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Process
Personnel
Design
Zoning, Differential Pressure Temperature Relative Humidity Personnel and Material Flow
Equipment
Personnel
Sterility Testing Particulate Testing Container Closure Integrity Testing Other Final Product/Release Testing Stability Testing Media Fill Records Production Batch Records EM Trend Data Release Testing Batch Records Investigation
Response to Excursions Corrective Actions
Documentation
Sterility Testing
Monitoring of aseptic processing Compendial requirement
US Pharmacopoeia European Pharmacopoeia British Pharmacopoeia Japanese Pharmacopoeia Code of Federal Regulations
Test methods became harmonized with the publication of the BP 2004, Ph Eur 5.1 and USP 28 editions
Incubate for 14 days 14 days? Or 14 x 24 hours? Why is the maximum incubation for bacteria 3 days in growth promotion test and 5 days in validation of sterility test? After all, why isnt the maximum incubation be 14 days?
Method Validation
Should validation of sterility test be repeated at each testing location for the same product, when testing methodology is the same? Is revalidation of sterility testing methodology necessary? If so, at frequency? Every 12 months? Can bulk material be used as a substitute for final vials in the validation of sterility test? How many firms use environmental/process isolates in the validation of sterility test?
How many firms perform stasis test (i.e. monitoring the efficacy of test media at the end of the incubation period)? How often should stasis test be performed on each product?
Is bulk sterility testing, as required by CFR for biologics, an absolute requirement for biotech products? Sampling plan for final product: Beginning, middle, end; or randomly throughout the entire batch? How to obtain 20 representative samples for a >10000 vials fill? How to qualify a sterility tester? Re-qualification of testers? How often?
Sample/Sampling Plan
Qualification of Personnel
These Pharmacopeial procedures are not by themselves designed to ensure that a batch of product is sterile or has been sterilized. This is accomplished primarily by validation of the sterilization process or of the aseptic processing procedures. When evidence of microbial contamination of the article is obtained by the appropriate Pharmacopeial methods, the result so obtained is conclusive evidence of failure of the article to meet the requirements of the test for sterility, even if a different result is obtained by an alternative procedure. A sterility positive result can be viewed as indicative of production or laboratory problems, and the entire manufacturing process should be comprehensively investigated since such problems often can extend beyond a single batch.
To invalidate a positive sterility test is extremely difficult, if not impossible. Quality should be built into the product, and testing alone cannot be relied on to ensure product quality.
Media Fills
Validation of aseptic processing True parameter for assuring that a manufacturing process is capable of producing sterile pharmaceuticals using an aseptic process. Media fill program provides evaluation of multiple systems.
Media Fill
FDA Guidance for Industry EU Guide to Good Manufacturing Practice Revision to Annex 1
Sample size/Lot
Media
Maximum 40
Soybean-Casein Digest Medium (TSB) Fluid Thioglycollate Medium (FTM) TSB 14 days @ 20-25C FTM 14 days @ 30-35C
Yes
All
Soybean-Casein Digest Medium (TSB)
TSB 7 days @ 20-25C TSB 7 days @ 30-35C Yes Non-destructive: Integral container No false positives Detects single vial failure
Destructive: Sample contents transferred False positives Detects high level sterility failure