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Thurloch OCriodain

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Title: Thurloch OCriodain


1
Recent Developments in Guidelines for Aseptic
Processing Applications and Practical Issues
  • Thurloch OCriodain
  • 29th Septemebr 2005

2
Recent Guidelines
  • EU Revised Annex 1
  • Manufacture of Sterile Medicinal Products
  • September 2003
  • FDA Guidance For Industry
  • Sterile Drug Products Produced by Aseptic
    Processing Current Good Manufacturing Practice
  • September 2004

3
Benefits to manufacturers of the new guidelines
  • Equivalence of standards between US and EU
  • Room Classification close correlation between
    the EU grading classification and the particulate
    classes referenced by FDA.
  • Media Fills Section 42 reads like an abstract of
    the detailed discussion in the FDA guideline.
  • Clarity of expectations a number of issues
    previously implied and accepted as unwritten
    rules, are now clearly stated.

4
Issues with the new guidelines
  • Language and interpretation
  • What is not included
  • Differences between agencies
  • EU and US
  • Within EU

5
Language and Interpretation
  • Example 1
  • A continuous measurement system should be used
    for monitoring the concentration of particles in
    the grade A zone, and is recommended for the
    surrounding grade B areas. (EU Annex 1, Section
    3, Note (a))
  • What is the meaning of recommended as a
    regulatory term?

6
Language and Interpretation
  • Example 2
  • The at rest state is the condition where the
    installation is installed and operating, complete
    with production equipment but with no operating
    personnel present. The in operation state is
    the condition where the installation is
    functioning in the defined operating mode with
    the specified number of personnel working. (EU
    Annex 1, Note 3)

7
Process Simulations (Media Fills)
Bulk solution
Fill - Finish
Packing
Distribution
8
Process Simulations (Media Fills)
Bulk solution
Fill - Finish
Shipment
Storage
Packing
Distribution
Typical point of sterility control
9
Process Simulations (Media Fills)
  • In this situation, can the entire operation be
    represented in one media simulation, or are
    several required?

Bulk solution
Fill - Finish
Shipment
Storage
Packing
Distribution
Point of sterility control for some products
10
SIP Systems
  • SIP interpreted as
  • Steam in place
  • Sanitise in place
  • Sterilise in place
  • The requirements for steam quality in autoclaves
    is defined through the application of standards
    EN285 and/or HTM 2010. What is the requirement
    for steam quality in an SIP system?

11
Differences between agenciesEU and FDA
  • Settle plates
  • An expectation in the EU guideline
  • An option in the FDA guideline
  • 5 µm particles
  • EU has a clear expectation of zero particles as
    the norm
  • FDA has no requirement

12
Differences between agenciesEU and FDA
  • Pre-sterilisation bioburden limits
  • EU limit is 10 cfu/100ml
  • (CPMP/QWP/486/95)
  • A pre-filtration bioburden limit should be
    established.
  • (FDA Guideline of 2004)

13
Differences between agenciesWithin EU
  • Steam sterilisation
  • IMB references HTM 2010 for autoclaves
  • MHRA references EN 285 for autoclaves
  • Some agencies reference only EN 554 for the
    sterilisation process.
  • 5 µm particles
  • EU has a clear expectation of zero particles as
    the norm. The procedure for handling exceptions
    is not clear.

14
Conclusion
  • The moves towards consistency of regulatory
    requirements is progressing, but slowly.
  • To achieve consistency of practices between EU
    and US, and within the EU will require further
    work.
  • There are aspects of the regulations yet to be
    clarified. Until that happens, risk assessment
    and consideration of the science will be the
    guiding principles for the industry.
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