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Cleaning Validation - WHO LPA - Virtual GMP Training Marathon - Sep-Nov 2020
Cleaning Validation - WHO LPA - Virtual GMP Training Marathon - Sep-Nov 2020
Cleaning Validation - WHO LPA - Virtual GMP Training Marathon - Sep-Nov 2020
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Cleaning Validation
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Disclaimer
© LPA
17/12/2020
Topic
• General Principle
• Cleaning Validation Execution
• Process development
• Process validation
• Continued process verification
• Revalidation
• When cleaning validation fails….
© LPA
General Principle
© LPA
WHO TRS 1019, Annex 3, 2019
Good manufacturing practices: guidelines on validation
Other
Technical guides
© LPA
WHO TRS 1019, 2019 Annex 3, Appendix 3: Cleaning validation
© LPA
PIC/S GMP PE009-14, Annex 15- 01 July 2018:
Qualification and Validation
© LPA
• WHO TRS 999, Annex 2, 2016: WHO GMP for Biological Products
© LPA
21 CFR211.67(a)
US-FDA • Equipment and utensils shall be cleaned, maintained, and, as appropriate for the
nature of the drug, sanitized and/or sterilized at appropriate intervals to prevent
malfunctions or contamination that would alter the safety, identity, strength,
quality, or purity of the drug product beyond the official or other established
requirements.
21 CFR111.27(d)
• You must maintain, clean, and sanitize, as necessary, all equipment, utensils, and
any other contact surfaces used to manufacture, package, label, or hold
components or dietary supplements.
21 CFR 810.70(e)
© LPA
Possible Contaminants in Pharmaceutical
Products to be removed by cleaning
• Contaminants associated with microbes (Bioburden and endotoxins)
• Previous products
• active pharmaceutical ingredients [APIs]
• excipient residues
• Residues of cleaning agents
• Airborne materials,
• Dust and particulate matters
• Lubricants
• Ancillary material, such as disinfectants, and decomposition residues from:
• product residue breakdown caused by using strong acids and alkalis during the cleaning
process;
• breakdown products of the detergents, acids and alkalis that may be used as part of the
cleaning process.
© LPA
Objective of cleaning validation
• To prove that the equipment is consistently cleaned of
• product,
• detergent and
• microbial residues
to an acceptable level
• To prevent possible
• contamination and cross-contamination
© LPA
Scope of cleaning validation
• Cleaning validation considered as important in multiproduct
facilities
• …..(Cleaning validation) SHOULD be performed, among others, for
• Equipment
• Sanitization procedures disinfection process validation
• Garment laundering
• Normally, cleaning validation would be applicable for critical cleaning
such as
• Cleaning between manufacturing of one product and another
• Cleaning of surfaces that come into contact with products, drug products and
APIs
© LPA
Scope of cleaning validation
“In general, cleaning validation
• Cleaning validation NOT necessarily should be directed to situations or
required for NON-CRITICAL cleaning such process steps where contamination
as or carryover of materials poses the
• cleaning takes place between batches of the greatest risk to API quality.
same product
• cleaning takes place on different lots of the For example, in early production it
same intermediate in a bulk process may be unnecessary to validate
• cleaning of floors, walls equipment cleaning procedures
• cleaning outside of vessels, where residues are removed by
• cleaning following some intermediate steps subsequent purification steps.”
ICH Q7
© LPA
General
Validation
Cleaning SOPs
• Cleaning validation plan (master plan)
• Cleaning validation protocols Cleaning
validation
• Cleaning validation reports (master) plan
Protocol
Data integrity - important
Report
© LPA
Manufacturer’s Cleaning policy and/or
cleaning procedure
• To cover these followings:
• Cleaning of Product contacted surfaces
• Cleaning after product changeover e.g. when changing one pharmaceutical
formulation to another
• Between batches in campaigns (when the same formula is being
manufactured over a period of time, and on different days);
© LPA
Cleaning policy and/or cleaning procedure
(continued)
• Bracketing products for cleaning validation.
• where products contain substances with similar properties [such as
solubility]
• where products contain the same substance in different strengths. An
acceptable strategy is to first manufacture the more dilute form [not
necessarily the lowest dose] and then the most concentrated form.
• There are sometimes “families” of products which differ slightly as to actives
or excipients.)
• Periodic evaluation
• Revalidation
© LPA
Bracketing
• Cleaning procedures for products and processes that are very similar
do not need to be individually validated.
• A validation study of the “worst case” may be considered acceptable.
There should be a justified validation programme for this approach,
referred to as “bracketing”, addressing critical issues relating to the
selected product, equipment or process.
