerically suggest worst-case MOC for each product as
facturing facility. These include coupon recovery well worst-case MOC across products. The data asso-
studies, cleanability studies and degradation/denatur- ciated with recovery studies become valuable inputs to
ation, and inactivation as discussed below. The find- risk assessments determining the extent of elastomer
ings of these small-scale studies determine the level of change-out and reduced sampling.
the commercial-scale cleaning validation/verification
work required to demonstrate that the validated clean- Cleanability Studies
ing processes remove any residual material to accept-
able levels. These acceptance levels are determined to Bench-scale cleanability studies are performed prior to
verify that potential residual Product A remaining introducing a new soil in to the manufacturing facility
would not be expected to affect the safety or product to give assurance that the existing cleaning cycle(s)
quality of Product B. will be effective. These studies are common in the
industry, as referenced by the Parenteral Drug Asso-
Without the controls of validated cleaning processes ciation (PDA): “Generally, the cleaning effectiveness
and routine monitoring, the use of risk-based change- of the existing system for new soils can be tested by
over practices for new products is impractical. Based performing laboratory experiments using coupons of
upon product knowledge, small-scale studies, and relevant materials. These experiments can be de-
cleaning validation, risk-based changeover practices signed to test both the effectiveness of the proposed
may be implemented for future campaigns. cleaning regimen and the relative difficulty of clean-
ing the new soils that have already been introduced
Changeover Assessments to the plant” (4).
The sections that follow identify activities which may A well-designed cleanability study will assess the
be considered and leveraged to support a risk-based manufacturing process conditions and soil(s) as well
changeover. In addition to these, your organization as the cleaning cycle(s). During testing, both the soil
may have additional program data that may be lever- and cleaning cycles can be manipulated to further
aged to support further risk-based changeover prac- challenge the effectiveness of the cleaning cycle(s).
tices. While the primary goal of these studies is to determine
if the process soil is a new-worst case situation and
Recovery Studies that the cleaning cycles are appropriate, the data also
indirectly supports changeover. Through demonstrat-
The use of rinse and swab recovery studies in sup- ing that the process soils are cleanable at the labora-
port of cleaning validation is routinely performed. tory scale, the risk associated with decreasing or elim-
These studies demonstrate how the soil of interest inating elastomer change-out or changeover sampling
(cleaning agents, product, or process) adheres to the may be assessed.
Product Degradation/Denaturing/Inactivation that the toxic or potent component has been degraded or
denatured allows for product contact equipment to be
For multiproduct equipment cleaning validation, shared and not dedicated to a product. This also allows
cleaning acceptance limits for residual process ma- for other methods for calculating acceptance criteria to
terials are typically set based upon the product be used (8, 9). If removal of toxic or highly potent
dosage and/or health-based exposure limits such as residues is demonstrated, changeover activities of asso-
acceptable/permitted daily exposure (ADE/PDE) or ciated equipment may be reduced based on risk assess-
threshold of toxicological concern (TTC) of Product ments.
A. These values are used to calculate the maximum
allowable carryover (MAC) of residue from Product Cleaning Validation/Verification
A to Product B. However, the activity of biological
products such as monoclonal antibodies and thera- Cleaning validation establishes documented evi-
peutic proteins rapidly degrade/denature when ex- dence that a cleaning system (including cleaning
posed to pH extremes and/or heat, and thereby equipment, cleaning cycles, and associated proce-
become pharmacologically inactive (5, 6). When dures) performs as expected and that the parameters
product degradation and inactivation can be demon- of the cleaning cycle are adequate to ensure process
strated, the relative risk of product-to-product car- equipment is cleaned in an effective and consistent
ryover is significantly reduced. From a risk-based manner. With scientific guidance from the laborato-
perspective, demonstration of degradation/inactiva- ry-scale cleanabiltiy studies, the validation may be
tion lowers the associated risk of foregoing elasto- applied in a grouping approach to multiple products
mer change-out and drastically reduces or elimi- that are proven through laboratory-scale cleanabil-
nates the primary risk of product carryover between ity studies to be less challenging to clean. The
products. Furthermore, when product inactivation is advantage to changeover gained through cleaning vali-
demonstrated and cleaning validation has been com- dation is the potential reduction and/or elimination of the
pleted, the requirement for changeover sampling need to perform extensive sampling at each changeover,
may be assessed to reduce or eliminate sampling. By thereby reducing changeover time.
