points to consider on the different approaches – including ...€¦ · 41 to establish carryover...
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Working document QAS/20.849 May 2020
1
DRAFT WORKING DOCUMENT FOR COMMENTS: 2
3
Points to consider on the different approaches – 4
including HBEL – to establish carryover limits in 5
cleaning validation for identification of contamination 6
risks when manufacturing in shared facilities 7
8
Please send your comments to Dr Valeria Gigante, Technical Officer, Norms and Standards for Pharmaceuticals, Technical Standards and Specifications ([email protected]), with a copy to Ms Claire Vogel ([email protected]) before 30 June 2020. Please use our attached Comments Table for this purpose.
Our working documents are sent out electronically and they will also be placed on the WHO Medicines website (http://www.who.int/medicines/areas/quality_safety/quality_assurance/guidelines/en/) for comments under the “Current projects” l ink. If you wish to receive all our draft guidelines, please send your email address to [email protected] and your name will be added to our electronic mailing l ist.
9 © W o rld Health Organization 2020 10 11 All rights reserved. 12 13 This draft is intended for a restricted audience only, i.e. the individuals and organizations having received this draft. The draft 14 may not be reviewed, abstracted, quoted, reproduced, transmitted, distributed, translated or adapted, in part or in whole, in 15 any form or by any means outside these individuals and organizations (including the organizations' concerned staff and member 16 organizations) without the permission of the World Health Organization. The draft should not be displayed on any website. 17 18 Please send any request for permission to: Dr Sabine Kopp, Group Lead, Norms and Standards for Pharmaceuticals, Department 19 of Access to Medicines and Health Products, World Health Organization, CH-1211 Geneva 27, Switzerland, email: 20 [email protected]. 21 22 The designations employed and the presentation of the material in this draft do not imply the expression of any opinion 23 whatsoever on the part of the World Health Organization concerning the legal status o f any country, territory, city or area or 24 of its authorities, or concerning the delimitation of its frontiers or boundaries. Dotted lines on maps represent approximate 25 border lines for which there may not yet be full agreement. 26 27 The mention of specific companies or of certain manufacturers’ products does not imply that they are endorsed or 28 recommended by the World Health Organization in preference to others of a similar nature that are not mentioned. Errors and 29 omissions excepted, the names of proprietary products are distinguished by initial capital letters. 30 31 All reasonable precautions have been taken by the World Health Organization to verify the information contained in this draft. 32 However, the printed material is being distributed without warranty of any kind, either expressed or implied. The responsibilit y 33 for the interpretation and use of the material lies with the reader. In no event shall the World Health Organization be liab le for 34 damages arising from its use. 35 36 This draft does not necessarily represent the decisions or the stated policy of the World Health Organization. 37
38
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SCHEDULE FOR DRAFT WORKING DOCUMENT QAS/20.849 39
Points to consider on the different approaches – including HBEL – 40
to establish carryover limits in cleaning validation for identification 41
of contamination risks when manufacturing in shared facilities 42
Description of Activity Date
During the Fifty-third Expert Committee on Specifications for Pharmaceutical Preparations (ECSPP), the WHO Secretariat was recommended to revise the Appendix 3, Cleaning Validation of Annex 3, Good manufacturing practices: guidelines on validation (WHO Technical Report Series, No. 1025, 2019).
October 2018
The update of Appendix 3, Cleaning Validation, was further discussed during the informal consultation on Good Practices for Health Products Manufacture and Inspection.
July 2019
Following a recommendation by the ECSPP, the WHO Secretariat was recommended to develop a Points to consider document on cleaning validation introducing the possibility of using HBEL-based approaches to setting safe cleaning limits and establishing a common understanding on which to develop guidelines that are appropriate for all stakeholders.
