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Initial Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director Lan Zhang [email protected] Aug, 2015 1

Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

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Page 1: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation

Acceptance Criteria and Control Level

Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Lan Zhang

[email protected]

Aug, 2015

1

Page 2: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level

Acknowledge

Odile Smith

Director

Manufacturing Technology Process Technology

Sanofi Pasteur, Swiftwater, US

Shawn Haynes

Director

Quality Validation

Sanofi Pasteur, Swiftwater, US

Page 3: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Agenda

● Definitions

● Initial Acceptance Criteria Calculation

● MAC Calculation Equation Selection Rationales

● MAC Calculation Equations and Applicable Conditions

● Initial Acceptance Criteria Calculation

● Control Level Calculation

● Parameters in Initial Acceptance Criteria Calculation

● Equipment Surface Area and Batch Volume

● Rinse Volume

● Examples of Initial Acceptance Criteria Calculation

●Product Dedicated Equipment

●Multi-Product Contact Equipment

Page 4: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Definitions

● Initial Cleaning Validation Acceptance Criteria● Calculated per the health based, toxicity based, daily dose based and/or general limit

based maximum allowable carryover (MAC) of the potential contaminants.

● The initial acceptance criteria are the limits that are safe to the patient.

● Process capability is built into the cleaning process during cycle design and

development. The Cleaning Validation initial acceptance criterion is not the goal for a

cleaning cycle design and development.

● Control Level● Calculated per the statistical analysis of the cleaning validation and cleaning monitoring

data.

● The control level reflects the cleaning process capability.

● The control level will be used as the acceptance criterion of cleaning revalidation or for

similar new process equipment.

Page 5: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Initial Acceptance Criteria Calculation

● MAC Calculation Equation Selection Rationales

●The potential contaminants may be removed during the purification process. The acceptance criteria for formulation and filling equipment may be more stringent than those for fermentation/inoculation, primary purification and purification equipment.

●Proteins are usually degraded during the cleaning process and became easy-to-clean and non-active.

●Usually the cleaning validation acceptance criteria for dedicated equipment and for indirect product contact equipment are calculated using the General Limit Based MAC Calculation only because:Cleaning Validation for product dedicated equipment is to demonstrate residues are

not accumulated on equipment, the degraded residues are removed, and the risk of bioburden and endotoxin are under control. It is not to validate the carryover of one product to another product.

Compared with direct product contact equipment, the product contamination risk from indirect product contact equipment is low.

Page 6: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Initial Acceptance Criteria Calculation

● MAC Calculation Equations and Applicable Conditions

MAC Calculation

Equation

Application Conditions

Cleaning/

Disinfecti

on/Decont

amination

Agent

Direct Product Contact Equipment Indirect

Product

Contact

Equipment

Multi-Product Equipment Dedicated

Equipme

ntNon-toxic

Intermediate

(bulk

manufacturing),

Media,

Non-toxic Buffer

Toxic

Intermediate

(bulk

manufacturing),

Toxic Buffer

Non-toxic

Formulati

on or

Final

Product

Toxic

Formulation or

Final Product

ADE/PDE

(Health)

Based MAC

Calculation

Refer to

APIC

Guidance;

Refer to

EMA

Guideline

N/A N/A N/A N/A Applicable N/A N/A

LD50 Based

MAC

Calculation

Refer to

APIC

Guidance

Applicable N/A Applicable N/A Applicable,

if the ADE

based MAC is

not available.

N/A N/A

Daily Dose

Based MAC

Calculation

Refer to

APIC

Guidance

N/A N/A N/A Applicable Applicable N/A N/A

General

Limit Based

MAC

Calculation

Refer to

APIC

Guidance

Applicable Applicable Applicable Applicable Applicable Applicable Applicable

Summary All the applicable equations, whichever is lower.

Page 7: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Initial Acceptance Criteria Calculation

● Initial Acceptance Criteria Calculation Equations

●TOC – MAC Based Calculation

●Bioburden – Process Equipment Bioburden Control Limit

Based Calculation

If the in-process product bioburden control limit is not

available, the initial acceptance criterion is 10CUF/mL (1/10

of the USP Purified Water Specification).

If the equipment is sterilized after cleaning, the initial

acceptance criterion is USP Purified Water specification

100CFU/mL.

Page 8: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Initial Acceptance Criteria Calculation

● Initial Acceptance Criteria Calculation Equations (continued)

●Endotoxin – Process Equipment Endotoxin Control Limit Based Calculation

If the in process product endotoxin control limit is not available, use USP WFI specification ≤0.25 EU/mL.

