Title: Thurloch OCriodain
1Recent Developments in Guidelines for Aseptic
Processing Applications and Practical Issues
- Thurloch OCriodain
- 29th Septemebr 2005
2Recent 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
3Benefits 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.
4Issues with the new guidelines
- Language and interpretation
- What is not included
- Differences between agencies
- EU and US
- Within EU
5Language 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?
6Language 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)
7Process Simulations (Media Fills)
Bulk solution
Fill - Finish
Packing
Distribution
8Process Simulations (Media Fills)
Bulk solution
Fill - Finish
Shipment
Storage
Packing
Distribution
Typical point of sterility control
9Process 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
10SIP 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?
11Differences 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
12Differences 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)
13Differences 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.
14Conclusion
- 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.