• Where “bracketing” of products is done, consideration should be
given to the type of products and equipment.
© LPA
Bracketing strategies
By Product By Equipment
• Similar products by nature, risk, •Similar type of equipment
therapeutic or other properties and •Similar MOC
• Processed by the same equipment •Same type of equipment but
and different size e.g. 300 L, 500 L and
• Identical cleaning procedure 1000 L tanks
• Worst case – Product most difficult •Alternative approach -Smallest and
to clean largest batch size of the products to
be validated separately
© LPA
Grouping of products by Therapeutic Use
• The risk associated with contamination and cross-contamination from one
product to another product in one therapeutic group, and between products in
different therapeutic groups in shared facilities, should be considered.
• For example, due to the risk, certain products should be manufactured in
dedicated or segregated self-contained facilities, including
• Certain antibiotics,
• certain hormones,
• certain cytotoxics and
• certain highly-active drugs
even though these are in the same therapeutic class.
• The risk assessment should include, for example, PDE values, batch size,
maximum daily dose of the next product, as well as other criteria associated with
cleaning.
© LPA
Cleaning Validation Execution
© LPA
Process Validation Principle
Principle of Process Validation to be applied:
• 3 stages of validation –
• Stage 1 - Process design (Process development)
• Stage 2- Process validation (Process performance
qualification)
• Stage 3 –Continued process verification
• Revalidation
© LPA
Terms related to new approach for cleaning
validation
• margin of safety. The margin of safety is the distance between a calculated acceptance
limit and the actual residues after cleaning. It indicates the probability that a patient has
to be exposed to the API residues resulting from cleaning.
© LPA
Maximum Safe Carryover (MSC)
• MSC calculation = ADE*(N/D)*(SWA/SSA)*Rs
Abbreviation Description
ADE Acceptable daily exposure (mg/day)
N Number of doses in the batch
D Maximum number of daily doses
SWA Surface area of the sample point
SSA Shared surface area between product A and B
R Recovery factor for a surface type
The equation is executed for all combinations of Product A to B within a product matrix, not just worst case.
Reference : PDA TR29
© LPA
Process validation element mapping
© LPA
Designing cleaning process -knowing historical
and scientific data
Factors to be considered:
• i. Time
• ii. Temperature
• iii. Cleaning agent & concentration
• iv. Flow rate
© LPA
Cleaning process development: Laboratory-
scale first!
• Laboratory-scale studies can answer typical cleaning validation
questions such as:
• Which product is the hardest to clean?
• Which cleaning agent provides the best cleaning?
• Can we demonstrate that two cleaning agents are equivalent?
• Which cleaning input parameters are critical?
• What are the optimal cleaning parameter settings?
• How long does it take to clean the equipment?
• Are dirty-hold-time studies necessary at commercial scale?
• Are clean-hold-time studies necessary at commercial scale?
© LPA
UNDERSTANDING CLEANING MECHANISM
to remove residues from equipment
• Mechanical / Physical action e.g.
• brushing
• scrubbing
• pressurized water to remove particulates
• Dissolution
• Water -most common and practical solvent
• non-toxic, cheap, does not leave residues, environment friendly
• Non-aqueous solvent or Aqueous + Non-aqueous solvents due to the
solubility characteristics of the materials.
• Alkaline or acidic solvents may enhance dissolution of the materials and could
be advantageous.
© LPA
UNDERSTANDING CLEANING MECHANISM
to remove residues from equipment (continued)
• Detergent requires the use of surfactant, usually in an aqueous
system. Detergents act in four different ways:
• wetting agent
• solubilizers
• emulsifiers
• dispersants.
• Chemical reactions e.g.
• Oxidation and hydrolysis in which the residues are chemically changed.
Example: Sodium Hypochlorite
© LPA
CLEANING AGENT/DETERGENT/SOLVENT :
Cleaning agents or detergents should be selected carefully.
© LPA
Cleaning method:
Manual Cleaning Method
• Difficult to validate
• Most extensive and elaborate cleaning procedures required
• High quality and extensive training program required.
• Risk involved in manual cleaning processes is taken care of with
following technical and organizational control:
• Proper washing room design with drying, protection and storage
requirement.
• Detailed cleaning SOP
• Training / Qualification of cleaning operators
• Quality of water use
© LPA
Cleaning method:
Clean-In-Place(CIP)Method
• Cleaning of the equipment is performed in place without
disassembling
• Cleaning process may be controlled manually or by an automated
program
• Very consistent and reproducible cleaning method
• Can be validated readily
• Being a closed system visual inspection of all components is difficult.
