Cleaning Validation A Practical Approach

CLEANING
VALIDATION
A Practical Approach
•••
Gil Bismuth
Shosh Neumann
informa
healthcare
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CRC Press
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Contents
PREFACE ix
PART ONE
DEVELOPING A CLEANING PROCEDURE
1. CONTAMINATION CONTROL 3
Introduction 3
Contamination Types 3
Chemical Contamination 3
Physical Contamination 4
Microbiological Contamination 4
Contamination Control 4
Facilities 4
Equipment 5
Personnel 6
Material and Waste Flows 6
2. REGULATORY REQUIREMENTS 7
3. CLEANING BASIC CONCEPTS 15
Introduction 15
Cleaning Mechanisms 15
Levels of Cleaning 16
Time Limitations 17
iii
iv Cleaning Validation-A Practical Approach
4. CLEANING PROCEDURE 21
Introduction 21
Equipment Design 21
Manufacturing Process 22
Operator 23
Materials and Tools 24
Solvents 24
Cleaning Agents 24
Cleaning Tools 25
Control of Materials and Tools 25
Cleaning Procedure 26
Types 26
Documentation 30
PART TWO
DEVELOPING A CLEANING VALIDATION PROGRAM
5. CLEANING VALIDATION POLICY 35
Introduction 35
Policy 37
Selecting the Worst Case Related to the Product 37

Product Grouping 38
Selecting the Worst Case Related to the Equipment 39
Equipment Grouping 39
Hard-to-Clean Locations 39
Selecting the Scientific Basis for the Contamination Limit 40

Contamination Limit Based on Toxicological Data 44
Dose-Related Contamination Limit 45
Contamination Limit Based on Other Considerations 46
Acceptance Criterion Based on Visual Inspection 47
The Proposed Approach 47
Selecting the Sampling Method 48

The Swabbing Method 48
The Rinse Sample Method 51
The Placebo Method 52
Contents v
Selecting the Analytical Method 53

Basic Requirements 53
Analytical Method Survey 54
Analytical Method Validation 55
Analytical Method Implementation 56
6. CONTAMINATION ACCEPTANCE LIMITS 57
Lowest Therapeutic Dose (LTD) 59

Maximal Daily Dose 60
Highest Unit Dose Weight and Smallest Batch Size 60
Calculation of the Sample Contamination Limit
for the Active Ingredient 61
Calculation of the Sample Contamination Limit
for the Cleaning Agent 61
Discussion of the Sample Contamination Limit 61
Averaging of Sample Swab Results 61
Equipment Train 62
7. CLEANING VALIDATION PLANNING AND EXECUTION 65
Introduction 65
Organization 65
Planning 67
Database 68
Equipment Grouping 68
Selection of the Equipment Worst Case 70
Product Grouping 74
Selection of the Product Worst Case 74
Cleaning Agents 78
Calculation of the Contamination Acceptance Limit 78
Active Ingredient 78
Cleaning Agent 78
Cleaning Validation Master Plan 78

Working Plan 80
Execution 80
vi Cleaning Validation-A Practical Approach
Cleaning Validation Protocol 83

Sampling and Testing 84
Cleaning Validation Report 84
8. CLEANING VALIDATION MONITORING AND MAINTENANCE 85
Monitoring 85
Maintenance of Validation 85
9. SPECIAL CLEANING VALIDATION ISSUES 89
Biocontamination 89
Penicillin Contamination 90
Nonpharmaceuticals 91
Contract Manufacturing and Packaging 91
10. CLEANING VALIDATION TRENDS 93
Introduction 93
Personnel 93
Equipment 94
Cleaning Agents and Tools 94
Sampling Technique 95
Analytical Methods 95
Regulatory Issues 95
The Future 96
Contents vii
APPENDICES
CLEANING AND CLEANING VALIDATION PROCEDURES
APPENDIX A-CLEANING 99
Policy-Equipment and Processing Area Cleaning 101

Purpose 103
Responsibility 103
Frequency 103
Procedure 104
Documentation 106
Cleaning Procedure-High Shear Mixer (Diosna) ll1

Equipment 113
Ancillary Equipment 114
Process Area 115
Visual Inspection 116
Reassembly 116
Status Label 116
Storage Conditions 116
Summary 117
Documentation 117
APPENDIX B-CLEANING VALIDATION ll9
Policy-Cleaning Validation 121

Purpose 123
Responsibility 123
Frequency 124
Procedure 124
Standard Operating Procedure-Cleaning Validation 129

Purpose 131
Responsibility 131
Frequency 132
Procedure 132
Documentation 135
viii Cleaning Validation-A Practical Approach
Standard Operating Procedure-Cleaning Validation-

Change Control 137
Purpose 139
Responsibility 139
Frequency 139
Procedure 139
Documentation 140
Work Instructions-Swab Sampling for Cleaning Validation 145

Safety 147
Equipment and Materials 147
Procedure 147
Acceptance Criteria 148
Documentation 148
Work Instructions-Swab Characterization for Cleaning

Validation 149
Safety 151
Procedure 151
Documentation 152
Work Instructions-Sampling Recovery Test 153
Safety 155
Procedure 156
Documentation 157
Cleaning Validation Protocol and Report 159

Purpose 163
Responsibility 163
Frequency 164
Procedure 164
Documentation 164
Conclusion 175
REFERENCES 177
INDEX 183
Preface
Alice: "Would you tell me, please, which way I ought to go from here?"
"That depends a good deal on where you want to get to", said the cat.
"I don't much care where", said Alice.
"Then it doesn't matter which way you go", said the cat.
"So long as I get somewhere", Alice added as an explanation.
"Oh, you're sure to do that", said the cat,
"if you only walk long enough".
Lewis Carroll, Alice in Wonderland
Unless you have gone through the experience yourself, dealing with cleaning validation
appears as an insuperable task. How can one deal with a multitude of products and a
variety of equipment? What resources are needed? Where does one start? The questions
seem as numerous as the products themselves, while the answers are scarce.
Although interest in cleaning validation started at the beginning of this decade,
there are only regulatory recommendations and a relatively small bundle of articles pro-
viding some basic principles on selected aspects of this wide field. These are highly
instructive in picturing cleaning validation as a multifaceted undertaking involving a
high degree of understanding and knowledge relating to quite different disciplines, such
as toxicological or clinical studies, pharmaceutics, analytical chemistry, and engineer-
ing. Yet the summation of the knowledge acquired is not to give more than a mosaic
of ideas, hints, and triggers. Although very useful, it is not sufficient to build up a com-
prehensive cleaning validation program.
Whether or not your company has been recently inspected, or even got an obser-
vation on deficiencies of your cleaning validation program, you won't have any diffi-
culty in convincing upper management of the need to establish a cleaning validation
program in order to satisfy the regulatory authorities. The U.S. Freedom of Informa-
tion Act, through the Food and Drug Administration (FDA) web site of the Internet,
gives real-time access to the citations and the warning letters issued by the FDA to com-
panies which did not adequately address this hot topic. Considering that violations cited
ix
x Cleaning Validation-A Practical Approach
in these dreadful letters may result in holding new applications, no company will allow
itself not to enter this relatively new field of the pharmaceutical industry. Cleaning val-
idation, however, is not only performed to satisfy authorities. The safety of patients tak-
ing your company's medicines is the prime objective, and no company would want to
be involved in a litigation resulting from product contamination.
Now the burden of developing a cleaning validation program is on you, the qual-
ity assurance manager or the research and development (R&D) manager or whoever in
your organization is responsible for it. You have gathered all the regulatory requirements,
read all the literature relating to the subject, and participated in one or more of the
many conferences and courses on cleaning validation. Your mind is burgeoning with a
lot of ideas and the everlasting questions What?, When?, and How? are swirling in your
mind like a predator preparing to rush its prey.
Beyond the confusion, and as for any new project, a cleaning validation program
is about understanding the objective, determining the approach, setting a scientifically
sound policy, organizing a program, and allocating adequate resources. The aim of this
book is to provide professionals in charge of the cleaning validation program with a
detailed step-by-step guide to establish a comprehensive, yet manageable cleaning val-
idation program, and with practical examples to illustrate the implementation of the
proposed program. The user-friendly database formats and practical data relating to
various aspects of cleaning validation also provided in this book will make it easy for
anyone to rapidly start up the program.
This book shows that what may have started with confusion ends up with a clear
and manageable program which, to the authors' opinion and experience, is deemed to
be acceptable by the various international regulatory authorities.
Gil Bismuth
Shosh Neumann
Part One
Developing a
Cleaning Procedure
1
Contamination Control
INTRODUCTION
The pharmaceutical industry strives to manufacture products that fit patients' needs
and expectations, while satisfying the regulatory requirements. The FDA Good Manu-
facturing Practice (GMP) regulations, presented in the introductory section of 21 CFR
Part 210, demand that a "drug meet the requirements of the act as to safety, and has
the identity and strength and meet the quality and purity characteristics that it pur-
ports or is represented to possess". The regulations go on to warn that "the failure to
comply with any regulation set forth in this part [210] and Parts 211 through 226 of
this chapter in the manufacture, processing, packaging, or holding of a drug shall ren-
der such drug to be adulterated under section 501 (a)(2)(B) of the [Federal Food, Drug
and Cosmetic] Act ... " (FDA, April 1998). As can be seen, not only the identity, the
strength, the intrinsic impurities, and pharmacological activity of a drug are consid-
ered, but also its safety with regard to harmful contamination of any kind. Obviously,
the patient is not supposed to absorb any substance other than the one he has been
administered.
CONTAMINATION TYPES
Drug contamination types may be classified in three categories: chemical contamina-

tion, physical contamination, and microbiological contamination.
Chemical Contamination
This type of contamination, also dubbed cross contamination, results from residuals
of an active ingredient or product during the chemical synthesis or during the phar-
maceutical manufacturing process, and is due to carryover such as in the processing
equipment or to inadequate segregation of facilities or air-handling systems. Chemical
contamination is not limited to active ingredients. Residues of cleaning agents involved
in the cleaning process are equally of concern. Chemical contamination raises serious
3
4 Cleaning Validation-A Practical Approach
concerns relating to patient safety. The term contamination used throughout the book
refers to chemical contamination.
Physical Contamination
Mechanical impurities and extraneous matter may be innocuous and only affect the
pharmaceutical elegance of some dosage forms or may be harmful, as in the case of
metallic particles in ophthalmic ointments or particulate matter and fibers in par-
enteral dosage forms.
Microbiological Contamination
This type of contamination is also called biocontamination or bioburden. Microor-
ganisms are ubiquitous and special care should be taken to prevent such contamina-
tion in pharmaceutical products, in particular those containing growth supporting
materials and a significant amount of water. Proliferation of microorganisms may result
in the destabilization of emulsions, suspensions, and creams. The microbiological con-
tamination of parenteral preparations presents a serious health risk, as it may cause life-
threatening conditions, due to the live microorganism cells as well as pyrogens, their
decomposition products. The risk of microbial growth in oral solid dosage forms is min-
imal due to their low water content.
CONTAMINATION CONTROL
Patient safety concerns govern the design, control, and monitoring activities with the
aim of minimizing, in a consistent manner, the contamination of the facilities, systems,
and equipment, through properly designed processes and procedures. Figure 1.1 pre-
sents a systematic approach to contamination control.
Facilities
Subpart C of 21 CFR 211 delineates the requirements for the design and construction
features of the buildings and facilities. "Separate or defined areas [are required] for the
firm's operations to prevent contamination and mix-ups" .... The need for "adequate
control over air pressure, microorganisms, dust, humidity and temperature .... Air fil-
tration systems, including prefilters and particulate matter air filters" and the measures
to be taken "to control recirculation of dust from production" and "to control con-
taminants" are addressed in 21 CFR 211.46. A rigorous environmental monitoring pro-
gram is necessary in order to ensure that the requirements are met. Such a program
shall include the following parameters: temperature, relative humidity, air flow
patterns-which are controlled by pressure differentials between different processing
areas, air changes, and environment microbiological monitoring.
Figure 1.1. Contamination Control
I Safety
I
Contamination
I Control I
I
I I I I
Facilities &
Systems Equipment Personnel Processes
I I I I
I
Design
I
Design lTraining & J
Qualification
I Waste
Material & J
Flows
I I I I
Control Validation I Gowning Line I
I I IQ/OQ/PQ I I Clearance
I I I
IMonitoring I I Personnel
Flow
I
Cleaning
Procedures
I
Cleaning
Validation
I
Cleaning
Monitoring
Equipment
Equipment design, construction, cleaning, and maintenance are referred to in 21 CFR
211 Subpart C. "Equipment ... shall be of appropriate design ... to facilitate opera-
tions ... for its cleaning and maintenance". "Equipment shall be constructed so that
surfaces that contact components, in-process materials, or drug products [the so-called
product contact surfaces] shall not be reactive, additive, or absorptive so as to alter the
safety, identity, strength, quality, or purity of the drug product, beyond the official or
other established requirements". Also required are "written procedures ... for clean-
ing and maintenance of equipment ... to prevent malfunctions or contamination".
Equipment design and construction are essential for its "cleanability" while close sys-
tems are needed for the minimization of production dust.
Personnel
The role of personnel in the minimization of contamination remains crucial, as the
industry still relies a great deal on operators. Comprehensive and well-organized train-
ing sessions covering the general behavior in the plant together with specific training
and qualification, will bring all the personnel to the same level of basic understanding
of the effect of an individual on product quality, including the risk of contamination.
Unlike other activities, which may be performed once, training to such sensitive issues
and increasing personnel awareness are an ongoing process which demands creativity,
changing formats and contents, and high skills.
Another aspect related to personnel is the appropriate gowning worn by opera-
tors in various locations of the plant. Company gowning, cleaned and maintained
according to pharmaceutical needs, brings the personnel to the same cleanliness level
and ensures that products are exposed to the desired level of cleanliness. Gowning also
protects personnel from the environment, which can be harmful. Training sessions in
personal hygiene and in proper gowning should, obviously, be part of the compre-
hensive training program. Personnel flow within the plant and its impact on contam-
ination should be scrutinized and well designed to minimize the propagation of
contamination.
Material and Waste Flows

Basic processes are designed in a pharmaceutical company to provide a behavioral pat-
tern of the personnel to this effect. Procedures covering the handling of material and
waste along the whole manufacturing process should be enforced in order to control
contamination. Routine controls such as line clearance are also instituted to ensure the
full separation between different products, batches, and/or campaigns.
2
Regulatory Requirements
Since 1963, the FDA has required that equipment be clean prior to use (GMP
Regulations-Part 133.4). This requirement is one of the basic GMP requirements, and
is mentioned in more than one section of 21 CFR 211 (FDA, April1998). Section 211.63
relates to equipment design, size, and location and requires that "equipment used in
the manufacture, processing, packing, or holding of a drug product shall be of appro-
priate design, adequate size, and suitably located to facilitate operations for its intended
use and for its cleaning and maintenance". Section 211.67 further requires that "equip-
ment and utensils shall be cleaned, maintained and sanitized at appropriate intervals to
prevent malfunctions or contamination that would alter the safety, identity, strength,
quality or purity of the drug product".
In addition to the requirements for appropriate design of the equipment and the
need for appropriate intervals for cleaning, Section 211.67 introduces in detail all the
parameters that should be at least included in a written procedure that shall be followed
for cleaning. Also equipment logs shall be included (Section 211.182) to show the date,
time, product, and lot number of each batch processed in chronological order.
The European Union (EU) and the World Health Organization (WHO) GMP
guides include additional elements related to the cleaning equipment itself to be con-
sidered: "Washing and cleaning equipment should be chosen and used in order not to
be a source of contamination", meaning that the cleaning agent, tools, washing solvent,
and the whole procedure will ensure an effective cleaning with no residues related to
the cleaning itself (EC Guide to Good Manufacturing Practice for Medicinal Products
1997; WHO Good Manufacturing Practices for Medicinal Products 1992).
Historically, FDA investigators have looked for gross contamination due to inade-
quate cleaning and maintenance of equipment and/or poor dust control. Also penicillin
contamination in non-penicillin drug products, and potent steroids or hormones con-
taminating a drug product were a great concern. Indeed, a number of products have
been recalled due to actual or potential penicillin cross contamination.
A few events increased awareness and pushed FDA to publish new guidelines
demanding proper cleaning procedures and later, in the 90s, even cleaning validation.
In 1988, Cholestyramine Resin USP was recalled due to pesticide cross contamination
(FDA, July 1993; "The Gold Sheet", May 1993). The bulk pharmaceutical chemical was
contaminated with low levels of agricultural pesticides while being produced. This
happened while using recovered solvent drums, which were used also for recovered
7
solvents from pesticide production process. Shipments of this contaminated bulk phar-
maceutical to another facility caused pesticide contamination in the other facility.
In 1992, an import alert was instituted on a foreign bulk pharmaceutical manu-
facturer. The company was manufacturing potent steroid products as well as non-
steroidal products in the facility using the same equipment.
In the same year, FDA officers could be quoted saying that "while the word 'vali-
dation' associated with process development has been a relatively recent buzzword, the
evaluation and justification of cleaning processes have been employed in the pharma-
ceutical industry for many years" (FDA, May 1993). They also emphasized that, "In a
July 1966 seminar on the topic of Control Procedures in Drug Production, Harley
Rhodehamel discussed the development and evaluation of cleaning procedures at a large
pharmaceutical manufacturing facility. The concepts and methods discussed in his
paper presented in 1966 are still current today".
In the early 1990s, as previously mentioned, the FDA and other regulatory agen-
cies started to require validation of cleaning procedures. Advances in analytical tech-
nology allowed for detection of residues at very low levels. Therefore, the requirement
based on "visibly clean" for the equipment, which was the basis in the GMP, has
changed to validation requirement based on quantitative determination of residues. This
tendency generated some regulatory documents, including the FDA Guide to Inspec-
tion of Bulk Pharmaceutical Chemicals (FDA, September 1991 ). This document clearly
states that "cleaning of multiple use equipment is an area where validation must be car-
ried out". The issues related to cleaning validation were briefly addressed: "Cleaning
process will remove residues to an acceptable level". A sampling plan was also required,
while the only method mentioned was the final rinse water or solvent. The need for an
analytical method was raised to enable the monitoring of a specific residue substance
at a rational level in a practical, achievable, and verifiable manner. The nonuniformity
nature of the residue was briefly discussed in relation to swab sampling.
Following the USA vs. Barr court decision reached in February 1993, more regu-
latory documents were published discussing cleaning validation principles and, since
then, FDA investigators check more carefully for equipment cleaning procedures and
cleaning validation programs (FDA CGMP Regulations, February 1993).
The court decision (USA vs. Barr) actually instituted the basic requirement that
"in order for the cleaning rules to be effective, the specific methods chosen must be
shown to be effective". The cleaning validation studies have to cover all equipment
including milling machines, not just major equipment. Surprisingly, in the absence of
problems, a one-run validation was suggested to be sufficient. This suggestion was
dropped later on. The court decision opened the cleaning validation issue to discus-
sions within the industry, as well as to a dialogue with FDA representatives in profes-
sional forums. This process seems to be fruitful, due to the clarifications made along
the way leading to a better understanding of the considerations to be taken into account
in cleaning validation studies.
Warning letters were increasingly sent to firms, including parenteral firms, repack-
ers, over-the-counter manufacturers, and biotech firms. Parenteral firms received warn-
Regulatory Requirements 9
ing letters in 1992 for having "no documented validation to show that the cleaning pro-
cedures used for equipment have been validated" ("The Gold Sheet", May 1993).
In February 1993, warning letters were issued by FDA to three repackers. Lack of
basic housekeeping (for example, cleaning procedures) was a problem observed by the
agency's investigators for these operations.
Warning letters and citations (FDA 483) were issued for several biotech companies
as well. FDA concerns with cleaning procedures for biological products were similarly
apparent in pre-approval as well as in post-approval inspections at biotech plants ("The
Gold Sheet", May 1993).
The USA vs. Barr Laboratories case has strengthened the need to enforce cleaning
validation standards. The first regulatory document dealing solely with cleaning vali-
dation was FDA Cleaning Validation Mid Atlantic Region Inspection Guide published
in May 1993 (FDA, May 1993). This guide actually sets the basic requirements for clean-
ing validation as they are known today. In July 1993, a more elaborate guide was pub-
lished, Guide to Inspections of Validation of Cleaning Processes (FDA, July 1993). This
guide is intended to cover equipment cleaning for chemical residues, although it is men-
tioned that "microbiological aspects of equipment cleaning should be considered". It
is recognized that there may be more than one way to validate a cleaning process. There-
fore, the guide only addresses the aspects that should be taken into consideration while
validating cleaning processes. Some common validation elements for cleaning valida-
tion studies are described which are, in fact, in the same spirit as required for every
validation as described in Validation Documentation Inspection Guide-FDA, 1993, and
summarized as follows:
a. Written cleaning procedures should be established. Attention should

