D Ballarín-20211006
D Ballarín-20211006
D Ballarín-20211006
Pharmaceutical ispe.org
RESTRICTED
INDEX
➢ EJEMPLOS PRÁCTICOS
Pharmaceutical ispe.org
RESTRICTED
RESTRICTED
Contamination & Cross-contamination
best practices
RESTRICTED
Where and why did all this begin?
It all began in 2005, 16 years ago!
First we have to look back at some of the industry drivers that have influenced
us over the last 10 years, and have had a huge impact on our GMP texts about
cross-contamination risks in the last years:
RESTRICTED
Influences of cross-contamination control guidance
From all these, the following most influenced the
cross-contamination control guidance:
• Many APIs – Increasing potency & toxicity
• Reducing scale of manufacturing – personalised medicine
• Increased complexity
• Increasing novelty
• Squeezed profit margins
• They seemed to be squeezed into more and more dedicated and separate
facilities. They didn’t want these unless there was a really good reason for
them.
• The language of the GMPs, bracketing attributes of products in a non
scientific way was an issue.
Slide 7 RESTRICTED
The problem clauses
Dedicated facilities must be available for:
Certain
Antibiotics
Hormones
Cytotoxics
Sensitisers
Clauses 3.6, 5.18, 5.19 & 5.20 in the regulatory guidance are the problem EU & PIC/S GMP
Slide 8 RESTRICTED
The problem clauses
Clauses 3.6, 5.18, 5.19 & 5.20 in the regulatory guidance are the problem EU & PIC/S GMP
RESTRICTED
The problem clauses
Clauses 3.6, 5.18, 5.19 & 5.20 in the regulatory guidance are the problem EU & PIC/S GMP
RESTRICTED
Segregated and dedicated facilities EU/PIC-S regulatory background
• Applies to:
– GMP pilot plant.
– Clinical scale Investigational Product manufacturing (IPs).
– Commercial scale manufacturing.
RESTRICTED
EMA tries to fix the problem in 2005
• A concept paper was published in 2005. This announced
changes to Chapter 3.6 and 5.18 intended to remove the
existing ambiguity.
• Chapter 3.6 mentions, for example, "certain" products
that should not be manufactured in the same production
facility.
This implies use of a dedicated facility, but the actual
products covered are unclear.
• The text also mentions "exceptional cases"
without defining either these or the "certain"
products.
Industry, including Inspectors, were confused!
RESTRICTED
• The lengthy discussion about this subject prevented the
revision of the guide from being completed on schedule
(2006/7).
• Due to the great interest, EMA published a progress
report on 9th January 2008 on the state of the revision.
• This report says that the GMP/GDP Inspectors Working
Group has reached consensus that there should be:
– A list of substances for which a dedicated facility is mandatory.
– Additionally a list would identify substances for which specific
risk-based arguments will be necessary to allow shared facilities
to be used.
– Here, the text does not give any further details.
RESTRICTED
So, the key issues in 2008 were…
• A prescriptive list(s) or not ?
• Our regulators were still open to science-based
persuasion at this stage.
• What do the following mean?
– “Dedicated…”
– “Self-contained...”
– “Exceptional cases”… ”campaign working…can
be accepted”
• Does this only relate to facilities?
• Could it also be systems serving facilities e.g.
HVAC ?
So called RiskMaPP.
Note: A 2nd Edition is already done (ICH Q9 Q R M).
• Gets away from lists.
• Requires application of scientific knowledge of ADI
(allowable daily intake), and assessment of the risk that
cross-contamination ≧ ADI could occur, and application of
mitigation measures to keep below this threshold.
RESTRICTED
Acknowledgement
• Many of the images and
explanations included in this
presentation has been prepared
by member of ISPE’s Risk-MaPP
Task Team. They have been
utilised to ensure consistent
expression of the Risk-MaPP
objectives.
• Other slides expressing industry
practice and regulatory
experience are taken from the
authors international experience.