October 2019
Preparation of first draft working document. April – May 2020
Mailing of working document to the Expert Advisory Panel on the International Pharmacopoeia and Pharmaceutical Preparations (EAP) inviting comments and posting of the working document on the WHO website for public consultation
May – June 2020
Discussion of working document during the informal consultation on Good Practices for Health Products Manufacture and Inspection
June 2020
Revision of the working document based on comments received during the informal Consultation on Good Practices for Health Products Manufacture and Inspection.
July 2020
Mailing of revised working document to the EAP inviting comments
and posting the working document on the WHO website for public consultation.
August – September 2020
Consolidation of comments received and review of feedback. Preparation of working document for discussion.
End of September 2020
Presentation to the Fifty-fourth meeting of the ECSPP. 12-16 October 2020
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43
44
Any other follow-up action as required.
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Points to consider on the different 45
approaches – including HBEL – to 46
establish carryover limits in cleaning 47
validation for identification of 48
contamination risks when manufacturing 49
in shared facilities 50
51
1. Introduction and background 52
2. Scope 53
3. Glossary 54
4. Traditional approach 55
5. New approaches 56
References 57
58
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1. Introduction and background 59
60
The World Health Organization (WHO) has published the guideline entitled Good Manufacturing 61
Practices for pharmaceutical products: main principles in the WHO Technical Report Series, No. 986, 62
Annex 2, 2014 (1). 63
64
The WHO Supplementary guidelines on good manufacturing practice: validation were published in 2006 65
and were supported by seven appendices. In 2019, the WHO Good manufacturing practices: guidelines 66
on validation (2) were updated and republished. Some of the seven appendices were also individually 67
updated between 2013 and 2019: 68
• Appendix 1. Validation of heating, ventilation and air conditioning systems (3). 69
• Appendix 2. Validation of water systems for pharmaceutical use (4). 70
• Appendix 3. Cleaning validation (5). 71
• Appendix 4. Analytical procedure validation (6). 72
• Appendix 5. Validation of computerized systems (7). 73
• Appendix 6. Guidelines on qualification (8). 74
• Appendix 7. Non-sterile process validation (9). 75
76
Appendix 3, relating to cleaning validation (5), was not updated at that time. Its revision, however, was 77
discussed during an informal consultation held in Geneva, Switzerland, in July 2019. The outcome of 78
the discussion was presented to the WHO Expert Committee on Specifications for Pharmaceutical 79
Products (ECSPP) meeting in October 2019. The ECSPP acknowledged the importance of 80
harmonization in regulatory expectations with regards to cleaning validation approaches. The Expert 81
Committee recommended a “Points to consider” document be prepared in order to describe the 82
current approaches used in cleaning validation and highlighting the complexities involved in order to 83
establish a common understanding. A revision of the relevant appendix would then be considered by 84
the Expert Committee thereafter. 85
86
Many manufacturers produce products in multi-product facilities where there is a risk of contamination 87
and cross-contamination. Some of the main principles of good manufacturing practices (GMP) include 88
the prevention of mix-ups and the prevention of contamination and cross-contamination. It is 89
therefore important that manufacturers identify all risks for contamination and cross-contamination 90
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and identify and implement the appropriate controls to mitigate these risks. These controls include, 91
for example, technical and organizational measures, dedicated facilities, closed systems, cleaning and 92
cleaning validation. 93
94
2. Scope 95
96
The scope of this document is to discuss the different possible approaches – including methods that 97
account for pharmacological and toxicological data (Health-Based Exposure Limits {HBEL}) – that could 98
be used when establishing safe Carryover limits when manufacturing in shared facilities. 99
100
This document further provides clarification on cleaning validation and presents points to consider 101
when reviewing the current status and approaches to cleaning validation in multiproduct facilities. It 102
reflects the current regulatory guidance and expectations. It further focuses on approaches where 103
HBELs setting need to be considered in cleaning and cleaning validation approaches. 104
105
The principles should be applied in manufacturing facilities with active pharmaceutical ingredients 106
(APIs) and finished pharmaceutical products (FPPs). 107
108
This document should be read in conjunction with the main GMP text and supplementary texts on 109