be addressed to dedicate certain equipment to a specific product
such as fluid bed dryer bags, and to residues originating from the
cleaning detergents or solvents themselves.
b. Procedures on how validation will be performed should be in place.
c. Who is responsible for performing and approving the study.
d. Acceptance criteria should be set.
e. Procedures dealing with the subject of when revalidation is required,

should be in place.
f. Validation protocols should be prepared before each validation study

stating issues such as sampling procedure and analytical methods.
g. Study should be conducted according to the protocol.
h. Approved report should state the validity of the cleaning process.

Great emphasis is put on the elements that are to be considered while evaluating
the effectiveness of the cleaning process. The first one is related to the determination
of what cleaning process will be used. This decision should take into account the
design of the equipment "particularly in those large systems that may employ semi-
automatic or fully automatic clean-in-place (CIP) systems, since they represent sig-
nificant concern".
The second element, which is described in length, is the need for a written clean-
ing procedure. The documented cleaning processes ought to be specific and detailed.
The third element discussed is the analytical method used to detect residuals or
contaminants. The method has to be specific and sensitive enough to be able to detect
the level of residues in relation to the limits which should be set for the validation. "The
firm should challenge the analytical method in combination with the sampling method"
which is the determination of recovery due to the sampling from the equipment sur-
face. It is emphasized that the analytical method has to be specific and "check to see
that a direct measurement of the residue or contaminant is performed".
The fourth element to be considered is the sampling technique. Two types of sam-
pling techniques have been found acceptable. The preferred type is the direct method
of sampling the surface of the equipment. The other technique is the use of rinse solu-
tions. The advantages of the direct sampling are that it is possible to sample hard-to-
clean locations in the equipment and even insoluble materials can be sampled by
physical removal. In the case of rinse samples, however, insoluble contaminants or
residues may be occluded in the equipment. A third method, which is less recom-
mended, is the use of placebo product. In this case, a placebo batch is manufactured
following the cleaning process and a sample of the placebo batch is tested for residues.
The greatest concern using this method is that "one cannot assure that the contami-
nate will be uniformly distributed throughout the system".
As required for each kind of validation, the basic step toward cleaning validation
is to set acceptance limits to determine whether a cleaning process is validated. Since
this guide is applicable to a wide range of activities, equipment, and products, the FDA
stated that it has no intention to set specifications. Therefore, it is the obligation of the
company to use a rationale scientifically justifiable to set the limits. The guide brings
some limits used by the industry, such as: 10 ppm, biological activity of 1/1000 of the
normal therapeutic dose and organoleptic levels as no visible residue. Detergent residues
should also be checked during validation. Finally, it is stated that it is usually not con-
sidered acceptable to "test until clean".
In 1995, it was reported in the literature, for example, that "The agency (FDA)
wants a detailed protocol listing equipment to be sampled, how and where samples will
be taken, drugs made with that equipment and (company's) schedule for sampling and
study completion" (Washington Drug Letter, February 1995). In the same year the FDA
issued a 483 report to another company "that cleaning procedures for dispensing, gran-
ulation and tabletting facilities were not properly validated. Validation was done after
certain batches, but should have been planned also for later in production" (Washing-
ton Drug Letter, March 1995).
In 1996, it was acknowledged that FDA has increased its attention to foreign facil-
ities. The basic requirement for adequate written cleaning procedures is still held. "Plant
operators must document their cleaning methods and, sometimes even more importantly,
be able to justify their approach" (Washington Drug Letter, January 1996).
In recent years, as regulatory international activities are covering wider areas, it can
be seen that guidelines issued by FDA, European, and other regulatory bodies are more
uniform.
In January 1996, the Pharmaceutical Inspection Convention (PIC) published a
document, Principles of Qualification and Validation in Pharmaceutical Manufacture,
which includes cleaning validation as one of the four validation areas (Document PH
1999). Basically, their recommendations are in line with the FDA requirements (FDA,
July 1993). However, more clarifications and focuses are added in this document
as follows:
• While cleaning validation is intended for procedures for product con-

tact surfaces only, "consideration should be given to noncontact parts
into which product may migrate".
• The term "bracketing" is mentioned here for validation. "It is consid-

ered acceptable to select a representative range of similar products and
processes concerned and to justify a validation program".
• At least three consecutive applications of the cleaning procedure should

be performed.
• The difference in raw materials sources and characteristics should be

considered while designing cleaning procedures.
• Revalidation in cases of changes in equipment, product, or process, and

also periodic revalidation should be considered.
• Reassessing manual methods more frequently than clean-in-place
(CIP) systems.
• Analytical methods used for cleaning validation must be validated.
The trend in harmonizing regulations internationally can be clearly seen in two

recently published draft documents for active pharmaceutical ingredients (API) GMP
guides. One document was published by the PIC-PIC/S (Pharmaceutical Inspection
Convention, Pharmaceutical Inspection Co-operative Scheme) (PIC-PIC/S, September
1997), and the other was published by the FDA (FDA, March 1998).
In both documents, cleaning requirements combine the aspects published in pre-
vious regulatory documents by the CFR (FDA, April 1998), EU GMP (EC Guide to
Good Manufacturing Practice for Medicinal Products 1997), and WHO GMP (WHO
Good Manufacturing Practices for Pharmaceutical Products 1992). For cleaning vali-
dation, besides all previous requirements, the term "worst-case" selection of product
or scenarios is pronounced clearly in these documents.
However, even in January 1998, the FDA is still citing warning letters to pharma-
ceutical companies: "Currently, the firm is not performing periodic testing of equip-
ment rinse samples for product residue". Another company was cited because "the
process used to clean and disinfect aseptic processing areas and equipment has not been
established. In addition, the effectiveness of the agents used has not been established".
During 1997, warning letters, summarized by "The Gold Sheet" (February 1998)
show that firms continue to struggle with cleaning validation. Several firms were cited
for such problems, in particular non-U.S. bulk pharmaceutical manufacturers. Table
2.1 summarizes issues related to cleaning and cleaning validation as they appear in warn-
ing letters sent to various companies during 1997-1998.
"Drug GMP Report" (June 1997) reviews some GMP consultants' opinions on how
to build a cleaning validation program. "GMP consultants will tell drug makers to val-
idate cleaning procedures based on worst-case scenario. This can include picking the
most sensitive drugs, and hardest to clean equipment". Some consultants have recom-
mended conducting a risk analysis to determine which equipment is the hardest to clean.
The basic GMP regulations require companies to ensure cleanliness of equipment.
This straightforward rule is established to ensure the safety, identity, strength, quality,
and purity of the drug product. Over the years, a need to enforce this regulation was
raised because of cases where safety of patients was a concern, and when advances in
analytical technologies could allow development of cleaning validation programs. Warn-
ing letters and investigators' reports cited to companies prove that companies are still
struggling to find ways to validate and establish their cleaning procedures (Washing-
ton Drug Letter, June 1998; "GMP Trends", January 1997; "GMP Trends", November
1997; "GMP Trends", December 1997; "GMP Trends", June 1998; Inspection Monitor,
June 1998; Drug GMP Report, June 1998).
The following chapters of this book present a systematic and practical approach to
address the regulatory concerns related to cleaning and cleaning validation.
Table 2.1. Cleaning and Cleaning Validation Warning Letters Citations,

1997-1998
1. Equipment cleaning procedures
2. Adherence to cleaning SOP
3. Cleaning records
4. Cleaning of equipment at appropriate intervals
5. Equipment cleaning/maintenance
6. Equipment cleaning
7. Cleaning of packaging rooms and equipment
8. Cleaning of repackaging equipment
9. Facility cleaning
10. Aseptic area/equipment cleaning and disinfecting
11. Cleaning logs
12. Contamination prevention
13. Controls to prevent product mix-ups and cross contamination
14. Validation of sterilization-in-place or clean-in-place processes
15. Cleaning validation
16. Cleaning validation for dedicated equipment
17. Evaluation of adequacy of cleaning process
18. Effectiveness of cleaning agents
19. Effectiveness of cleaning process

3
Cleaning Basic Concepts
INTRODUCTION
Cleanliness in the pharmaceutical industry is crucial to avoid safety concerns that may
result from contamination. For that reason, regulatory authorities have set requirements
for the basics of cleanliness in the GMP regulations. The Food Drug & Cosmetic Act
even defines that: "A drug ... shall be deemed to be adulterated ... if it consists ...
in part of any filthy, putrid or decomposed substance" (FDA, April 1998). The clean-
ing operations must ensure avoidance of adulteration of products so as to minimize
the risk of cross contamination between products or carryover of degradation products.
Only after cleaning procedures are established and implemented can the cleaning
validation phase start to prove its consistent and reliable performance.
CLEANING MECHANISMS
Cleaning can be defined as removal of residues and contaminants. These residues and
contaminants can be the products themselves manufactured in the equipment (the
active and nonactive materials), residues originating from the cleaning procedure
(detergents), and degradation products resulting from the cleaning process itself.
Several basic mechanisms exist to remove residues from equipment, including mechan-
ical action, dissolution, detergency, and chemical reaction (LeBlanc et al. 1993).
Mechanical action refers to physical actions, such as brushing, scrubbing, and pres-
surized water to remove particulates.
Dissolution involves dissolving residues with a suitable solvent. The most common
and practical solvent is water because of its advantages: water is nontoxic, cheap, does
not leave residues, and is environment friendly. However, in some cases it may be prefer-
able to use a non-aqueous solvent or a combination of both aqueous and non-aqueous
solvents due to the solubility characteristics of the materials. Alkaline or acidic solvents,
for example, can enhance dissolution of the materials and could be advantageous.
15
The third mechanism, detergency, requires the use of surfactant, usually in an aque-
ous system. Detergents act in four different ways: wetting agents, solubilizers, emulsi-
fiers, and dispersants. As wetting agents or surfactants they lower the water surface
tension and improve penetration. As solubilizers they break up the materials using their
surfactant properties. Emulsification is similar to the solubilization mechanism and
refers to the creation of emulsion droplets in fats. Dispersion refers to the property to
improve suspension of the materials. Usually detergents possess all these properties
which broaden their action.
The fourth mechanism includes chemical reactions, such as oxidation and hydrol-
ysis in which the residues are chemically changed. The most common example of oxi-
dation is the use of sodium hypochlorite (chlorine bleach) as an oxidant to break down
organic materials to make them more readily removable (LeBlanc et al. 1993).
Usually, these four mechanisms will play a role in combination in one cleaning pro-
cedure. During cleaning validation, the effectiveness of these mechanisms will be chal-
lenged and checked as a whole in the cleaning procedure. However, for the sake of
simplicity, the worst-case product participating in the cleaning validation study, which
is selected as the reference drug, will be chosen based only on the solubility of its active
drug in the cleaning solvent (such as water). As will be shown in chapter 5, the solu-
bility of the active ingredients is selected as one of the critical factors in the design of
the cleaning validation, actually ignoring the role of other cleaning mechanisms. This
simple attitude is very popular because it is very complex and even impossible to eval-
uate and quantify the role of the combination of all these mechanisms on a product
containing both active and nonactive drugs.
Cleaning mechanisms includes mechanical action, dissolution, deter-

gency, and chemical reactions.
LEVELS OF CLEANING
Most companies have two levels of cleaning in place, depending on the level of clean-
liness to be achieved. Obviously, in the context of cross contamination, cleaning
between batches of different products is more stringent than cleaning between batches
of the same product manufactured in a series. The first level designated as major clean-
ing defines a complete procedure which will clean to below a specified level of residues
and contaminants left in the equipment. In this case, validation of the effectiveness of
the cleaning procedure in removing residues to the required level is mandatory. The
second level, designated as minor cleaning, is only performed between batches of the
same product manufactured in a series, or between different strengths of the same prod-
uct when the formulations are qualitatively identical. For batches of products which
contain the same active material but different excipients, a minor cleaning may not be
Cleaning Basic Concepts 17
sufficient. In case of minor cleaning, the level of cleanliness depends on the product
and the process, taking into consideration the element of time limitation. Usually, an
abbreviated cleaning procedure (compared to major cleaning) is used which requires
washing and rinsing with purified water, leaving the equipment essentially free of any
visible product (Harder 1984). However, if the equipment is used for dry processing,
such as milling, blending, and so on, a dry cleaning using vacuum is preferable to avoid
microbial growth. For minor cleaning, cleaning validation is not required, since cross
contamination is not an issue.
The API process is different from the pharmaceutical dosage form process in that
the final process is largely a purification step (Lazar 1997). Therefore, different clean-
ing levels are considered for early and intermediate steps and for the final step. How-
ever, the same rules as previously discussed apply to API processes. Major cleaning will
be performed in cases of product changeover and minor cleaning between batches in
a campaign.
Generally, in dedicated equipment the issue of carryover of one product to another
product does not exist since only one product is manufactured on that particular piece
of equipment and the cleaning validation study includes only the detergent residues
determination. However, it is important to bear in mind that, while manufacturing
batches of the same product one after the other does not cause carryover of contami-
nants as in multipurpose equipment, degradation products between batches might
change the impurity profile. This concern leads to the issue of time limitation.
Major cleaning is required between products and minor cleaning between

batches of the same product. Cleaning validation is required only for
major cleaning.
TIME LIMITATIONS
While the cleaning procedure details all the elements needed for a specific piece of
equipment and must be validated, and while the level of cleaning determines the strin-
gency of the cleaning procedure, time limitation is meant to manage other considera-
tions, such as microbiological contamination or carryover of degradants which might
develop with time, or simply the ease of cleaning residues of product before they dry
out on the equipment.
Time limitations have to be established in relation to cleaning between different
steps in the manufacturing process, taking into account the manufacturing processes
and the products.
The first time limitation which has to be considered is the lapse of time between
the end of manufacture and the start of cleaning. This limitation will control the ease
of cleaning before the product dries out. This aspect is strongly product dependent and
will prevent the degradation of materials exposed in thin layers to the environment.
For a piece of equipment which is constantly used on a day-to-day basis, establishment
of this time limitation may be found to be unnecessary.
The second time limitation which has to be reflected in each cleaning procedure
is the lapse of time between the cleaning and drying processes. This limitation will con-
trol the microbial contamination, since working conditions are in a non-sterile envi-
ronment, microorganisms will grow rapidly in humid, warm, and nutritious conditions.
Therefore, it is very important to completely dry the equipment immediately after it
has been cleaned.
The third time limitation is related to the frequency of cleaning between batches
of the same product manufactured in a campaign in non-dedicated equipment or
between batches manufactured in dedicated equipment. As mentioned, in these cases
there is no need for major cleaning since no foreign product is carried over from one
batch to the other. So, theoretically, it might happen that in dedicated equipment, no
cleaning at all, or only minor cleaning, will be carried out. However, from the point of
view of microbiological contamination and/or degradants which might develop in the
next batches from residues of batches previously manufactured, the frequency of major
cleaning has to be established unless there is a justification not to do so. The draft guid-
ance for APis relates to this subject as follows:
Dedicated equipment should be cleaned at appropriate intervals to pre-

vent the build-up of objectionable material or microbial growth. As
processing approaches the purified API, it is important to ensure that
incidental carryover of contaminants or degradants between batches
does not adversely impact the established impurity profile. . . .
However, this does not generally apply to biological APis, where many
of the processing steps are accomplished aseptically, and where it is
often necessary to clean and sterilize equipment between batches (FDA,
March 1998).
The fourth time limitation is related to the need for re-cleaning cleaned equipment
waiting for the next use. This cautious act usually holds for equipment which is not
used very frequently. A rinse before use of the equipment will get rid of dust which
might have been inadvertently introduced into the equipment.
All these time limits are seldom based on a full cleaning validation study, but
rather empirically and arbitrarily fixed to be as short as feasible in a production envi-
ronment. A standard operating procedure and a means for the verification of compli-
ance to these time limitations should be in place.
For products prone to microbial proliferation or known to degrade rapidly in the
wet stage or firmly adhering to the product contact surfaces after drying, cleaning must
be performed immediately after processing and this should be clearly mentioned in the
manufacturing procedure. When none of these considerations prevail for consecutive
batches of the same product manufactured in a series or for a product manufactured
in dedicated equipment, a larger and arbitrary time limit may be set and cleaning is
Cleaning Basic Concepts 19
performed at the end of the series. Information for establishing these time limitations,
even though set arbitrarily, is supported by the knowledge of the processes and the
products. In addition, more general information is gathered from routine testing which
can further give confidence to these limits. This includes microbial count testing of puri-
fied water, used as the final rinse. Routine microbial environment monitoring should
estimate the microbial contamination of the working environment. Finally, microbial
limit counts of the product may give an indication on the overall handling in all dif-
ferent manufacturing steps. Random sampling and testing is performed on products
for which microbial testing is not mandatory.
The cleaning procedure should define time limitations in relation to

a. time between end of manufacturing and start of cleaning.
b. time between final rinse and drying.
c. frequency of major cleaning for manufacturing batches of the same

product in campaign.
d. time until additional cleaning is performed for unused clean equipment.

