http://pharmacie.hug-ge.ch/ens/confe...tion_krk08.pdf

Cleaning validation of cleanrooms and preparation
equipments
Dr Farshid SADEGHIPOUR
Head of production
Central Pharmacy, Geneva University Hospitals
EAHP Foundation Seminar:
“Patient Safety; More About Compounding"
23-25 May, 2008
Krakow, Poland
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
2
Useful Definitions
™ Cleaning :
“ Removal of soil particles /product residues
from surfaces by the use of chemical
agents and manual or mechanical action
™ Sanitization (Disinfection) :
“ Destruction of vegetative state organisms
1
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
3
Legal Basis
™ “Particular attention should be accorded to
the validation of … cleaning procedures”
(WHO)
™ “Cleaning validation should be performed in
order to confirm the effectiveness of a
cleaning procedure” (PIC/S, EU GMP)
™ “The data should support a conclusion that
residues have been reduced to an
‘acceptable’ level” (FDA)
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
4
New in Hospital Pharmacy
™ Development of the sterile drugs prepared
by aseptic techniques
™ Centralization of the preparation of
cytotoxic drugs in hospital pharmacies
2
Cleaning validation of clean-rooms and preparation equipments
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
5
Problems
™ Cross-contamination of the preparations
™ Microbiological problems due to poor
cleaning
™ Chemical contamination of the operators
Cross-contamination of the
preparations
6
™ Hospital Pharmacy Production units :
a Multi-product facility
“ an effort of validating the cleaning of each
piece of equipment which has been exposed
to a product
“ if not, considering seriously the possibility
and the cost of permanently dedicating this
equipment to a single product
3
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
Cross-contamination of the
preparations
7
™ Hospital Pharmacy Production units :
a Multi-product facility
“ For each Equipment :
ƒ cleaning validation is performed during process
development
ƒ Test-until-clean not considered acceptable
“ The validation methodology :
ƒ Products which simulate the physicochemical
properties of the substance to be removed may
be considered for use instead of the substances
themselves, when such substances are either
toxic or hazardous
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
8
Microbiological aspects
™ There should be some documented evidence that
routine cleaning and storage of equipment do not
allow microbial proliferation : equipment should
be dried before storage
™ The 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
4
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
9
Operators Chemical contamination
™ Preparation of cytotoxic drugs and
other hazardous drugs
“ Contamination due to aerosol formation
and drugs sublimation/evaporation
“ Spill management
“ After production cleaning procedures
and the risk assessment
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
10
Operators Chemical contamination
™ The risk associated with occupational lowlevel exposure has not been determined
™ Without evidence to the contrary, risk is
assumed to be present and proportional to
exposure in a dose-dependent fashion
™ A GMP compliant Cleaning validation
covers also operators risks
5
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
11
Defining the problem
™ Product (patient) oriented
“ Cross contamination
“ Residues
“ Microbiology
™ Operator oriented
“ Contamination risk
“ Accumulation problem due to poor cleaning
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
12
Ideal cleaning solution
™ Non-toxic to operators
™ Non-flammable
™ Fast-drying but not reasonably so
™ Not harmful to clean room surfaces
™ Not likely to leave particles or residue that
could be harmful to the product
™ Effective in removing undesirable
contamination
™ Reasonably priced
6
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
13
Possible contaminants
™ Product residues
™ Cleaning agent residues and breakdown
™ Airborne matter
™ Lubricants, ancillary material
™ Decomposition residues
™ Bacteria, mould and pyrogens
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
14
Strategy on cleaning validation
™ Product contact surfaces
™ After product changeover
™ Bracketing products for cleaning
validation
™ Periodic re-evaluation and revalidation
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
7
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
15
Cleaning Validation Protocol I
™ Objective of the validation
™ Responsibility for performing and
approving validation study
™ Description of equipment to be used
™ Interval between end of production and
cleaning, and commencement of
cleaning procedure
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
16
Cleaning Validation Protocol II
™ Cleaning procedures to be used
™ Any routine monitoring equipment used
™ Number of cleaning cycles performed
consecutively
™ Sampling procedures used and rationale
™ Sampling locations (clearly defined)
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
8
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
17
Record of Cleaning Validation
™ Analytical methods including Limit of
Detection (LOD) and Limit of
Quantification (LOQ)
™ Acceptance criteria and rationale
™ When revalidation will be required
™ Must have management and QA
involvement
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
18
Results and reports
™ Cleaning record signed by operator,
checked by production and reviewed by
QA
™ Final Validation Reports, including
conclusions
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
9
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
19
Personnel
™ Manual cleaning methods are difficult to
validate
™ Must have good training
™ Must have effective supervision
™ Cannot validate people; can measure
proficiency
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
20
Microbiological aspects
™ Include in validation strategy
™ Analyze risks of contamination
™ Consider equipment storage time
™ Equipment should be stored dry
™ Sterilization and pyrogen contamination
10
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
21
How to sample
™ Swab/swatch
™ Rinse fluid
™ Placebo
™ The sample transport and storage
conditions should be defined
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
22
