dr dan egan (msd) ispe cleaning slide

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    ISPE Seminar:

    a sson u o e ,Cork

    Ma 22nd 2014

    Equipment Cleaning in a multipurpose API

    facility and the development of a Risk Based

     Approach to Cross Contamination Control

    Dr. Daniel Egan

    Technical Lead, API

    MSD

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    MSD Businesses across Ireland

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    • Named API R&D Commercialisation site in 2005• ew ormu a on ac y opera ona n

    • 430 employees + ~70 full time outside contractors

    Site currently supportsworldwide revenues of

    .

    on new product R&D

    commercialisation

    25 international customers

    ~

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    Cross Contamination Control – Using a Risk Based

     Approach   . Risk Identification Risk Analysis Risk Evaluation

    Role of Cleaning Validation in Cross ContaminationControl Development of a new cleaning regime

    ean ng pec ca ons Cleaning Validation Documentation Cleaning Execution

    Using the Risk Based approach in Cleaning Validation

    Key Take Aways/Challenges/Opportunities

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      a y ne : qu pmen 

    53 vessels (reactors, extractors, tanks)

    7 centrifuges (Tolhurst & Heinkel) & 2 Filter Driers 4 Rotar Dr ers 

    Factory 03: 25 vessels (reactors, extractors, tanks)

      ,

    4 Conical Dryers

    Both Facilities are modular: The outlet(s) of any vessel can be

    Typically 25 campaigns (450 Modules cleaned per year)

    including new process steps both Clinical and Commercial.

    Cleaning is just one part of our overall strategy for crosscontamination control.

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    ISPE Baseline Guide,

    Volume 7 'Risk Based

    Manufacture ofPharmaceutical Products'.

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     Applying the Risk based Approach to

    Cross Contamination

    ep : s en ca on:

    The Cross Contamination Hazards are

     API’s/Intermediates/Raw Materials

    Impurities

    By-products Degradants

    Deter ents

    Solvents

     

    Exposure) Limit.

    .

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    Step 2: Cross contamination Risk

    ssessmen na ys s 

    Need to identify the quantity of the Hazard & the Failure mode Quantity

    Carry over that will cause an adverse affect:

     ADE*106= 0.1mg/day*106/100 = 1000mg/kg = 1.0g/Kg (0.1Kg/100kg)

    Route to cross contamination Severity of the

    effect

    Severity ranking

    based on Quanti ty

    Quantity per 100Kg batch

    Mix-Up Critical effect 9 > 1Kg

    Retention Critical effect 9 0.05 - 1Kg

    Mechanical Transfer  Major effect 6 6 0.01-0.05Kg (10g-50g)

    r orne rans er    .

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    Step 2: Cross contamination Risk

    Route for CrossDefinition Examples

    Mix UpMix-up is defined as

    contamination at unsafe levels ofone product with another

    Charge of material to the wrongequipment

    Charge of incorrect material toequipment

    Retention

    Carry-over on product contactsurfaces from one product to

    another in the same equipmentused in a se uential or cam ai n

    Inadequate cleaning of equipment

    Inadequate cleaning specifications

    Inadequate visual inspection of

    manner.equipment post cleaning

     

    Routes by which material can betransferred from contaminatednon-product contact surfaces,

    Carry-over of product on operatorclothing

    Carry-over of product on equipment

    MechanicalTransfer

    inadvertent or transient contactwith other contaminated non-

    designated product contact areasand direct contact of the product

    with such surfaces as operator

    Carry-over of product onwalls/ceilings/ledges

    Carry-over of product on wasteappare an g oves

     

     Airborne Transfer

    Routes by which a suspension offine solid/liquid particles in air

    moves to another area where it

    Carry-over of product in generalventilation

    Carry-over of product in the specific

    on another exposed product.ventilation

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    Step 2: Cross contamination Risk

    ssessmen na ys s 

    Route to cross

    contamination

    Detection Detection Ranking How?

    Mix-Up Very High probability 1

    Detectable by procedural

    controls, material balances,

    analytical testing

    Retention Good Probability 3Detectable by pre-

    campaign checks, analytical

    testing

    Mechanical Transfer Low Probability 6Maybe detectable by

    analytical testing

    Unlikely to be caught by

    low level

     

    Occurrence is the determining factor .

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     This step evaluates available data for each of the identified failure modes and determines either a

    quan a ve es ma e e.g. numer ca or qua a ve escr p on e.g. g , me um or ow o

    occurrence of the Failure Mode

    Mix Up:

    Defined as contamination at unsafe levels of one product with another.

    Examples are charging of the desired material to the wrong equipment, charge of incorrect

    material to desired e ui ment and accidental use of dirt e ui ment. 

    Review Controls Include:

    Facility design (Single product rooms)

    Identification procedures (both equipment and Materials)

    Batch record Controls/Checks

    Equipment Cleaning status

    Site Audit programme

     

    Deviation review

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      .

    Retention is defined as carry-over of material on product contact surfaces.

    qu pmen ean ng a a on rogramme: Modular basis using pre-defined cleaning regime Solvent rinse where a ro riate swab and visual ins ection

    specifications.

    Detailed cleaning procedures are in place

     

    used with the maximum carry-over using 'Health Based Calculation'.