4
Cleaning Procedure
INTRODUCTION
A vital element of cleaning is the cleaning procedure which combines all the knowl-
edge and considerations relating to the equipment design, the manufacturing process,
and materials and tools used in the cleaning procedure. All this information is given
to the operator who has been trained to perform the cleaning operations effectively and
safely. Although the cleaning procedures have to be specific to the equipment and
product, it is more practical to use a limited number of cleaning agents, the same clean-
ing process, and the same methodologies. This approach makes these routine proce-
dures easy to handle and validate.
EQUIPMENT DESIGN
Points to consider while developing a cleaning procedure, and that should be consid-
ered while acquiring a new piece of equipment, relate to cleanability and include: the
material of construction, design, the degree of dismantling, rinsability, and product
carryover potential, originating mainly from hard-to-clean locations.
In most cases, equipment for pharmaceutical use is constructed of stainless steel.
However, glass, silicone, PVC, and other materials are also used. The equipment has to
be suited to the cleaning mode so the surfaces are not affected by the cleaning opera-
tion, and residues are neither generated nor transferred. In the case of a clean-in-place
(CIP) system, for example, attention should be paid to several elements: the quality of
all building materials, integrity and sealing of welds, isometry and draining, design of
sampling points, and installation of sensors or measurement devices (Laban et al. 1997).
Equipment design should be evaluated in relation to general GMP concerns and
cleaning issues as described in Table 4.1.
The most important issue related to cleanability of equipment is related to hard-to-
clean locations. Usually these locations are poorly accessible sites of the machine, in which
contaminants and residues can be trapped. Therefore, as part of cleaning validation study,
the hard-to-clean locations must be identified and sampled, and the samples tested for lev-
els of contaminant and residue leftovers after the cleaning process has been conducted.
21
Table 4.1. General GMP Concerns in the Design of Processing Equipment
1. Product contact surfaces shall not be reactive, additive, or absorptive. Surfaces shall be
hard and smooth, and shall not shed particles. Surfaces shall withstand the repeated use
of cleaning and sanitizing agents.
2. The equipment shall be designed so as to prevent dead ends or spots, in which products
could accumulate and be hidden from the operator's view.
3. All parts of the equipment shall be easily dismantled to permit visual inspection.
4. Valves shall be of a sanitary type.
5. All connections to utilities shall be fitted with a back flow prevention valve.
6. Vessels and containers shall be drainable.
7. Valves and instrumentation shall be installed flush with product contact surfaces.
8. Small parts, screws, and bearings, if unavoidable, shall be fixed in such a way as to pre-
vent their accidental fall into the product.
9. Any substance required for operation, such as lubricants and coolants, shall not come into
contact with the product. The engine shall be located or designed so as to prevent acci-
dental dripping of these substances into the product.
10. The engine, the electric and electronic parts, should be hermetically encased to allow for
easy cleaning and to prevent safety concerns during cleaning.
The cleaning procedure development should consider the design of the equipment
and the hard-to-clean locations that will be challenged in the cleaning validation study.
MANUFACTURING PROCESS
The cleaning procedure should be developed considering the type of process executed
by the equipment. Different types of processes will leave different types of residues
to be removed. Topical preparations, such as creams and ointments, can be difficult
to clean due to the fact that they can contain many ingredients with different char-
acteristics, part of them thick, oily, and fatty constituents. These materials are pres-
ent in high concentration in the formulation. On the contrary, injectable aqueous
solutions can be easy to clean due to a limited number of ingredients which are usu-
ally water soluble and present in relatively low concentrations. The cleaning proce-
dure can be different mainly in the prewash step where the gross residue is removed.
For creams, the use of high temperature can break the consistency of the cream and
make it easier to remove. In the case of solutions, a superficial rinse can be sufficient
as the prewash step.
OPERATOR
"Unless a process is fully automated, people are an important variable in a process and
this variable must be taken into account if we wish to have processes that consistently
and with a high degree of assurance produce products with the requisite quality char-
acteristics expected by our customers" (Kieffer 1998). This statement is valid for clean-
ing processes as well as for any other manufacturing operation. The operator can be
the weak link, especially in manual methods and in automated methods if human
interventions of any kind are possible. The key to overcome this problem is to make
sure that the operator is very well trained to perform all the cleaning procedures in a
reliable way. Above all, the procedure should be developed so that the operator's health
will not be in danger at work.
Training of the operator is of great significance in the cleaning process. Since many
variables are inherent in the manual method originating from this type of activity and
are difficult to quantify, it is impossible to instruct the operator how much force to put
in the scrubbing step as much as it is difficult to make sure that all the hard-to-clean
locations are reached. This is true for the same operator in different days and moods,
and more significantly for different operators with different skills, attitudes, and abil-
ity. For some technologies (mixers, blenders, containers and even tablet presses), the
operator's parameter can be minimized by using CIP systems, but for some manufac-
turing steps, it seems almost impossible at present until different concepts are devel-
oped. A multiproduct packaging line for solid oral dosage forms, for example, is
generally regarded as one of the most sensitive parts in a pharmaceutical facility in the
sense of cross contamination originating from products (and mix-ups from packaging
materials). Clear and friendly procedures as well as good training can help minimize
the above-mentioned deviations. Procedures must detail the quantitative parameters
as much as possible and still be kept simple. As Kieffer summarizes: "One needs first
of all well-designed, fail-safe, simple optimized processes; secondly, people qualified to
do their tasks in these processes, and thirdly, an empowering, motivating environment"
(Kieffer 1998). The third condition relates to the overall atmosphere and culture built
into the manufacturing plant, which cannot be documented, but can serve as a driving
force to perform activities with understanding and to take responsibility for them.
In CIP methods, extreme conditions such as high temperature, high pressure,
and/or high or low acidity or alkalinity can be used, this cannot be done in manual
methods due to operator's safety concerns. Only moderate conditions are used. There-
fore, safety warnings should be included in the cleaning procedure to avoid accidents.
Only when these conditions are fulfilled and reproducibility in the execution of the
cleaning procedure is attained can the cleaning validation studies be initiated.
Training of the operator and his safety should be of great concern, espe-
cially in manual cleaning.
MATERIALS AND TOOLS
Each cleaning procedure has to accurately describe the materials and tools that should
be used. It is obvious that the cleaning performance is strongly dependent on these vari-
abies, therefore they should be controlled. The cleaning materials and tools will be cho-
sen taking into consideration several issues: the type of equipment, the type of
manufacturing process (cream, solution, tablet ... ), and the type of cleaning proce-
dure (manual, automated). In a multiproduct manufacturing plant, it would be
extremely wise to have a very limited list of different materials and tools. First, this facil-
itates the logistic management of the cleaning processes; second, it gives the operator
a simple common routine to perform, which can help to attain a better reproducibil-
ity; third, from the validation standpoint, the idea of executing the validation study on
one product per equipment type is applicable only when the same cleaning procedure
(with the same materials and tools) is used for all products manufactured on that equip-
ment and, economically speaking, this results in a completely different scale of invest-
ment. For certain products, if the routine procedure is not sufficient due to special
residues resulting from the cleaning process itself or if colored residues can only be elim-
inated with special care, it is advisable to apply a pretreatment which will eliminate the
specific residue and then perform the routine procedure. This kind of pretreatment or
prewash (which may include the use of acid, alkaline, or oxidising agents) is usually of
a chemical nature resulting in a change of the residue to another entity which can be
easily cleaned.
The cleaning procedure therefore should accurately define the solvents, cleaning
agents, and cleaning tools to be used.
Solvents
Water is the most common solvent used because it is inert, nontoxic, cheap, environ-
ment friendly and freely available. For the prewash step, tap water will be sufficient,
while for the final rinse purified water or (for sterile preparations) water for injection
is used. In special cases, organic solvents (such as alcohol) may be used, due to their
solubilization properties.
Cleaning Agents
Cleaning agents can be organic solvents, acidic/alkaline materials, or detergents which
can act in different mechanisms. In some cases, single component cleaning agents are
used, while in others, formulated cleaners are preferred. In any case, it is important to
consider the following aspects listed in Table 4.2 while choosing a cleaning agent.
Organic solvents are used based on their properties to dissolve certain products,
which would be difficult to clean effectively with water. This is particularly true in API
manufacturing. In some cases, they will be used because of intolerance of some machine
parts to water exposure. For example, alcohol must be used to clean a tablet press, par-
ticularly the die table and other parts, to avoid corrosion. A combination of organic
solvent with water may give better results from cleaning and safety perspectives.
Table 4.2. Cleaning Agent Properties
1. It should not be corrosive to the equipment surface.
2. It should be nontoxic.
3. In case of manual procedures, it should not be harmful to the operator.
4. It should be as friendly as possible to the environment.
5. It should be very easily dissolved in water, so it can be easily rinsed.
6. It should be able to solubilize or suspend the product so that the latter can be removed
without leaving any residue.
7. In case of CIP, because of the high pressure used in the process, it should not produce foam.
Alkaline agents (sodium or potassium hydroxides) can eliminate organic stains

from various sources while acidic agents (nitric, phosphoric, or citric acids) apply to
mineral stains (Laban et al. 1997). These cleaners can be used in a simple formulation
or a complex one containing other functional additives, such as dispersants or chelat-
ing agents, for a stronger and wider effect.
The use of a formulated detergent has advantages over the use of a single com-
ponent detergent because a formulated detergent has several components, which can
together act in several ways such as wetting, solubilizing, emulsifying, and dispers-
ing. As a result, it can act on formulations of multiple components with different char-
acteristics. "Some facilities like to have one universal cleaning product and process
for all their systems. A formulated cleaner can provide the flexibility for adequate
cleaning for many-although certainly not all-types of residues" (LeBlanc 1993).
Due to their multiple actions, the formulated detergents are more effective in their
use, so that solvents, which are discouraged for use from an environmental perspec-
tive, can be avoided.
Cleaning Tools
The WHO GMP requires that "washing and cleaning equipment should be chosen and
used as not to be a source of contamination" (WHO Good Manufacturing Practices
for Pharmaceutical Products 1992). This means that if brushes, rags, or fabrics are used
they should not release hair or particles. Cross contamination should be avoided while
using the same multipurpose tools. Vacuum cleaners might pose this risk if they are
not properly cleaned between different products.
Control of Materials and Tools

The key issue for having reproducible cleaning procedures, in addition to the thorough
training of the operators, is to have complete control over all materials and tools. This
will prevent contamination of equipment, facilities, and products. Control should be

established as follows:
• Water quality:
Tap water, which is used for initial rinse, should be tested periodically for micro-
biological quality. Purified water, which is used for final rinse, should be of the
same quality as for the corresponding manufacturing activities. Water has to be
routinely chemically and microbiologically monitored.
• Solvents:
Solvents used for rinsing should be of a defined grade and from a manufacturer
which is approved by the company as a supplier of this material for this purpose.
A certificate of analysis should be received from the manufacturer stating con-
formance with specifications. A procedure for receipt (as for raw materials), and
a testing plan should be in place.
• Cleaning agents:
It is recommended to obtain from the manufacturer the safety data sheet and,
under a secrecy agreement, the composition of the cleaning agents. A procedure
for receipt and testing should be in place and instructions for use should be
defined in the cleaning procedure. To ensure a consistent quality, a declaration
should be signed by the manufacturer not to change the composition without
prior notice.
• Tools:
Only brushes and fabrics that do not shed hair and are lint-free should be used
and periodically checked.
The change control procedure should evaluate the impact of a change in solvents, clean-
ing materials, and tools on the cleaning procedure with respect to cleaning validation.
Solvents, cleaning materials, and tools should be described in the clean-

ing procedure. Any change should be evaluated in relation to cleaning
validation through the change control procedure.
CLEANING PROCEDURE
Types
Methods used for cleaning equipment can be divided into manual procedures and
automated procedures, such as CIP. In all cases, cleaning procedures must prove to be
effective, consistent, and reproducible.
FDA's guideline for API manufacturing recommends that: "where feasible, clean in
place (CIP) should be used to clean process equipment and storage vessels", in order
to reproduce exactly the same procedure each time (FDA, March 1998). With a man-
ual procedure, one must rely on the operator's skills and a thorough training of the
operator is necessary to avoid variability in performance. However, in some instances,
it may be more practical to use only manual procedures.
Manual Cleaning
Most cleaning procedures follow the same pattern of cleaning sequences and the thor-
oughness of each step in a sequence depends on the equipment and the product (see
Table 4.3).
• Disassembly:
The degree of disassembly should be detailed in the cleaning procedure. While
for certain types of equipment, such as a high-shear mixer, it will mainly include
disassembly of the impeller, other types of equipment, such as a tablet press or
a packaging line, will require extensive disassembly.
• Prewash:
This step includes dedusting and removal of material and waste by several tech-
niques. Vacuum cleaning is used when accessibility to surfaces is difficult, for
example, in the case of the tablet press and the packaging line. It is important to
clean the vacuum cleaners themselves to avoid cross contamination. Although
not recommended, blowing with pressurized air can only be used, in conjunc-
tion with an efficient suction device, if the equipment is located in a segregated
place and there is no danger of cross contamination and no risk to the operator.
Prewash can also be conducted by partially filling the equipment with tap water,
operating the equipment, and then draining the equipment.
Table 4.3. Manual Cleaning Sequence
l. Disassembly
2. Prewash Tap Water
3. Wash Cleaning Solution
4. Rinse Tap Water
5. Final Rinse Purified Water
6. Drying Hot Air
7. Visual Inspection
8. Reassembly
• Wash:
This step is the most important step in removing all the residues from the equip-
ment surfaces. For equipment used in a wet environment, such as containers,
blenders, mixers, and fluid bed dryers, washing is executed with brushes and
sponges. For equipment used in a dry environment, such as a packaging machine,
a wiping technique is used. The cleaning will be performed with absorbent fabrics
soaked with a detergent solution or alcohol solution as in the case of the tablet press.
• Rinse:
The initial rinse removes all contaminant residues of the product and detergent.
Tap water is usually sufficient for this purpose.
• Final rinse:
The final rinse is usually done with purified water to remove cleaning agent
residues left after the initial rinse. Sometimes hot water is used to facilitate water
evaporation from surfaces and to allow easier drying.
• Drying:
This step is crucial to avoid microorganism growth, especially in equipment used
for the preparation of liquids and semisolids. Drying can be done simply by using
a dry absorbent fabric in case of equipment such as a packaging machine. Some-
times, when alcohol solution is used to avoid surface corrosion as in the case of
the tablet press, compressed air can be blown (only if the machine is located in
a segregated area) followed by lint free fabric or paper wipes. Heating can be used
in the case of containers and double-jacketed tanks to dry equipment.
• Visual inspection:
21 CFR 211.67 requires that "inspection of equipment for cleanliness immediately
before use" should be conducted. Therefore, visual inspection has to be included
as part of the cleaning procedure. Even though it is a qualitative evaluation, exper-
iments show about four micrograms of material per square centimeter on a stain-
less steel surface can be seen (Fourman and Mullen, 1993). This examination
should be conducted before the assembly is executed to allow inspection of all
hard-to-clean locations in the equipment and all the disassembled parts.
• Reassembly:
Reassembly is carried out only after conducting visual inspection following the
order defined in the cleaning procedure.
Automated Cleaning
Nowadays, most pharmaceutical equipment manufacturers can provide the equipment
fitted with a cleaning-in-place or a washing-in-place device. In common language, the
two verbs are almost indifferently used. "To wash", according to Webster's New World
Dictionary, is "to clean with water or other liquid", and "to clean" is "to make clean
(free of dirt and impurities)". After washing or cleaning, equipment is "washed" or
"cleaned", but it can be determined as "clean" only after its cleanliness has been tested.
The two actions do not achieve the same degree of cleanliness.
Manufacturers of washing-in-place systems do not make any claim regarding the
level of cleanliness, and usually some degree of disassembly and hand scrubbing is nec-
essary in order to complete the cleaning. While it is advisable for consistency of the
cleaning operation and for cost considerations to use automated cleaning systems, it
must be kept in mind that not all automated systems can provide at any given site of
the processing equipment the degree of cleanliness required to minimize cross conta-
mination. The following example serves as an illustration of the above-mentioned fact.
The large cylindric smooth surfaces of a simple piece of equipment like a twin shell
blender may be effectively cleaned with hot water and detergent delivered by a high pres-
sure spray ball, but the discharging valve of the same blender with a much smaller sur-
face area than the cylinders has to be disassembled and hand scrubbed.
Cleaning-in-place (CIP), on the other hand, means cleaning the equipment to an
acceptable, quantifiable, and validatable level of cleanliness, so that another product
may be manufactured in the equipment immediately after cleaning-in-place without
any human intervention. The level of cleanliness to be achieved should be agreed
between the vendor and the buyer and must be guaranteed by the vendor, based on
documented evidence.
For a CIP system to be effective, the most critical factors are the cleaning proce-
dure, determined by the product and process characteristics, and the processing equip-
ment design.
The development of a CIP procedure is similar to that of a manual cleaning pro-
cedure and depends on such factors as the solubility of active and inactive ingredients
and the presence and amount of lubricating, dispersing, and wetting agents. A CIP sys-
tem takes advantage of the use of cleaning conditions that could be harmful for oper-
ators: high temperature, high pressure, high detergent concentration, or high or low
pH of the cleaning agents. The basic CIP variables are: time, pressure, volume, tem-
perature, cleaning agent concentration, recycling, and the sequence of cleaning, rins-
ing and drying. A typical CIP cycle runs as shown in Table 4.4.
Table 4.4. CIP Sequence
1. Prewash Tap water
2. Wash Cleaning solution
3. Blow out Compressed air
4. Rinse Tap water
5. Final rinse Purified water
6. Blow out Compressed air
7. Drying Hot, compressed air

A simplified scheme of a CIP system was shown in Figure 4.1.

