Thursday, December 21, 2017

Chemical quality control analysis method validation technical guidelines



Chemical quality control analysis method validation technical guidelines 

I. Overview
To ensure drug safety, effectiveness, quality control is the basic principles of drug development and evaluation should be followed,  Among them, the quality control of medicines is the basis and premise to ensure the safety and effectiveness of medicines. To achieve control The purpose of quality control, the need for multi-angle, multi-level control of drug quality, that is to drugs
Conduct multiple project tests to thoroughly examine drug quality. In general, each test item is optional Different analysis methods, in order to make the test results accurate and reliable, we must analyze the method used Scientific, accurate and feasible verification to fully demonstrate that the analysis method is in line with the test project Purpose and requirements, which is commonly referred to as validation of the method. The purpose of method validation is to determine whether the analytical method used is scientific, reasonable and effective
The intrinsic quality of pharmaceuticals. In essence, the method validation is based on the requirements of the test items, pre- First set a certain content of the verification, and through the design of a reasonable test to verify the analysis method used Can meet the requirements of test items. Method validation plays an important role in the establishment of analytical methods and has become a quality research and quality The component of volume control. Only validated analytical methods can be used to control the quality of medicines This method of verification is the basis for the development of quality standards. Method validation is an important part of the drug research process.
This guideline focuses on the essentials of method validation, combining the requirements of analytical method validation with the desired To the purpose of combining systematic andregular elaboration, focusing on how to scientifically and reasonably Design of line demonstration scheme. The guiding principle mainly includes the general principles of method verification. The method verification involves three main parties

Surface, method of verification of the specific content of the method of verification and other content. This principle together with other relevant technical guidelines constitute a more complete quality control guidelines. With the continuous improvement of R & D level of new drugs in our country, the understanding of method validation will continue to deepen
Guiding principles will be gradually improved and revised. Due to the particularities of biological products and Chinese medicines, this principle is mainly applicable to chemical products. Second, the general principles of method validation
In principle, the method of analysis used in each test item requires method validation.
The content of the method validation should be based on the requirements of the test items, combined with the characteristics of the analysis method used determine. The same analysis method used for different test items will have different validation requirements. For example, adopted HPLC for the identification of reagents and impurities Quantitative test methods should be different requirements of the test The former focuses on the verification of the specialization, while the latter focuses on the verification of the specificity, accuracy and reliability
Limits Third, the method validation involves the three main aspects
(A) the need to verify the test items
Test items is to control the quality of medicines, to ensure safe and effective set of test items. according to The purpose of the test items and the verification requirements of the different requirements of the guidelines will need to verify the test The project is divided into identification, impurity inspection (limit test, quantitative test), quantitative determination (content determination, Dissolution, release, etc.), other specific test items such as four categories. The purpose of identification is to determine that the analyte is the target compound, but not other substances, to identify The analytical method requires a strong specificity. Impurity inspection is mainly used to control the impurities other than the main component, such as organic impurities, inorganic impurities.

Impurity inspection can be divided into two kinds of limit test and quantitative test. Method of analysis for limit testing Verification focuses on specificity and detection limits. Validation of analytical methods used for quantitative tests emphasizes specificity and precision
Accuracy and limit of quantification. Quantitative determination of content, including determination of the dissolution of the preparation, etc., due to the accuracy of such projects
Sexual requirements are high, so the analytical methods used require a certain degree of specificity, accuracy and linearity. Other specific test items include particle size distribution, optical rotation, molecular weight distribution, etc., as these seized Test items and identification of identification, impurity inspection, quantitative determination of different, for these projects
Analysis method validation should have different requirements.
(B) analysis methods
The method of analysis referred to in this guideline is a test that has been established and established to accomplish each of the above test items Methods, including analytical methods and principles, instruments and equipment parameters, reagents, system suitability tests,
Preparation of test solution, reference solution preparation, determination, calculation and test results report. Test methods can use chemical analysis methods and instrumental analysis methods. These methods have their own characteristics, The same test method can be used for different test items, but the verification content may not be the same.
(C) Verify the content
Verification includes method specificity, linearity, range, accuracy, precision, limit of detection,
Quantitation, durability and system suitability. Fourth, the method of verification of the specific content
(A) exclusive
Specificity refers to the other components (such as impurities, degradants, excipients, etc.) may exist, the use of  The analytical method can correctly identify and detect the characteristics of the analyte. In general, identification, impurity testing, content determination methods should examine its specificity. As used
 Method is not enough, should be used to supplement a number of ways.