The initial acceptance criterion for formulation and filling equipment is USP WFI specification ≤0.25 EU/mL.

● Conductivity – MAC Based Calculation

Calculation from MAC,

Make Concentration – Conductivity - PH curve.

Convert the acceptance criteria from concentration to conductivity.

If the pH at the acceptance criterion calculated based on MAC is not within WFI specification 5.0 to 7.0, test both conductivity and pH.

The initial acceptance criterion for formulation and filling equipment is USP WFI specification. If the calculated acceptance criterion is lower than WFI specification, reduce the rinse volume.

Page 9: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Initial Acceptance Criteria Calculation

● Initial Acceptance Criteria Calculation Equations (continued)

● PH – MAC Based Calculation

Calculation from MAC,

Make Concentration-PH curve.

Convert the acceptance criteria from concentration to pH.

The initial acceptance criterion for formulation and filling

equipment is USP WFI specification.

Page 10: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Control Level Calculation

●Control Level Calculation

● Cleaning Validation data, cleaning monitoring data and

cleaning revalidation data are statistically analyzed using 99th

Percentile, Negative Binomial Distribution (for bioburden), or

other appropriate approaches for the control levels. Out of

limit data are excluded.

●Control levels shall not be lower than USP WFI specifications

and the QL of the test methods, and shall not be higher than

the initial cleaning validation acceptance criteria.

●Control levels shall be periodically calculated when more

data.

Page 11: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Parameters in Initial Acceptance Criteria Calculation

● Equipment Surface Area and Batch Volume

●When the contaminants can be removed from the downstream purification steps

The initial acceptance criteria for the equipment will be calculated separately. It is not by equipment train.

The Total Surface Area is the product contact surface area of the individual system, e.g. a fermenter and the transfer lines.

The batch volume is the batch volume at this step.

●When the contaminants cannot be removed from the downstream purification steps

The initial acceptance criteria will be calculated for the equipment train.

The Total Surface Area is the sum of the product contact surface areas of the systems in the equipment train.

The batch volume is the corresponding final product volume.

Page 12: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Parameters in Initial Acceptance Criteria Calculation

● Rinse Volume

●The rinse volume for rinse samples is generally 1 ml/cm2

or a more appropriate value. The rinse volume shall be

verified against the requirements below:

The rinse volume shall not cause the acceptance criteria

lower than the QL of the test method.

The rinse volume shall be executable.

The rinse volume is generally lower than the minimum

batch volume.

Grab sample (final rinse sample) is taken before

completion of the cleaning cycle; therefore, it is a worst

case. The rinse volume used to calculate the acceptance

criteria of grab samples shall ensure all product contact

surfaces of the system are covered. Usually the rinse

volume used for grab sample acceptance criteria

calculation is between the equipment minimum operating

volume and the minimum batch volume.

Page 13: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Examples of Initial Acceptance Criteria Calculation

● Product Dedicated Equipment

When the acceptance criteria calculated using the lowest MAC is too low compared with the background caused by the ingredients with higher MACs; the second lowest MAC will be used to calculate the cleaning validation acceptance criteria, and a specific test method shall be developed for the ingredient with the lowest MAC.

Page 14: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Examples of Initial Acceptance Criteria Calculation

● Multi-Product Contact Equipment

The product with the lowest calculated Cleaning Validation

acceptance criteria may not be the worst case soil of the

product group. If the cleaning cycle developed using the worst

case soil cannot reach the Cleaning Validation acceptance

criteria, the product causing the lowest acceptance criteria may

be manufactured using product dedicated equipment.

Cleaning Validation Acceptance CriteriaNote: After manufacturing of products A, B and C, the

equipment is cleaned using the same cleaning process.

The Next Product

A B C

The Current

Product

A AA AB AC

B BA BB BC

C CA CB CC

Cleaning Validation Acceptance Criteria

for the equipment and product group

The Minimum of the Acceptance

Criteria in this Table.

Page 15: Initial Cleaning Validation Acceptance Criteria and … Cleaning Validation Acceptance Criteria and Control Level Sanofi Pasteur, Swiftwater, MTech Process Technology, Deputy Director

Initial Cleaning Validation Acceptance Criteria and Control Level: Examples of Initial Acceptance Criteria Calculation

● Equipment Group

Calculate the acceptance criteria for each equipment in the

equipment group. The lowest value is the Cleaning Validation

acceptance criteria for the equipment group.