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Copyright © 2018 STERIS Corporation. All Rights Reserved.
13 Aug 2020
Cleanroom Control and Best Practices
Beth Kroeger
Technical Service Senior Manager
STERIS Life Sciences
Contamination Control Solutions
Copyright © 2018 STERIS Corporation. All Rights Reserved.
• Definition of Cleanroom and how classified
• Cleanroom behavior
• Cleanroom startup
• Cleaning and Disinfection Best Practices• Cleaning and disinfection techniques/development of Cleaning SOP
• Rotation of disinfectants/sporicidal agents
• Rinsing
Agenda
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Origin of the Cleanroom
• Invented in 60’s by Willis Whitfield “Mr. Clean”
– Pioneer of Unidirectional airflow.
• Invented room 1000 x cleaner
• “Particle counters broken”
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Why do we need Cleanrooms?
• 21 CFR 211.46(b) “Equipment for adequate control over air pressure, micro-organisms, dust, humidity and temperature shall be provided when appropriate for the manufacture, processing, packaging or holding of a drug product.”
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Clean-room Classifications
• Clean-room users concerned with 2 types of particulates:
: lint, soil, skin flakes, etc.
: bacteria, viruses, molds and spore forming organisms
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FS209 Cleanroom
Classification
ISO 14644-1 Cleanroom
Classifications
EU GMP Annex 1 Grades
≥ 0.5µm particles/m3
Viable Microbes(cfu/m3)
Mean Airflow Velocity
(fpm)
Air-changes/hr
100,000 8 D 3,520,000 100 5 – 10 5 – 48
10,000 7 C 352,000 10 10 – 15 60 – 90
1,000 6 - 35,200 7 25 – 40 150 – 240
100 5 A & B* 3,520 1 40 – 80 240 – 480
*at rest. Grade B in operation is equivalent to a Grade C at rest.
Cleanroom Classifications/requirements
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Don’t forget, in case of questions….
Contamination Sources
People• Gowning rooms
• Attire (clothing, shoe covers,
hoods, face masks, goggles, etc)
• Conduct
• Standard Operating Procedures
Facility• Poor design
• Aging facility
• Maintenance
• Cleaning and
disinfection
Materials• Pass through sterilizers
(autoclaves, dry heat ovens,
depyrogenation tunnels, etc.)
• Decontamination chambers (EO,
VHP, UV, etc.)
• Material handling airlocks
Genus A/B (6729) C/D (2500)
Micrococci (and related) 38% 40%
Staphylococci 21% 11%
Bacillus (and related) 13% 10%
Pseudomonas (and related) <1% 8%
Corynebacterium (and related) 3% 5%
Rhodococci <1% N/A
Fungi N/A 3%
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• Failure to have sanitation program/not following procedures
• Poor aseptic technique
Procedures to prevent microbial growth
Disinfectant contact time not specified
Disinfectant used in ISO 5 area not sterile
No sanitization of items into hood
Failure to consistently sanitize gloved hands
Failure to work slow and deliberate
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Personnel Practices:Cleanroom Behaviors
• Manipulations• Keep body/hands out of the path of unidirectional flow
• Contact sterile materials only with sterile instruments
• Always walk and move slowly: • Prevents turbulence to laminar airflow in the room.
• Can increase particles in area.
• No excessive talking
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• Limit movement
• Do not lean against walls or equipment.
• Do not touch floors. • If process requires work on floor, put down barrier or leave after task is
complete.
• If you drop something, pick it up, spray it off and IPA/EtOH item and hands.
• May have to exit
• Do not touch face, masks, or Safety glasses once gowned.
• NO GUM and NO Reaching for phones inside of gown!
Personnel Practices:Cleanroom behaviors
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• Personnel transmission:
• Inspectors are paying attention to operator’s gloves
• Integrity (packaged and while worn)
• Frequency of sanitization
• Compatibility
• Residue removal
• Proper gowning
• Adulteration
• Expect written procedures to detail methods used to don
• Expect micro surface sampling after manipulations
Personnel PracticesHealth and Hygiene
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• Your gown has been compromised/soiled.
• If gown or inner glove is torn.
• Your gown contacts the floor due to kneeling, etc.
• After plating
• Any doubt your suit is compromised.
Personnel Practices:Re-gown if…..
