An Easy to Understand Guide to Cleaning Validation

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This book describes how to comply with equipment cleaning validation regulations and guidelines successfully for activities related to or in support of the manufacture of drug products and substances (and their associated components produced for consumption by humans and animals).
Following the instructions in this book will ensure that you develop and document your cleaning validation processes in a consistent, understandable and traceable manner.

The rules and guidelines in this book are either a direct reflection of the “predicate rules” (the legislation governing the industry) or are best practices used within the industry. Although written primarily with the pharmaceutical and biotechnology industries in mind (two of the most highly regulated industries), these guidelines and good practices can be deployed anywhere.

Learning Objectives

  • Discuss the principles of cleaning validation;
  • Understand regulatory requirements and expectations;
  • Understand validation requirements;
  • Decide which equipment and process require validation;
  • Review testing methods used for cleaning process validation;
  • Understand different sampling methods;
  • Determine cleaning validation acceptance criteria;
  • Develop cleaning validation protocols for cleaning processes;
  • Create validation reports;
  • Understand the need to maintain a validated status.

What Will You Learn?

Upon the completion of this book you will be able to, discuss the principles of cleaning validation, understand regulatory requirements and expectations, understand validation requirements, decide which equipment and process require validation, review testing methods used for cleaning process validation, understand different sampling methods, determine cleaning validation acceptance criteria, develop cleaning validation protocols for cleaning processes, create validation reports and understand the need to maintain a validated status.

Who Should Read This Book?

At around 82 pages, this book is an easy read. As you move through the book you’ll quickly notice that it’s written in a clear tutorial format that’s easy to understand. If you hate wading through dry “academic-style how to” texts, this book will be a breath of fresh air to you. If you want to learn about cleaning validation or want to brush up on your current knowledge this book is made for you!

We’ve broken down this book into 24 key sections:

  • What is Cleaning Validation?
  • Regulatory Requirements
  • The Scope of Cleaning Validation
  • The Cleaning Validation Sequence
  • Pre-requisites
  • Cleaning Validation Strategy, Plan & Policy
  • Sampling
  • Recovery Studies
  • Analytical Method Selection and Development
  • Analytical Method Validation
  • Acceptance Criteria
  • Cleaning Method Development
  • Validation Master Plan
  • Cleaning Validation Plan
  • Cleaning Process Standard Operating Procedures (SOP)
  • Cleaning Validation Protocols
  • Protocol Execution
  • Deviations
  • Clean and Dirty Hold Times
  • Validation Report
  • Post Validation Monitoring
  • Maintaining the Validated Status
  • Retrospective Cleaning Validation

Purchase a Copy Today

Click here to purchase a copy of “An Easy to Understand Guide to Cleaning Validation”

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An Alternative View of the ICH Q10 Pharmaceutical Quality System (PQS)

The image below is that depicted by the International Conference of Harmonisation (ICH) Q10, Annex 2, and is supposed to depict a PQS or Pharmaceutical Quality System.

Typically, I really love the ICH. When we have to deal with outdated regulations from different global organizations it becomes a real nightmare trying to keep track of the nuances and the ICH has done a pretty good job of bringing several of the key organizations together and aligning them on how best to organize and meet the expected requirements.

That being said the diagram below and the depiction in Q10 of what a PQS should look like is greatly lacking.

Development Phases

In section 1.8 under the Quality Manual the ICH Q10 guidance states, “The description of the PQS should include: …(c) Identification of the pharmaceutical quality system processes, as well as their sequences, linkages and interdependencies.

Process maps and flow charts can be useful tools to facilitate depicting the pharmaceutical quality system processes in a visual manner”.

I completely agree.

The problem is using the graphical depiction they present in Annex 2 is completely worthless.

Basically they listed some of the PQS elements in a bar and then said they all apply to the entire product lifecycle, which simply isn’t true.

When we are in the development phase of our product lifecycle why would we do that under the change management system, or monitor process performance?