validation (1-10). 110
111
3. Glossary 112
113
cleaning validation. Documented evidence to establish that cleaning procedures are removing residues 114
to predetermined levels of acceptability, taking into consideration factors such as batch size, dosing, 115
toxicology and equipment size. 116
117
contamination. The undesired introduction of impurities of a chemical or microbiological nature, or of 118
foreign matter, into or on to a starting material or an intermediate or pharmaceutical product during 119
handling, production, sampling, packaging, repackaging, storage or transport. 120
121
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cross-contamination. Contamination of a starting material, intermediate product or finished product 122
with another starting material or product during production. 123
124
margin of safety. The margin of safety is the distance between a calculated acceptance limit and the 125
actual residues after cleaning. It indicates the probability that a patient has to be exposed to the API 126
residues resulting from cleaning. 127
128
maximum safe Carryover (MSC). Mathematically calculated quantity of residue from a previous product 129
when carried over into a different product that can represent potential harm to the patients. 130
131
maximum safe surface residue (MSSR). The maximum safe surface residue is mathematically calculated 132
dividing the quantity of residue on a contact surface by the total area of contact (Maximum Safe 133
Carryover/Total Equipment Surface Area). 134
135
verification. The application of methods, procedures, tests and other evaluations, in addition to 136
monitoring, in order to determine compliance with GMP principles. 137
138
4. Traditional approach 139
140
For details on the traditional approaches in cleaning validation, see the WHO Technical Report Series, 141
No. 1019, Annexure 3, Appendix 3, 2019 (5). 142
143
One traditional approach is that cleaning validation is performed and the appropriateness of the 144
cleaning procedure was based on acceptance criteria suggested in GMP texts. This approach may no 145
longer be acceptable and justifiable as HBELs were not considered. 146
147
Where traditional acceptance limits are used, the decision should be discussed and justified as an 148
alternative to new approaches in setting acceptance criteria. 149
150
In view of the risks of contamination and cross-contamination, the new approaches, as described 151
below, should be implemented without delay. 152
153
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5. New approaches 154
155
Traditional cleaning validation approaches were often based on verifying that a cleaning procedure was 156
effective. However, in many instances, no development work or cleanability studies were performed 157
for these cleaning procedures. 158
159
Manufacturers should ensure that their cleaning is effective and appropriate and that their cleaning 160
validation provides scientific evidence that identified products can be manufactured in shared facilities 161
– with control measures implemented to mitigate the risks of contamination and cross-contamination. 162
163
This approach should include at least the following points which are further described in the text below: 164
• cleanability studies; 165
• risk assessment and risk control; 166
• technical and organizational controls; 167
• HBELs setting; 168
• analytical procedures; and 169
• cleaning verification with proven capability through statistical evaluation. 170
171
Manufacturers should describe their policy and approaches, including the points mentioned above, in 172
a document such as a master plan. 173
174
It is strongly recommended that manufacturers review their existing technical and organizational 175
measures, suitability of cleaning procedures and appropriateness of cleaning validation. Genotoxic and 176
carcinogenic substances, degradants and other contaminants should be identified and the appropriate 177
action should be taken in order to ensure that materials and products are not contaminated when 178
produced in shared facilities. 179
180
5.1 Documentation 181
182
Risk management principles, as described in other WHO guidelines on quality risk management 183
(10), should be applied to assist in identifying risks and controls to mitigate contamination and 184
cross-contamination. 185
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Procedures, protocols, reports and other related and supportive documentation should be 186
prepared, used and maintained. 187
188
The policy and approaches in cleaning and cleaning validation may be described in a Cleaning 189
Validation Master Plan. Experiments and validation should be performed in accordance with 190
predefined, authorized standard operating procedures, protocols and reports. 191
192
The design and layout of documents, and the reporting of data and information, should be in 193
compliance with the principles of good documentation practices (11) and should also meet 194
data integrity requirements (12). 195
196
5.2 Equipment 197
198