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• Adequacy of design and qualification studies to ensure facility is meeting expectations for air balance and air flow
• Practices
Inadequate Facility/studies
Failure to perform filter leak tests
No control over opening and closing doors to different classifications
Issues with room pressure differentials
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• After HEPA’s installation, protect return vents with filter prior to Construction clean
• Cleaning of debris, dirt, soiling, particles
• Removing cardboard, boxes, equipment, hoses
• Single or Double Cleaning with a formulated cleaner
• Acidic, Neutral, or Basic Cleaner can be utilized
• Neutral cleaner is often used to prevent any substrate compatibility issues
• Goal: Clean Pristine Surfaces
• Source: [International Standard 14644-5, Cleanroons and associated controlled environments – Part 5: Operations: 2004]
New Cleanroom Facility
Information
Chapter 19, p. 213 - 218Start-up of Cleanrooms, Initially and After a Worst-Case EventBy Jim Polarine and Beth Kroeger
Chapter 4, p. 97 – 120 How Issues Related to Utilities, Surfaces, and Practices Impact Cleanroom EnvironmentsBy Jim Polarine and Beth Kroeger
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• After the initial cleaning and large debris removal is complete• Clean construction work may still occur (no invasive work)
• Frequency in ISO 146441-2• ~ every 12 months, not exceeding 366 days in use or 400 days when not
in use
• ISO 5 every 6 months
• May damage filter or seals w/ install – buy extra
• The room should meet all the ISO-14644 (including ISO-14644 part 3) specs for particles and air control
• If Aseptic Manufacturing is taking place, then the requirements for the Aseptic Processing Guide (2004) should be met for EM
Certification
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• Particle Concentration Test
• Airflow Test• volume of air per unit of time (m3/hr)
• Determines air exchange rate
• Air Pressure Differential Test
• Temperature Test
• Humidity Test
• Recovery Test• Ability to eliminate airborne particles
• Evaluates 100:1 recovery time
• Installed filter system Leak Test
ISO 14644 (part 2 – specs; part 3 – test methods)
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• Once the cleaning program is established, it is important to follow the recommendations below to maintain the environment during routine operations.
• No cleaning should take place in an area during open operations and/or environmental monitoring.
• Rooms divided by lines of demarcation, separating two classes in the same room, should be cleaned and monitored per the stricter classification.
• Solutions and equipment from a less-strict classification should not be used to clean a stricter room classification.
Cleaning around the facility
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Environmental Control:Buildings and Facilities
• HVAC function• Temperature and RH control is vital
• 30 – 60% RH
• 16 - 24°C
• Maintain 24 hours a day
• A velocity of 0.45 m/s has generally been established, with a range of 20% around the set point, when measured 15 – 30 cm from the filter face
• Airflow: AC/HR depends on room and system• Class 100,000: > of 20 airchanges/hr
• Class 10,000: > of 50 airchanges/hr
• Class 100: > of 100 airchanges/hr
• Blockage and placement of feed and return vents
References: • FDA Guidance for Industry, Sterile Drug Products
Produced by Aseptic Manufacturing –Current Good Manufacturing Practice. Sep. 2004. p 4
• Parenteral Drug Association (2015) PDA Points to Consider for Aseptic Processing, Part 1, January 2015, Parenteral Drug Association.
• ISO 14644-4 Design, Construction, and Start-up
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Environmental Control:Buildings and Facilities
• HVAC function • HVAC systems maintain pressure between spaces
• Dependent on nature of operation
• Pressure differential: 0.04 – 0.06” WC (10 – 15 Pascals)
• “Close the door policy”
• Monitor continuously, alarms documented, and deviations investigated.
• Procedures in place for excursions• CONFIRM
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Environmental Control:Buildings and Facilities
• Airlocks, Passthroughs & Gowning rooms• Restricted access.
• Doors should be interlocked.• Locked, alarmed (audible/visual) or procedures
• DRAFT Annex 1 now requires interlocks, also describes a time delay
• Divided into “Dirty” and “Clean” sides.• Room cleaned to the higher level of ISO level
• Cart with wipes and disinfectants available.
