#7 ispe environmental monitoring
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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