RESTRICTED
ISPE RiskMaPP
Decision tree to assist with Manufacturing and Sourcing decisions Compound X - cGMP/Regulatory focus
Are there any other factors that Y Can these issues be resolved?
Could prevent the use of a Y
Multi-product plant?
facility standards
Y N
operational
business confidentiality Can only be in multi-product facility with dedicated equipment or
units. Can only be in
OPTIONS single product
N Can be in multi-
facility
product facility
Disposable Dedicated Dedicated unit
equipment for equipment for
given step given step
RESTRICTED
1.The basic requirement
demands understanding
the X- contam risk,
severity, and applying
appropriate control
measures for all multi-
product facilities.
2.Default requirement.
Dedicated facilities are
required when:
- Operational or
technical measures
are inadequate.
- Toxicological
evaluation does not
support controllable
risk.
RESTRICTED
3.Some broadening
of the basic
requirements to
separate technical
poisons from
medicines.
4.Some more
general
requirements,
including an element
of risk to the patient
can be the route and
duration of
administration of the
medicine.
RESTRICTED
5.Identifies the
QRM role, and lists
some aspects to
consider
6.Broadens the
concept of
dedication and
segregation to
contact parts, and
specific zones
within a general
facility.
RESTRICTED
Now we have the new EU GMP requirements
7. Useful guidance
section on the
Technical
measures you
might consider to
manage the X-
contam risk to an
acceptable level.
RESTRICTED
9. A periodic
review of the
effectiveness of
the procedures is
required.
RESTRICTED
Summary – separated and dedicated facilities – the new GMP requirements
RESTRICTED
Embed into Quality Management System
Pharmaceutical ispe.org
RESTRICTED
API Details (Note 31 products with 10 APIs)
API ADE OEL LOWEST Scenario 4 in Risk-MaPP Second
mcg/day mcg/m3 DAILY DOSE Edition
mg/day
Anti-cancer 170 10 50
Anti-epileptic 250 10 150
Anti-hypertensive 1 25 3 2.5
Anti-hypertensive 2 400 50 50
Anti-psychotic 1 830 10 1800
Anti-psychotic 2 280 40 50
Anti-psychotic 3 1000 185 200
Misc. Agent 9750 580 300
Opioid 50 50 25
Vitamin B3 4200 2300 4
Pharmaceutical ispe.org
RESTRICTED
Information and Data Needed for Risk Analysis
✓ Product list including ADE/PDE, process, maximum daily dose, API form, product
presentation
✓ Equipment list including what products are produced in which equipment
✓ Process Flow diagrams
✓ Floor Plan, Flow diagrams, HVAC diagrams, room pressurization diagrams
✓ SOPs
✓ Historical Data
✓ Cleaning results, pressure differential alarm log, data from other data gathering studies, regulatory
actions, audits, deviations, incidents, and change control log
Pharmaceutical ispe.org
RESTRICTED
How Health Based Limits are used for Risk Assessment
Cleaning Limits
Potential for Airborne and Mechanical Transfer
Surrogate in Placebo
Drug in Drug
Ranking of Severity in FMEA and other risk ranking tools
✓ The Health Based Limit is a direct indication of the potential harm to patient using the scientific knowledge to
meet one of the primary principles laid out in ICH Q9
Pharmaceutical ispe.org
RESTRICTED
Effect of adding safety factors
Pharmaceutical ispe.org
RESTRICTED
Hierarchy of Limits
Acceptance
Limits
Action
Limits
Based on
The HBEL Alert Limits
Process
Based on historical
Control
data and/ or
Limits statistical analysis
of the process
Pharmaceutical ispe.org
RESTRICTED
Causes of Airborne Transfer
✓ Inadequate alarm/monitoring
Pharmaceutical ispe.org
RESTRICTED
Emission – Exposure –
What is “emitted” from the Contact with the emission
process (hazard)
✓ Used to determine the likelihood of airborne and mechanical transfer by measuring the tendency of an API to
migrate and settle on surfaces
✓ The rate of sedimentation is used to calculate the potential exposure due to the openness of the process and
the duration of openness.