• Cleaning often referred to as 2-step cleaning.• Disinfectant/Sterilant followed by IPA or EtOH as a rinse agent or where residue is a
concern
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• Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
• All germicidal products fall under the FIFRA as amended (1988) and administered by EPA
• FDA regulation as medical device per Food Quality Protection Act of 1996 if used to reprocess other medical devices or if used as a sterilantfor medical devices
Disinfectant regulation
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EPA classifications
• Sanitizer
• Disinfectant
• Sterilant
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• Proper use results in bacteria reduction of >99.9% • Used on precleaned surfaces
• How many bacteria can be found on the head of a pin?
• Log reduction 1,000,000
• 1-Log Reduction would reduce the number of bacteria 90%• Example: 100 bacteria would be reduced to 10, or 10 reduced to 1
Sanitizer defined
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Disinfectant defined
• Proper use results in 100% kill of vegetative bacteria, target viruses and target fungi
• May or may not require precleaning• Serum efficacy
• Staphylococcus aureus
• Salmonella enterica
• Pseudomonas aeruginosa
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• Proper use results in 100% kill of all microorganisms, including bacterial spores
• Demonstrated 6-7 Log reduction
• Always requires precleaning
Sterilant defined
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Cleaning and Disinfection: Techniques
• Grid
• Overlapping strokes
• Pull and lift
• Figure 8 for floors or unidirectional mopping strokes
• Modified Figure 8 for walls
Anne Marie Dixon, Ch. 11, Cleaning of Non-Product Contact Surfaces, p 226, in Cleaning and Cleaning Validation for the Pharmaceutical and Medical Device Industries, Vol. 1 Basics, Expectations, and Principles. Paul L. Pluta, Ed., PDA, Bethesda, MD, and DHI Publishing, LLC, River Grove, IL. 2009.
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Cleaning and Disinfection:Techniques
• Two Bucket routine:– Disinfectant in front or both
– Bucket under wringer is rinse & waste
• Three Bucket routine:– Third bucket used for catching wrung
out solutions
• Changing out the use dilutions– Every 600 ft2/ 55.74 m2 (ISO 5,6)
– Every 1000 ft2/ 92.90 m2 (ISO 7,8) Bucket #1 contains
disinfectant solution
Bucket #2 contains rinse
solution
Bucket #3 contains wrung
out waste
Link to the YouTube video for the 3 bucket mop technique: http://youtu.be/ajZ5_QHErqU
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Visible Particulate on Surfaces
excessive soil is easy to see
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Result of typical technique using wetted wipers
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Single pass stroke to remove particulate
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Importance of overlapping
strokes
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• Cleanest to dirtiest area
• Top to bottom and back to front
• Most critical to least critical surface
• Clean the farthest corner of the room towards the exit that will be used to leave the room.
• Rooms divided by demarcation with two “classifications”
• Clean to the stricter classification
• Mops and buckets: ISO level dedication
• Different Mop for Walls, Floors, and Ceilings
• Double glove when cleaning floor drains
Cleaning and Disinfection: Techniques
34
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• Don’t complicate procedures.
• Give yourself some leeway when starting up a cleaning program.
• Define daily, weekly, monthly, etc. Consider weekends and holidays.• Daily can mean “business day”
• Weekly – 7 ± 3 days
• Monthly – 30 days ± 10 days
• Triple clean definition• Different for everyone
• Satisfies monthly, weekly and daily requirements.
Cleaning SOP development
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Cleaning SOP development
• Draft procedures to handle unplanned events• Non-routine cleaning – spills, excursions, disturbances
• Address room pressure excursion cleaning• If excursion occurs: “room will be two-stepped….if less
than 5 min. with traffic or less than one-hour without..”• If excursion exceeds above: “room will be two stepped….tagged
OOS, Management and Quality notified….”
• Room is monitored and placed back into service.
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Cleaning SOP development
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• Alternation of antimicrobial actives• Two disinfectants in sequence,
regular rotation, with sporicidal agent as needed
• One disinfectant daily, with sporicidalweekly or monthly
Key issue - Rotation
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• Why do facilities rotate?• Good practice to ensure all microorganisms eliminated
• Inspectors from FDA, MHRA, etc. expect it
• Recommended by USP 37 <1072>, Aseptic Processing Guide, Annex 1, Orange Guide etc.