© LPA
Cleaning method:
Clean-Out-Of-Place (COP) Method
• Cleaning of disassembled equipment is performed in a central
washing machine.
• The washing machine also requires validation such as :
• Temperature
• Ultrasonic activity
• Cycle time
• Cleaning operation sequence
• Detergent quantity dispensed
• etc.
© LPA
Choosing the Cleaning Method
CIP : Clean in Place
© LPA
Developing Cycle Times for Cleaning Procedure
CIP- Cycle times
determined by
controlling the • detergency,
primary factors contact time.
of cleaning
efficacy
• temperature
conductivity
Online monitors pH
and sensors for detergent supply flow rate,
pressure sensors
etc.
© LPA
Automatic process
• Validation should consider the level of automation in the cleaning
process.
• Where an automatic process is used, the specified normal operating
range of the utilities and equipment should be validated.
© LPA
Microbiological Risk
• Risk presented by microbial and endotoxin contamination should be considered
during the development of cleaning validation protocols.
• Influence of the time between manufacture and cleaning and the time between
cleaning and use should be taken into account to define dirty and clean hold
times for the cleaning process.
• Impact on the ease of cleaning at the end of the campaign should be considered
and the maximum length of a campaign (in time and/or number of batches)
should be the basis for cleaning validation exercises.
© LPA
Microbiological risk
• Equipment should be stored in a dry condition after cleaning. Stagnant water
should not be allowed to remain in equipment after cleaning.
• Control of the bioburden through adequate cleaning and appropriate storage of
equipment is important to ensure that subsequent sterilization or sanitization
procedures achieve the necessary assurance of sterility, and the control of
pyrogens in sterile processing.
• Equipment sterilization processes may not be adequate to achieve significant
inactivation or removal of pyrogens.
© LPA
• For all cleaning processes an assessment should be performed to
determine the variable factors which influence cleaning effectiveness
and performance, e.g. operators, the level of detail in procedures
such as rinsing times etc.
• If variable factors have been identified, the worst case situations
should be used as the basis for cleaning validation studies.
© LPA
Worst Case considerations
Once the product groups have been established, the next step is to determine the
so-called “worst case” representative of each group.
It is that member(s) who shows the highest challenge on cleaning program.
Worst case product : Toxicity / solubility / highly characterized / difficult to clean
ingredients.
Worst case eq. train : Longest train.
Worst case equipment : Larger size equipment (identical design), hardest to clean
Worst case acc. criteria: Stringent acceptance criteria.
Hold time studies : Longest possible duration.
Campaign Mfg. : Highest possible nos. of batches.
26
© LPA
Sampling procedure
Rinse
For inaccessible areas Swab
and sampling large For most desirable direct method of
surface areas surface sampling
© LPA
Swab sampling (Direct method)
• Factors that should be considered include
• supplier of the swab,
• Area swabbed,
• number of swabs used,
• whether they are wet or dry swabs,
• Swab handling and swabbing technique.
• Critical areas, that is, those that are hardest to clean, should be
identified, particularly in large systems that employ semi-automatic or
fully automatic clean-in-place systems.
• The sampling medium and solvent used should be appropriate to the
task.
© LPA
Rinse sample (Indirect method)
• Allows sampling of a large surface, of areas that are inaccessible or that
cannot be routinely disassembled, and provides an overall picture.
• Rinse samples may give sufficient evidence of adequate cleaning where
accessibility of equipment parts can preclude direct surface sampling, and
may be useful for checking for residues of cleaning agents, for example,
detergents.
• Rinse samples should be used in combination with other sampling methods
such as surface sampling.
• There should be evidence that samples are accurately recovered. For
example, a recovery of >80% is considered good, >50% reasonable and
• <50% questionable.
© LPA
Batch Placebo Method
• The batch placebo method should be used in conjunction with rinse
and/or surface sampling method(s).
• Samples should be taken throughout the process of manufacture.
Traces of the preceding products should be sought in these samples.
(Note that the sensitivity of the assay may be greatly reduced by
dilution of the contaminant.)
© LPA
Sampling Locations
Worst case locations for contaminants
© LPA
Critical Supportive Data/Information for
Cleaning Validation
• Surface recovery studies e.g. Stainless steel, glass etc.