1, identification reaction Identification tests should confirm that the analyte meets its characteristics. Specificity tests require that proof be possible with possible
Presence of substances or structural similar compounds to distinguish, to be confirmed with the analyte for the test was positive reaction, Negative controls that do not contain the component under test are negatively responsive, structurally similar, or related compounds in the component
Should be negative reaction.

2, impurity inspection
As a purity check, the analytical method used should ensure that impurities in the analyte can be detected Quantities, such as related substances, heavy metals, organic solvents and so on. Therefore, impurity inspection requirements analysis method has one Set the specificity.
In the case of impurities available, can be added to the test sample a certain amount of impurities that impurities And coexisting substances can be separated and detected, and with appropriate accuracy and precision. In the case of impurities or degradation products can not be obtained, the specificity can be with another proven Reasonable but separation or detection of different principles, or with a strong ability to distinguish between methods to compare the results
set. Or the test sample with strong light irradiation, high temperature, high humidity, acid, alkali hydrolysis and oxidation method
Destruction (preparation should consider the impact of excipients), comparing the number and amount of impurities detected before and after damage. necessary Diode array detection and mass spectrometry can be used for chromatographic peak purity check.

3, content determination
The purpose of the assay is to obtain accurate results of the analyte content or potency in the test sample. In the case of impurities available, for the determination of the main component can be added to the test sample impurities Or excipients, examining the determination of whether the interference, and without impurities and accessories for the test compared to the test Set the result.


4.In the case of impurities or degradation products can not be obtained, you can use another validated or Pharmacopoeia Methods to compare the results of two methods compared. Destructive testing can also be used (bright light Shooting, high temperature, high humidity, acid, alkali hydrolysis and oxidation) to obtain a sample containing impurities or degradation products, The two methods were used to determine the content and compare the results. When necessary, the peak purity of the chromatographic examination, It is proved that the chromatographic peak of the content determination component does not contain other components.
(B) Linear
Linear means within the scope of the design of the test, the test results and the concentration of the analyte in the test (Volume) is directly related to the degree of linearity.
Linearity is the basis for quantitative determination, involving quantitative determination of the project, such as impurity quantitative test and containing The quantity determination needs to verify the linearity. The linear relationship should be determined within the design measurement range. A stock solution can be used for precision dilution, or Respectively, accurately weighed sample preparation of a series of measured concentrations of substances were measured, prepared at least 5 thick degree. Take the measured response signal as a function of the analyte concentration to see if it is linear and use Least squares method for linear regression.
When necessary, the response signal can be mathematically converted, and then linear regression calculation, and explain the basis.
(C) range
Range refers to the ability to achieve a certain degree of accuracy, precision and linearity, the test method is suitable for the test Sample range of concentration or amount of analyte level limit.
The range is the specified value, the scope of the verification and the test method should be determined before the start of the pilot study. Can be used to meet the requirements of the preparation of different concentrations of raw materials, in accordance with the appropriate measurement methods experimenting. The range is usually expressed in the same units (eg percent concentration) as the test results of the analytical method. Involving

And to the quantitative determination of the test items need to verify the scope, such as content determination, content uniformity Degree, dissolution or release, impurity quantitative test.
The range should be based on dosage forms and / or test items to determine the requirements.
1, content determination
The range should be 80% to 100% or more of the test concentration.
2, formulation content uniformity
The range should be 70% to 130% of the test concentration. Depending on the dosage form characteristics, such as aerosols, sprays, When necessary, the scope may be appropriately relaxed.
3, dissolution or release For dissolution, the range should be ± 20% of the limit, and if the limit is specified, the lower limit -20% to + 20% of the upper limit.
For the release, if the limit is in the range of 20% to 24 hours after 1 hour 90%, the verification range should be 0 ~ 110%.
4, impurities
Determination of impurities, the scope should be based on preliminary results of the test, to develop the required limit of ± 20%. If the determination of content and impurity testing simultaneously measured by area normalization method, the linear range should be miscellaneous -20% of the specified limit to + 20% of the limit (or upper limit).
(D) accuracy
Accuracy means the approximate value of the result measured by this method and the true value or recognized reference value degree. Sometimes called reality.
A certain degree of accuracy is a necessary condition for quantitative determination and thus involves the detection of quantitative determination
Head are required to verify the accuracy, such as content determination, impurity quantitative test.