To be able to rely on the automated cycles for cleaning purposes, it is necessary to
qualify and validate the CIP. In addition, it should be demonstrated that parameters such
as pressure, temperature, and volume can be controlled and monitored, and that in case of
failure, an alarm system should be in place. As a routine practice: "once CIP systems are
validated, appropriate documentation should be maintained to show that critical para-
meters (e.g., temperature, turbulence, cleaning agent concentration, rinse cycles) are
achieved with each cleaning cycle" (FDA, March 1998).
The design criteria which should be followed when installing a CIP system are
as follows:
• The equipment must be cleanable. For example, the vessels should be

made of stainless steel (with no dead zones), and fully drainable. The
piping also should be made of stainless steel, use sanitary valves with
no sudden change of pipe diameter, and shouldn't have dead legs.
• The CIP system should be installed in a technical area, not in the pro-
duction area.
• The CIP sequence should be reproducible by controlling the process

parameters, such as: temperature of rinsing water and cleaning solu-
tions, time of each step, concentration of the cleaning agent, volume of
rinsing water and cleaning solutions, flow rate, and mixing speed.
• Avoid microbiological contamination by use of purified water at final

rinse and heat drying.
• Avoid contamination between the CIP system and the equipment by

using automated back flow prevention valves.
Documentation
The documentation of the cleaning procedure is essential. The cleaning philosophy of
the company should be reflected through this document and expressed in a simple yet
detailed way to the operator.
The cleaning procedure must be simple, clear, precise, and documented in a way
that helps the operator to execute the cleaning in a reproducible and safe manner. The
basis for relying on manual cleaning performed by an operator and sometimes by dif-
ferent operators, knowing that this might raise concerns related to wide variations
between operators, is that the procedure is written in a way that eliminates ambigui-
ties as much as possible. This is also the basis on which these procedures can be vali-
dated and only after validation visual inspection will be sufficient to evaluate the
cleanliness of the equipment.
Figure 4.1. l. CIP system installed with tanks, heat exchangers, detergent dosing
components, and others. 2. CIP-pump to reach pressure and flow as required. 3. The
equipment to be cleaned. 4. CIP-return pump-to circulate and drain the cleaning
solution and water.
3 1
Equipment CIP System
The cleaning procedure must present detailed step-by-step directions to be fol-

lowed, preferably in a checklist format. The cleaning procedure shall contain all the rel-
evant parameters and information such as volumes of detergent, solvent, temperature,
time, and pressure. This information should be given in detail to enable the operator
to always conduct the cleaning in a reproducible manner.
Efforts should be made to standardize all or most of the cleaning procedures. For
example, when possible, all the manual procedures should be written in the same for-
mat, give the order of cleaning steps, use the same detergents, and use the same types
of water or solvents in the same steps with same cleaning materials and tools. This will
provide the operator a routine and easy-to-manage procedure. Sometimes, the most
common procedure is not sufficient for the cleaning of a certain product. In this case,
additional steps can be added to the common procedure using chemically reactive
cleaning materials such as hypochlorite (chlorine bleach), when oxidative agents are
needed, or alkaline or acidic solvents such as sodium or potassium hydroxide or citric
acid. This additional step will be followed then by the common procedure. Only when
the common procedure cannot be utilized, a different suitable procedure shall be used.
The same holds for CIP procedures, the same detergents and solvents should be used
for all CIP systems existing in the plant, if possible.
The documentation of the cleaning performance provides evidence of the control
on this procedure. The cleaning procedures must be written and the operator has to
certify, by his or her signature, the performance of the cleaning sequences to enable
tracking and investigating an event related to cleanliness, and to make appropriate cor-
rective action.
Each cleaning procedure has to include the steps outlined in the following box.
l. Objective: Cleaning of equipment and the edition number of the pro-

cedure in order to control changes, and also to be able to track them.
2. Equipment name and identification number: For similar or identical

pieces of equipment, the same procedure can be used bearing all the
identification numbers and the names of the equipment.
3. Cleanliness level: The same procedure can be used for minor and
major cleaning. It should be indicated which steps are relevant for
each level of cleaning.
4. Operator's name and his signature.
5. Precautions and safety warning should be specified.
6. Degree of disassembly has to be directed so that accessibility to hard-

to-clean locations is enhanced.
7. Cleaning tools and materials should be specified. If brushes or

sponges are used, it should be written in the relevant step. For clean-
ing agents, their name, concentration and their dilution instructions
have to be part of the procedure. Also, for the water or the solvents
which are used, their quantity or volume, temperature, and quality
will be written.
8. Cleaning instructions should contain a step-by-step description. For

CIP procedures, the sequence should set parameters for each step.
Parameters such as time, temperature, pressure, volume, and flow rate
of the solvent will be programmed for each step: prewash, rinse and
final rinse. The operator should be made aware of how to treat hard-
to-clean locations, such as: how to clean behind baffles, inside noz-
zles, and under the agitator. If an agitator is operated while cleaning,
the agitator speed and time of operation should be mentioned.
9. Drying: This step is very important to prevent microbiological pro-

liferation. Sometimes the final rinse is conducted with hot purified
water to facilitate evaporation of the water.
10. Visual inspection: No traces or particles visible to the naked eye should
be observed after the cleaning.
11. Cleaned status has to be indicated either by putting a label or a card

on the clean equipment, or moving it to a clean area, or hanging a
clean card on the room.
An example of a standard operating procedure for cleaning is presented in Part

Three of this book.
Part Two
Developing a Cleaning
Validation Progratn
5
Cleaning Validation Policy
INTRODUCTION
Now that the optimal cleaning procedure has been developed-whether manual or auto-
mated-the question remains, What do we have to demonstrate in cleaning validation?
Ideally, a well-designed cleaning procedure should leave the manufacturing equipment
free from residues of the previous product and a visual inspection would suffice to ver-
ify the equipment cleanliness. It has been shown, however, that visual detection has lim-
itations and that sufficiently sensitive analytical methods may detect residues beyond
the human eye capability. For dedicated equipment where cross contamination is not
an issue, a visual examination after cleaning may indeed be used as the sole cleaning
validation criterion. But, for multipurpose equipment, we will want to show that not
more than an acceptable residual amount of any product may be found in a defined
quantity of any other product, without adversely affecting patient safety. Consequently,
we should define what is the acceptable residual amount of the contaminant product
and how this should be determined, and what is a defined quantity of the contami-
nated product. Cleaning agent residues should be determined for dedicated, as well as
for multipurpose equipment.
What contaminants are we looking for in cleaning validation? In most cases, a prod-
uct contains a few inactive ingredients in addition to one or more active substances.
The cleaning procedure is able to introduce residues related to the cleaning procedure
itself, such as detergents and solvents. Degradation products and impurities can also
develop in the cleaning process. To make the validation effort manageable and practi-
cal, however, it is deemed logical and acceptable to monitor residues of the active sub-
stances and of the cleaning agent in order to demonstrate the effectiveness of the
cleaning procedure. The FDA's Guidance for Industry, Manufacturing, Processing or
Holding of Active Pharmaceutical Ingredients, Draft for Discussion (March 1998),
states that the "residue limits [for APis] ... should encompass raw materials, inter-
mediates, precursors, degradation products, isomers and cleaning agents". However,
from the reading of the FDA Guide to Inspections of Validation of Cleaning Processes
(July 1993), it would appear that the requirements for degradation products do not apply
to pharmaceutical dosage forms: "Unlike finished pharmaceuticals where the chemical
35
identity of residuals are known {i.e., from actives, inactives, detergents), bulk processes
may have partial reactants and unwanted by-products which may never have been
chemically identified".
For an operation involving a small number of products with a limited number of
pieces of equipment, cleaning validation may be addressed by validating the cleaning pro-
cedure of each piece of equipment for each product manufactured in the equipment
train. For equipment used for a wide variety of products, this approach is not feasible
due to the enormous analytical load involved in the development and the validation of
sufficiently sensitive analytical methods. Consequently, a practical approach is to be
adopted to develop a manageable program based on adequate assumptions, taking into
consideration worst cases and using additional safety factors to ensure, with a high degree
of confidence, that both patient safety and regulatory requirements are satisfied.
In the absence of dearly defined requirements and of authoritative publications,
the industry is struggling in order to define a practical approach to make the cleaning
validation effort manageable. An extensive literature search shows that different
approaches have been adopted by different companies, depending on the complexity
of their operations-namely the number of products manufactured and the number of
pieces of equipment involved in the manufacturing processes (Laban et al. 1997;
Mendenhall 1989; McCormick and Cullen 1993; McArthur and Vasilevsky 1995;
Jenkins and Vanderwielen 1994; Hwang et al. 1997; Nilsen 1998; Forsyth and Haynes
1999; PDA Technical Report No. 29 1998; LeBlanc 1998; Shea et al. 1996).
By definition:
The objective of cleaning validation is to attain documented evidence

which provides a high degree of assurance that the cleaning procedure
can effectively remove residues of a product and of the cleaning agent
from the manufacturing equipment, to a level that does not raise patient
safety concerns.
The cleaning validation program, once established, shall cover all the manufacturing
operations for all products and include a tracking system to allow for the timely per-
formance of the cleaning validation of newly developed products. Thereafter, a change
control system should be in place to evaluate the impact of changes in product for-
mulation, equipment, and/or cleaning procedure, in order to maintain the equipment
cleaning validation status.
Part Two of this book focuses on the cleaning validation of equipment in complex,
multiproduct pharmaceutical operations. The policy and its underlying basic princi-
ples may be applied also to active pharmaceutical ingredients (API) (Romanach et al.
1999), biological and biotechnological products (McArthur and Vasilevsky 1995; Lom-
bardo et al. 1995; Sofer 1995; Baffi et al. 1991), with appropriate adaptations and in
Cleaning Validation Policy 37
conformity with the applicable regulations. A cleaning validation program is presented

step by step as follows:
1. Policy
2. Contamination Acceptance Limits
3. Planning and Execution
4. Monitoring and Maintenance
Entering into a cleaning validation program is a major commitment and a time-

consuming and costly activity to which significant resources have to be allocated. The
objective is a cleaning validation program, which covers all the manufacturing equip-
ment and is manageable and cost effective without compromising the quality of the
products. Therefore before embarking in the program, a policy should be defined in
writing, agreed upon, and approved by upper management. The policy must include
the basic principles covering all the aspects related to cleaning validation which, when
brought together, create the manageable cleaning validation program.
POLICY
The cleaning validation policy consists of the following steps:
• Selecting the worst case related to the product
• Selecting the worst case related to the equipment
• Selecting the scientific basis for the contamination limit
• Selecting the sampling method
• Selecting the analytical method
SELECTING THE WORST CASE RELATED TO THE PRODUCT
Ideally, for multiproduct equipment, a cleaning validation study would be performed for
all the products manufactured in any manufacturing sequence. This undertaking is
obviously beyond the resources of any company. In order to reduce the analytical work-
load involved in testing all the permutations of the manufacturing sequences, products
and equipment are grouped into families and the worst case is selected in each family.
The matrix and worst-case approaches are invaluable in establishing a manageable clean-
ing validation program. The matrix approach enables the use of a representative prod-
uct or equipment out of all products or equipment grouped according to similarities.
With the worst-case approach, on the other hand, the most stringent acceptance crite-
ria are set to fit all the products manufactured in any sequence.
Cleaning agents are treated as special cases of the active ingredients.
Based on these approaches, a cleaning validation policy has been developed to select
a product, which can represent all other products manufactured in a piece of equipment,
using the same cleaning procedure. The selection of an active substance as representa-
tive of all these products is based on different characteristics of the active substances,
such as: structural similarity, similar sorption/desorption isotherm behavior, similar for-
mulation, similar potency, solubility, and degree of cleaning difficulty (Mendenhall
1989). For each characteristic, the worst case is selected out of all the products processed
in a piece of equipment. These worst case characteristics are gathered to create an all-
worst-case virtual product to be used as a reference product to demonstrate the effec-
tiveness of the cleaning procedure. A similar approach for the design of the cleaning
validation program makes the use of a "guiding substance" (Zeller 1993) or a "targeted
substance" (Laban et al. 1997) selected to best fit predetermined criteria, such as phar-
macological activity, solubility, concentration, and analytical detection.
The solubility of the active ingredient of the contaminant product in water, or any
other solvent used for equipment cleaning, is a critical factor for the ease of cleaning.
The more insoluble the active ingredient, the more difficult it is to get rid of it. The
worst case is represented by the product with the most insoluble active ingredient and
the cleaning validation study will be performed after cleaning the manufacturing equip-
ment from this product, using an analytical method of an adequate sensitivity, devel-
oped and validated for this active ingredient.
Based on the aforementioned approach, the following policy is introduced:
Only one product out of a group of products processed in a piece of

equipment is selected for the cleaning validation study, based on the low-
est solubility of the active ingredient.
Product Grouping
As for equipment, products may be grouped according to similarities: same active
ingredient with several strengths or formulations differing in the inactive ingredients.
The product worst cases are presented by the highest strength of the
active ingredient and by the most difficult to clean formulation.
SELECTING THE WORST CASE RELATED TO THE EQUIPMENT
The matrix and worst-case approaches are applied in order to limit the number of pieces
of equipment that have to be validated for cleaning. Taking into consideration that the
product contact surfaces are mostly made of stainless steel and that similarities exist
in the equipment design, operating principle and size, and in the cleaning procedure,
a rationale for grouping pieces of equipment and selecting one representative piece for
the cleaning validation study is developed.
Also to be addressed is the critical issue of identifying, sampling, and testing the
hard-to-clean locations in the equipment.
Equipment Grouping
To make the cleaning validation program manageable, the manufacturing equipment
is grouped, according to the following criteria listed, so that one piece of equipment in
a group may represent the entire group. Consequently, the cleaning validation study is
performed on this representative piece of equipment. The criteria for equipment group-
ing are listed as follows.
Identical, interchangeable pieces of equipment with the same cleaning

procedure can be grouped together.
Batch processing equipment of different sizes, where only one batch size is
processed, may not be grouped as opposed to continuous processing equipment. Usu-
ally, a product is manufactured in one type and size of granulator or blender, however
it can be milled, compressed, or filled in more than one type of equipment. In the lat-
ter cases, pieces of equipment with the same operating principle may be grouped.
Equipment with the same operating principle and the same cleaning
procedure, but with different product contact surface area, can be
grouped, if they can be interchanged.
Since a larger batch is processed in larger equipment, the equipment with the
larger surface area represents the worst case.
Hard-to-Clean Locations
The issue of the homogeneity of dispersion of residues has been discussed and the
potential for pockets of residual products in poorly accessible parts of certain types of
processing equipment has been stressed (Mendenhall, 1989). The "best case scenario"
described by Agalloco in his theory of dispersion would be represented by freely solu-
ble residues-as in solution formulations-as opposed to the "worst case scenario" rep-
resented by a low-level residue in solid dosage forms. Since the homogenous dispersion
of the contamination in the equipment can only be assumed, the identification of the
hard-to-clean locations is crucial to the cleaning validation study. The regulatory
requirements are clear, and there is a consensus in the industry in this regard.
Some experiments have been made to determine the hard-to-clean locations by
using water soluble (sodium chloride) or insoluble (sodium benzoate) materials or a
soluble dye (sodium fluorescein) and detecting the locations that remain unclean visu-
ally or with the help of an ultraviolet (UV) light. These experiments may be valuable
for small equipment or for cleaning verification of drug containers, such as glass
ampoules and vials. This is not recommended, however, for larger equipment or for
equipment with inaccessible parts. In these cases, the risk exists that the indicator
materials may not be completely washed out on the first cleaning and will reappear in
the next product manufactured. The knowledge of the equipment design and con-
struction is of better value to assess these hard-to-clean locations.
Special consideration should be given to cleaning-in-place systems. A thorough ver-
ification of the equipment cleanliness should be performed after a CIP cycle and should
include impellers, blades, screens, gaskets, valves, and instrument connections.
The worst case in relation to equipment refers to the hard-to-clean locations, such
as valves and gaskets. These locations should be identified in the selected piece of
equipment based on the intimate knowledge of the manufacturing equipment and its
operating principle, on scrupulous visual inspection, and on cleaning experience.
Table 5.1. shows hard-to-clean locations for the most commonly used equipment
for solid dosage forms. The list is indicative and not intended to be exhaustive. More-
over, since specific adaptations or modifications may have been made to the original
equipment, it is advisable to carefully examine the equipment after processing, and espe-
cially after products known to be difficult to clean. Antacids are such an example, due
to the large surface area of the active ingredients present in high concentration.
The worst case for a group of equipment is represented by the equip-

ment with the larger product contact surface and the hardest-to-clean
locations.
SELECTING THE SCIENTIFIC BASIS FOR THE

CONTAMINATION LIMIT
Your answer to the question, How clean is clean? forms the basis of your cleaning vali-
dation program and must be scientifically justifiable. At present, there is no universally
Table 5.1. Potential Hard-to-Clean Locations in Manufacturing Equipment

