A Cost-Effective Approach to Cleaning Validation and Verification
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A Cost-Effective Approach to Cleaning Validation and Verification
Alexander Wellems, Director – Manufacturing, Ropack Pharma Solutions
A full-‐service contract manufacturing organization (CMO) encounters many compounds
at different phases of development and varying customer requirements. From fully
developed large scale manufacturing to a single development batch, the CMO must be
prepared to handle multiple compounds in the same facility. One extremely important
requirement is ensuring that the established cleaning procedures remove all residual
Active Pharmaceutical Ingredient (API) from all product-‐contact equipment parts utilized
during manufacturing so that there is no risk of cross-‐contamination.
The FDA clearly outlines its expectations within the “Validation of Cleaning Processes”
under Inspections Guides. To satisfy the enumerated expectations, there can be many
different approaches to cleaning verification and/or validation, and the CMO must
determine the most efficient, cost-‐effective and practical approach. In a CMO setting,
a standard three-‐batch validation approach may not be the most practical as there may
not be three sequential batches being manufactured at one time. Additionally, a
verification following each manufactured batch could be considered as it would be
sufficient to ensure no residual API, or detergent. However, this is not the most cost-‐
effective approach as this approach would result in a large amount of sample analysis
and obvious increases to laboratory costs.
A risk-‐based approach using a worst-‐case scenario is the most appropriate for a CMO.
By using a known compound with low solubility and low potency on the highest-‐risk
equipment and equipment locations, a validation protocol can be developed to ensure
A Cost-Effective Approach to Cleaning Validation and Verification
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the removal of the API. All considerations outlined in the FDA’s Inspection
Guide must be satisfied, including equipment design evaluation, written
and repeatable cleaning procedures and sampling procedures, validated analytical
methods and established acceptance criteria.
Following successful completion of the validation protocol, a risk-‐based matrix and
process must be created. Every new compound must be evaluated using the defined
matrix including all excipients and equipment to be used. If a new compound is found to
be a higher risk than the compound originally tested, a new validation protocol must be
established and performed using the new compound.
By establishing a worst-‐case scenario risk-‐based matrix approach to cleaning
verification/validation, a CMO can satisfy all regulatory and cGMP requirements
while maintaining a lean and cost-‐effective operation.
References:
FDA Inspection Guides – Validation of Cleaning Processes. http://www.fda.gov/ICECI/Inspections/InspectionGuides/ucm074922.htm
Guidance on aspects of cleaning validation in active pharmaceutical ingredient plants http://apic.cefic.org/pub/pub-‐cleaning-‐validation.pdf