Accuracy should be established within the scope of the provisions for the preparation of the general recovery rate test to test certificate. Test design to be considered within the provisions of the preparation of three different concentrations of the sample, the determination of 3
Times, that is, measured 9 times, reported the recovery rate of known addition (%) or the average of the measured results and true The difference between the real value and its credible limit.
1, content determination
The raw material medicine can use the known purity reference substance or the qualified raw medicine to carry on the determination, or use this The results of the method are compared with the results of another method that has established the accuracy. The formulation can be determined using a mixture of components containing a known amount of the analyte. If you can not get the preparation Of the total composition can be measured by adding a known amount of the test substance to the preparation, if necessary, A method has been established to compare the accuracy of the results.
2, impurity quantitative test
Quantitative testing of impurities can be measured by adding a known amount of impurities to the drug substance or preparation. in case
Can not get impurities, the method can be used to determine the results compared with another mature method, such as Pharmacopoeia Method or proven method. If you can not measure the relative response of impurities, online measurement of impurities related data, such as mining
UV detector with diode array detector, when the impurity spectrum and the main component of the spectrum is similar, You can use the API response factor approximation to calculate the impurity content (self-control method). And should be clear single
The total amount of impurities and impurities corresponds to the weight ratio (%) or area ratio (%) of the main component.
(E) precision
Precision refers to the provisions of the test conditions, the same homogeneous test samples, after repeated sampling A series of tests to determine the degree of closeness (dispersion).
Precision generally deviations, standard deviations or relative standard deviation. Use standard deviation or relative standard


When the quasi-deviation is expressed, the sampling times should be at least 6 times.
Precision can be investigated from three levels: repeatability, intermediate precision, reproducibility.
1, repeatability
Repeatability refers to the same operating conditions, in a relatively short time interval, by the same analyst
The results of the determination of the precision of the staff. Repeatability determination can be within the specified range, at least 9 times the measurement results were evaluated, as prepared 3 different concentrations of the sample, each measured 3 times, or 100% of the concentration level, measured with at least 6 The results of the evaluation.
2, intermediate precision It means the same intermediate precision laboratory, due to internal conditions of the laboratory changes, such as time, Analysts, instruments and equipment, the determination of the precision of the results. Variations in the validation design are typically dates, analysts, equipment.
3, reproducibility
Refers to the different laboratories between different analysts to determine the precision of the results. When analytical methods will be adopted by statutory standards, reproducibility tests should be carried out.
(F) detection limit
Limit of detection refers to the minimum amount of analyte in the sample can be detected, but not necessarily accurate Determine the amount. The significance of the verification index is to examine whether the method has a sensitive detection capability. So mixed
Quality limit test, to prove that the method has a sufficiently low detection limit to ensure that the detection of impurities to be controlled.
1, intuitive method
Intuitive evaluation can be used for non-instrumental analysis methods as well as instrumental analysis methods.

The detection limit is determined by analyzing a series of test specimens of known concentration and using Can accurately and reliably detect the minimum or minimum concentration of the analyte to establish.
2, signal to noise ratio method
For the analysis of the baseline noise can be displayed that the known low-concentration samples detected signal and The noise signal is compared to calculate the lowest detectable concentration or amount. The general signal to noise ratio of 3: 1
The corresponding concentration or the amount of equipment injected determines the limit of detection. Other methods are based on the slope of the working curve and the standard deviation of the response method Wait. Regardless of the method used, a certain number of samples are applied at concentrations near or equal to the detection Limits, analysis is performed to reliably determine the limit of detection.
(7) Quantitative limit
The limit of quantification refers to the minimum amount of analyte in a sample that can be quantitatively determined, and the result of the measurement Should have a certain accuracy and precision. Quantitative limit reflects the analytical method has the ability to sensitive quantitative detection. Impurity quantitative test, The limit of quantitation of the method needs to be investigated to ensure that impurities with very low contents can be accurately detected.
Common signal to noise ratio to determine the quantitative limit. The general signal to noise ratio of 10: 1 corresponding concentration or Note Enter the amount of equipment to be determined.
1, intuitive method
Intuitive evaluation can be used for non-instrumental analysis methods as well as instrumental analysis methods. The limit of quantitation is generally determined by analyzing a series of samples containing analytes of known concentration
Accuracy and precision are required to meet the requirements of the circumstances, to determine the minimum amount of measurable substance can be quantified.
2, signal to noise ratio method