✓ Compare this value to the Health Based Exposure Limit to determine the risk of cross contamination by
airborne transfer
Pharmaceutical ispe.org
RESTRICTED
Sample Results from Gradient Study
Pharmaceutical ispe.org
RESTRICTED
Sample Results from Gradient Study
Pharmaceutical ispe.org
RESTRICTED
Sample Results
Pharmaceutical ispe.org
RESTRICTED
FMEA – Airborne Transfer
Process Potential Failure Effect of S Potential Cause O Current Control D RPN
Step Failure
Milling Loss of pressure Airborne 5 Door open – single door 7* Manually check gauge at 7 245
differential to corridor beginning of shift
Pharmaceutical ispe.org
RESTRICTED
Causes of Mechanical Transfer
✓ Open systems
✓ Movement of materials/equipment without decontamination and cover
✓ Inadequate flow within the wash room
✓ Inadequate order of washing equipment/room
✓ Inadequate separation of clean and dirty equipment
✓ Inadequate gowning procedures
✓ Inadequate maintenance procedures
Pharmaceutical ispe.org
RESTRICTED
FMEA – Mechanical Transfer
Process Potential Effect of S Potential Cause O Current Control D RPN
Step Failure Failure
Compression Dirty Gown Mechanical 5 Inadequate Procedure 10* Procedure 10 500
not removed Transfer
Pharmaceutical ispe.org
RESTRICTED
Causes of Manual Cleaning Failures
Pharmaceutical ispe.org
RESTRICTED
Inadequate Cleaning Limits/ Limit of Detection
✓ Not health-based using ADE/PDE
✓ Limit of detection near limit
✓ Incorrect calculation for 1/1000th of low clinical dose
✓ Use of lowest dose manufactured rather than low clinical dose of product
✓ Use of lowest dose does not taken into account contraindications (i.e. pregnancy, pediatric, etc.)
Pharmaceutical ispe.org
RESTRICTED
Inadequate Cleaning Procedure
✓ Not enough detail
✓ How to clean – scrub, etc.
✓ Detergent
✓ type and concentration
✓ Water
✓ type, temperature, amount
Pharmaceutical ispe.org
RESTRICTED
Inadequate Cleaning Verification
API ADE LOWEST Lowest 1/1000th LCD
mcg/day DAILY Cleaning Cleaning
✓ Manual cleaning – validated with DOSE Limit Limit
verification yearly mg/day mcg/cm2 mcg/cm2
Anti-cancer 170 50 2.0 0.6*
✓ Routine monitoring visual only
Anti-epileptic 250 150 2.6 1.5*
✓ Visual range not determined. Literature
suggests 4 mcg/cm2 Anti- 25 2.5 0.13 0.01*
hypertensive 1
✓ Compounds in red require chemical Anti- 400 50 41 5.1*
analysis for routine monitoring hypertensive 2
Anti-psychotic 1 830 1800 11 23.9
✓ Compounds in green require
chemical analysis for routine Anti-psychotic 2 280 50 3.0 0.54*
monitoring if using 1/1000th for limit Anti-psychotic 3 1000 200 7.6 1.5*
✓ Compounds with * indicate a possible Misc Agent 9750 300 108 3.3*
need for more sensitive analytical
Opioid 50 25 264706 132353
methods since the limit is lower
using 1/1000th cleaning limit PharmaceuticalVitamin B3 4200 4 48 0.05*
ispe.org
RESTRICTED
Did Not Follow Procedure
✓ Inadequate training
✓ State of mind
✓ Distracted
✓ Rushed
Pharmaceutical ispe.org
RESTRICTED
FMEA - Retention
Process Potential Failure Effect of S Potential Cause O Current Control D RPN
Step Failure
Granulation Not clean to limits Retention 5 Inadequate verification 7* Visual inspection 10 350
Granulation Not clean to limits Retention 5 Inadequate procedure 7** SOP 7 245
Below is an assessment if chemical analysis is used at product change over and SOP improved (detail
and verification of steps)
Pharmaceutical ispe.org
RESTRICTED
What are the advantages?