Consideration for cleaning validation should cover contact surfaces, as well as non-contact 199
surfaces, where the latter have been identified as areas of risk. 200
201
Authorized drawings of equipment should be current, accurate and available. These should be 202
used when equipment surface areas are calculated. Source data for these calculations should 203
be available. The calculated values should be used in the calculations in cleaning validation. 204
205
Equipment and components that are difficult to clean, such as sieves, screens and bags, should 206
also be included in the cleaning validation and calculations. 207
208
5.3 Detergents and solvents 209
210
Solvents and detergents used in cleaning processes should be selected with care. They should 211
also be appropriate for their intended use. The selection of the relevant solvent and detergent 212
should be justified. 213
214
There should be proof of effectiveness and appropriateness of the selected solvent and 215
detergent. 216
217
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Other points to consider include the concentration in which these are used, their composition, 218
and removal of their residues after cleaning. 219
220
The use of solvents and detergents should be included in cleanability studies. 221
222
5.4 Sampling 223
224
Traditionally, cleaning validation included the sampling of equipment and other areas in order 225
to determine whether or not there was any residue remaining on the surfaces. The focus was 226
mainly on contact surface areas. Non-contact surface areas were sometimes considered by 227
some manufacturers. 228
229
A combination of at least two or three sampling methods should be used. These include a 230
combination of swab samples, rinse samples and visual inspection. 231
232
The appropriate sampling procedures and techniques should be selected and used to collect 233
samples. These should be clearly described in procedures and protocols. The location (swab 234
sample) and the manner in which the samples are collected should be clearly described and be 235
scientifically justifiable. 236
237
The manner in which a rinse sample is collected should be described in detail. The procedure 238
should be clear and unambiguous. 239
240
The manner in which samples collected are prepared for analysis should be appropriate and 241
described in detail. 242
243
5.5 Cleanability studies 244
245
Before a cleaning procedure is validated and adopted for routine use, a cleanability study 246
should be performed in order to determine the appropriateness of the procedure for removing 247
material, product residue, cleaning agents and microorganisms. 248
249
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The lowest concentration of a substance that can be removed by following the cleaning 250
procedure should be established for different materials, intermediates and products on 251
different materials of construction. The concentration can be expressed in mg/m2. 252
253
Cleanability studies should be described in authorised documents, such as protocols and 254
procedures. The method should be scientific and may include spiking on coupons made from 255
different materials of construction. The so-called beaker method, or other appropriate 256
method, may be used. 257
258
Consideration should be given to all substances and different procedures where different 259
processes or solvents are used, including different surface materials. 260
261
The results should be documented in authorized reports and used in further determinations, 262
such as Maximum Safe Residue. 263
264
5.6 Risk assessment and risk control 265
266
Risk identification should be performed with a focus on the assessment of risks and defining 267
and implementing controls to mitigate the risk of contamination and cross-contamination. 268
269
These should include technical and organization controls, including but not limited to, 270
premises, equipment, utilities, containment, closed systems, cleaning and cleaning validation. 271
272
5.7 Technical and organizational controls 273
274
The appropriate technical and organizational controls should be defined and implemented. 275
276
Their appropriateness and effectiveness should be evaluated. Note: Cleaning and cleaning 277
validation are considered additional and supplementary controls to technical and 278
organizational controls. 279
280
Technical and organizational controls should be justifiable and clearly documented. 281
282
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Technical controls, such as the design of the premises and utilities (e.g. heating, ventilation and 283
air-conditioning {HVAC}, water and gas), should be appropriate for the range of products 284
manufactured (e.g. pharmacological classification, activities and properties). 285
286
Organizational controls, such as dedicated equipment, procedural control, and campaign 287
production, should be considered where appropriate as a means to reduce the risk of cross-288
contamination. 289
290
5.8 Health Based Exposure Limits (HBELs) setting 291
292