For the analysis of the baseline noise can be displayed that the known low-concentration samples detected signal and The noise signal is compared to calculate the lowest detectable concentration or amount. The general signal to noise ratio of 10: 1. Other methods are based on the slope of the working curve and the standard deviation of the response method Wait. Regardless of the method used, a certain number of samples are applied at concentrations close to or equal to the quantitation Limits for analysis to reliably determine the limit of quantitation.
(H) Durability
When small changes in durability means the measurement conditions occur, the result of the measurement is not affected tolerance level. Durability mainly investigates the anti-interference ability of the method itself for variable test factors. Start researching When analyzing methods, consider their durability. If the test conditions demanding, it is recommended in the method
In the statement. Typical variables include: the composition, flow rate, and pH of the mobile phase in liquid chromatography, not With the same brand or different batch number of the same column, such as column temperature. Gas chromatography and carrier gas flow rate,
Different brands or lot numbers, stationary phase, support, column temperature, inlet and detector temperature. After testing, should indicate small changes in line with the system suitability test requirements to ensure that the method effective.
(IX) System suitability test
For some instrument analysis methods, when performing method validation, it is necessary to integrate the analytical equipment, electronics
The instrument is evaluated as a complete system together with experimental procedures, test samples and the like. System suitability It is an indicator of the entire system to be assessed. System suitability test parameters set to betested Depending on the type of card method.
Chromatography methods for analytical equipment, electronic instruments rely on a high degree, so all the chromatographic methods This indicator should be validated and the system suitability as part of the analytical method. Experience Card parameters and methods refer to the relevant provisions of Chinese Pharmacopoeia. Fifth, the method re-verification In some cases, such as the change of raw material drug synthesis process, preparation prescription changes, analytical methods
Health changes, etc., are necessary to once again analyze the analytical methods in full or in part to ensure that the points Method is reliable, this process is called method re-verification.
Revalidation principle: According to the degree of change corresponding revalidation.
When the API synthesis process changes, the introduction of new impurities, impurity inspection methods and The specificity of the content determination method needs to be verified to prove that the relevant material inspection method can Newly introduced impurities are to be detected and the newly introduced impurities should be free from interference with the determination of the content of the main components. When the formulation changes the composition of prescriptions, accessories change, may affect the identification of the specificity, dissolution
Outcome and determination of the accuracy of the content, so the need for identification, determination of content verification method. When the original
Changes in origin of feedstocks may affect the specificity and accuracy of impurity testing and determination
Therefore, it is necessary to re-verify the impurity inspection method and content determination method. When the quality standard of a project analysis method partial change, such as the use of high-performance liquid color When spectrum content is measured, the detection wavelength changes, you need to re-test limits, specificity, Accuracy, precision, linearity and other content verification, proof of the rationality of the revised analysis method can be Line.
Similarly, there have been national standards of drug quality research, based on the declaration of raw materials synthesis process, Preparation of prescriptions and other accessories generally can not guarantee the consistency of the drugs already on the market, the need for quality standards The middle part of the project to re-validate the method.
Method validation is the process of perfection of analytical methods and should be re-tested based on actual changes