• Why is it important to rotate like or compatible chemicals?• Some disinfectants contain incompatible ingredients
• For example, cationic (Quats) and anionic (Phenolics) surfactants cannot be mixed
Key issue - Rotation
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Key issue - Rotation
• Recent scientific discussion on need for rotating disinfectants
– Bacteria resistance?
• Chemical disinfectants
– have a higher biocidal activity and bacterial populations are generally very low in cleanrooms.
• Persistent bacterial populations due to:
– Ineffective cleaning methods
– Disinfectant cannot reach the bacteria
– Misuse of disinfectant
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Antibiotic Action Sites
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• Disinfectants have three mechanisms of action or ways that they affect or kill an organism• Cross-linking, coagulating, clumping
• Structure and function disruption
• Oxidation
• Chlorine – Oxidizing proteins, lipids, and carbohydrates
• Peroxide compounds – Oxidizes cell membrane and protein coat on spore causing them to collapse exposing core to lethal disinfectant
• Phenols – penetrates and disrupts proper functioning of the cell wall
How Disinfectants Work
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• Alcohols cause cell proteins to clump and lose their function
Alcohol
Bacteria’s lipid membrane is held together because the hydrophobic part of the lipid sticks closely in the core
Reference: https://www.youtube.com/watch?v=j5jaHwuSuzo
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• Quaternary Ammonium Compounds denatures proteins of the bacterial or fungal cell, causes substances to leak out of cell causing death
Quaternary Ammonium Compounds
Images reference: https://teamaquafix.com/biocides-food-processing/
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“The antimicrobial agents typically employed in cleanrooms continue to be
effective because they have numerous effects on a number of aspects of
cellular physiology. That means multiple mutations would be required in a
short period of time (ex. 5 minutes) with exposure to low numbers of cells
typically found in a cleanroom to overcome their detrimental effects. As
such, resistance of a cell to agents used in a disinfection process would be
highly unlikely given the environmental conditions and low cell number.”
Microbial Resistance?
“…. Routinely used disinfectants should be effective against the
normal microbial vegetative flora recovered from the
facility.….” and “…Therefore, a sound disinfectant program
also includes a sporicidal agent, used according to a written
schedule and when environmental data suggest the presence of
sporeforming organisms.”
FDA guidance on aseptic manufacturing (2004)
Eudralex annex 1 (2008)
Given this knowledge, the pharmaceutical and biotechnology industries
have moved away from the rotation of two disinfecting agents. This
formerly common practice led to high residue levels and subordinate
efficacy performance. Today most firms use a system whereby a
disinfectant is rotated with a sporicide to more effectively reduce the
bioburden levels. The rotation of a disinfectant with a sporicide is
superior to the use of rotations of multiple disinfectants.”
JP guidance on aseptic manufacturing (2006)
“Cleaning and disinfection of facilities and
equipment A program for cleaning and
disinfecting facilities and equipment should be
established taking into account the potential
development of drug-resistant microorganisms.
The program should contain procedures for
screening and classifying bacterial isolates in each
manufacturing environment. »
(3) If selected disinfectants might have inferior
efficacy against microorganisms isolated from the
environment, the efficacy should be reevaluated and
the replacement with or alternate use of different
disinfectants should be considered and implemented, as
appropriate.
(4) If environmental monitoring data indicate or
suggest the presence of spore-forming bacteria or
fungi, suitable sporicides or fungicides should be
selected for disinfection.”
PIC/S
WHO
“61. The sanitation of clean areas is particularly important. They
should be cleaned thoroughly in accordance with a written
programme. Where disinfectants are used, more than one
type should be employed. Monitoring should be undertaken
regularly in order to detect the development of resistant strains.»
PDA TR70 cleaning and disinfection (2015)
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Key issue - Rotation
• CURRENT USP <1072> DISINFECTANTS AND ANTISEPTICS
• “The development of microbial resistance to disinfectants is less likely to occur…, as disinfectants are more powerful biocidal agents than antibiotics”.
• “…they are normally applied in high concentrations against low populations of microorganisms usually not growing actively, so the selective pressure for the development of resistance is less profound”.
• “…frequently isolated microorganisms ….may be periodically subjected to use-dilution testing with the agents used in the disinfection program to confirm their susceptibility, as there are real differences among different species in resistance to the lethal effects of different sanitizers”.