Manufacturers should establish, document and implement a company-wide policy on HBELs 293
setting for shared facilities. 294
295
APIs and products manufactured in shared facilities should be reviewed based on scientific 296
evidence in order to determine whether production and control activities in shared facilities 297
may be considered acceptable or whether dedicated facilities are required for the production 298
and control of identified products. 299
300
This is applicable to legacy products as well as the introduction of new products introduced 301
into a facility through a change control procedure. 302
303
Procedures should be established and implemented describing how scientific data and 304
toxicological information on HBELs should be obtained. 305
306
Data and information should be gathered and presented in a report. The data should be free 307
from bias. Where this service is outsourced, the appropriate measures should be put in place 308
in order to ensure that the data obtained are reliable. GMP requirements, such as vendor 309
qualification, agreements and other related aspects, should be considered. 310
311
The report should include scientific detail, including information on: 312
• chemical structure; 313
• hazard identification; 314
• mode of action; 315
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• identification of critical effects; 316
• establishing NOAELs (no-observed-adverse-effect level); 317
• adjustment factors; 318
• pre-clinical, clinical and non-clinical data; 319
• pharmacokinetics and pharmacodynamics; 320
• expert assessment; 321
• identification of the critical effect; 322
• assignment of adjustment factors (AF); 323
• argumentation for the selected HBEL; 324
• routes of administration; 325
• point of departure (POD); 326
• justification for critical effect of POD; and 327
• justification for factor. 328
329
The Permitted Daily Exposure (PDE) should be calculated based on the data and information 330
obtained. For example: 331
332
PDE = NOAEL x weight adjustment 333
F1 x F2 x F3 x F4 x F5 334
335
Where NOAEL is no-observed adverse event level, and 336
F represents various factors. The value selected should be justifiable. 337
338
The report should be reviewed by the manufacturer’s in-house team for completeness and 339
appropriateness. Team members should have the appropriate qualifications and experience in 340
the field of toxicology. A summary report should be prepared for each product and contain 341
information on the PDE value, genotoxicity and carcinogenicity (13). 342
343
These scientific reports should be used when considering the cleaning validation control 344
measures. 345
346
Manufacturers should periodically review and update PDE reports. The appropriate action 347
should be taken where such a report needs to be updated. 348
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5.9 Acceptance criteria 349
350
Limits established in cleaning validation should be justifiable. 351
352
Manufacturers often specified acceptance limits based on historical GMP texts. These 353
traditional limits may no longer be acceptable as HBELs (PDE) and cleanability studies were not 354
performed in many cases. 355
356
Criteria such as Margin of safety, Maximum Safe Carryover (MSC) and Maximum Safe Surface 357
Residue (MSSR) values should be calculated. Calculations and data should be available and 358
comply with data integrity principles. The calculation should include values of PDE, maximum 359
daily dose, batch size and equipment surface areas. 360
361
Maximum Safe Surface Residue (MSSR) should be calculated and presented, for example, in 362
table form listing preceding and following product values. The cleanability value obtained 363
should be considered in determining the acceptability of the procedure(s) and whether other 364
controls including separate, dedicated facilities are required. (See Annex 1 as an example.) 365
366
5.10 Grouping by therapeutic use 367
368
The risk associated with contamination and cross-contamination from one product to another 369
product in one therapeutic group, and between products in different therapeutic groups in 370
shared facilities, should be considered. For example, due to the risk, certain products should 371
be manufactured in dedicated or segregated self-contained facilities, including certain 372
antibiotics, certain hormones, certain cytotoxics and certain highly-active drugs – even though 373
these are in the same therapeutic class. 374
375
The risk assessment should include, for example, PDE values, batch size, maximum daily dose 376
of the next product, as well as other criteria associated with cleaning. 377
378
The higher the PDE value, the lower the risk. The products and therapeutic groups considered 379
for manufacturing should be plotted based on an identified scale of risk (14, 15). An illustration 380
is presented in figure 1 where hazard is plotted against risk 381
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Figure 1. Increasing hazard and PDE values 382
383
5.11 Analytical procedures 384