Card to ensure that the analytical methods used to control the intrinsic quality of the drug.
Sixth, the method validation evaluation For method validation, the following aspects deserve attention.
(A) General considerations on methodological validation and evaluation
In general, method validation should focus on the purpose and general principles of validation, method validation content The choice and test design should be systematic and reasonable, and the verification process should be rigorously regulated. Not all methods of analysis for each test item require verification of all content, but at the same time Note that the verification should be sufficient to justify the analytical method used. Such as impurity limits test
Generally need to verify the specificity and detection limit, and for precision, linearity, limit of quantification involved The measurement of the project, you generally do not need to verify.
(B) method of verification of the integrity and systematic
Method validation content interrelated, is a whole. Therefore, no matter from the perspective of research or development Evaluation point of view, method validation are focused on the integrity and systematic. For example, to identify the specificities needed for a project, it is generally not likely that an analytical method Fully identify the analyte, this time using two or more analytical methods can enhance the identification of the entire project
Body specificity. There is also a greater correlation between method validation content that can be complemented with each other. Such as bulk drugs Determination of content using volume analysis, due to the method itself, the specificity of slightly worse, but if in the Impurity detection using a more specific chromatography, it is generally considered the detection method also has Strong specificity.
In short, due to the complexity of the actual situation, it is not advocated dogmaily during the verification of the method Line method validation. In addition, more and more new methods are constantly being used in quality control for these
How to verify the method requires specific analysis of the specific circumstances, and can not copy the guidelines. Seven, reference
1. FDA.Guidance for Industry: analytical procedures and methods
validation, chemistry, manufacturing, and controls documentation (Draft), 2000.8.
2. ICH Q2A.Test on   Validation of Analytical Procedures 
3. ICH Q2B.Validation of Analytical Procedures: Methodology
4. Chinese Pharmacopoeia 2000 edition two appendices. Drug quality standard analysis method validation
Eight, author
Study Group on Technical Guiding Principles for Validation of Chemical Quality Control Analysis Methods

Validation of Cleaning Processes

GUIDE TO INSPECTIONS VALIDATION OF CLEANING PROCESSES




  • INTRODUCTION

  • Validation of cleaning procedures has generated considerable discussion since agency documents, including the Inspection Guide for Bulk Pharmaceutical Chemicals and the Biotechnology Inspection Guide, have briefly addressed this issue. These Agency documents clearly establish the expectation that cleaning procedures (processes) be validated.
    This guide is designed to establish inspection consistency and uniformity by discussing practices that have been found acceptable (or unacceptable). Simultaneously, one must recognize that for cleaning validation, as with validation of other processes, there may be more than one way to validate a process. In the end, the test of any validation process is whether scientific data shows that the system consistently does as expected and produces a result that consistently meets predetermined specifications.




  • BACKGROUND

  • For FDA to require that equipment be clean prior to use is nothing new, the 1963 GMP Regulations (Part 133.4) stated as follows "Equipment *** shall be maintained in a clean and orderly manner ***." A very similar section on equipment cleaning (211.67) was included in the 1978 CGMP regulations. Of course, the main rationale for requiring clean equipment is to prevent contamination or adulteration of drug products. Historically, FDA investigators have looked for gross insanitation due to inadequate cleaning and maintenance of equipment and/or poor dust control systems. Also, historically speaking, FDA was more concerned about the contamination of nonpenicillin drug products with penicillins or the cross-contamination of drug products with potent steroids or hormones. A number of products have been recalled over the past decade due to actual or potential penicillin cross-contamination.
    One event which increased FDA awareness of the potential for cross contamination due to inadequate procedures was the 1988 recall of a finished drug product, Cholestyramine Resin USP. The bulk pharmaceutical chemical used to produce the product had become contaminated with low levels of intermediates and degradants from the production of agricultural pesticides. The cross-contamination in that case is believed to have been due to the reuse of recovered solvents. The recovered solvents had been contaminated because of a lack of control over the reuse of solvent drums. Drums that had been used to store recovered solvents from a pesticide production process were later used to store recovered solvents used for the resin manufacturing process. The firm did not have adequate controls over these solvent drums, did not do adequate testing of drummed solvents, and did not have validated cleaning procedures for the drums.
    Some shipments of this pesticide contaminated bulk pharmaceutical were supplied to a second facility at a different location for finishing. This resulted in the contamination of the bags used in that facility's fluid bed dryers with pesticide contamination. This in turn led to cross contamination of lots produced at that site, a site where no pesticides were normally produced.
    FDA instituted an import alert in 1992 on a foreign bulk pharmaceutical manufacturer which manufactured potent steroid products as well as non-steroidal products using common equipment. This firm was a multi-use bulk pharmaceutical facility. FDA considered the potential for cross-contamination to be significant and to pose a serious health risk to the public. The firm had only recently started a cleaning validation program at the time of the inspection and it was considered inadequate by FDA. One of the reasons it was considered inadequate was that the firm was only looking for evidence of the absence of the previous compound. The firm had evidence, from TLC tests on the rinse water, of the presence of residues of reaction byproducts and degradants from the previous process.


