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    Environmental MonitoringR Raghunandanan, Mumbai

    Director ISPE India26th February 2011

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    Introduction

    Agenda

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    All the factors impacting quality and

    safety of pharmaceutical products

    Facility

    Utilities

    Machines

    Personnel

    Environment includes

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    GMP requirement

    Facilities are designed to protect products from

    contamination or deterioration

    Facility must operate to meet the design

    criteria

    Only routine monitoring can prove that

    facilities are functioning as designed.

    Why environmental monitoring is

    important

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    Regulatory Requirements, US FDA Microbiological control of drug manufacturing

    areas: Statutory requirement as per 21 CFR 211 as

    stated in Sections 211.46, 211.56, and 211.113 211 CFR 211.46, Ventilation, air filtration, air

    heating and cooling:

    Adequate control over microorganisms, dust,

    humidity and temperature.

    Pre filters and particulate matter air filters for air

    supplies to production areas

    Why environmental monitoring is

    important

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    Regulatory Requirements EM is a requirement of GMP as per WHO, MHRA,

    MCC,TGA etc too.

    Schedule M requirements Sec 8.2.1. The licensee shall prevent mix-up and

    cross-contamination of drug material and drugproduct (from environmental dust) by proper air-

    handling system, pressure differential, segregation,status labeling and cleaning. Proper records andStandard Operating Procedures thereof shall bemaintained.

    Why environmental monitoring is

    important

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    Schedule M requirement

    All environmental parameters listed under para

    3.1 to 3.10 shall be verified and established at

    the time of installation and thereafter

    monitored at periodic intervals. The

    recommended frequencies of periodic

    monitoring shall be as follows :-

    Why environmental monitoring is

    important

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    Schedule M requirement - recommended frequencies

    (a) Particulate monitoring in air 6 Monthly.

    (b) HEPA filter integrity testing (smoke testing) Yearly

    (c) Air change rates 6 Monthly.(d) Air pressure differentials Daily.

    (e) Temperature and humidity Daily

    (f) Microbiological monitoring by settle plates and/or

    swabs in aseptic areas - daily, and at decreased

    frequency in other areas

    Why environmental monitoring is

    important

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    Product deterioration Microbiological deterioration

    Thermal deterioration

    Humidity induced deterioration Product contamination

    Particulate contamination

    Cross contamination Increased bio-burden

    Sterility failures

    What impacts from environment

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    Product exposed areasAseptic preparation

    Aseptic filling, blending

    Preparatory areasSolution preparation

    Component preparation

    General areasComponent washing

    Different environments

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    Non-viable air monitoring (particulates) Viable air monitoring (microbiological)

    Surface monitoring (facility and equipment)

    Personnel monitoring (garments & gloves) Temperature and humidity

    Pressure differentials (p)

    Gases and other utilities (including water) Disinfectants

    Detergents and washing agents

    What need to be monitored

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    Different classes of environments

    EUGrade

    ISO Class Class US FEDSTD

    A 5 100 M 3.5

    B 6 1000 M 4.5C 7 10,000 M 5.5

    D 8 100,000 M 6.5

    (US FED STD now replaced by ISO 14644-1 though

    we frequently use the terminology Class 100 etc.)

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    Available standards and guidance

    EU Annex 1, 2008 USP 32, General Chapter

    ISO 14644

    Schedule M of D&C Act and Rules of India

    Guidance for industry, US FDA Sterile DrugProducts produced by Aseptic Processing-Sept

    2004

    21 CFR Part 211.42

    21 CFR Part 211.46

    (and others)

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    Available standards and guidance

    It is important to remember that

    All standards are not exactly identical

    Manufacturer to follow the market

    requirements as a minimum

    You are free to have tighter in-house

    standards

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    Area particulates (non-viable) EU Annex 1

    Maximum no of particles per cubic meter

    At rest In Operation

    Grade 0.5

    micron

    5.0

    micron

    0.5

    micron

    5.0

    micron

    A 3520 20 3520 20

    B 3520 29 352,000 2900

    C 352,000 2900 3,520,000 29,000

    D 3,520,000 29,000 Not

    defined

    Not

    defined

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    At rest and In Operation At rest

    Air flow is ON

    Equipment installed but not in use

    No personnel in the area

    In Operation

    Air flow is ON

    Equipment in operation (sometimes

    simulated)

    Specified no. of personnel in the area

    Define these for each clean room

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    Microbiological monitoring standards

    (EU Annex 1)

    Limits for microbial contamination

    Grade Air sample

    Cfu/m3Settle plate

    Cfu/4 Hrs

    Contact

    plate

    Cfu/plate

    Glove

    print

    Cfu/glove

    A

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    Define Your Monitoring philosophy

    Reduction of risk to patients

    High confidence levels of sterility assurance

    A systematic and risk based approach of

    monitoring Investigation linked to Corrective and

    Preventive Actions

    Make assessments through trending theresults

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    Carry out risk assessment