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      .Mechanical Transfer 

    Mechanical Transfer is the process by which material can be transferred from

    • Contaminated non-product contact surfaces

    • inadvertent or transient contact with other contaminated non-designated

    product contact areas

    •  

    gloves.

     

    Procedural Controls around open product handling

    Gowning/PPE (Personnel Protective Equipment)

    - ,

    Room cleaning Procedures

    Site Audit programme

      ranng

    Deviation review

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      . 

     Airborne Transfer is the process by which a suspension of

    fine solid/liquid particles in air moves to another areaexposed product.

    Review Controls Include:  Air flows/differential pressures design and Monitoring

    y : . .

    Provision of HEPA filtered air (no recycling).

     Air Changes per Hour (ACPH)

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      .Overall FMEA Scorin Overall a Risk Priority Number (RPN) can be calculated as follows for each

    failure mode.

    RPN= Severity x Detection x Occurrence

    Retention for non-dedicated equipment was the highest riskwith Airborne Transfer and Retention on dedicatedequipment the lowest RPN.

    We understand the materials we are handling & our facility isdesigned to handle such materials

    Next…..Cleaning of Multipurpose Equipment

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      For a new product: Developed based on technical evaluation.

    Identifying the main contaminants in each module

    Solubility in water and other possible cleaning solvents (taking,

    Forced degradation studies/cleaning interactions as required.

    Laborator cleanin simulation.

    Documented in a ‘Cleaning Technical Assessment Memo’.

    Critical cleaning parameters are identified

     Analytical development is completed (UV Rinse + Universal HPLCSwab Method).

    solvent through all the vessel loops (out bottom, in top).

    Cleaning ex Clinical Manufacture - Cleaning Verification

    Cleaning ex Commercial Manufacture - Cleaning Validation

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    Pre-defined justified cleaning specifications.

    Set based on the ‘Health Based Cleaning’ methodology. Rinse tested to meet pre-determined specification

    Swab testing to meet pre-determined specification 100mcg/25cm2

    swab

    Vessel visually clean (inspected when dry)

    .

    • Suitability of the cleaning specifications going into the process step.

    • Calculation of the total carry-over for each contaminant going into thecampaign.

    • The worst case carr -over is calculated based on the maximum swabspecification .

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     Prior to cleaning:

    Cleaning Technical assessment memo.

    Cleaning Sample Keys (summary of testing requirements for the Laboratory)

    Cleaning validation protocol – This documents the validation plan for the campaign. For new products: Cleaning Specification Justification including Genotoxic

    assessment.

    Post Campaign Flush (typically with the process solvent or Methanol) Modular approach - Each equipment module associated with a process equipment

    train is cleaned se aratel to an other module in that train.

    Validation status is applied to each module which is uniquely associated with the

    process from which the module is being cleaned

    Three successful cleanouts of a module are required for a clean-out to be deemedvalidated.

    Post execution of cleaning

    ean ng va a on comp e on ocumen e as pos execu on sec on o pro oco .

    Includes all Laboratory cleaning Results

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    Using the Risk based Approach in Cleaning

    Validation

    ► Risk based approach to swabbing as part of cleaning validation

    programme► Equipment which is not shared product contact (e.g. insides of glove-

    boxes).

    Question

    What is the

    equipment

    classification?

    What is the

    surface area ofproduct

    contact part?

    What is the

    potential toabsorb/adhere

    product?

    Is it easilyCleaned?

    Is it easily

    Visually

    Inspected?

    FinalRating

    Score/Multiplier 40 20 20 15 5 100

    3Direct Product

    Contact>50% High potential Difficult Difficult 300

    2 Auxiliary

    Component10-50%

    Medium

    potentialModerate Moderate 200

    1Proximity

     Area

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    Using the Risk based Approach in

    ean ng a a on

    ► Swab Locations: Worse case assessment of hard to cleanlocations (Cannot swab all the vessel!)

    ► r y o me an ampa gn eng w ere s a pro emand not for all equipment.

     is to be used for immuno suppressed populations,parenterals, products which are non-inhibitory to microbialgrowth.

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    re- ampa gn ec s

    Equipment status check (electronic tracking system) is

    completed which confirms that the equipment is cleannsure con am na on rom mec an ca se -up wor oes

    not impact on product quality

      , .

    Before Processing, Water Dummy Runs, Solvent

    steps) are completed.

    Not part of formal cleaning and confirm ‘equipmentreadiness’ for processing.

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    ey a eaways Cross Contamination Control is not just equipment Cleaning.

     Apply a Risk Based Approach and formally document the Risk

     Assessmenta a e qu pmen ean ng – omp ex ys em or non-

    dedicated Equipment (Multiple Modules, Multiple products all with

    different processes).

    Understanding of Process Contaminants and Cleaning Regimesis paramount – Should not be underestimated…

     

    Process Understanding

     

    Robust business systems

    People with Expertise and Experience

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    Challenges/Opportunities

    Cleaning Verification only?

    Reduced Verification Post Cleaning Validation

    Turnaround: Time spent in cleaning and set up.

     

    Science of Cleaning – Solubility only, Detergents?

      –where does cleaning fit in?

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    Thank You

    ues ons