• Hold time studies-
• Clean equipment hold times,
• Dirty equipment hold times,
• Sample hold times
• Procedure for collecting rinse, swabs and performing visual inspection
• Analytical test method validation
© LPA
Sampling Recovery Studies
© LPA
Test Methods for Cleaning Validation
© LPA
Analytical Test Methods
Non Specific Assay
TOC
pH (cleaning agent residue)
Conductivity (cleaning agent residue)
Titrations
UV-spectroscopy
Bioburden
Limulus Amoebocyte Lysate (LAL)
© LPA
Acceptance criteria
28
© LPA
Limit Setting Approach
• The limit-setting approach can:
• be product-specific;
• group products into families and choose a worst-case product;
• group products into groups according to risk, for example, very soluble
products, products with similar potency, highly toxic, or difficult-to-detect
products;
• use different safety factors for different dosage forms, based on physiological
response (this method is essential for potent materials)
© LPA
Limit Setting Approach
• Limits may be expressed as a concentration in
• a subsequent product (parts per million – ppm),
• limit per surface area (µg/cm2), or
• in rinse water as ppm.
• The sensitivity of the analytical methods should be defined, to enable
• reasonable limits to be set.
• The rationale for selecting limits for carry-over of product residues
should meet defined criteria.
© LPA
• Certain allergenic ingredients
• penicillins and cephalosporins) and
• highly potent material (e.g. anovulent steroids, potent steroids and cytotoxics)
should be undetectable by the best available analytical methods.
• In practice, this may mean that dedicated manufacturing facilities
should be used fr the manufacture and processing of such products.)
© LPA
Acceptance criteria
• A visual check for cleanliness is an important part of the acceptance
criteria for cleaning validation. It is not generally acceptable for this
criterion alone to be used.
• Repeated cleaning and retesting until acceptable residue results are
obtained is not considered an acceptable approach.
© LPA
Limits for the carryover of product residues
© LPA
Maximum Safe Carryover (MSC)
• MSC calculation = ADE*(N/D)*(SWA/SSA)*Rs
Abbreviation Description
ADE Acceptable daily exposure (mg/day)
N Number of doses in the batch
D Maximum number of daily doses
SWA Surface area of the sample point
SSA Shared surface area between product A and B
R Recovery factor for a surface type
The equation is executed for all combinations of Product A to B within a product matrix, not just worst case.
Reference : PDA TR29
© LPA
Acceptance Criteria for Cleaning
Acceptance criteria for selected test markers include the following:
• Visual inspection –Visual cleanliness
• Bioburden -Microbial load cfu/ml
• LAL -Endotoxin (EU/ml)
• Conductivity -Cleaning agent uS/cm
• TOC -Total organic carbon (ppm)
Test method for any analyte associated with process/product/ cleaning
agent and critical for demonstrating effectiveness of cleaning procedure.
© LPA
• Time when equipment dirty to equipment cleaned
Dirty Equipment • Nature of soil may change overtime with drying or
Hold Times microbial proliferation Changes make soil more
difficult to remove by the cleaning process
Times
Sample Hold • Time test samples collected to time test samples
tested
times
© LPA
Cleaning validation of Chromatography-
Biopharmaceutical Products/ Biological Products
• During regulatory inspections, manufacturers of biopharmaceuticals
and biological products often find attention directed to cleaning and
cleaning validation of chromatography resins and multiuse
purification systems.
• Chromatographic resins must either be disposed of or sufficiently
cleaned to ensure reproducibility in subsequent cycles.
• The decision to recycle or dispose of resins is typically driven by cost.
The economics depend on unit operation scale, resin cost and
compatibility with cleaning agents, feedstream quality, position of the
resin in the purification scheme, and stage of product development.
© LPA
Same questions to be asked when cleaning/
Cleaning validating Chromatography-1
• How will you measure cleanliness?
• TOC , HPLC , SDS-PAGE, UV-Spectro, pH, Conductivity – to be justified
• Visual inspection
• What are you trying to remove? To consider…
• Basic chemistry of what to be removed, Nature of surface of what to be removed
from it.
© LPA
Same questions to be asked when cleaning/
Cleaning validating Chromatography-2
• What is the best cleaning method?
• Compatibility of the resin and associated equipment wetted surfaces with available
and affordable cleaning agents (Data from vendor –important!)
• Capability to use a cleaning agent in production environments, and ability of the
cleaning protocol to deliver a resin meeting its acceptance criteria.
• NaOH, NaCl - most used cleaning agents
• Additional cleaning agents may be required. When selecting a cleaning agent, make
sure you can detect it to demonstrate its removal before reuse of resins and
equipment.
• For example, anion-exchange column loaded with high level of DNA during protein
purification, very difficult to remove DNA.
• Dnase could be used to clean the column; cost of disposing the resin comparing with cost of
cleaning agent and validation of its removal to be determined.
• Alcohols are sometimes used for cleaning, and their removal must also be validated.
