The authors recommend a strategy for classifying similar nonstainless-steel surfaces into three groups based upon the analytical recovery that was observed in this study.
The US Code of Federal Regulations states that equipment and utensils shall be cleaned, maintained, and sanitized at appropriate intervals to prevent malfunctions or contamination that would alter the safety, identity, strength, quality, or purity of the drug product (2). In accordance with 21 CFR 211.67, ICH issued recommendations on equipment maintenance and cleaning (Q7A, Sections 5.20–5.26) for compliance and safety that include similar, but more detailed requirements (3).
The US Food and Drug Administration's 1993 guidance on cleaning inspections states that for a swab method, recovery should be established from the surface (4). The guidance contains no specific requirements about how to establish these recovery estimates, or the acceptance limits. It is up to the manufacturer to document the cleaning rationale (i.e., process and acceptance limits) for maintaining the quality and purity of the drug product being manufactured.
Cleaning validation and verification
Cleaning verification consists of routine monitoring (e.g., swab analysis) of equipment-cleaning processes. Cleaning validation confirms the effectiveness and consistency of a cleaning procedure and eliminates the need for routine testing (5). For example, cleaning limits are established to determine the maximum allowance of Product A that can carry over to Product B. The calculation of these limits is well documented and includes factors that increase the margin of safety to protect the patient (6, 7). Because it is not feasible to swab every square inch of the equipment, swabbing locations are chosen based upon factors such as how difficult the area is to clean, the size of the equipment, and the areas where product buildup is likely. All product-contact surfaces must be considered during cleaning verification to demonstrate that equipment is clean, and a recovery value is expected to be established for each product-contact surface during method validation. The recovery is used to correct the submitted swab result for incomplete removal from the surface and to compare it with the acceptance limit. This last aspect of risk management (i.e., establishing the surface recovery) is the focus of this article.
Several variables (i.e., roughness average, material of construction, active ingredient, and spiked amount) were evaluated in a randomized fashion to prevent systematic bias that could be introduced by going from the lowest to the highest acceptance limit, from the smoothest to the roughest surface, or from one material of construction to the next. The initial design of experiments included two active pharmaceutical ingredients (APIs), three spiked acceptance-limit levels (i.e., 0.5, 5.0, and 50 μg/swab), seven surface types, four target roughness averages (Ra < 25, 75, 125, and 150 μin.), and six replicates per surface. These Ras were targeted to evaluate whether surface recovery depended on the surface Ra. Coupons were divided into a group of polymers [i.e., Lexan (polycarbonate), acetal (Polyoxymethylene), and PTFE] and a group of metals (i.e., stainless steel 316L, bronze, Type III hard-anodized aluminum, and cast iron). These surfaces were chosen to represent a cross section of surfaces found in the CTM manufacturing and packaging areas and required 1008 swab determinations to complete the study. The remaining product-contact surfaces found in the clinical-trial manufacturing and packaging areas were evaluated according to the initial design of experiments. These surfaces included nickel, anodized aluminum, Rilsan (polyamide), Oilon (blended-oil nylon), and stainless steel 316L with a 4 × 4-in. area.
The authors chose two APIs for this evaluation on the basis of their solubility profiles to represent the most- and least-soluble compounds a company would likely manufacture. Compound A, the less soluble, is slightly soluble in methanol and insoluble across the pH range, but Compound B is soluble in all solvents. In addition, Eli Lilly (Indianapolis, IN) identified Compound A as one of the most difficult compounds to clean from equipment, based on its low solubility and staining properties. A control (i.e., stainless steel 316L, 0.5 μg/swab, Compound A) was run each day that data were generated.
Equipment and operating conditions
In this study, a single analyst evaluated the analytical swab recovery from a representative set of surfaces found in the CTM manufacturing and packaging areas. The surfaces were manufactured specifically for this study to have a broad range of Ras. In addition to Ra, the effect of the material of construction, acceptance limit, compound, and method variability also were evaluated. Based upon these data sets, the authors used a strategy involving three groups of materials to represent all of the surfaces in CTM operations. Merck and Co. used a similar strategy to establish five recovery groups (9). The authors expanded on Merck's strategy by adding a detailed study supporting the groups and an approach for determining the appropriate placement of new surfaces into pre-established groups.
Roughness average (Ra). The Ra targets listed above were difficult to achieve. The intermediate Ra values were significantly lower than the target values given in the design of experiments section above. Both intermediate Ra values, initially targeted for 75 and 125 Ra, were measured to be approximately 40 μin. Although the machining process at each level yielded visually different surfaces, the measured Ra changed little from surface to surface. The authors decided to proceed with the surfaces and define smooth surfaces as Ra < 100 μin. and rough surfaces as Ra > 100 μin. This approach allowed for an assessment of the anticipated relationship between Ra and analytical recovery.