  • GENERAL REQUIREMENTS

  • FDA expects firms to have written procedures (SOP's) detailing the cleaning processes used for various pieces of equipment. If firms have one cleaning process for cleaning between different batches of the same product and use a different process for cleaning between product changes, we expect the written procedures to address these different scenario. Similarly, if firms have one process for removing water soluble residues and another process for non-water soluble residues, the written procedure should address both scenarios and make it clear when a given procedure is to be followed. Bulk pharmaceutical firms may decide to dedicate certain equipment for certain chemical manufacturing process steps that produce tarry or gummy residues that are difficult to remove from the equipment. Fluid bed dryer bags are another example of equipment that is difficult to clean and is often dedicated to a specific product. Any residues from the cleaning process itself (detergents, solvents, etc.) also have to be removed from the equipment.
    FDA expects firms to have written general procedures on how cleaning processes will be validated.
    FDA expects the general validation procedures to address who is responsible for performing and approving the validation study, the acceptance criteria, and when revalidation will be required.
    FDA expects firms to prepare specific written validation protocols in advance for the studies to be performed on each manufacturing system or piece of equipment which should address such issues as sampling procedures, and analytical methods to be used including the sensitivity of those methods.
    FDA expects firms to conduct the validation studies in accordance with the protocols and to document the results of studies.
    FDA expects a final validation report which is approved by management and which states whether or not the cleaning process is valid. The data should support a conclusion that residues have been reduced to an "acceptable level."