✓ A robust risk management system for cross contamination provides knowledge on the
products, processes, facilities and equipment to permit better and more informed decisions
throughout the organization
✓ The HBEL provides a value that meets the intent of ICH Q9’s requirement that the evaluation of
risk is based on scientific knowledge that ultimately links to the protection of the patient
✓ Using a hierarchy of limits allows processes to be monitored and corrected prior to failures
requiring full investigation
✓ Using HBEL based cleaning limits are conservative (even for low hazard compounds) and in
many cases will allow the continued use of visual inspection only for routine monitoring
Pharmaceutical ispe.org
RESTRICTED
Key messages
✓ Risk is a function of hazard (the compound) and exposure (the process and controls)
✓ Hazard remains constant with the API and is characterized by the ADE/PDE
✓ The process/equipment/procedures are assessed to determine the potential exposure of one compound to
another
✓ Assessing how well the facility implements the GMP’s is an essential part of the risk
assessment process
✓ Use of data is essential to a robust risk assessment
✓ Cleaning is just one mode of cross contamination
✓ HBEL’s are used to set cleaning limits as well as for assessment of airborne and mechanical
transfer
✓ Embed the process into the Quality Management System to ensure it is a lifecycle approach
Pharmaceutical ispe.org
RESTRICTED
Processes
Process: Sample, weigh, mill, granulate, mill, dry, mill, blend, compression, and pack (10 steps)
All processes are fairly open (i.e., there are no containment devices or engineering controls used)
The facility uses a matrix approach to cleaning validation so therefore the cleaning limit used as
the acceptance criteria for validation and routine verification/monitoring is 0.1 mcg/cm2. This value
corresponds to the lowest cleaning limit combination (Anti-hypertensive1 and Anti-hypertensive2)
The cleaning procedures are all manual based with only a visual inspection by the operator and a
supervisor to verify the equipment is cleaned to the limits (0.1 mcg/cm2).
Pharmaceutical ispe.org
RESTRICTED
FMEA Scoring
Value Severity Occurrence Detection
10 Injury to a patient or More than once per batch Not detectable by current
employee; ADE< 1 mcg/day methods
7 Cause extreme customer Once per batch All manually inspected
dissatisfaction; ADE 1-10
ug/day
5 Something likely to result in a Once per 6 months Statistical sampling
complaint; ADE 10-100 Manual inspection with
mcg/day verification
3 Minor nuisance resulting in no Once every 1 – 3 years 100% inspection
loss; ADE 100-1000 mcg/day
1 Be unnoticed and not affect One occurrence in greater Obvious or controlled and
performance; ADE > 1000 than five years monitored and alarmed by
mcg/day control system
RESTRICTED
RPN Action Ranges
Pharmaceutical ispe.org
RESTRICTED
Causes of Mix-up
Pharmaceutical ispe.org
RESTRICTED
FMEA – Mix-up
Facility Process Step Potential Effect of S Potential Cause O Current Control D RPN
Failure Failure
OSD Receiving Wrong Label Mix-up 5 Inadequate 3 SOP 7 105
verification
OSD Compounding Wrong Mix-up 5 Human Error – 5 Manual verification 7 175
Materials materials staged
in corridor
Pharmaceutical ispe.org
RESTRICTED
K5
C
o4
n
n
o
n
w
le
ec
t
d
gi
en
g
Limit (mcg/cm2) = ADE(PDE)A x Batch SizeB Where MDD = Maximum Daily Dose
MDDB x SSA SSA – Shared Surface Area
Pharmaceutical ispe.org
RESTRICTED
Contamination main factors
RESTRICTED
Design Opportunities
The design of a facility, its Heating Ventilation and Air Conditioning (HVAC) system and equipment
is the first and critical step in preventing contamination and cross- contamination.