Variability. Method variability was evaluated by performing a control sample (Compound A, 6 replicates, 0.5-μg swab, stainless steel 316L, Ra = 3.5) each day. The mean recovery of the entire experiment was 52%. These data suggested that the swabbing ability of the analyst did not change over time. The standard deviation within a day typically was less than 6. The pooled-within-run standard deviation was 3.99 over the course of the experiments. This value was used as a criterion for grouping new surfaces. The day-to-day standard deviation was 15.34.
The analytical recovery of Compound A was evaluated for Ertalyte, stainless steel 420, and stainless steel 630 at the 5.0-μg/in. 2 level. The authors used the validated method to evaluate the recovery of the three new surfaces compared with a representative surface from Group 1 (i.e., stainless steel 316L), Group 2 (i.e., cast iron), and Group 3 (Type III hard anodized aluminum). Recovery was evaluated for both the group representative and the new surfaces on the same two days with three replicates on each day. As an alternative, six replicates may be performed on the same day as the controls because the comparison of recovery is relative.
- If the NSR > mean stainless-steel recovery – 3.0%, the new surface belongs in Group 1.
- If the NSR > mean cast-iron recovery – 3.0%, the new surface belongs in Group 2.
- If the NSR > mean Type III anodized aluminum recovery – 3.0%, the new surface belongs in Group 3.
- If the NSR < mean Type III anodized aluminum recovery – 3.0%, the new surface becomes a new group or becomes the worst-case surface for Group 3 and is used in all future method validations.
The authors' data-driven risk-management approach to cleaning verification methods uses analytical-recovery values for a model compound to place product-contact surfaces into groupings for analytical-method validation. The data generated during the studies supported the formation of three recovery groups to validate analytical swab methods. Groups 1–3 were represented by stainless steel 316L, cast iron, and Type III hard anodized aluminum, respectively. This approach allowed all surfaces to be considered during analytical-method validation and provided an objective mechanism to incorporate new surfaces into the strategy.
The benefits of this strategy are numerous. First, only three surfaces must be validated on each compound, which drastically minimizes the number of recovery values established to support the entire portfolio. Second, the strategy includes a way to add new materials of construction to the cleaning program if new equipment is purchased. Traditionally, all swab methods must be revalidated to incorporate the new surface. With this strategy in place, a model compound is evaluated, the new surface is grouped, and no changes to existing methods are required. Third, the strategy allows for a constant state of compliance. A relative recovery value is known for any material of construction for all equipment.
Because the grouping strategy is applied to a small fraction of the total surface area, no surface material of construction is ignored, each molecule undergoes a typical method validation, and the strategy places surfaces into groups conservatively. The authors believe that the strategy controls risks appropriately and that the data set given in this study scientifically supports the strategy of grouping materials of construction to support analytical methods within the cleaning program.
The authors would like to acknowledge the following colleagues at Eli Lilly: Gifford Fitzgerald, intern, for generating the swab-recovery data; Ron Iacocca, research advisor, for the SEM data; Sarah Davison, consultant chemist; Mike Ritchie, senior specialist; Mark Strege, senior research scientist; Matt Embry, associate consultant chemist; Kelly Hill, associate consultant for quality assurance; Bill Cleary, analytical chemist; and Laura Montgomery, senior technician, for their contributions and insightful suggestions throughout the project. In addition, Leo Manley, associate consultant engineer, provided the roughness measurements in support of this project.
Brian W. Pack* is a research advisor for analytical sciences research and development, and Jeffrey D. Hofer is a research advisor for statistics, discovery and development, both at Eli Lilly and Company, Indianapolis, IN, tel. 317.422.9043, firstname.lastname@example.org [email@example.com]
*To whom all correspondence should be addressed.
Submitted: Oct. 12, 2009. Accepted: Dec. 22, 2009.
1. ICH, Q9 Quality Risk Management, Step 5 version (2005).
2. Code of Federal Regulations, Title 21, Food and Drugs (Government Printing Office, Washington, DC), Part 211.67.
3. ICH, Q7 Good Manufacturing Practice Guide for Active Pharmaceutical Ingredients, Step 5 version (2000).
4. FDA, Guideline to Inspection of Validation of Cleaning Processes (Rockville, MD, July 1993).
5. L. Ray et al., Pharm. Eng. 26 (2), 54–64 (2006).
6. PDA, Technical Report 29, "Points to Consider for Cleaning Validation" (PDA, Bethesda, MD, Aug. 1998).
7. G.L. Fourman and M.V. Mullen, Pharm. Technol. 17 (4), 54–60 (1993).
8. ICH, Q2 Validation of Analytical Procedures: Text and Methodology, Step 5 version (1994).
9. R.J. Forsyth, J.C. O'Neill, and J.L. Hartman, Pharm. Technol. 31 (10), 102–116 (2007).