  • EVALUATION OF CLEANING VALIDATION

  • The first step is to focus on the objective of the validation process, and we have seen that some companies have failed to develop such objectives. It is not unusual to see manufacturers use extensive sampling and testing programs following the cleaning process without ever really evaluating the effectiveness of the steps used to clean the equipment. Several questions need to be addressed when evaluating the cleaning process. For example, at what point does a piece of equipment or system become clean? Does it have to be scrubbed by hand? What is accomplished by hand scrubbing rather than just a solvent wash? How variable are manual cleaning processes from batch to batch and product to product? The answers to these questions are obviously important to the inspection and evaluation of the cleaning process since one must determine the overall effectiveness of the process. Answers to these questions may also identify steps that can be eliminated for more effective measures and result in resource savings for the company.
    Determine the number of cleaning processes for each piece of equipment. Ideally, a piece of equipment or system will have one process for cleaning, however this will depend on the products being produced and whether the cleanup occurs between batches of the same product (as in a large campaign) or between batches of different products. When the cleaning process is used only between batches of the same product (or different lots of the same intermediate in a bulk process) the firm need only meet a criteria of, "visibly clean" for the equipment. Such between batch cleaning processes do not require validation.
    1. Equipment Design
    2. Examine the design of equipment, particularly in those large systems that may employ semi-automatic or fully automatic clean-in-place (CIP) systems since they represent significant concern. For example, sanitary type piping without ball valves should be used. When such nonsanitary ball valves are used, as is common in the bulk drug industry, the cleaning process is more difficult.
      When such systems are identified, it is important that operators performing cleaning operations be aware of problems and have special training in cleaning these systems and valves. Determine whether the cleaning operators have knowledge of these systems and the level of training and experience in cleaning these systems. Also check the written and validated cleaning process to determine if these systems have been properly identified and validated.
      In larger systems, such as those employing long transfer lines or piping, check the flow charts and piping diagrams for the identification of valves and written cleaning procedures. Piping and valves should be tagged and easily identifiable by the operator performing the cleaning function. Sometimes, inadequately identified valves, both on prints and physically, have led to incorrect cleaning practices.
      Always check for the presence of an often critical element in the documentation of the cleaning processes; identifying and controlling the length of time between the end of processing and each cleaning step. This is especially important for topicals, suspensions, and bulk drug operations. In such operations, the drying of residues will directly affect the efficiency of a cleaning process.
      Whether or not CIP systems are used for cleaning of processing equipment, microbiological aspects of equipment cleaning should be considered. This consists largely of preventive measures rather than removal of contamination once it has occurred. There should be some evidence that routine cleaning and storage of equipment does not allow microbial proliferation. For example, equipment should be dried before storage, and under no circumstances should stagnant water be allowed to remain in equipment subsequent to cleaning operations.
      Subsequent to the cleaning process, equipment may be subjected to sterilization or sanitization procedures where such equipment is used for sterile processing, or for nonsterile processing where the products may support microbial growth. While such sterilization or sanitization procedures are beyond the scope of this guide, it is important to note that control of the bioburden through adequate cleaning and storage of equipment is important to ensure that subsequent sterilization or sanitization procedures achieve the necessary assurance of sterility. This is also particularly important from the standpoint of the control of pyrogens in sterile processing since equipment sterilization processes may not be adequate to achieve significant inactivation or removal of pyrogens.
    3. Cleaning Process Written
    4. Procedure and Documentation
      Examine the detail and specificity of the procedure for the (cleaning) process being validated, and the amount of documentation required. We have seen general SOPs, while others use a batch record or log sheet system that requires some type of specific documentation for performing each step. Depending upon the complexity of the system and cleaning process and the ability and training of operators, the amount of documentation necessary for executing various cleaning steps or procedures will vary.
      When more complex cleaning procedures are required, it is important to document the critical cleaning steps (for example certain bulk drug synthesis processes). In this regard, specific documentation on the equipment itself which includes information about who cleaned it and when is valuable. However, for relatively simple cleaning operations, the mere documentation that the overall cleaning process was performed might be sufficient.
      Other factors such as history of cleaning, residue levels found after cleaning, and variability of test results may also dictate the amount of documentation required. For example, when variable residue levels are detected following cleaning, particularly for a process that is believed to be acceptable, one must establish the effectiveness of the process and operator performance. Appropriate evaluations must be made and when operator performance is deemed a problem, more extensive documentation (guidance) and training may be required.
    5. Analytical Methods
    6. Determine the specificity and sensitivity of the analytical method used to detect residuals or contaminants. With advances in analytical technology, residues from the manufacturing and cleaning processes can be detected at very low levels. If levels of contamination or residual are not detected, it does not mean that there is no residual contaminant present after cleaning. It only means that levels of contaminant greater than the sensitivity or detection limit of the analytical method are not present in the sample. The firm should challenge the analytical method in combination with the sampling method(s) used to show that contaminants can be recovered from the equipment surface and at what level, i.e. 50% recovery, 90%, etc. This is necessary before any conclusions can be made based on the sample results. A negative test may also be the result of poor sampling technique (see below).
    7. Sampling
    8. There are two general types of sampling that have been found acceptable. The most desirable is the direct method of sampling the surface of the equipment. Another method is the use of rinse solutions.
      1. Direct Surface Sampling - Determine the type of sampling material used and its impact on the test data since the sampling material may interfere with the test. For example, the adhesive used in swabs has been found to interfere with the analysis of samples. Therefore, early in the validation program, it is important to assure that the sampling medium and solvent (used for extraction from the medium) are satisfactory and can be readily used.
      2. Advantages of direct sampling are that areas hardest to clean and which are reasonably accessible can be evaluated, leading to establishing a level of contamination or residue per given surface area. Additionally, residues that are "dried out" or are insoluble can be sampled by physical removal.
      3. Rinse Samples - Two advantages of using rinse samples are that a larger surface area may be sampled, and inaccessible systems or ones that cannot be routinely disassembled can be sampled and evaluated.
      4. A disadvantage of rinse samples is that the residue or contaminant may not be soluble or may be physically occluded in the equipment. An analogy that can be used is the "dirty pot." In the evaluation of cleaning of a dirty pot, particularly with dried out residue, one does not look at the rinse water to see that it is clean; one looks at the pot.
        Check to see that a direct measurement of the residue or contaminant has been made for the rinse water when it is used to validate the cleaning process. For example, it is not acceptable to simply test rinse water for water quality (does it meet the compendia tests) rather than test it for potential contaminates.
      5. Routine Production In-Process Control
      6. Monitoring - Indirect testing, such as conductivity testing, may be of some value for routine monitoring once a cleaning process has been validated. This would be particularly true for the bulk drug substance manufacturer where reactors and centrifuges and piping between such large equipment can be sampled only using rinse solution samples. Any indirect test method must have been shown to correlate with the condition of the equipment. During validation, the firm should document that testing the uncleaned equipment gives a not acceptable result for the indirect test.