Swab samples
™
™
™
™
™
Direct sampling method
Reproducibility
Extraction efficiency
Document swab locations
Disadvantages
“ inability to access some areas
“ assumes uniformity of contamination
surface
“ must extrapolate sample area to whole
surface
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
11
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
23
Rinse samples
™ Indirect method
™ Combine with swabs
™ Useful for cleaning agent residues
™ pH, conductivity, TOC
™ Insufficient evidence of cleaning
™ Sample very large surface areas
™ Need specific and sensitive analytical
method
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
24
Analytical methods I
™ Validate analytical method
™ Must be sensitive assay procedure:
“ HPLC, GC, HPTLC
“ TOC
“ pH
“ conductivity
“ UV
“ ELISA
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
12
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
25
Analytical methods II
Check:
™ Precision, linearity, selectivity
™ Limit of Detection (LOD)
™ Limit of Quantification (LOQ)
™ Recovery, by spiking
™ Consistency of recovery
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
26
Setting limits I
™ Regulatory authorities do not set limits
for specific products
™ Logically based
™ Limits must be practical, achievable and
verifiable
™ Allergenic and potent substances
™ Limit setting approach needed
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
13
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
27
Setting limits II
™ Uniform distribution of contaminants not
guaranteed
™ Decomposition products to be checked
™ Setting limits; cleaning criteria:
“ visually clean
“ 10ppm in another product
“ 0.1% of therapeutic dose
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
28
Setting limits: “Visually clean”
™ Always first criteria
™ Can be very sensitive but needs
verification
™ Use between same product batches of
same formulation
™ Illuminate surface
™ Spiking studies
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
14
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
29
Setting limits: “10 ppm”
Historical
In some poisons regulations
Pharmacopoeias limit test
Assumes residue to be harmful as heavy
metal
™ Useful for materials for which no
available toxicological data
™ Not for pharmacologically potent
material
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
™
™
™
™
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
30
Setting limits: not more than 0.1%
™ Proportion of MINIMUM daily dose of
current product carried over into
MAXIMUM daily dose of subsequent
product
™ Need to identify worst case
Training Modules on Good Manufacturing Practices, WHO, EDM , 01.2002
15
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
31
Auto-inspection questions
™ How is equipment cleaned?
™ Are different cleaning processes required?
™ How many times is a cleaning process
repeated before acceptable results are
obtained?
™ What is most appropriate solvent or
detergent?
™ At what point does system become clean?
™ What does visually clean mean?
™ When prefer to use disposable devices?
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
32
Operator Validation
16
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
33
Operator Validation
Validation Elements
™ Validation of each operator evaluating his
capacity to control chemical contaminations
during cytotoxic preparations
™ Scheduled at the end of the work session
with a second controlling operator
™ A total validation time of 60 minutes
™ Worst conditions Concept
™ Negative pressure isolator
™ A total cleaning of the isolator after the
validation
R. Ing & al., GSASA Congress Zurich, 2005,
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
34
Operator Validation
Validation Materials
™ A non-toxic tracer : 0,1 M Quinine HCl
solution
™ KCL 1 M 50 mL vials
™ NaCl 0.9% solution infusion bags
™ Sterile : Cytosafes, syringes, needles,
stoppers, Transfer-set, tubing, connectors,
gloves, working pad, waste bag, …
R. Ing & al., GSASA Congress Zurich, 2005,
17
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
35
Operator Validation
Validation Procedure
™ Sterile gloves over the isolator gloves
™ Dissolve the quinine vial with the
solvent to have a final 0.1 M solution
(drug reconstitution simulation)
™ Preparation of 4 different drug
simulation
R. Ing & al., GSASA Congress Zurich, 2005,
36
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
Operator Validation
Validation Procedure
20
x
=
R. Ing & al., GSASA Congress Zurich, 2005,
18
Quinine quantity [µmol] / Number of spots
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
Operator Validation
Operator
37
Detection equipment
™ Fluorimetric detection
(Perkin Elmer LS 40)
™ UV light
(CAMAG)
Working pad
R. Ing & al., GSASA Congress Zurich, 2005,
Operator Validation
38
Results
Quinine quantity
Number of spots
C. Ziewitz, Pharmacy HUG, 2008
19
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
39
Operator Validation
Discussion
™ Detected quantities:
“ 0.116 – 0.441 µmol of Quinine
“ (= 1.16 – 4.41 µl of the Quinine 0.1M solution)
™ « Acceptable level » according to FDA:
“ 0.1% of the daily dose of the active ingredient
“ 5-FU 50 mg/ml, Daily dose 1000 mg
ƒ « acceptable level »
ƒ Detected quantity equivalence :
min
max
→ 100 µg
→ 6 µg
→ 22 µg
“ Vincristine 1 mg/ml, Daily dose 2 mg
ƒ « acceptable level »
ƒ Detected quantity equivalence :
min
max
→ 2.0 µg
→ 1.6 µg
→ 4.6 µg
C. Ziewitz, Pharmacy HUG, 2008
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
40
General Conclusions
™ Need for a cleaning validation strategy
™ Assess each situation on its merits
™ Scientific rationale must be developed
“ equipment selection
“ contamination distribution
“ significance of the contaminant
™ “Visually clean” may be all that is required
™ Disposable devices each time it is possible
™ Developing non-toxic evaluation methods
20
Cleaning validation of clean-rooms and preparation equipments
Dr Farshid SADEGHIPOUR
EAHP Foundation Seminar,
“Patient Safety; More About Compounding”
23-25 May 2008, Krakow, Poland
41
References
™ Supplementary Training Modules on
Good Manufacturing Practices, WHO, EDM ,
01.2002
™ FDA. "Guide to Inspectors of Validation of
Cleaning Procedures," 1993
™ Health Canada, Health Products and Food Branch
Inspectorate, "Good Manufacturing Practices Cleaning Validation Guidelines, 2000
21