Granulation
High-shear mixers Diosna inner side of lid

lid gasket
inner side of discharge valve
bottom of impeller
impeller blades
chopper blades
vent filter
Dry Granulators Compactor feed hopper

dosing spiral
rollers
oscillator blades
screen
Planetary mixers
Drying
Fluid bed dryers Glatt trolley window

upper cylinder wall
trolley gasket
filter bags
Tray ovens All tray corners

exhaust air duct or grill
Particle Size Reduction
Cutting mills Fitzpatrick cutting blades

screen
Screening mills Oscillating (Frewitt) oscillator blades

screen
Rotating (Glatt) rotor blades

screen
Blenders
Diffusion mixers V-blender inner side of lid

lid gasket
intensification bar
Bins All inner side of lid

Continued on next page
Continued from previous page
Unit Dosing
Tablet press All feed hopper

force feeder
punch and die
Capsule filling machine All feed hopper
Volume fill piston
Auger fill plate filler
Powder filler Auger fill feed hopper

dosing spiral
dosing funnel
Coating
Pan All pan

exhaust air duct
dosing pump
baffles
Fluidized bed Glatt trolley window

upper cylinder wall
trolley gasket
filter bags
dosing pump
Note: The equipment name and classification are listed as given in SUPAC IR/MR-Manufacturing Equip-
ment Addendum (FDA, January 1999).
accepted contamination limit for the active ingredient or for the cleaning agent residues.
The regulatory authorities offer little help in this matter. "The firm's rationale for the
residue limits established should be logical, based on the manufacturer's knowledge of
the materials involved and be practical, achievable and verifiable. It is important to define
the sensitivity of the analytical methods in order to set reasonable limits. Some limits
that have been mentioned by industry representatives in the literature or in presenta-
tions include analytical detection levels such as 10 ppm, biological activity levels such as
1/1000 of the normal therapeutic dose and organoleptic levels such as no visible residue".
Except for penicillin (21 CFR 211.17 6, Penicillin Contamination), FDA

has not established standard acceptance limits for cleaning validation.
Due to the wide variation in both equipment and products produced,
it would be unrealistic for the agency to determine a specific limit ...
Firms need to establish limits that reflect the practical capability of
their cleaning processes, as well as the specificity of the analytical test
method ... This application of the [ICH and USP] 0.1 o/o impurity
threshold is inappropriate because the limit is intended for qualifying
impurities that are associated with the manufacturing process or related
compounds and not extraneous impurities caused by cross contami-
nation ... When determining the acceptance limit, relevant factors gen-
erally include ( 1) evaluation of the therapeutic dose carryover; (2)
toxicity of the potential contaminant; (3) concentration of the conta-
minant in the rinses; ( 4) limit of detection of the analytical test
method; and (5) visual examination. While we suggest that these fac-
tors be considered, relying only on visual examination would not be
scientifically sound (Human Drug cGMP Notes 1998).
It is, therefore, up to the company to set limits. The key success factors are that
residue limits should be practical, achievable, and verifiable. A review of the articles,
published in the recent years by industry experts and of presentations made by FDA
representatives in various meetings and conferences, shows a consensus toward the
adoption of a limit based on the pharmacological activity (potency) or toxicological
(safety) data of the active ingredient. However, contamination limits based on other
considerations have been proposed and are discussed later in this chapter.
In most cases, an arbitrary safety factor has been added in order to achieve a lower,
yet reasonable, contamination level. Factors of 1/10, 1/100, and 1/1000 have been used,
for benign, potent, and highly potent products, respectively (Mendenhall 1998;
Flickinger 1997). The 1/1000 factor has been interpreted as follows:
There are 3 factors of 10 in the 1/1000 fraction. The first is that phar-
maceuticals are often considered to be non active at 1/10 of their nor-
mally prescribed dosage; the second is a safety factor [for the first
one]; and the third is that cleaning validation should be robust, i.e.
be vigorous enough that it would be considered acceptable for quite
some time in a world with ever-tightening standards (Fourman and

Mullen 1993).
Another explanation to the use of a safety factor stems from the realization that,
although most contamination limit determination strategies assume a uniform distri-
bution of the contaminant, the actual distribution may not be as uniform as one would
like it to be (Jenkins and Vanderwielen 1994).
The determination of the acceptable contamination limit should first take into con-
sideration the specific manufacturing operation. For example, the following scenarios
in an API facility may be different from one process to the other and they depend on
the end use of the product (Lazar 1997).
• Sequential step within one process
• Nonsequential intermediate steps of one process
• Intermediate step of a different process
• Final bulk to final bulk (different products)
• Equipment dedicated to one process step
For approved pharmaceutical dosage forms or for APis, it is usually a difficult task
to set acceptance limits. For investigational drugs, this mission can be even harder due
to the limited knowledge of parameters, such as therapeutic dose, toxicity, or safety.
In addition, due to the versatile use of equipment at this stage of development and the
fact that these drugs are subject to frequent changes in processing, formulation, and
dosage strength, cleaning verification after each run is recommended. This involves test-
ing of residuals to confirm that they have been removed to an established level, gener-
ally using an absolute limit expressed in part per million (ppm).
Contamination Limit Based on Toxicological Data

Long-term toxicity data for humans are lacking for most chemical compounds and
therefore acute and chronic toxicity studies on laboratory animals of the mammalian
species are evaluated to estimate potential toxic effects on man (Layton et al. 1987).
Toxicological assessments normally include acute toxicity data, using different routes
of administration as well as mutagenicity, carcinogenicity, teratogenicity, sensitization,
and irritation. For the purpose of assessing human toxicological effects, various indices
have been used, such as the no-observed-effect level (NOEL), the lethal dose (LDSO),
and the acceptable daily intake (ADI).
• The NOEL is usually based on a two-year chronic toxicity study on various

mammalian species and is defined as the highest dose at which no toxic effects
are observed (Layton et al. 1987). OSHA (Occupational and Safety Health Orga-
nization, USA) developed this index to limit worker exposure to various chem-
ical compounds in the work place (Agalloco 1992).
o The LDSO is based on an acute toxicity study on various mammalian species and
is an estimate of the lethal dose to 50% of the animals, following a single dose
(Layton et al. 1987). This value is mostly used for nonactive ingredients such as
cleaning agents or sanitizers ( Agalloco 1992).
o ADI is defined as the amount of toxicant in milligrams per kilogram body weight
per day which is not anticipated to result any adverse effects after chronic expo-
sure to the general population of humans (Dourson and Stara 1983). The ADI
is difficult to establish and can be estimated based on the LDSO using a factor of
5 X 10- 6 to 1 X 10- 5 that incorporates variability associated with animal-to-
human toxic response and dose equivalence (Layton et al. 1987).
ADis are usually associated with food additives, vitamin preparations, and other
ingested non-pharmaceutical products. The acceptable level would depend on whether a
drug is administered to treat an ailment, or whether it was carried through a manufactur-
ing process as an impurity. The acceptable daily intake level of a chemical administered to
relieve an illness would be essentially identical to the lowest therapeutic dose. The accept-
able level of the chemical present as an impurity would be no higher than the NOEL.
NOELs are occasionally included in computer accessed safety databases. However,
the term NOEL is used to describe the highest dose that did not cause a measurable or
observable effect in a specific test. The NOEL for an acute oral toxicity test will be dif-
ferent than the NOEL determined for teratology, neurotoxicity, subchronic toxicity,
acute inhalation, and other tests. The NOEL depends on the route of exposure (oral,
dermal, inhalation, etc.), duration of exposure (single dose or multiple doses), species
in which the test was conducted, and the endpoint measured.
Another approach makes use of the compound's LDSO to calculate the NOEL,
which is used with an animal-to-human uncertainty factor and the average adult weight
to derive the ADI (Layton et al. 1987; Conine et al. 1992; Kirsch 1998).
The previously mentioned toxicological indices are converted in conjunction with the
dosage regimen and the batch size to the maximum allowable carryover to the next prod-
uct. This holds true for APis as well: "[The] amount of residue [is] assumed to be trans-
ferred to the finished dosage product at its highest dosage level. The theoretical amount of
contamination should be calculated for one dosage unit and compared with the set limit".
In general, it is logical to set residual limits on a pharmacologically defined con-
centration based on the potency of the substance. However, with less potent drugs, this
could lead to intolerably high residual limits (Zeller 1993).
Dose-Related Contamination Limit
This limit is based on the lowest therapeutic dose (LTD). The LTD is
defined as the lowest dose in any of the active ingredients that may be
given to a patient in any dosage form available, and is generally equiva-
lent to one unit dose, i.e., one tablet or one capsule.
Contamination Limit Based on Other Considerations

• Not Detectable
This type of limit refers to a specific analytical method. The disadvantage of this
type of limit lies in the fact that the detection level decreases as the sensitivity
of new analytical methodology increases. The setting of the contamination limit
based on the detection level of the analytical method requires a full revalidation
of the cleaning procedure with the introduction of the more sensitive method
and therefore should be avoided.
• Absolute Limit
An absolute limit also termed "single limit" or "blanket specification" means that
the same limit is set for any product, without consideration to toxicological data
or to the detection level of the analytical method, and is usually expressed in parts
per million (ppm) (McCormick and Cullen 1993). In this approach, it is sug-
gested to set limits in line with residual limits set for hazardous compounds, such
as pesticides in food (Harder 1984). This recommendation is based on 21 CFR,
Part 193 "Tolerances for Pesticides in Food Administered by the Environmental
Protection Agency". Based on the fact that the amount of administered drug is
much lower than the quantity of food that would be eaten, limits in the ppm
range-acceptable for hazardous compounds in food-seem to be reasonable.
This type of limit is also based on an acceptable contamination level set by offi-
cial pharmacopeias, such as the heavy metals or arsenic tests. A limit of not more
than 10 ppm seems to be widely used (Fourman and Mullen 1993), although
lower limits, as low as a few ppm or even less, have been used by some firms
(McCormick and Cullen 1993; Kirsch 1998).
Deciding upon an allowable contamination level irrespective of the potency of the

drug reduces the quality of the product or the cost effectiveness of manufacturing. For
drugs with low pharmacological potency, this decision results in overcleaning while for
high potent drugs it leads to insufficient cleaning (Zeller 1993).
A variant of the absolute limit, which is seldom used, requires the contamination
to be less than 1 mg/m 2 of the product contact surface area (Laban et al. 1997).
• Combination of Absolute Limit and Pharmacological Limit

An approach combining the absolute limit and the pharmacological limit was sug-
gested (Zeller 1993), so that the allowable contamination level has to decrease
with minimum therapeutic doses in a linear relation for all therapeutic doses
lower than 1 mg.
In the case of products for external use, the limit could be increased by an order
of magnitude, due to their low bioavailability, when compared to that of products
administered orally. However, for parenterals, the acceptable contamination level could
be halved in comparison to oral drugs (Zeller 1993).
Log Reduction of Contaminant Concentration

This type of acceptance criterion is based on the reduction by an arbitrary num-
ber of orders of magnitude, usually 3 logs (one log is a tenfold reduction), in the
concentration of the contaminant, measured before and after cleaning of the
equipment. This type of criterion is widely used in the validation of aseptic
processes, for example, to determine the effectiveness of the depyrogenation
process. Without correlation to adverse effects of the contamination in humans,
this type of limit cannot be meaningful.
Acceptance Criterion Based on Visual Inspection

This acceptance criterion states that no residues may be visible in the equipment after clean-
ing and drying. While this criterion may sound too unsophisticated and non-quantitative,
it was stressed that "the visual cleanliness criterion was more rigid and clearly adequate"
in comparison to quantitative calculations. Therefore, the visual inspection must be part
of the cleaning procedure, even though the cleanliness level of the equipment is chem-
ically determined. It has also been shown that, while other criteria such as LTD/1000 or
10 ppm were met, residues could still be visible after cleaning of equipment in which
sodium chloride tablets were processed (Fourman and Mullen 1993). The visual detection
limit of most active ingredients, according to the same source, is approximately 100 flg
per 25 sq. em. Clearly, for high potent or toxic drugs, the calculated allowable amount of
residuals may be well below visual detectability.
The use of a set of criteria is frequently implemented. The approach of setting few
criteria is quite known. This approach is presented already by Fourman and Mullen
(1993) using dose-related limit together with 10 ppm absolute value and visual inspec-
tion. The same principle is presented by Forsyth and Haynes (1999) using safety (ADI)
as the first criterion. The second criterion is an adulteration limit which states that no
more than 10 ppm of any product will appear in another product. The third criterion
is that the equipment must be visually clean.
The Proposed Approach

The approach proposed here for setting the residue limit for the active ingredient uses
the LTD, as the most easily available index and the most widely used in the industry
and for the cleaning agent the LDSO, both with the addition of an arbitrary safety fac-
tor of 1/1000.
The acceptance criteria of cleaning validation may be formulated as follows:
The maximum contamination level of active ingredient from any prod-

uct in the maximum daily dose of another product is not more than
1/1000 of the LTD of the former product.
and
The maximum contamination level of cleaning agent in the maximum

daily dose of any product is not more than 1/1000 of the LDSO of the
cleaning agent.
and
No visible residue must be found in the equipment, after cleaning.
SELECTING THE SAMPLING METHOD
There are three known sampling methods: the swabbing (or direct surface sampling)
method, the rinse sampling method and the placebo method. A description of the meth-
ods, their advantages, and their disadvantages are presented from regulatory as well as
practical viewpoints.
The Swabbing Method

This method is based on the physical removal of residue left over on a piece of equip-
ment after it has been cleaned and dried. A swab wetted with a solvent is rubbed over
a previously determined sample surface area to remove any potential residue, and there-
after extracted into a known volume of solvent in which the contaminant active ingre-
dient residue is soluble. The amount of contaminant per swab is then determined by
an analytical method of adequate sensitivity.
The advantages of direct sampling are that areas hardest to clean and
which are reasonably accessible can be evaluated, leading to estab-
lishing a level of contamination or residue per given surface area.
Additionally, residues that are 'dried out' or are insoluble can be sam-
pled by physical removal (FDA, July 1993).
Advantages and Disadvantages

The following are the major advantages of the swabbing method.
• Direct evaluation of surface contamination.
• Insoluble or poorly soluble substances may be physically removed from the

equipment surfaces.
• Hard-to-clean but accessible areas are easily incorporated into the final evaluation.
The main disadvantages of the swabbing method are these:
Difficult to implement in large-scale manufacturing equipment.
• Extrapolation of results obtained for a small sample surface area to the whole
product contact surface of the equipment.
• Less accessible or hard to clean areas are more difficult to sample and may require
a combination of the swabbing method with the rinse sample method.
Product may accumulate in these hard-to-clean locations leading to a high amount

of active ingredient in a small surface area. Therefore, for the results to be significant,
the contribution of the hard-to-clean location surface areas to the whole equipment
product contact surface area must be taken into account in the calculation of the con-
tamination limit (Lazar 1997).
Although swabbing is not the preferred method for routine testing of large-scale
manufacturing equipment, the direct evaluation of surface contamination makes it a
most valuable tool in a cleaning validation study (Smith 1992).
Swab Characterization
Natural or synthetic cotton wool, glass wool, synthetic fabric, and filter paper are com-
monly used as the carrier for removing the contaminant from the equipment surface.
The selection of the best swab material is guided by physical as well as chemical crite-
ria, with the objective of having-with no previous treatment-good physical removal
properties and the least significant chemical background contribution. The selection of
the swab material is based on the following criteria.
• Swab absorption capacity:

The swab material must have a solvent absorption capacity sufficient to be
moistened or saturated in order to add a solubilization effect to the physical
removal process.
• Swab interference:
Particles, fibers, and lints released in swab solvent extract obscure the light beam
path in spectrophotometric methods and should be filtered out before testing.
Lint-free, long fiber fabrics or wool, and quantitative filter paper are the preferred
materials. Swab extracts are tested using solvents which will normally be used in
sampling and analytical testing: water, ethanol, diluted acids and alkalis.
Substances extracted by solvents from the swab must not interfere with the analyt-
ical detection method. As with the previous property, this one is also critical and must
be checked in the characterization study to be performed for the analytical detection
method. When testing swab samples, a blank determination of a virgin swab solvent
extract is mandatory to eliminate extraneous factors that may influence the quantitative
determination of the contaminant.
Some swabbing materials, such as quartz wool and synthetic fabrics, have been
screened in connection with the use of Total Organic Carbon (TOC) as the ana-
lytical detection method (Jenkins et al. 1996). The use of low-carbon leaching
swabs is recommended when TOC is the analytical detection method (Lombardo
1995). A filter paper swab has been used with Fourier Transform Infra Red (FTIR)
(LeBlanc 1993).
Swab Recovery
A swab recovery study must be performed to determine the ability of the swab to quan-
titatively remove the contaminant from the surface sampled.
The roughness and the surface area of the swab material are also of importance in
the physical removal process. Swab materials that are too smooth or too coarse do not
ensure complete removal of the contaminant. Synthetic lint-free fabrics or synthetic
cotton wool in which the fiber length is controlled to a certain extent and quantitative
filter paper, such as Whatman #42 or equivalent, are materials of choice.
Another parameter which might influence the recovery is the ability of the swab
to absorb or adsorb the contaminant. This is a critical property which must be checked
in the recovery study by spiking swabs with known concentrations of the contaminant
and then extracting it.
The recovery factor must be taken into consideration in the calculation of the allow-
able contamination limit. This is particularly important due to the fact that the result
obtained from a small surface area is extrapolated to the entire equipment product con-
tact surface. A recovery factor of 70% is acceptable, however, factors as low as 50% may
be obtained. In cases where low results are obtained in a reproducible manner, the sam-
ple surface area may be sampled again using a second swab and the results obtained
from both swabs added together.
The swab recovery study is generally performed on pieces (also called coupons) of
the same construction material as the equipment. An area equivalent to the equipment
sample surface area is swabbed and tested.
The swab recovery study may be performed as part of the validation of the ana-
lytical method.
Sampling Locations and Number of Samples

The sampling locations are dictated by worst-case conditions. The equipment's hard-
to-dean locations are identified, based on cleaning experience and the intimate knowl-
edge of the equipment design, including the engineering piping and instrumentation
diagrams (P&ID). Before starting the cleaning validation study, it may be useful to per-
form a contamination mapping of the equipment, including the expected hard-to-
clean locations, by simulating the contamination with soluble and insoluble materials
(such as sodium chloride and sodium benzoate, respectively), using rapid analytical
methods of moderate specificity.
Since the homogeneity of the contaminant on the equipment product contact sur-
face can only be assumed, several samples, but not less than three samples per piece of
equipment, must be taken, including the hardest-to-clean locations. The number of
samples should take into consideration the equipment surface area, design, shape, oper-
ating principle, and construction materials.
Sample Surface Area

Sample surface areas usually vary from 25 sq. em to 100 sq. em and should be large
enough to allow the recovery of the contaminant in a quantity sufficient to be detected
by the analytical method. This small sample surface area is assumed, by extrapolation,
to represent the amount of residual contaminant in the whole equipment surface area.
Stainless steel templates are used on flat accessible surfaces to delimit the area to be
swabbed. For more reproducible results in hard-to-clean locations, it is recommended,
where feasible, to swab the whole area.
Swabbing Technique
As a manual and mechanical operation, the swabbing method is difficult to standard-
ize. Operators performing the sampling must be adequately trained and given precise
instructions in order to obtain reproducible results. The full coverage of the sample sur-
face area, the amount of pressure to be applied, the amount of solvent absorbed by the
swab and the strokes' direction must be emphasized in the operators' training. The swab-
bing technique must describe, in detail, the direction and numbers of strokes (or pas-
sages) needed for the full coverage of the sample area in a reproducible manner. Such
techniques have been described in the literature (Lombardo 1995; Shea et al. 1996).
Swab Saturation and Extraction Solvents

The solvents used for swab saturation and extraction may be one and the same. The
selection of the swab saturation solvent must take into consideration the solubility of
the contaminant active ingredient, so that the recovery is the highest and reproducible.
The toxicity of the solvent should also be considered to protect the operator and to pre-
vent solvent residues from being transferred to the next product. The most useful sol-
vent is ethanol, which can readily dissolve a large number of compounds, evaporates
quite rapidly, and has a low toxicity compared to other solvents.
The nature of the swab extraction solvent is dictated by the analytical method, tak-
ing into consideration its dissolution properties as well as the analytical technique used.
The Rinse Sample Method

This method is based on the analytical determination of a sample of the last rinsing
solvent (generally water) used in the cleaning procedure (LeBlanc 1998). The volume
of solvent used for the last rinse must be known to allow for the quantitative determi-
nation of the contaminant. The rinsing sample method is part of the cleaning proce-
dure and therefore does not require any special instruction to be performed.
Two advantages of using rinse samples are that larger surface areas
may be sampled and inaccessible systems or ones that cannot be rou-
tinely disassembled can be sampled and evaluated. A disadvantage of
rinse sample is that the residue or contaminant may not be soluble or
may be physically occluded in the equipment (FDA, July 1993).
Advantages and Disadvantages

The following are the major advantages of the rinse sample method.
• Ease of sampling.
• Evaluation of the entire product contact surface.
• Accessibility of all equipment parts to the rinsing solvent.
• Best fitted to sealed or large-scale equipment and equipment which is not easily
or routinely disassembled.
The main disadvantages of the rinse sample method are these:
• No physical removal of the contaminant.