  • ESTABLISHMENT OF LIMITS

  • FDA does not intend to set acceptance specifications or methods for determining whether a cleaning process is validated. It is impractical for FDA to do so due to the wide variation in equipment and products used throughout the bulk and finished dosage form industries. The firm's rationale for the residue limits established should be logical based on the manufacturer's knowledge of the materials involved and be practical, achievable, and verifiable. It is important to define the sensitivity of the analytical methods in order to set reasonable limits. Some limits that have been mentioned by industry representatives in the literature or in presentations include analytical detection levels such as 10 PPM, biological activity levels such as 1/1000 of the normal therapeutic dose, and organoleptic levels such as no visible residue.
    Check the manner in which limits are established. Unlike finished pharmaceuticals where the chemical identity of residuals are known (i.e., from actives, inactives, detergents) bulk processes may have partial reactants and unwanted by-products which may never have been chemically identified. In establishing residual limits, it may not be adequate to focus only on the principal reactant since other chemical variations may be more difficult to remove. There are circumstances where TLC screening, in addition to chemical analyses, may be needed. In a bulk process, particularly for very potent chemicals such as some steroids, the issue of by-products needs to be considered if equipment is not dedicated. The objective of the inspection is to ensure that the basis for any limits is scientifically justifiable.


  • OTHER ISSUES

    1. Placebo Product
    2. In order to evaluate and validate cleaning processes some manufacturers have processed a placebo batch in the equipment under essentially the same operating parameters used for processing product. A sample of the placebo batch is then tested for residual contamination. However, we have documented several significant issues that need to be addressed when using placebo product to validate cleaning processes.
      One cannot assure that the contaminate will be uniformly distributed throughout the system. For example, if the discharge valve or chute of a blender are contaminated, the contaminant would probably not be uniformly dispersed in the placebo; it would most likely be concentrated in the initial discharge portion of the batch. Additionally, if the contaminant or residue is of a larger particle size, it may not be uniformly dispersed in the placebo.
      Some firms have made the assumption that a residual contaminant would be worn off the equipment surface uniformly; this is also an invalid conclusion. Finally, the analytical power may be greatly reduced by dilution of the contaminate. Because of such problems, rinse and/or swab samples should be used in conjunction with the placebo method.
    3. Detergent
    4. If a detergent or soap is used for cleaning, determine and consider the difficulty that may arise when attempting to test for residues. A common problem associated with detergent use is its composition. Many detergent suppliers will not provide specific composition, which makes it difficult for the user to evaluate residues. As with product residues, it is important and it is expected that the manufacturer evaluate the efficiency of the cleaning process for the removal of residues. However, unlike product residues, it is expected that no (or for ultra sensitive analytical test methods - very low) detergent levels remain after cleaning. Detergents are not part of the manufacturing process and are only added to facilitate cleaning during the cleaning process. Thus, they should be easily removable. Otherwise, a different detergent should be selected.
    5. Test Until Clean
    6. Examine and evaluate the level of testing and the retest results since testing until clean is a concept utilized by some manufacturers. They test, resample, and retest equipment or systems until an "acceptable" residue level is attained. For the system or equipment with a validated cleaning process, this practice of resampling should not be utilized and is acceptable only in rare cases. Constant retesting and resampling can show that the cleaning process is not validated since these retests actually document the presence of unacceptable residue and contaminants from an ineffective cleaning process.


  • REFERENCES

    1. J. Rodehamel, "Cleaning and Maintenance," Pgs 82-87, University of Wisconsin's Control Procedures in Drug Production Seminar, July 17-22, 1966, William Blockstein, Editor, Published by the University of Wisconsin, L.O.C.#66-64234.
    2. J.A. Constance, "Why Some Dust Control Exhaust Systems Don't Work," Pharm. Eng., January-February, 24-26 (1983).
    3. S.W. Harder, "The Validation of Cleaning Procedures," Pharm. Technol. 8 (5), 29-34 (1984)
    4. W.J. Mead, "Maintenance: Its Interrelationship with Drug Quality," Pharm. Eng. 7(3), 29-33 (1987).
    5. J.A. Smith, "A Modified Swabbing Technique for Validation of Detergent Residues in Clean-in-Place Systems," Pharm. Technol. 16(1), 60-66 (1992).
    6. Fourman, G.L. and Mullen, M.V., "Determining Cleaning Validation Acceptance Limits for Pharmaceutical Manufacturing Operations," Pharm. Technol. 17(4), 54-60 (1993).
    7. McCormick, P.Y. and Cullen, L.F., in Pharmaceutical Process Validation, 2nd Ed., edited by I.R. Berry and R.A. Nash, 319-349 (1993)
    This document is reference material only and does no confer any rights, privileges, benefits, or immunities for or on any person(s).