    Carry out a risk assessment based on

    Type of product manufactured

    Type and age of facility

    Type and age of machinery Extent and type of containment used

    Document the rationale based on the risk

    assessment Periodically review the rationale and update

    monitoring levels

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    Essentials of monitoring

    programme

    Should be capable of detecting an adverse

    drift in a timely manner

    This only will facilitate meaningful and

    effective corrective actions

    The programme should be facility specific

    The manufacturer should develop, initiate,

    implement and document a monitoringprogram meeting these essentials

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    SOP for environmental monitoring (i)

    Detailed SOP for EM is one of the first steps and the

    SOP to include

    Reference to risk assessment

    Responsibilities of various functions Locations of monitoring (drawing etc.),

    document rationale

    Sampling and testing methods, sample sizes

    Specific sampling equipment and

    techniques

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    SOP for environmental monitoring (ii)

    Detailed SOP for EM to include

    Frequency and time of sampling

    Alert and action levels

    Documentation and periodic reviews

    Trending of results

    Notification to all concerned duringexcursions

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    Need for trained personnel

    Personnel involved in EM should

    Be adequately qualified

    Be experienced and trained

    Know the local regulatory requirements

    Know how to handle excursions

    Have investigational skills

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    Area monitoring non-viable

    Particulates monitoring required for all cleanrooms

    During qualification

    As part of routine review

    Particulates equal to or greater than 0.5m

    and 5.0m must be quantified

    Samples must be at least one cubic meter involume (see ISO 14644-1)

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    Grade A monitoring - non-viable

    Continuous monitoring of particulates in GradeA zones during preparation and operation

    Continuous monitoring of particulates in GradeB is recommended

    Point of fill monitored within 30 cm during

    operation

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    Grade A monitoring - non-viable

    Where particles are generated during operationuse simulated conditions (e.g. powder filling)

    Rationale for simulated conditions should be

    justified and documented

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    Area monitoring viable SOP to include additional details for

    Media requirements, growth promotion tests

    Need for neutralizers if any

    Incubation requirements (time & temp)

    Identification of organisms recovered

    Precautions to avoid contamination during

    and after monitoring (e.g.: use of contact

    plates) Monitoring for anaerobic organisms at

    defined intervals

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    Surface monitoring (i)

    Surface monitoring involves sampling varioussurfaces for microbiological quality

    Product contact surfaces, floors, walls, and

    equipment should be tested on a regular basis Contact plates and/or swabs are the choice

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    Surface monitoring (ii)

    Contact plates for smooth and easy to samplesurfaces

    Swabs for difficult to sample surfaces

    Helpful to assess Cleaning efficacy

    Contamination potentials

    Recovery studies need to be done

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    Personnel monitoring (i)

    Personnel significantly affect the quality of theenvironment

    Maintain contamination-free gloves and gowns

    throughout operations Monitoring of each operator's gloves and

    garments at exit

    When exceed established levels or show anadverse trend, carry out investigation

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    Personnel monitoring (ii)

    Follow-up actions shall include

    Increased sampling

    Increased observation of aseptic behavior

    Retraining

    Gowning re-qualification

    Shifting the individual to other operations

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    Personnel monitoring (iii)

    Trends from daily monitoring of personnel canprovide important information indicating possible

    routes of contamination

    Adequacy of personnel practices and training

    shall be routinely reviewed

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    Temperature & humidity levels

    Define product specific requirements

    When exceeded assess impact on product

    quality and patient safety

    Understand regulatory requirements

    Employ automated monitoring techniques

    where possible

    Alarms and notifications when limits are

    exceeded

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    Setting alert and action levels

    This is driven by

    Product specific requirements

    Regulatory requirements

    Market requirements (customer market)

    Findings during initial qualification

    Arising out of trend analysis

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    Trend analysis

    Monitoring trends provide assurance

    That facility is under control

    That practices are acceptable

    Trends change when changes are made to

    facility or practices

    Trends help updating alert and action levels

    and also frequencies

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    Dealing with excursions

    Notification to all concerned Investigation to commence

    Root cause identification

    Interview personnel involved

    Impact assessment on various batches

    Remedial actions

    Corrective and preventive actions

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    Corrective & Preventive Actions

    CAPA should be agreed and documented Changes may be required to

    Facility, HVAC system

    Equipment, containment, barrier systemsWays of working

    Training to personnel

    CAPA should be progressed and closed

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    EM and batch release

    EM data should be reviewed before release ofbatches of sterile products

    Any excursions must be investigated and actions

    completed before batch release Batches prior to and post to the excursions

    should also be included in the investigations

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    Remember

    A well-designed facility without

    proper environmental monitoring

    is nothing more than

    an ill-designed facility

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    Questions