reducing or eliminating elastomer change-outs and
changeover sampling, the overall waste (e.g., mate- Cleaning verification is the process of collecting
rial disposal, equipment and resources availability) evidence to demonstrate that the equipment is prop-
associated with changeover is reduced. erly cleaned. Cleaning verification is typically used
where there are not sufficient process lots to per-
Product Toxicity/Potency form validation, or in support of investigations, as
well as during product changeover. The challenge
It is important to ensure that the potent or toxic with verification is that to fully demonstrate that the
process soil risk can be reduced during product residues have been removed from all surfaces, ex-
changeover in order to prevent cross-contamination tensive sampling (rinse and swab) throughout the
into the subsequent or concurrent product being man- equipment is required. This often necessitates dis-
ufactured within the facility. If process soils are toxic assembly and/or intrusive actions that can signifi-
or highly potent, then additional safeguards need to be cantly add to changeover times, especially when
considered in order to ensure pure, safe, and effective lock-out/tag-out and other safety requirements (e.g.,
product for patients. Safeguards that can be taken confined space tank entries) and post-sample re-
include product-dedicated equipment, use of cleaning cleaning are factored in. Therefore, if cleaning valida-
cycles that degrade or denature process soils, and/or tion has not been completed and cleaning verification is
product/component-specific assays. performed to support changeover, the reduction or elim-
ination of changeover sampling and elastomer change-
It is also important to understand the impact of the out are more difficult to justify.
cleaning cycles on the toxic or potent process soil. If
the cleaning cycle degrades, denatures, or in some Routine Monitoring
manner eliminates the potent or toxic aspect of the
process soil, and this can be proven, then the cleaning Routine monitoring of cleaning cycles is required to
acceptance criteria can be set using a non-specific provide ongoing evidence that the cleaning processes
limit rather than a specific assay. In addition, proving are effective in ensuring the equipment is clean and
TABLE III
Risk-Based Changeover Examples
ations. Valve diaphragms are evaluated for a smooth before, during, and after the process operations” (11).
surface finish and components that minimize wear The International Society for Pharmaceutical Engi-
from repeated toggling or use. The selection of elas- neering (ISPE) Baseline Pharmaceutical Engineering
tomer materials of construction ensures that they are Guide, Volume 6, provides guidance on performing
suitable for use in a multi-product environment and closure analysis. The ISPE guide breaks the process
that a comprehensive training program is in place to into three fundamental phases: Review and Selec-
ensure that elastomers are installed, maintained, and tion ➜ Calculations and Definitions ➜ Outcome.
handled in a manner that reduces the potential for
elastomer failure and subsequent potential product Although closure analysis is typically performed to
cross-contamination. assess viral and microbial control within the process,
the principles may be applied to the risk of simulta-
As noted above, soil cleanability of new or modified neous manufacture of multiple products. In the context
product and process materials is determined through of changeovers, closure analysis can be used to iden-
bench-scale cleaning evaluations. Using this data, a tify unit operations with sufficient controls to permit
risk assessment may be conducted to minimize or concurrent manufacturing. Systems or processes are
eliminate elastomer change-out from one product to defined as being briefly exposed, closed, functionally
the next. Once assessed, the need for elastomer closed, or open. Once the systems and processes have
change-out may be based on defined preventive main- been defined, an assessment may be performed to
tenance intervals (10). determine which unit operations have adequate con-
trols to permit concurrent manufacturing. Concurrent
Closure Analysis manufacturing allows the simultaneous manufacture
of multiple products within a well controlled area.