• The rinsing solvent may not reach inaccessible or occluded equipment parts.
• Use of organic solvents for water insoluble materials.
Although the rinsing sample method has its limitations, it is widely used in large-
scale equipment, especially in the API industry, where equipment is cleaned by rinsing
and refluxing with the appropriate solvent.
The Placebo Method

The technique known as the placebo method is seldom used. This method is based on sam-
pling and testing of a portion of a placebo batch processed in a piece of equipment after
cleaning and drymg. The regulatory authorities vigorously discourage the use of this method.
The FDA has identified disadvantages to the placebo method.
One cannot ensure that the contaminant will be uniformly distrib-

uted throughout the system .... Additionally, if the contaminant or
residue is of a larger particle size, it may not be uniformly dispersed
in the placebo. Some firms have made the assumptions that a resid-
ual contaminant would be worn off the equipment surface uni-
formly; this is also an invalid conclusion. Finally, the analytical
power may be greatly reduced by dilution of the contaminant.
Because of such problems, rinse and/or swab samples should be used
in conjunction with the placebo method (FDA, July 1993 ).
The preferred sampling method and the one considered as the most
acceptable by regulatory authorities is the swabbing method.
SELECTING THE ANALYTICAL METHOD
Basic Requirements
A wide variety of sensitive analytical methods is presently available (Smith 1993;
Gavlick eta!. 1995 ). However, the detection of residues for cleaning validation purposes
present a special challenge to the analytical scientist. The regulatory authorities put an
emphasis on the development of specific and sensitive methods.
Determine the specificity and sensitivity of the analytical method

used to detect residuals of contaminant. With advances in analytical
technology, residues from the manufacturing and cleaning processes
can be detected at very low levels. If levels of contamination or resid-
ual are not detected, it does not mean that there is no contaminant
present after cleaning. It only means that levels of contaminant greater
than the sensitivity or detection limit of the analytical method are not
present in the sample. The firm should challenge the analytical method
in combination with the sampling method(s) used to show that con-
taminants can be recovered from the equipment surface and at what
level, i.e., 50% recovery, 90%, etc. This is necessary before any con-
clusions can be made based on the sample results. A negative test may
also be the result of poor sampling technique (FDA, May 1993).
The very low contamination limit, resulting from the use of high safety factors and
worst cases, as well as the analytical methods available, impose contingencies in the
analytical method development (see Table 5.2).
Table 5.2. The Basic Requirement for the Analytical Method
1. The sensitivity of the method shall be appropriate to the calculated contamination limit.
2. The method shall be practical and rapid, and, as much as possible use instrumentation
existing in the company.
3. The method shall be validated in accordance with ICH, USP and EP requirements.
4. The analytical development shall include a recovery study to challenge the sampling and
testing methods.
Analytical Method Survey
Specific Methods
• Chromatographic methods such as LC/MS, GC/MS, and HPLC
Advantages:
These chromatographic methods are the methods of choice, as they separate ana-
lytes, are highly specific, highly sensitive, and quantitative. Various detection tech-
niques may be used to enhance these properties and to allow for the
determination of a wide variety of active pharmaceutical ingredients and clean-
ing agents. Among these techniques, the following are commonly used: spec-
trophotometric, electrochemical, fluorescence, and refractive index (Kirsch 1998;
Mirza et al. 1998).
Disadvantages:
These methods are costly and time-consuming.
• Thin layer chromatography (TLC)

Advantages:
TLC is highly specific and moderately sensitive. Various detection techniques may
be used to enhance the visualization and determination of the analytes: UV and
visible wavelength and colorimetry.
Disadvantages:
The method is semiquantitative and therefore may be used only to give an indi-
cation of the equipment cleanliness level at the preliminary stage of development
of the cleaning procedure.
• Specific ion meter

Advantages:
The quantitative determination of an active ingredient is rapid and specific.
Disadvantages:
The method can only be used if the active ingredient alone possess a specific ion.
Nonspecific Methods
Although not recommended, nonspecific, yet rapid methods, have been used, sometimes
with modification in order to achieve a meaningful specificity.
• Spectrophotometric methods in the visible, infrared, or UV ranges

Advantages:
These methods are rapid, inexpensive, and moderately specific. Fourier trans-
form infrared spectroscopy has been used as a primary qualitative tool to obtain
a finger print of cleaning agent residues before their quantitative analysis
(LeBlanc 1993).
Disadvantages:
Active ingredients can only be quantitated, if they possess a strong chromophore
that can be detected at very low levels and when the inactive ingredients do not
interfere with active ingredient at the same wavelength. In some cases where the
absorption of the inactive ingredients is low, correction may be made by sub-
tracting the absorbance of the formulation placebo.
• Total organic carbon (TOC)
Advantages:
The TOC method offers, at a moderate cost and in addition to its rapidity, a detec-
tion capability down to the ppb range. The method can also be applied to on-
line measurements. TOC in conjunction with other methods, such as conductivity
and pH, has been used to demonstrate the absence of residual cleaning agent in
rinse samples (Jenkins et al. 1996; Holmes and Vanderwielen 1997).
Disadvantages:
The limitation of the method resides in the fact that only water-soluble com-
pounds can be analyzed and that most, if not all, inactive ingredients are organic
compounds which contain carbon atoms and thus interfere in the measurement
of the active ingredient.
• Other Methods
Nonspecific methods such as pH, conductivity, and total solids have very lim-
ited use and can only be used in conjunction with a specific method.
In conclusion:
The chromatographic methods are preferred for cleaning validation stud-

ies because of their sensitivity, specificity, and ability to quantify.
Analytical Method Validation

The validation of the analytical method follows ICH guidelines ( 1995, 1997), USP ( 1995).
In addition to these basic requirements, all the cleaning validation elements related to the
sampling method, such as swab interference, placebo, solvent, shall be verified through
the validation of the analytical method.
The method validation should demonstrate:
• Accuracy (recovery) and range
• Precision
• Linearity
• Selectivity
• Detection Limit
• Quantitation Limit
• Stability of standard and sample solutions
Analytical Method Implementation

The analytical method, once validated, is transferred to the quality control (QC) lab-
oratory for implementation and routine testing. The reproducibility of the method
between the analytical development laboratory and the QC laboratory is part of the
technology transfer and of the method validation.
6
Contamination Acceptance Limits
The basic elements of a cleaning validation program relate to the products, the equip-
ment, the cleaning procedures and the sampling method. The characteristics, which
must be taken into account for each element, include (see Table 6.1):
• Characteristics related to the contaminating product, such as its therapeutic dose

and the solubility of its active ingredient, as it relates to cleanability
• Characteristics related to the contaminated product, the next produced product,
such as the batch size and the maximal daily dose (the number of tablets or cap-
sules taken in one day)
• Characteristics related to the equipment, such as the product contact surfaces and
the hard-to-clean locations
• Characteristics related to the cleaning procedure, such as the cleaning agents
• Characteristics related to the sampling method, such as the sample surface area
and the recovery
Let us develop together the matrix and worst-case approaches. Assume that you are
manufacturing only two products, using only one piece of equipment. The two possible
manufacturing sequences are: Product A before Product B or Product A after Product
B. For equipment cleaning validation in this simplified case, your goal is to demonstrate
that not more than an acceptable amount of active ingredient residue of Product A (or
Product B) can be detected in the maximal daily dose of Product B (or Product A). The
characteristics of Product A and Product B are tabulated in Table 6.2.
Each of the product characteristics has a different effect on the calculation of the
allowable amount of contaminant carried over to the next product and this amount has
to be the lowest to present the worst case scenario. It follows that the product with the
lowest therapeutic dose should be selected so that the minimal amount of contaminant
will be left after cleaning. The product with the highest daily dose should be selected
so that when the batch is divided into the maximum number of units, each unit will
contain the minimal residual amount of contaminant. The product with the smallest
batch size should be selected so that the overall quantity of residues allowed for each
manufactured batch will be minimal. To illustrate the concept, let us go back to our
57
VI
00
Table 6.1. Cleaning Validation Elements
Therapeutic Dose Solubility Batch Maximal Product Hard-to- Sample Recovery
Activity/Toxicity Size Daily Contact clean Area ~
;:$
Intake Surfaces Locations ~-
~
product §:...
Contaminated
s·
;:$
product ~
~
....~
Equipment
...
Sampling [
method ~
"<:;)
Cleaning agent ti$:I

g..
Contamination Acceptance Limits 59
Table 6.2. Product Characteristics
Therapeutic Dose Maximal Daily Dose Batch Size
Product A low low small
Product B high high large
previously mentioned Product A and Product B scenario and determine the worst case
values to be selected (see Table 6.3 ).
We have thus created a "virtual" product, which, for the sake of cleaning valida-
tion, combines all the worst case parameters. In practice, when many products are man-
ufactured in the same piece of equipment, the lowest therapeutic dose, the maximal
daily dose, and the smallest batch size of different products will be used to calculate
the acceptance limit.
The contamination acceptance limit is calculated using the virtual prod-

uct worst case characteristics: lowest therapeutic dose, maximal daily
dose, and smallest batch size.
LOWEST THERAPEUTIC DOSE (LTD)
The product with the lowest active ingredient therapeutic dose (LTD) represents the
worst case and this value is used to calculate the acceptance criterion of the cleaning
validation study for the group of products manufactured in one equipment group. The
LTD, as defined in Chapter 5, may be found in national or international medical com-
pendia, such as the Physician's Desk Reference (USA current edition), Martindale-The
Extra Pharmacopoeia (U.K., current edition), Vidal (France, current edition), Rote Liste
(Germany, current edition).
By using a safety factor of 1/1000, LTD/1000 represents the maximum amount of
contaminant that may be carried over to the maximal daily dose of the next product.
Table 6.3. Product Characteristics-Worst Case Scenario
Therapeutic Dose Maximal Daily Dose Batch Size
Product A low low small
Product B high high large
Selected Product A B A
MAXIMAL DAILY DOSE
The maximal daily dose (D), also named the maximal daily intake, is the maximal dose in
mg that should not be exceeded. This data also appears in the aforementioned compendia.
The contaminant product residues are assumed to be spread all over the equipment
product contact surfaces and to be divided equally in all the units (tablets or capsules)
of any other product batch subsequently processed in the same piece of equipment. The
higher the maximal daily doses of the subsequent product the bigger the amount of
contaminant that will be absorbed in one day by the patient. The worst case is there-
fore represented by the product with the highest maximal daily dose. The above men-
tioned assumption seems contradictory to the FDA statement "One cannot ensure that
the contaminant will be uniformly distributed through the system" (FDA, July 1993).
However, as already discussed, the sampling and testing of the equipment hard-to-clean
locations ensure that accumulation of contaminant in such a location is taken into
account.
LTD/1000
----represents the maximum allowed amount of contaminant in the
D maximal daily dose of the contaminated product.
HIGHEST UNIT DOSE WEIGHT AND SMALLEST BATCH SIZE
Furthermore, the same amount of contaminant may be divided in a high (for exam-
ple, 1,000,000 tablets) or in a small (for example, 100,000 tablets) number of units of
the subsequent product. For two different products with the same maximal daily dose,
the maximal daily dose of the contaminated product with the smaller batch size will
contain a higher amount of contaminant. The worst case here will therefore be the
smallest number of units in a batch of product manufactured in the same piece of equip-
ment. For the virtual all-worst-case product, the smallest number of units is obtained
by dividing the smallest batch size in weight (Wb) for any product by the highest unit
dose weight (Wt) for any product in the product group (see Table 6.4).
Table 6.4. The Worst Cases as They Relate to Products
1. Lowest therapeutic dose
2. Highest maximal daily dose
3. Smallest batch size
4. Highest unit dose weight

CALCULATION OF THE SAMPLE CONTAMINATION LIMIT

FOR THE ACTIVE INGREDIENT
From the above principles and the selected characteristics for the hypothetical all-
worst-case product, the following equation has been developed to calculate the max-
imum allowable amount of contaminant (MC) in mg per swab, for a specific piece
of equipment:
LTD/I 000 Wb Ss
MC (mg/swab) = X- X- X R
D Wt Se
Where:
LTD - Lowest Therapeutic Dose (mg)

D - Highest Maximal Daily Dose (Dose units)
Wb - Smallest Batch Size (g)
Wt - Highest Unit Dose Weight (g)
Ss - Swab Area (cm 2 )
Se - Equipment Product Contact Surface Area (cm 2 )
R - Recovery Factor of Active Ingredient with Lowest Solubility (o/o)
From the above equation, it can be seen that the most stringent acceptance crite-
rion, i.e., the lowest contamination level, is obtained when the values for LTD and Wb
are the lowest while the values for D and Wt the highest.
CALCULATION OF THE SAMPLE CONTAMINATION LIMIT

FOR THE CLEANING AGENT
The same approach can be adopted to calculate the contamination limit for the clean-
ing agent, using LDSO. When formulated cleaning agent is used, the LDSO of the most
toxic component is used. LDSO values can be found in the literature.
DISCUSSION OF THE SAMPLE CONTAMINATION LIMIT
The calculation of the sample contamination limit is the result of the development of the
cleaning validation rationale, based on scientifically justified assumptions. However, there
are limitations that should be kept in mind as well as practices that should be avoided.
Averaging of Sample Swab Results

Swab samples are taken from various locations using templates of a known surface
area, and from the hard-to-clean locations. Equipment of complex geometry may
be decomposed in portions, such as the conical or cylindrical portions, for ease of
calculation of the portion surface area. The sum of the surface areas of all portions
is equal to the entire surface area of the equipment. The swab samples taken from
the various equipment portions are extracted and tested separately and the amount
of material per swab is calculated according to the above mentioned equation. Sat-
isfactory results are obtained when the amount of material (mg/swab) in any equip-
ment portion is lower than the calculated sample contamination limit for this
portion. Each swab result must individually comply with its specific limit. The
results obtained for the individual swabs may be added taking into account their rel-
ative contribution to the contamination level. Averaging of results is not acceptable
to the regulatory authorities. Out-of-specification results for any of the swabs deny
the assumption of homogeneous contaminant dispersion and lead to the possibility
that some of finished dosage form units may contain an amount of contaminant in
excess of the allowable limit.
The measurement of the surface area of a hard-to-clean location (such as the dis-
charge valve of a twin shell blender) is more difficult than that of large smooth sur-
faces and has to be measured with the best approximation. Apart from this, a
hard-to-clean location is treated just like any other sampling location.
Equipment Train
Any pharmaceutical product is processed through an equipment train, e.g., for a tablet,
a granulator, a mill, a blender and a tablet press are used. Each piece of equipment makes
its own contribution to the amount of contaminant that may be present in the finished
dosage form. Therefore the worst-case results, obtained for each piece of equipment
are summed up to give the total amount of contaminant in the equipment train. The
worst-case carryover of contaminant to the next product is obtained by dividing the
total amount of contaminant in the train by the smallest number of units of product
processed in the train.
Although this approach gives an overall estimation of the amount of contaminant
in the next product, it involves additional calculation. Considering the safety factors
introduced in the equation, it is deemed sufficient to use the single criterion stating
that any individual swab sample result must not exceed the calculated swab sample con-
tamination limit.
The most desirable approach is to have one set of acceptance criteria. The FDA dis-
courages the use of variable acceptance criteria for individual swab results based on
location, the averaging of individual swab results or the use of a single acceptance cri-
terion based on cumulative residues from swab samples. The concern is again poten-
tial masking of excessive variability of an ineffective cleaning procedure and the
disproportionate dilution (averaging) of high results.
The FDA expects swab sampling at multiple sites representative of the product con-
tact equipment surface, including hard-to-clean locations. Each swab sample needs to
be evaluated against a single acceptance criterion. During validation, single site sam-
piing (i.e., worst-case) may be questioned, even if there is hard data that supports the
worst case site selection. It would also be expected that, if the worst case swab samples
show out-of-specification results, improved cleaning would need to be implemented to
resolve this situation. However, for routine monitoring after cleaning validation, the
use of the most difficult to clean location for determining the reproducibility of the
cleaning procedure would be acceptable to regulatory authorities.
7
Cleaning Validation
Planning and Execution
INTRODUCTION
The next step in our validation program is to plan the activities to be performed based
on the cleaning validation policy developed in Chapter 5, and then execute a cleaning
validation study. A systematic approach must be developed in order to program paral-
lel activities, which involve different groups in the organization, and to conduct the
cleaning validation study in a timely and cost-effective manner.
ORGANIZATION
The program, after having been developed, must be presented and explained to the var-
ious groups in the company (R&D, production, production planning, engineering,
quality assurance and quality control) taking part in the validation studies, whether
their participation is active or supportive only. The close cooperation between these
groups, their understanding of the fundamentals of validation and of cleaning valida-
tion in particular, and their adequate and timely contribution are all vital to the suc-
cessful management of the cleaning validation program.
In most companies, the cleaning validation program is managed by the quality
assurance unit, but it could be managed by any other unit depending on the company
organization, provided that the program is supervised and controlled by the quality
assurance unit. It is advisable to establish a dedicated cleaning validation team or unit-
at least at the learning stage of the program-to provide a full overview and a focused
attention to all the aspects of cleaning validation. A steering committee consisting of
representatives of the aforementioned disciplines should also be instituted to deal with
changes in the policy, protocol deviations, and with any unexpected event or result in
the course of the validation study.
The typical responsibilities of the various groups involved in the following clean-
ing validation program may differ from company to company. While the repartition
65
of the responsibilities is obvious for most of the groups, R&D, the validation group,
and QA assume interchangeable roles depending on the company organization.
Validation Unit
Responsibilities of the validation unit include:
• Prepare validation master plan, working plan, and protocol, including prepara-
tion of database, grouping, determination of worst cases, and identification of
hard-to-clean locations.
• Calculate the contamination limit for the active ingredient and the cleaning agent.
Conduct validation study including sampling.
• Prepare validation report.
Production
Responsibilities of the production group include:
• Approve the validation master plan and the working plan.
• Verify accuracy of the cleaning procedure.
• Identify the equipment hard-to-clean locations.
• Perform cleaning.
Production Planning
Responsibilities of the production planning group include:
• Provide all information to build database.
Engineering
Responsibilities of the engineering group include:
• Verify accuracy of drawings and calculate product contact area.
• Assist in the identification of equipment hard-to-clean locations.
Quality Assurance
Responsibilities of the quality assurance group include:
• Approve the validation master plan and the working plan.

