Environmental Monitoring: Brazil-PDA March 2020 Anvisa Regulations
Environmental Monitoring: Brazil-PDA March 2020 Anvisa Regulations
Brazil-PDA
March 2020
ANVISA REGULATIONS
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Why monitor?
Air
1. Total Particulates (Inert or Nonviables plus Viables)
2. Viables
a. Settle Plates
b. Active Air Sampling
Surfaces (Viables)
1. Facilities and Instruments
2. Personnel (Gloves, garment, etc)
a. Contact Plates
b. Swabs
GMP Requirements
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PIC/S
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• Pharmaceutical Manufacturing
– FDA GMP: 21 CFR Parts 210/211
– EU GMP: EudraLex Volume 4 “Guidance for
Good Manufacturing Practices for Medicinal
Products for Human and Veterinary Use”
• Aseptic Processing
– FDA: “Guidance for Industry, Sterile Drug
Products Produced by Aseptic Processing”
• Sep 2004
– EU: Eudralex vol. 4 Good Manufacturing,
“Annex 1, Manufacture of Sterile Medicinal
Products”
• Mar 2009
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3. Data review: The data accrued from the monitoring must be reviewed in
light of the risk to finished product quality.
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Cleanroom Grades
• Grade A: Local zones for high risk operations (filling, closing, etc.)
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EU GMP (PIC’S)Annex 1
Grade D
Grade C
Grade B
Grade A
ISO 4.8/4.8
ISO 5/7
ISO 7/8
ISO 8/U
At Rest / In Operation
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EU 2009
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2 1
4 2
6 3
8 4
10 5
24 6
28 7
32 8
36 9
52 10
56 11
64 12
68 13
72 14
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104 16
108 17
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148 19
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• 5 m x 12 m = 60 m2 => 12 locations (from table) 192 21
232 22
• The cleanroom or clean zone area is divided up into a grid of 276 23
sections of near equal area, whose number is equal to the number 352
436
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of sampling locations. 636 26
1000 27
• Sampling location representative of the characteristics of the >1000 See Equation A.1
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• Cn,m is the class limit (number of particles per cubic meter) for the
considered particle size specified for that class.
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• Applying the formula, the single volume ( Vs )per location is calculated as:
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PICS
FDA
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EU Annex 1 (PIC’S):
• “Cleanrooms and clean air devices should be routinely monitored in
operation.”
• “Classification should be clearly differentiated from operational
process monitoring.”
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EU Annex 1
• “Monitoring locations based on a formal risk analysis study and the
results obtained during classification”
Note: Risk analysis has to be described in a formal written plan that is followed. The plan
details must be rationalized and have good description.
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Why an update of the Guideline?
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New EU GMP Annex 1 - Scope
This Annex provides general guidance that should be used for all sterile medicinal
products and sterile active substances, via adaption, using the principles of Quality
Risk Management (QRM), to ensure that microbial, particulate and pyrogen
contamination associated with microbes is prevented in the final product.
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Old Annex 1 Section Number
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Section Number
1. Scope 6. Equipment
Areas (other than sterile medicinal products) to apply General guidance on the design and operation of equipment.
general principles of the annex. 7. Utilities
2. Principle Guidance with regards to the special requirements of utilities
General principles as applied to the manufacture of such as water, air and vacuum.
medicinal products. 8. Production and specific technologies
3. Pharmaceutical Quality System (PQS) Discusses aseptic and terminal sterilization process approach
Highlights the specific requirements of the PQS when and different technologies such as lyophilization and Blow Fill
applied to sterile medicinal products. Seal (BFS) and their requirements. Discusses approaches to
4. Personnel product sterilization, equipment and packaging components.
Guidance on requirements for specific training, 9. Viable and non-viable environmental and process
knowledge and skills. Also gives guidance to the monitoring
qualification of personnel. Differs from section 5. Applies to ongoing routine monitoring
5. Premises for setting alert limits and reviewing trend data. Discusses
General guidance on needs of premises design and requirements of Aseptic Process Simulation.
qualification including the use of barrier technology. 10. Quality control (QC)
Discusses sterile medicinal product QC requirements.
11. Glossary explanation of specific terminology
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New EU-GMP Annex 1 – Why an Update
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Annex 1: 2008 Vs Annex 1: 2017 - Terminology
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Viable vs non viable – Scientific basics
Comment
Total Particulate
= viable + non viable(inert) particles
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Clean room qualification vs Monitoring
Comment
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5µm Removal from classification
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Greater or Equal to 5 µm removal for classification
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Clean room qualification vs Monitoring
Comment
• 5.28 Clean room qualification (including • Do not use classification limits (ISO 14644-
classification) should be clearly 1) for Monitoring!!!
differentiated from operational process
• Grade A and B zones are treated equally
environmental monitoring.