“Closure analysis is a type of a risk assessment that From a lifecycle perspective, the changeover path to
should focus on the probability and severity of expos- concurrent manufacturing may occur incrementally.
ing a process system to the surrounding environment When closure analysis has been completed and all
controls required by quality risk assessments have With disposable technology, the permanent surfaces
been assessed and are in use, concurrent manufactur- are replaced by disposable plastic surfaces with inher-
ing may be implemented. With each new product, the ent appurtenances that enable process control of the
process must be performed; however, data can be contents. Current examples include single-use biore-
leveraged, potentially shortening the process. actors (SUBs), single-use mixing systems (SUMs),
and disposable skids for depth filtration, chromatog-
Once the requisite data has been generated to support raphy, and ultrafiltration.
concurrent manufacturing, logistical efficiencies are
also necessary to facilitate concurrent manufacturing. The advantage of disposable technology, aside from
The staging of changeover parts must be both efficient the elimination of cleaning, is the minimizing of mov-
and timely. Sufficient trained resources must be avail- able parts and piping connections, which reduces the
able to guarantee the efficient changeover between need for change-out of gaskets, o-rings, valve dia-
products. Tools such as single-minute exchange of die phragms, and other elastomers. By being entirely non–
(SMED) may be used to improve logistical change- product contact, the replacement of any elastomeric
over efficiency. In an ideal state, sufficient controls are surfaces on disposable equipment is dictated by a PM
in place, cleaning processes are validated, products are schedule only and is not required during product
non-toxic and non-potent, and product degradation has changeover, further enabling the implementation of
demonstrated that the requirement for changeover may risk-based changeover practices.
be minimized or even eliminated.
Examples of Risk-based Application
Viral Reduction and Segregation
The examples provided in Table III and Figure 3 are
not intended to explicitly define the changeover re-
Another consideration of risk-based changeover is the
quirements for the systems discussed; they merely
viral reduction and viral segregation controls of the
provide a general guidance on what the application of
process. Viral reduction studies are typically per-
risk assessments to determine changeover controls
formed to demonstrate the ability of cleaning pro-
may permit. The level of risk tolerance and product-
cesses, steam-in-place (SIP) or autoclave processes, to
specific considerations of those performing the assess-
reduce viral loads to acceptable levels. The studies
ments may result in different outcomes than those
may be used to assess the risk associated with change-
shared below. The intent is to demonstrate how the
overs in which pre-viral inactivation portable equip-
guidance may be generically applied.
ment are moved to post-viral inactivation steps. De-
pendent on the viral reduction studies and viral
Conclusion
controls, a risk assessment of the need for elastomer
change-out may be performed to prescribe the appro- Traditional changeover philosophies and methods are
priate level of elastomer change-out. For systems such being revisited as the needs of the industry have
as portable tanks that incorporate SIP unit operations, changed over time. Current regulatory guidance sup-
the need for elastomer change-out may not be neces- ports the use of appropriate, scientifically justified,
sary. However, for systems that are incapable of SIP risk-based changeover methods, some of which have
operations, the change-out of elastomers as well as been outlined in this article. Utilizing a risk-based
other decontamination processes must be considered approach supported by a strong data set comprised of
and may be required. items such as bench-scale studies, cycle validation,
and lifecycle management, the efforts and inefficien-
Disposable Technology cies of the traditional changeover model can be re-
duced. However, any reduction in changeover activi-
The use of disposable technology in biologics man- ties must be able to be readily defended to demonstrate
ufacturing allows for the complete adoption of risk- that the appropriate product carryover controls are in
based changeover principles by eliminating the place to ensure both product and patient safety.
sources of potential product carryover: the perma-
nent stainless steel, glass, or acrylic surfaces that Glossary
require cleaning in between use and the elastomer
surfaces that require replacement for absolute as- Briefly Exposed—Open processes containing process
surance of residual product removal. and/or product components that are rendered closed by
means of an appropriate closing process (e.g., media includes parts changeover and/or special cleaning to
and buffer operations) (12). eliminate cross-contamination (17).
Crossover—Contamination of a system by compo- The author(s) declare that they have no competing
nents or contaminants found in neighboring system. interests.
Crossover typically occurs with open processes shar-
ing environments. Crossover can also occur when References
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