 

Controlling Change – No Value Add

There is no point in controlling changes for a product that is purposely being changed, nor does it offer any value to monitor the process performance for a process that has yet to be developed.

This isn’t a graphic depiction of the PQS, but rather a graphic of how they depict the lifecycle management (which also has some issues).

The PQS is the quality system and its subsystems and how they interrelate.

While it’s useful to look at how the PQS and product Lifecycle Management overlap and what elements of the PQS system are relevant at each lifecycle stage, it is not the point of the PQS, and even if that’s the end goal it’s not depicted here at all.

This image offers almost no value.

A Better Approach

So, what should this graphic look like?

While this is not a perfect view of a PQS, I would propose that the image below is a much better depiction of how the PQS should be visualized and a good place to start.

At the core of any quality system should be management. This goes back to Deming, who said, “Quality begins with the intent that is fixed by Management”.

Quality has to be rooted in the executive management team.

Define Core Quality Systems

Core quality systems then need to be defined. These are systems that impact all aspects of the business and include a Risk Management Policy, Resource Management, Document Control and CAPA systems.

All of the other subsystems, Deviations, Supplier Management, Equipment Qualifications, Validation, Material Management, etc, etc. all should be risk based or involve risk assessment, they all require resources and training, they call require documents (procedures, policies, records), and the CAPA system of course drives for process improvement regardless of the process.

Subsystems

All subsystems feed back into the main Management module. The subsystems listed, all are interconnected, with the exception of Post Market Systems.

The subsystems are important too, but they are farmed out to different groups and have different levels of importance depending on the stage of the product lifecycle.

Post Market Systems

The one exception is the Post Market Systems. This includes complaint management, product reviews, recall processes and other systems to support marketed products.

These generally do not interact with the other subsystems unless it is through the CAPA system or other management functions, but still utilizes all the systems under the management umbrella.

Alternate View

The PQS presented here, isn’t intended to be perfect, but I thought it was worth presenting an alternate view to the one presented by the ICH.

The ICH concept is a good one, and the ideas are fairly well laid out in the ICH, but the graphical representation of the PQS leaves a lot to be desired.

When establishing a PQS, it is better to start with something to what we’ve depicted here, and customize it as needed for the organization.

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How 21 CFR Part 11.3(7) Applies to Electronic Batch Records [Video]

When dealing with Part 11 it’s important to understand what an electronic signature actually means

The definition of electronic signatures or e-sigs can be found in 21 CFR Part 11.3(7).

Electronic Signature

An electronic signature or e-sig means a computer data compilation of any symbol or series of symbols executed, adopted, or authorized by an individual to be the legally binding equivalent of the individual’s handwritten signature.

Handwritten Signatures

We also need to understand what a handwritten signature means in the context of Part 11.
The definition of handwritten signatures can be found in 21 CFR Part 11.3(8).

Handwritten signature means the scripted name or legal mark of an individual handwritten by that individual and executed or adopted with the present intention to authenticate a writing in a permanent form.

The act of signing with a writing or marking instrument such as a pen or stylus is preserved. The scripted name or legal mark, while conventionally applied to paper, may also be applied to other devices that capture the name or mark.

Electronic Batch Records

Eric works in a Pharmaceutical company and he is responsible for the filling process of the batch been manufactured.

Each time Eric performs the filling process he has to populate a batch record with the appropriate details

After each step Eric must also fill in his signature and date to verify that he actually performed each task.

Eric is manually handwriting these details and they are legally binding to Eric.

21 CFR Part 11.3(8)

This is when 21 CFR Part 11.3(8) applies.

Fast forward 12 months and Eric’s company has implemented a brand new Manufacturing Execution System (MES) where all details around the batch manufacturing process are recorded electronically.

21 CFR Part 11.3(7)

Now when Eric performs the filling process he now populates everything electronically and signs with his username and password combination to verify that he has performed those tasks.

This is when 21 CFR Part 11.3 (7) applies.

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