• Safety concern when using alcohol, Heated NaOH, etc.
© LPA
Same questions to be asked when cleaning/
Cleaning validating Chromatography-3
• How clean is clean?
• Maximum carry over limit to be determined based on QRM
• Cleanability studies to be performed
• Adequately cleaned columns should repeatedly provide an intermediate
product that possesses its critical quality attributes.
• To understand the product and the impurities that are removed in every
purification step.
• Attention to Virus clearance
© LPA
Process validation
© LPA
Cleaning Validation Protocol
© LPA
Cleaning validation report
• Relevant cleaning records (signed by the operator, checked by
production and reviewed by quality assurance)
• Source data (original results) should be kept.
• The results of the cleaning validation should be presented in cleaning
validation reports stating the outcome and conclusion.
© LPA
Continued Process Verification
© LPA
Goal - to operate at process capability that
ensures that predefined acceptance limits are
consistently met in a reproducible manner
Considerations
for Process Residue data used to generate process limits
Capability,
Reliability and
Consistency
Acceptance limits - scientifically justifiable,
achievable and risk-based.
© LPA
Goal - to operate at process capability that
ensures that predefined acceptance limits are
consistently met in a reproducible manner
Considerations
for Process Residue data used to generate process limits
Capability,
Reliability and
Consistency
Acceptance limits - scientifically justifiable,
achievable and risk-based.
© LPA
Process capability
Reference: PI 006-3
© LPA
Reference: www.rockfordpowertrain.com/supplier
What is process capability? It is a
measure of how well
a process is within a specification. A
CpK =
A divided by
B B
Specification Specification
Limit Limit
CpK = A divided by B
A = Distance from process mean to closest spec limit
B = 3 Standard Deviations (also called “3 Sigma”)
© LPA
“Process Capability” is the ability of a process
to fit its output within the tolerances.
A
CpK =
A divided by
B B
Specification Specification
Limit Limit
…a LARGER “A”
…and a SMALLER “B”
…means BETTER “Process Capability”
© LPA
An Analogy
A
CpK =
A divided by
B B
Specification Specification
Limit Limit
Analogy:
The bell curve is your automobile.
The spec limits are the edges of your garage door.
If A = B, you are hitting the frame of your garage door with your car.
© LPA
What does a very good CpK do for us?
A
This CpK is
B about 2.
Very good!
Specification Specification
Limit Mean Limit
Note that when CpK = 2, our process mean is 6 standard deviations from
the nearest spec, so we say it has “6 Sigma Capability.”
© LPA
What does a problem CpK look like?
A
This CpK is just
B slightly greater
than 1. Not good!
Specification Specification
Limit Limit
© LPA
What does a very bad CpK look like?
A
This CpK is less
B than 1. We desire
a minimum of 1.33
and ultimately we
want 2 or more.
Specification Specification
Limit Limit
A significant part of the “tail” is hanging out beyond the spec limits.
This process is producing scrap, rework, and customer rejects.
Notice that if distance “A” approaches zero…
…the CpK would approach zero, and…
…the process would become 50% defective!
© LPA
Monitoring data provides important information
Application of for defining the cleaning process capability.
Continued
Process
Verification and The trend is to depart from the use of general
default limits, no-observed-effect levels (NOELs)
Continual and toxicity limits to risk and statistically derived
improvement criteria that are based on process performance
© LPA
© LPA
What does a very good CpK do for us?
A
This CpK is
B about 2.
Very good!
Specification Specification
Limit Mean Limit
Note that when CpK = 2, our process mean is 6 standard deviations from
the nearest spec, so we say it has “6 Sigma Capability.”
© LPA
Cleaning validation vs. Cleaning Verification
© LPA
Revalidation
• To be done when there is a change of the cleaning procedure e.g.
• Type of cleaning agent
• Cleaning agent concentration
• Equipment
• Etc.
© LPA
What about you?
© LPA
References
• WHO TRS 1019, Annex 3, Appendix 3: Cleaning validation
• PIC/S GMP Annex 15 Qualification and Validation
• US FDA, Validation of Cleaning Processes (7/93): GUIDE TO
INSPECTIONS VALIDATION OF CLEANING PROCESSES, 2014
• Cleaning Validation for The 21st Century, Pharmaceutical Online
• Ruijin Song; Alfredo Canhoto, Ph.D.; and Andrew Walsh: Cleaning
Process Development: Cleanability Testing And "Hardest-To-Clean"
Pharmaceutical Products, Pharmaceutical Online, January 18, 2019
• PDA TR 29 and PDA TR 49
© LPA
Disclaimer
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17/12/2020
Thank you
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