RESTRICTED
Design Opportunities
Equipment
All equipment should have smooth inert surfaces which are not additive or adsorptive, and installed in an
area that is easily cleaned.
If the equipment is difficult to clean, then consider using it for a dedicated purpose.
HVAC system
Airborne contaminants are controlled through effective ventilation and filtration. The criteria is detailed in
the next section, Effective Airflow/Extraction and HVAC Design.
RESTRICTED
Effective Airflow/Extraction and HVAC Design
External contaminants should be removed by effective filtration of the supply air, to retain the
required cleanroom classification.
Internal contaminants should be controlled by displacing the airflow:
RESTRICTED
Manufacturing Process
There are many opportunities for contamination of raw material, intermediates or packaging materials
throughout the manufacturing process.
RESTRICTED
Personnel Training and Clothing
Training is key in instilling good practices in personnel, that is: knowing that each and every person has a
responsibility to consumer health. Each employee must understand their role and responsibilities, which
should be clearly outlined in a job description.
Prior to and during employment, all personnel should undergo the relevant GMP and cleaning training
and be periodically assessed for competency.
The importance of gowning should be implicit and competency of gowning/de-gowning procedures
should be clearly documented and routinely monitored particularly in sterile situations via
microbiological testing.
Personnel should wear appropriate clothing to the duties they perform and the environment they work
in. These include:
• Personnel protective equipment (PPE)
• Clean body coverings (refer to Figure 3: Basic GMP Gowning)
• Cleanroom clothing (appropriate for each cleanroom classification), which can withstand repeated
wear and laundering with minimal deterioration (refer to Figure 4: Cleanroom Gowning)
• Appropriate footwear (e.g.: steel-capped shoes and shoe covers), which is provided by the company.
RESTRICTED
Gowning
RESTRICTED
Gowning
RESTRICTED
Cleaning Procedures
The following lists some of the cleaning criteria for cleaning equipment and general
housekeeping.
RESTRICTED
TAKEAWAYS____________________________
➢ It is critical that the facility, equipment and HVAC design allows for effective cleaning and
ensures cross-contamination is controlled. The facility and equipment should:
➢ Regular training and revalidation testing will ensure methods are consistent and are adhered
to.
RESTRICTED
Impacto
Pérdidas de
Beneficio
Relación con
Proveedores
Reputación
Regulatorio
Suministro
Paciente
RESTRICTED
Ejemplos de contaminantes
Aceite Plomo Cristal
RESTRICTED
RESTRICTED
Ejemplos de observaciones detectadas durante GEMBAs
RESTRICTED
Ejemplos de observaciones detectadas durante GEMBAS
RESTRICTED
Ejemplos de observaciones detectadas durante GEMBAs
RESTRICTED
Ejemplos de observaciones detectadas durante GEMBAs
RESTRICTED
¡Ahora tu!
¿Puedes identificar riesgos de contaminación fisica en los
siguientes casos?
RESTRICTED
Sin guantes Herramientas depositadas sobre bin
abierto
Puerta abierta
Conducto
sostenido
mediante cable
atado
Presencia de materiales de
desecho
Accesorio
depositado sobre
tapa bin
RESTRICTED
¿Cómo puedes TÚ ayudar a prevenir la
contaminación?
• Sigue los procedimientos (y desafía / plantea potenciales problemas si crees que el procedimiento
necesita mejorar)
• Mantén siempre un lugar de trabajo limpio y ordenado
• Pon más énfasis en la prevención durante auto-inspecciones
• Asegúrate de que estás vestido correctamente
• Si no estás seguro, siempre PARA y pregunta a tu responsable o supervisor
• Informa siempre de incidencias y fallos de equipo, no asumas que ya se ha abordado. Cuanto antes
identifiquemos la posible contaminación del producto, más posibilidades tenemos de minimizar el
impacto
RESTRICTED
FUENTES:
• Contamination & Cross-contamination best practices – PHARMOUT
RESTRICTED
Muchas gracias
RESTRICTED
RESTRICTED