385
Samples obtained in cleaning validation should be analyzed by using specific, validated 386
procedures. The procedures should be developed, validated and appropriate for their intended 387
use. 388
389
Specific methods, such as HPLC, should be used where possible. Non-specific methods 390
including UV spectrophotometry should only be used where specific methods cannot be 391
employed. 392
393
Testing for total organic carbon (TOC) may be used where indicated and where justified. 394
395
Analytical procedures validation should be done on-site. Where analytical procedures were 396
developed and validated off-site, the scope and extent of validation should be defined and 397
justified. This includes procedures that are transferred from research and development 398
laboratories to site laboratories. (For analytical procedure validation, see reference 6). 399
400
Manufacturers should ensure that the procedures remain in a validated state. 401
402
403
404
405
406
Increasing hazard
Health Based Exposure Limit (HBEL) – PDE
>10 000ug/day <10ug/day
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5.12 Data integrity 407
408
Data, information and results pertaining to, for example, HBELs, PDE reports, results obtained 409
from cleaning validation and calculations should be scientific and should be in compliance with 410
the principles as contained in data integrity guidelines (12). 411
412
5.13 Cleaning validation and cleaning verification 413
414
The cleaning procedure should be validated after the cleaning procedure had been developed 415
and the cleanability study had been done. 416
417
Cleaning validation should include proof of, for example, the applicability of the procedure to 418
clean equipment that: 419
• had been kept in an unclean state for a period of time (dirty equipment hold time); 420
• are used after product change-over; 421
• are used in a campaign, where multiple batches of a product are produced one after 422
the other; and/or 423
• are stored in a clean state for defined periods of time (clean equipment hold time). 424
425
Cleaning validation should include consideration of HBELs when the appropriate method used 426
in establishing Carryover limits. Where HBELs are not used, scientific justification should be 427
provided. 428
429
The company should describe the policy and approach to cleaning verification. The 430
effectiveness of the validated cleaning procedure should be routinely verified. The approach 431
may include swab or rinse samples. The results obtained from testing on a routine basis should 432
be reviewed and subjected to statistical trending. 433
434
5.14 Visually clean 435
436
Visually clean is an important criterion in cleaning validation and should be one of the 437
acceptance criteria used on a routine basis. 438
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Visible residue limits (VRLs) should be determined. The process to determine the limit should 439
be appropriately described in procedures and protocols including concentrations, method of 440
spiking, surface areas, material of construction and other conditions such as light and angles. 441
442
VRLs should be quantitatively established for APIs, excipients, detergents and pharmaceutical 443
products. 444
445
Visual Detection Index (VDI) may be calculated using MSSR. 446
447
5.15 Cleaning verification and process capability 448
449
The cleaning procedure should remain in a validated state. Cleaning verification and process 450
capability may be used to provide data to support this. For example, the results from cleaning 451
verification sample analysis could be statistically trended. The capability of the cleaning 452
process is then calculated through an appropriate statistical process. 453
454
The presentation of individual results and data used in the calculation, such as with a Central 455
Processing Unit (Cpu) and acceptable daily exposure (ADE) base limit, should meet ALCOA 456
principles. 457
458
Data should be presented, for example, in graph form, and the capability of the process in 459
relation to control limits and the margin of safety should be discussed as part of continuous 460
improvement. 461
462
5.16 Personnel 463
464
Personnel should be trained in the principles of cleaning validation, with an emphasis on 465
contamination and cross-contamination control, HBELs setting, equipment disassembly, 466
sampling, testing and statistical calculations. 467
468
469
470
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5.17 Quality metrics and performance indicators 471
472
Aspects of HBELs setting, cleanability studies, cleaning validation and cleaning verification, as 473
well as process capability, should be considered in quality metrics, with performance indicators 474
identified and to be monitored. 475
476
5.18 Life cycle 477
478
HBEL reports, protocols, cleaning validation and cleaning verification should be included in a 479
company policy and life cycle approach in preventing cross-contamination in shared facilities. 480
481
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