Cleaning Validation Planning and Execution 67
• Approve validation protocol.
• Oversee the validation study.
Approve validation report.
R&D Analytical Development

Responsibilities of the R&D group include:
• Develop and validate the analytical method.
Quality Control
Responsibilities of the quality control group include:
• Perform the recovery study.
• Test samples and prepare analytical report.
PLANNING
The planning of the cleaning validation program consists of a series of steps starting
from the establishment of a database and, resulting, through the grouping and the
worst-case approaches of equipment and products, in the selection of the specific
equipment and the representative product on which cleaning validation is performed.
The sequential steps are described in Table 7.1.
In the following sections, a step-by-step description will lead the reader through
the whole process of building the cleaning validation master plan. An example of a short
list of equipment and products is provided to help the reader to follow the process.
Table 7.1. Planning Stages for Cleaning Validation

l. Database (* Equipment List, * Product List)
2. Grouping (* Equipment, * Products)
3. Worst-case selection (* Equipment, * Product)
4. Calculation of the contamination limit
5. Validation master plan
6. Working plan
7. Execution
DATABASE
The list of products and cleaning agents and the list of equipment are the basic docu-
ments on which the cleaning validation database is built. These lists must be con-
trolled, by date and edition, verified to be accurate at the time the cleaning validation
study starts and maintained up-to-date through the change control system. The lists
represent the collection of the equipment and the product characteristics that will
enable the grouping and the selection of the worst cases and that must be taken into
account to calculate the contamination limit.
A list of equipment pieces used for manufacturing the products is prepared using
the list of products and the product master batch documents. An example of such lists
are shown in Tables 7.2 and 7.3.
In total, the products in Table 7.2 are manufactured using 13 pieces of equipment.
EQUIPMENT GROUPING
First, the equipment pieces are categorized according to technological groups: mixers,
dryers, mills, and so forth.
From Table 7.4, it can be seen that equipment nos. 4, 7, 10, and 11 are dedicated
to products E, D, C, and A, respectively. As such, they are not included in the cleaning
validation program and are therefore deleted from the table.
According to the cleaning validation policy described in Chapter 5, as it relates to
equipment, grouping is done by comparing the operating principle, the product con-
tact surface area, and the cleaning procedure of the pieces of equipment. The group-
ing rationale must be justified and documented.
The cleaning procedure used for cleaning each piece of equipment after the man-
ufacture of each product is verified. Usually one cleaning procedure is used for clean-
ing one piece of equipment. However, for certain products manufactured in the same
piece of equipment, another cleaning procedure may be used, due to difficulties in
removing residues from these products. In this case, a cleaning validation study has to
be performed on the same piece of equipment for each cleaning procedure. It is assumed
in Table 7.4 that only one cleaning procedure is used to clean one piece of equipment
from all the products.
The equipment operating principle is a characteristic that differentiates pieces of
equipment used for the same process: both a high-shear mixer and a fluid bed dryer
may be used for wet granulation, but they are considered as different classes of equip-
ment. A high-shear mixer and a low-shear mixer belong to the same class, but are con-
sidered as subclasses of equipment used for the same process.
The product contact surface area represents a characteristic of the equipment that
is taken into account in the calculation of the contamination limit. This value is pro-
portional to the equipment size. At this stage, the equipment size is used for grouping
and is listed in Table 7.5.
Table 7 .2. List of Products
Product A Product B Product C Product D Product E
Table 7.3. List of Equipment per Product

Product A Product 8 Product C Product D Product E
Mixer #1 Mixer #2 Mixer #2 - Mixer #1
Dryer #1 Dryer #1 Dryer #1 - Dryer #2
Mill #1 Mill #2 Mill #1 Mill #3 Mill #2 ~

;:t
~·
Blender #1 Blender #2 Blender #3 Blender #1 Blender #2
Tablet press # 1 Tablet press #2 Tablet press #3 Tablet press #3 Tablet press #2
~
-~ - ~- ---- -- ---------- -~-- - - ------ -
~
c:;·
;:t
~
;:t
;:t
~·
~
;:t
~
w
...c:;·~
;:t
0\
\0
Table 7 .4. Equipment Categories
Equipment No. Equipment Name Products
Mixer #1 A,E
2 Mixer #2 B,C
3 Dryer #1 A,B,C
4 Dryer #2 E
5 Mill #1 A,C
6 Mill #2 B,E
7 Mill #3 D
8 Blender #1 A,D
9 Blender #2 B,E
10 Blender #3 c
11 Tablet press #1 A
12 Tablet press #2 B,E
13 Tablet press #3 C,D
The following rationale is used to group the equipment listed in Table 7.5: Mills
#1 and 2 are grouped together because they have the same operating principle. Both
are screening mills with an oscillating bar and are of the same size. Blenders #1 and 2
cannot be grouped. Although both are twin shell blenders, they are different in size.
The products manufactured in a group of equipment are also grouped. The result
of the grouping is shown in Table 7.6.
SELECTION OF THE EQUIPMENT WORST CASE
The contamination limit equation, developed in Chapter 6, shows that the larger the
equipment product contact surface, the lower is the amount of contaminant allowed
to be carried over in the next product batch. It follows that the worst-case equipment
in the group, on which the validation will be conducted, is the one with the largest prod-
uct contact surface.
As a result, a shorter list of equipment, on which the cleaning validation study has
to be performed, is obtained. In this list, 8 out of 13 pieces of equipment-representing
the 8 groups-will participate in the cleaning validation program. As the number of pieces
of equipment increases and there is more interchangeable equipment, the list of equip-
ment to be validated for cleaning is dramatically reduced. Table 7.7 shows the list of equip-
ment on which the cleaning validation study will be performed.
Table 7.5. Equipment Grouping
Equipment No. Equipment Name Operating Principle Size Products
1 Mixer #1 High-shear mixer X A,E
bottom driven
2 Mixer #2 High-shear mixer X B,C

side driven
3 Dryer #1 Fluid bed dryer X A,B,C
5 Mill #1 Screening mill X A,C

with oscillating bars
6 Mill #2 Screening mill X B,E

~
::t
with oscillating bars ~-
~
~
8 Blender #1 Twin shell blender X A,D
::t.
0
9 Blender #2 Twin shell blender 2X B,E ::t
~
!:>
12 Tablet press #2 Force fed X B,E ::t
::t
~-
13 Tablet press #3 Gravity fed X C,D !:>
----- - - - - ----- -- ::t
lO:l...
~
~
.....
g·
::t
"-.1
.....
;j
Table 7 .6. Equipment and Products Grouping
Group No. Equipment No. Equipment Name Operating Principle Product Contact Products
Surface Area (")
~
1 1 Mixer #1 High-shear mixer y A,E

§
bottom driven ~-
~
~...
2 2 Mixer #2 High-shear mixer y B,C
side driven
5"
::t
3 3 Dryer #1 Fluid bed dryer y A,B,C
l
4 5 Mill #1 Screening mills with y A,B,C,E ~
~
6 Mill #2 oscillating bars y ::l".
5 8 Blender #1 Twin shell blender 25,000 cm 2 A,D

-
£
~
~
Blender #2 Twin shell blender 50,000 cm 2 B,E ~

6 9
s.
7 12 Tablet press #2 Force fed y B,E
8 13 Tablet press #3 Gravity fed y C,D

Table 7.7. Equipment for Cleaning Validation
Group No. Equipment No. Equipment Name Operating Principle Product Contact Products
Surface Area
1 1 Mixer #1 High-shear mixer y A,E
bottom driven
2 2 Mixer #2 High-shear mixer y B,C

side driven
3 3 Dryer #1 Fluid bed dryer y A,B,C
4 5 Mill #1 Screening mill y A,B, C,
5 8 Blender #1
with oscillating bars
Twin shell blender 25,000 cm 2

E
A,D
r
::t
~·
Blender #2 Twin shell blender 50,000 cm2 B,E

~
6 9
y B,E
...c:;·~
7 12 Tablet press # 1 Force fed ::t
8 13 Tablet press #3 Gravity fed y C,D ~

::t
::t
~·
;:,
::t
1:1..
i...
c:;·
::t
'-I
~
Finally, and as an additional equipment worst case, the hard-to-clean locations are
identified for the representative piece of equipment in a group. The table in Chapter 5 may
be used as a guide to identify the hard-to-clean locations for the most commonly used
equipment for solid dosage forms. The hard-to-clean locations are then marked on the
equipment diagram, which is included in the validation protocol.
The whole data collection and selection processes are summarized in Table 7.8,
which represents the equipment database.
PRODUCT GROUPING
The aim of the product grouping is to determine the representative product manufac-
tured in a piece of equipment. The representative product is the one containing the most
insoluble active ingredient in the solvent used to clean the equipment. The contami-
nation limit is computed by using the worst-case characteristics of all the products man-
ufactured in the representative piece of equipment in an equipment group.
The characteristic data of the products manufactured in each equipment group
determined previously are tabulated. These data, as explained in Chapter 6, are prod-
uct related: active ingredient, solubility, LTD, daily dose and unit weight; and process
related: batch size. If the product contains more than one active ingredient, all of them
shall be listed. The data for the products manufactured in the equipment groups are
presented in Table 7.9.
SELECTION OF THE PRODUCT WORST CASE
The worst case related to products is the most insoluble active ingredient. As defined
in the cleaning validation policy, cleaning validation is performed after cleaning the
equipment from the product containing the most insoluble active ingredient. The ana-
lytical detection method is developed for this ingredient. The solubility of the various
active ingredients is listed according to the pharmacopeia! definitions, i.e., very solu-
ble, freely soluble, soluble, sparingly soluble, slightly soluble, very slightly, or insoluble.
To differentiate between active ingredients of the same solubility definition, their sol-
ubilities must be given in mg/ml of water (The Merck Index, current edition). It can
be seen in Table 7.9 that only products A, B, C, and E participate in the cleaning vali-
dation studies, since one of their active ingredients is the most insoluble. This also means
that analytical methods are developed only for active ingredients "a", "b", "c", and "e".
As to the other characteristics of the products, the worst cases are selected, with the
contamination limit equation in mind, to create the virtual all-worst-case product. The
worst cases are represented by products with the lowest LTD, the highest maximal daily
dose in units (D), the highest unit dose weight (Wt) and the smallest batch size (Wb).
The selected worst cases related to products in Table 7.9 appear in italic type. As
an example, the virtual worst-case product in equipment group no. 5 has the charac-
teristics listed in Table 7.1 0.
Table 7 .8. Equipment Database
Group No. Equipment No. Equipment Name Operating Principle Product Contact Hard-to-Clean Products
Surface Area Locations
1 1 Mixer #1 High-shear y Lid gasket A,E
mixer Discharge valve
bottom driven Impeller blades
Chopper blades
Vent filter
2 2 Mixer #2 High-shear y * B,C

mixer
side driven
CJ
3 3 Dryer #1 Fluid bed dryer y * A,B,C ~
;::.
;::
~-
4 5 Mill #1 Screening mill
with oscillating y * A,B,C,E ~
bars
~.....
<::;•
5 8 Blender #1 Twin shell 25 000 cm 2 * A,D ;::
~
blender
;::
;::
6 9 Blender #2 Twin shell SO 000 cm 2 * B,E ~-
blender ;::.
;::
;::...
12 Tablet press # 1 Force fed y * B,E
7
~
Tablet press #3 Gravity fed y C,D
~.....
8 13 * <::;•
;::
• Refer to the table in Chapter 5
'-I
1.11
'l
Table 7.9. Product Database 0\
Group No. Product Name A~tive Solubility In LTD (mg) Daily Dose Unit Weight Batch Size
Ingredient (s)
Q
Water (mg/ml) (Units/day) (mg) (kg) "';::
>:::>
~·
1 A
0 I Insoluble I @] 4 170 [EI] ~
E e
g
Very slightly
Very soluble
10
100
w 8
~
245
245
245
~
.....
c;·
;::
2 B
CD ISlightly soluble I OJ CD 123 12471 l
c c Sparingly soluble 125 3 110601 265
~
<')
.....
f Freely soluble 50 ;::;·
3 1060 265 !:..
0 I I @] ~
3 A Insoluble 4 170
~ "ti
....
0
B b Slightly soluble 2
CD 123 247 >:::>
<')
;::,;-

f Freely soluble 50 3 1060 265
4 A
0 I Insoluble I @] 4 170
~
B b Slightly soluble 2 6 123 247
f Freely soluble 50 3 1060 265
E e
g
Very slightly
Very soluble
10
100
w 8
245
245
245
245
continued on following page

continued from pevious page
Table 7.9. Product Database

5 A 0 I Insoluble I @] 4 170
~
D d Soluble 1 [L] ~ 493
h Soluble 25 8 530 493
6 B b Slightly soluble
QJ 6 123 247
E 0g I Very slightly I 10 [L] 12451 12451

Very soluble 100 8 245 245
7 B b Slightly soluble [TI 6 123 247
E
0g I Very slightly I 10 [L] 12451 12451 ~
!:>
Very soluble 100 8 245 245 ;:s
~-
8 c Df ISparingly soluble! 125 3 110601 12651 ~
Freely soluble so 3 1060 265
~
...
D d Soluble [!] [L] 530 493 o·
;:s
h Soluble 25 8 530 493
------ -
~
;:s
;:s
~-
!:>
;:s
!:>..
~
~
...o·
;::
;:s
"-1
"-1
In other words, the cleaning validation study of group no. 5 is performed on

Blender #1 (equipment no. 8 in group no. 5) using the virtual worst-case product as
the representative of product A (active ingredient "a") and product D (active ingredi-
ents "d" and "h"). The analytical detection method is developed for active ingredient
"a", since it is the most insoluble of the active ingredients in the products manufac-
tured in equipment group no. 5.
Following the same principles, a virtual worst-case product is obtained for each of
the equipment groups.
CLEANING AGENTS
A similar approach is applied to the cleaning agents, using the LDSO of the most toxic
component instead of LTD and the most insoluble component to represent the virtual
worst-case cleaning agent.
For group no. 5, the cleaning agent characteristics are tabulated in Table 7 .11.
CALCULATION OF THE CONTAMINATION ACCEPTANCE LIMIT
Active Ingredient
By putting the characteristics of the virtual worst-case product presented in the con-
tamination acceptance limit equation and assuming a recovery factor of 70%:
LTD/ 1000 Wb Ss
MC(mg/swab) = x-x-xR
D Wt Se
we obtain the contamination acceptance limit of active ingredient "a" after cleaning
equipment no. 8:
0.5 mg/1000 238 x 10 3 g 25 cm 2
MC (mg/swab) = X X 2 X 0.7
8 0.530 g 50 000 em
MC (active) = 9.8 X 10-3 mg/swab
Cleaning Agent
The contamination acceptance limit for the cleaning agent is calculated by using the
same equation and replacing LTD by LDSO.
LDSO/ 1000 Wb Ss
MC (mg/swab) = X- x -x R
D Wt Se
CLEANING VALIDATION MASTER PLAN
It has been seen that only products A, B, C, and E participate in the cleaning validation
studies. Analytical methods must now be developed to detect active ingredients "a", "b",
"c", and "e", at a range bracketing the respective calculated contamination limit for the
Table 7.10. Sample Worst-Case Product
Group Equipment Equipment Product Active Solubility LTD Daily Unit Batch Size
No. No. Name Name Ingredient In water (mg) Dose Weight Wb
(mg/ml) D Wt (g)
(units/ (g)
day)
5 8 Blender #1 Virtual a Insoluble 0.5 8 0.530 238 X 10 3
product
Table 7.11. Cleaning Agent Characteristics