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Rotation
UPIP VAPI Working group on the Annex 1 revision
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Draft Annex 1: Disinfection – 2007 versus 20XX
• More than one type of disinfecting agent should be employed (if Regs require) and should include the periodic use of a sporicidal agent
• Disinfectants should be shown to be effective for the duration of their in-use shelf-life taking into consideration appropriate contact time and the manner in and surfaces in which they are utilized
• Monitoring should be undertaken regularly in order to show the effectiveness of the disinfection program and to detect the development of resistant and/or spore forming strains.
• Cleaning programs should be effective in the removal of disinfectant residues.
Future Requirements for Disinfectant Rotation
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•Do I need to rinse?
• 483 observations • Your firm does not always keep laminar flow hoods visually clean of
residue on HEPA filter surfaces and covering grates……I observed white and yellow residue on the HEPA filters…..and in areas up to approx. eight inches square on the filter…..
• I observed white particles on the floor of the clean room…approximately two to three millimeters square.
Cleaning and Disinfection:Rinsing
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• Efficacy concerns:• Residues inhibiting Biocides
• Do residues support harbor microbial growth?
• Do residues inhibit preceding actives (rotational chemistries)?
• Functional Issues: • Sticky or opaque surfaces due to residues
• Aesthetic Issues: • Surfaces do not look “clean”
• Safety Issues:• Transfer (direct and indirect) from surfaces to manufactured drug
products or medical devices
• Personnel safety (slippery, tacky, sticky, etc.)
Cleaning and Disinfection:Rinsing
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Typical Components in Disinfectants and what they look like
Component Residue Appearance
Water Water spots
SurfactantVery faint yellow to clear, gelatinous and sticky
White solid beads.
Chelants White or pinkish grey solid
Solvent No residue visible
Bases White to tan crystals
Acids Clear glaze with points of precipitates
Builders White powder
AntimicrobialsWhite to yellow
Brown, pinkish tanClear, gelatinous, sticky glaze
OxidantWater spots
No residue visible to white to tan powder or crystals from additives
Dyes Red, yellow, blue, color residues
Where does the residue come from?
• Compatibility issues• Different agents in rotation program
• Surface substrates
• Corrosion – attack of the impurities in the metal by chemical agent
• Deterioration by melting, softening, discoloration
• Drying – soft substrates such as Plexiglas, Kydex, Mipolam, epoxy.
• Staining
• Poor cleaning practices
• Drug product/process spills
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Residue on Substrates
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Residues on Substrates:
Desco Quartz Epoxy flooring system, 1.5 years, floors daily with phenolicsand 1/month application of sporicidalagent
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Residue removal trial
Desco Quartz Epoxy flooring system in an ISO 8 gowning room marked off in a grid pattern for in-situ testing. Two-year-old floors are disinfected daily with phenolics and once per month application of sporicidal agent one time per month without rinsing.
Desco flooring after residue removal trial using:• WFI (lane 1),• Sterile oxidative detergent (lane 2)• Sterile neutral detergent (lane 3)
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Residue removal trial
Application of sterile detergent Desco flooring after residue removal trial using sterile neutral detergent and rinse
Up-close before image
Up-close after image after cleaning with sterile neutral detergent
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Residue removal – Microbial removal
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Cleaning and Disinfection Best Practices
• How often to clean??? • Environmental cleaning frequency determined by:
• ISO Classification of area
• Activity level in area or use
• Environmental monitoring feedback
• Type of process being performed & equipment used
• Substrates
• Visual Observations
• Incorporate rinse/cleaning into cleaning and disinfection program
• Nondestructive mechanical action to remove contaminants and residue
• In addition to sanitizers, disinfectants or sporicides
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• For clean rooms we still recommend• Disinfectant Rotation
• Phenols or Quats on monthly basis (never a phenol and a quat)
• Sterilant use routinely based on environmental data
• Rinsing on a routine basis• Not necessarily daily, but SOPs should
include weekly/monthly rinsing with IPA or water
• Evaluate cleanability of heavy residue
Contamination Control Program Recommendation
ContaminationControl Program
RinsabilityResidue
Compatibility
Efficacy
Disinfectant
Stability
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13 Aug 2020
Cleanroom Control and Best Practices
Beth Kroeger
Technical Service Senior Manager
STERIS Life Sciences
Contamination Control Solutions