• Bi-annual requalification is not yet
• 5.29 Clean rooms should be requalified
standard and will create difficulties and
periodically and after changes to
loss of productivity at some facilities
equipment, facility or processes based on
the principles of QRM. For grade A and B • Risk Mitigation: Use of RMM to get the
zones, the maximum time interval for zones faster back into operation
requalification is 6 months. For grades C
and D, the maximum time interval for
requalification is 12 months.
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Quality Risk Management Methods and Tools
Below is a list of some of these tools (further details in Annex 1 and section
VIII):
❖ Basic risk management facilitation methods (flowcharts, check sheets, etc.)
❖ Failure Mode Effects Analysis (FMEA)
❖ Failure Mode, Effects, and Criticality Analysis (FMECA)
❖ Fault Tree Analysis (FTA)
❖ Hazard Analysis and Critical Control Points (HACCP)
❖ Hazard Operability Analysis (HAZOP)
❖ Preliminary Hazard Analysis (PHA)
❖ Risk ranking and filtering
❖ Supporting statistical tools
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FMEA: Environmental Monitoring
➢ Step 1: Risk analysis for each phase of the production process. The purpose
of this phase is to identify, through an FMEA approach, the critical
production areas where high-risk activities are performed for the product.
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Failure Mode Effects Analysis (FMEA)
1. Identify the functions of your scope. Ask, “What is the purpose of this system, design,
process or service?
2. For each function, identify all the ways failure could happen
3. For each failure mode, identify all the consequences on the system, related systems,
process, related processes, product, service, customer or regulations
4. Determine how serious each effect is. This is the severity rating, or S. Severity is usually
rated on a scale from 1 to 10, where 1 is insignificant and 10 is catastrophic.
5. For each failure mode, determine all the potential root causes
6. For each cause, determine the occurrence rating, or O. This rating estimates the
probability of failure occurring for that reason during the lifetime of your scope.
Occurrence is usually rated on a scale from 1 to 10, where 1 is extremely unlikely and 10 is
inevitable.
7. For each cause, identify current process controls.
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Failure Mode Effects Analysis (FMEA)
8. For each control, determine the detection rating, or D. This rating estimates how
well the controls can detect either the cause or its failure mode after they have happened
but before the customer is affected. Detection is usually rated on a scale from 1 to 10,
where 1 means the control is absolutely certain to detect the problem and 10 means the
control is certain not to detect the problem (or no control exists)
RPN = S x O x D
These numbers provide guidance for ranking potential failures in the order they should be
addressed. Identify recommended actions. These actions may be design or process changes to
lower occurrence. They may be additional controls to improve detection. Also note who is
responsible for the actions and target completion dates.
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Monitoring – frequency
EU Annex 1
• Grade A: Continuous monitoring required during setup and
operation
• Grade B: Recommend same as Grade A; frequency can be reduced
• Grade C, D: In accordance with principles of quality risk
management
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EU Annex 1
• “It is not necessary for the sample volume to be the same as that used for
formal classification of cleanrooms”
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Monitoring – special applications
• Powder filling
EU (PIC’S) acknowledge difficulty of monitoring close to fill point, but
both require monitoring prior to filling
– Recommendation:
• Monitor particles before and after filling. Monitor differential
pressure throughout.
• Monitor surrounding area, with frequency depending on the
barrier
• Dangerous product (cytotoxic, radioactive)
– Same as powder filling – monitor particles before and after filling
– Negative pressure isolator increases the importance of monitoring
the surrounding area.
EU Annex 1 (PIC’S)
• “Non-combustible gases should be passed through micro-organism
retentive filters.”
• “The integrity of critical gas and air vent filters should be confirmed
after use. The integrity of other filters should be confirmed at
appropriate intervals.”
• Supporting areas (Grade C/D, ISO 7/8) can be tested periodically with
portables or manifolds.
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Classification Monitoring
Frequency 6 months or annual Daily, weekly, monthly,
or continuous
Number of positions By formula Risk Analysis
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ANVISA
The next three slides are from a
presentation given by ANVISA
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0.5 µ Data
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Data analysis – Initial Qualification and Routine Monitoring
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Particle data interpretation (0.5 µm)
•95% UCL
• (SD x 2)
•Operationa
l Average
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Data interpretation guidance
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Different approaches
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5.0 µ Data
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Particle data interpretation (5.0 µm)
N:m = 3:10
Continuous Frequent
Where t = 1 min
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Data interpretation guidance
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ISO Standards
EU Annex 1 says:
“This guidance does not lay out detailed methods for determining the
microbiological and particulate cleanliness of air, surfaces, etc. References
should be made to other documents such as the EN/ISO Standards.”
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Questions or Comments?
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Thank you
Dave Crance
[email protected]