Group Equipment Equipment Cleaning Active Solubility LTD Virtual Virtual Virtual
~
~
No. No. Name Agent Ingredient In water (mg) Product Product Product ~·
(mg/ml) Daily Dose Unit Weight Batch Size
D (units/day) Wt (g) Wb (g) ~
5 8 Blender #1 Kleen k Soluble X 8 0.530 238 X 103 ~
...
--- ------- ----- ---------- -- ------ L____ - - . - - - - - - --- - -
c;·
~
i¥
~
~
~·
;:.
~
;:....
~
E
...
c;·
~
'I
IC
pieces of equipment participating in the cleaning validation studies. The range of cal-
culated contamination limits of an active ingredient in the various equipment groups
may be significantly different. In such cases, the analytical detection method is devel-
oped for the different ranges at the same time, thus saving important analytical resources.
At this stage, a cleaning validation master plan is drawn up and serves as the basis
for the determination of all the activities to be performed to conduct the cleaning val-
idation studies in a cost-effective and timely manner. The cleaning validation master
plan is a comprehensive and controlled document that include the following sections:
• Cleaning validation policy
• Product and equipment database
• Product and equipment grouping
• Product and equipment worst cases
• Calculation of the contamination limit for the active ingredient and the clean-
ing agent for each group of equipment
All the data are consolidated in one table listing the critical equipment and prod-
uct parameters to be taken into account to perform the cleaning validation studies (see
Table 7.12).
WORKING PLAN
A detailed working plan, based on the cleaning validation master plan and in accor-
dance with a priority order, is then prepared to include all the activities necessary to
perform the cleaning validation study for each piece of equipment, the time for com-
pletion of each activity, as well as responsibilities. Table 7.13 presents the sequence and
schedule of these activities.
EXECUTION
The execution of the cleaning validation studies includes all the activities listed in
Table 7.13. These activities are delineated in the cleaning validation protocol specific
for a piece of equipment representing the worst case of an equipment group, for exam-
ple equipment no. 8 (Blender #1) representing equipment group no. 5.
CLEANING VALIDATION PROTOCOL
A basic protocol is written in a generic format and adapted to be specific for the piece
of equipment to be validated. The protocol should refer to the cleaning validation mas-
ter plan, be concise, and give clear instructions how to conduct the cleaning validation
study. Any other applicable document should only be referred to in the text, available
Table 7.12. Cleaning Validation Master Plan
Group Equipment Equipment Product Hard-to-Clean Products Virtual Contamination Contamination
No. No. Name Contact Locations Product Limit (active) Limit
Surface Active mg/swab (cleaning agent)
Area mglswab
1 1 Mixer #1 y Lid gasket A,E A (a) ** **
Discharge valve
Impeller blades
Chopper blades
Vent filter
2 2 Mixer #2 y * B,C B (b) ** **
3 3 Dryer #1 y * A,B,C A (a) ** ** r

;::t
~-
4 5 Mill #1 y * A,B,C,E A (a) ** **
~
5 8 Blender #1 25,000
cm 2
* A,D A (a) 9.8 x w-3 ** ~.....
5"
;::t
6 9 Blender #2 50,000
cm2
* B,E E (e) ** ** ~
;::t
;::t
~-
7 12 Tablet press #1 y * B,E E (e) ** ** l':l
;::t
lO:l...
8 13 Tablet press #3 y * C,D C (c) ** ** ~
* Refer to the table in Chapter 5 ~
.....
* * Calculate as in the example for group no. 5 i:)"
;::t
...
00
00
1-..)
Table 7.13. Working Plan
I First Year I Second Year

~
$:>
Activity Responsibility Q2 Q4 Ql Q2 Q3 Q4 ::!
Analytical
development
R&D Lab I Active "c" Active "b"
~-
~
~
...
$:>
I I I
Analytical R&D Lab Active "c" Active "b" c;·
method ::!
validation I I I l
Analytical
method
implementation
I QCLab
-~ Active "c"
Active "b"
I I I I
'"tJ
~
...
<"I
[
~
Recovery study I QC Lab I •1 Active "c" I I Active "b" I I I I
'"<:)
ti
$:>
<"I
I I T"' ___ ! _______ .._ I T"' _ _ ! ______ .._
I I I ;:-
Validation Validation
protocol group
Manufacture Manufacturing Product C Product B

and sampling andQA
Testing of QCLab
samples
Validation Validation Equipment

report group I I group 2
Cleaning Validation Planning and Execution 83
for use at the time the study is conducted, and attached to cleaning validation report.
The equipment specific protocol should be reviewed and approved by the validation
group, production, and quality assurance before the execution of the study. Any devi-
ation from the protocol must be investigated and the results of the investigation
reviewed and approved by the same responsible persons. The protocol may be amended,
when scientifically justified.
A cleaning procedure, work instructions for sampling and recovery, and swab char-
acterization for a high-shear mixer are found in Part Three. Also presented in Part Three
is a template of a cleaning validation protocol for a high-shear mixer. The fill-in-the-
blank, easy-to-follow format is designed to be used for your own purposes.
The cleaning validation protocol should contain the sections listed in Table 7.14.
SAMPLING AND TESTING
Sampling is performed, as a worst case, at the end of the time limitation allowed before
cleaning. To prevent material from drying, and subsequent difficulties in cleaning, this
Table 7.14. Cleaning Validation Protocol
• Purpose
• Responsibility
• Frequency
• Procedure
• Manufacturing
·Sampling
• Acceptance criteria
• Visual inspection
• Contamination acceptance limit
• Documentation
• Product, cleaning agent, and equipment database
• Cleaning procedure
• Drawings
• Equipment surface area
• Hard-to-clean locations
• Analytical method and method validation

time period should be as short as feasible. Swab sampling is performed in accordance with
the working instructions and an approved diagram of the equipment, marked with loca-
tions to be sampled. A swab sampling record is filled in by the sampler to document the
actual sampling performance. It is important that the sampler be well trained in the swab-
bing technique and cognitive to report atypical events during sampling. In order to pre-
vent adventitious contamination, powder-free gloves must be worn by the sampler. The
swabs must be protected immediately after sampling in closed containers.
The residual materials in the swabs are extracted into a measured volume of an
appropriate extraction solvent, preferably by sonication or by using a magnetic stirrer-
as soon as possible after sampling and before testing-according to a standard operat-
ing procedure. When testing is not performed in a reasonable time period, the swab
samples are kept in the extraction solvent under refrigeration. In such a case, the sta-
bility of the active ingredient in these conditions has to be determined.
After extraction, the solvent is filtered and tested according to the appropriate ana-
lytical method. The results are recorded in mg (or f..lg) per ml, converted to mg or (f..Lg)
per swab, and compared to the calculated contamination limit.
CLEANING VALIDATION REPORT
The cleaning validation report closely follows and refers to the cleaning validation pro-
tocol and includes the records of sampling and testing performance, as well as the test-
ing results. In order to reduce paperwork, it is recommended to use a generic protocol
with specific attachments relating to the equipment being validated. These attachments
relate to the equipment and product grouping, worst cases, cleaning agent characteris-
tics, all-worst-case virtual product, equipment diagram marked with the sample loca-
tions, equipment surface area, analytical method used, and the calculation of the
acceptable contamination limit. The cleaning validation report ends with a conclusion
as to the compliance of the results with the acceptance criteria.
8
Cleaning Validation
Monitoring and Maintenance
MONITORING
With all its limitations, the visual inspection of the equipment after cleaning and before
use remains an essential part of the cleaning procedure. However, a periodic testing of
residues may be necessary to confirm the reproducibility of the cleaning procedure.
Clearly, the more automated the cleaning process, the less testing has to be performed.
For fully automated, well-designed, and properly validated CIP systems, no clean-
ing monitoring is needed. The reproducibility of the cleaning process is ensured though
the proper functioning of the system and verification of the cleaning cycle parameters
for each run, and is maintained through the change control procedure.
The reproducibility of the manual cleaning process cannot be ensured with the
same degree of confidence as with automated systems. The control of manual cleaning
resides in well-designed and detailed cleaning instructions and in intensive operator
training. The role of the human factor has already been emphasized in Chapter 4. It is
imperative to continuously enforce and monitor the performance of manual cleaning
procedures. Consequently, periodic monitoring is required to confirm the repro-
ducibility and the robustness of the cleaning procedure-when performed by the same
operator or by different operators, at different times. Cleaning monitoring is generally
performed by repeating the initial cleaning validation study, using the same sampling
and analytical methods, and the same acceptance contamination limit. Since the sam-
pling and testing activities involve various disciplines, they have to be coordinated and
planned in advance and this may have an unwanted impact on operator diligence.
MAINTENANCE OF VALIDATION
The design and development of a pharmaceutical product does not necessarily require
cleaning validation following the manufacture of the new product. However, the new
product and its characteristics, the equipment in which it is manufactured, and the
85
cleaning procedure are added in the database in order to determine whether the new
product introduces a new worst case in any one of the parameters listed. If this is not
the case, the pieces of equipment involved in the manufacture of the new product are
considered to remain in a state of validation. Otherwise, a reevaluation of the state of
validation must be made, depending on the new product characteristics introduced in
the database. As one can see from the calculation of the contamination limit, lower val-
ues for the lowest therapeutic dose (LTD) or for the batch size (Wb) and higher values
for the maximum daily dose (D) or for the unit dose weight (Wt) will give a lower max-
imum allowable contamination (MC) in mg per swab. The actual results obtained from
the previous validation are compared to the new value of MC. If these results are lower
than the new MC, the piece of equipment is considered to remain in a state of valida-
tion. If they are higher, the cleaning validation study has to be repeated after cleaning
the piece of equipment in which the new product has been manufactured. The clean-
ing validation is performed by testing active ingredient residues from the new product,
after having developed an analytical method sensitive enough to detect the new prod-
uct at a level corresponding to the newly calculated contamination limit. Another case
where the cleaning validation study has to be repeated is when the solubility of the active
ingredient of the new product is lower than the solubility of any other active ingredi-
ent already listed.
The effectiveness of the cleaning procedures in relation to the product, the equip-
ment, the cleaning procedure, the cleaning validation methods, or the cleaning moni-
toring results, must also be reevaluated in the following events:
Product
• The introduction of a new product
• Deletion of a product
• Any change in existing product, such as a change in formulation or in strength,

or a smaller batch size
Equipment
• The introduction of a new equipment
• A change to another equipment
• A change in the equipment, such as the design, the materials of construction and
a change in the product contact surface area
Cleaning Procedure
• The addition of a step in the cleaning procedure
• The deletion of a step in the cleaning procedure

Cleaning Validation Monitoring and Maintenance 87
• A change in the cleaning parameters (time, temperature, pressure, volume of solvent)
• A change in the cleaning agent
Cleaning Validation Methods

• A change in the sampling method
• A change in the testing method
The aforementioned changes are all governed by the change control procedure, a
critical procedure established to review, approve, and evaluate the impact of the changes
on the cleaning validation status. The rigorous implementation of the change control
procedure, as it applies to cleaning validation, ensures the continuous compliance of
the cleaning validation program. Following evaluation by R&D, engineering, produc-
tion, and QA, the changes may be categorized as major or minor, with the major ones
requiring either full revalidation of the cleaning procedure for three runs or partial
revalidation for one or more runs, and the minor ones no revalidation. The assessment
of the risks involved in the changes and the sound judgment of the potential impact of
these changes must be done carefully in order not to compromise the equipment vali-
dation status, and must be documented in a formal manner.
The importance of the change control procedure, which covers every aspect of the
pharmaceutical operations, cannot be stressed enough. This procedure provides a full
mapping of the actual procedures and processes in the plant, and dissipates any doubt
about what is really occurring and how changes may impact on product quality. As an
example, a change in a pressure transmitter may result in changes in pressure differ-
entials, and consequently in air-flow patterns, creating ideal conditions for cross con-
tamination. An effective change control system should be in place so as to provide a
powerful tool for knowledgeable and responsible personnel to assist them in the eval-
uation, and subsequent testing, of the impact of the change on quality. The rigorous
implementation of the change control procedure is the key to prevent unexpected or
unnoticed deviations and represents a fundamental aspect of the quality assurance sys-
tem of the company.
A standard operating procedure "Cleaning Validation-Change Control" is pre-
sented in Part Three of this book.
9
Special Cleaning Validation Issues
BIOCONTAMINATION
Although focusing on chemical contamination, cleaning validation would not be com-

plete without a reference to equipment biocontamination or bioburden. "Cleaning/
sanitization studies should address microbiological contamination for APis and
intermediate processes for which microbiological contamination is a concern" (FDA,
March 1998).
Nonsterile dosage forms are manufactured with materials and in environments
prone to the proliferation of microorganisms. The presence of water and growth-
supporting inactive ingredients-such as lactose and starch-in product formulations,
the microbiological quality of the water as an ingredient or as the cleaning solvent, and
the fact that most operations involve human intervention, impose the implementation
of a control and monitoring program to limit the bioburden. Equipment design and
the materials of construction have an important function in the minimization of
bioburden. Dead legs or portions of the equipment, which may contain stagnant water,
must be identified and eliminated wherever possible. Draining/drying of the equipment
after cleaning and time limitation for the storage of equipment after cleaning are crit-
ical measures to minimize equipment bioburden.
Cleaning procedures must be evaluated and validated with the aim of demon-
strating that the procedures effectively remove not only the active ingredient contam-
inant, but also viable microorganisms from the equipment product contact surfaces
(Cooper 1998).
The microbiological methods used to determine bioburden are the same as used
for monitoring sterile manufacturing equipment and environments. As opposed to the
analytical detection methods for chemicals, these methods are straightforward and do
not require a special development. However, a recovery study should be performed and
the methods should be validated to show that no substance, such as residual active ingre-
dient or cleaning agent, inhibits microorganism growth. If present, such residues must
be neutralized prior to testing. Representative colonies of the microorganisms isolated
during cleaning validation should be identified in order to build a plant microbial flora
89
baseline with the aim of locating and eliminating potential contamination sources. Spe-
cial attention should be given to the identification of objectionable microorganisms.
Two sampling methods are used for sampling equipment product contact surfaces.
Surface Sampling
Contact plates are used for sampling large smooth surfaces. This type of plate, com-
mercially available, contains a sterile growth medium with an outward swelling sur-
face. The growth medium, lightly pressed on the surface to be sampled, collects any
microorganism present on that surface. The plate is incubated at the appropriate tern-
peratures and time and colony forming units (CFU) representing the viable organisms
are counted. Care must be taken to thoroughly clean the area sampled to remove resid-
ual growth medium from the equipment surface after sampling. Due to the intrinsic
variability of microbiological determination, contamination levels rather than limits are
set to indicate, if exceeded, that action is required.
Swabs, such as cotton or cotton tips, are also used for sampling surfaces, but are
especially convenient to reach poorly accessible locations. Sterile swabs wetted with a
sterile solution are rubbed over the surface to be sampled to remove microorganisms
from the equipment surface and then rubbed again onto the surface of a plate containing
a sterile solid growth medium to release the microorganisms collected. The plate is incu-
bated as described above for contact plates.
The acceptance level for surface sampling is 10 CFU per 25 sq. em.
Rinse Sampling
This sampling method is particularly convenient for equipment that cannot be disas-
sembled easily, for large pieces of equipment, such as blenders, and to inaccessible loca-
tions or parts of the equipment, such as filling needles. After cleaning, a sample of the
rinse solution is tested, by pouring onto a sterile growth medium plate or by filtration
through a sterile membrane filter which is then laid on a sterile growth medium plate.
The plate is incubated and CFUs are counted as above.
The acceptance level for rinse sampling-not more than 100 CFU per 1 ml-is the
same as required by official compendia and acceptable to the FDA for Purified Water
(FDA Guide to Inspections of Water Systems 1993).
PENICILLIN CONTAMINATION
In the case of penicillins, due to their allergenic potential, FDA's approach goes beyond
the inclusion of a safety factor and requires no detectable level of penicillin in a drug sus-
pected to be contaminated with penicillins, when tested according to a sensitive microbi-
ological method. In the manufacture of penicillins, there is no reasonable way of
decontamination and it is extremely difficult to attain a nondetectable level of residuals.
Therefore, the use of dedicated facilities and equipment is recommended for this purpose.
There are some reports of the decontamination of facilities and equipment in order
to convert them for use with nonpenicillin products. Although not recommended,
Special Cleaning Validation Issues 91
such undertaking may be feasible when a systematic approach is employed. The diffi-
culty resides in the fact that penicillins are easily disseminated due to their small par-
ticle size. On the other hand, penicillins are labile materials, easily decomposed in the
presence of water. In order to increase the chance of success in a decontamination
project, a 0.1 N sodium hydroxide solution in water is used. Addition of a surfactant,
such as sodium lauryl sulfate, is useful to enhance the penetration of the sodium
hydroxide solution in crevices and not readily accessible areas. The sodium hydroxide
solution will not cause damage to stainless steel, but care should be taken to avoid con-
tact with other metallic surfaces, such as aluminum. The recommended procedure is
first to wash the walls, floors, and ceilings many times with plenty of water, then spray
the decontamination solution. A time of contact should be allowed before a final rinse
with water. The inactivation of penicillins in the way described has been reported by
Allan and Deeks (1996) and Hakimipour (1984).
FDA's GMP Regulations 21 CFR Section 211.176 specifies the analytical method to
be used for the detection of penicillins: "Procedures for Detecting and Measuring Peni-
cillin Contamination in Drugs". This is a microbiological analytical method using a
microorganism sensitive to penicillin. Another microbiological method widely used in
the dairy industry to check the presence of penicillin in raw cow's milk makes use of
bacillus stearothermophilus. A rapid method using this organism in a disk assay has been
developed and validated to provide results after three hours of incubation at 55°C.
Penicillin decontamination seems therefore possible, with some caveats. First, the
regulatory authorities must be consulted and must agree with the overall project plan
and outcome. Second, a monitoring program for testing residual penicillin in the envi-
ronment, as well as in the products, is mandatory over a period of time.
NONPHARMACEUTICALS
The use of common equipment for the manufacture of APis with nonpharmaceuticals, such
as pesticides and herbicides, has been addressed in FDA's Human CGMP Note, June 1998.
"Some nonpharmaceuticals pose unacceptable risks of cross contami-

nation .... In some cases, in addition to separate equipment, it would
be appropriate to use a separate facility.... These risks are influenced
by the nature and intended use of the drug product that will incorpo-
rate the API. ... Those risks may be of greater concern [for] large doses,
long term therapy, treating open wounds, injection or inhalation."
CONTRACT MANUFACTURING AND PACKAGING
Contract manufacturers and packagers are subject to the same regulations and must
meet the same requirements related to cleaning validation as the companies that
require their services. However, it should be kept in mind that the regulatory author-
ities regard the company that holds the marketing authorization as responsible for the
safety, identity, and purity of the marketed product. It is therefore the company's duty
to check and verify that the contract manufacturer or packager has a cleaning valida-
tion program in place. The matter is complicated by the fact that these contractors
manufacture or package for many other companies and the contract giver cannot get
the knowledge of the safety and cleanability of the other products, due to secrecy
agreements. On the other hand, the contracting business is based on giving the ser-
vice and quality in the conditions in which they operate. This is their raison d' etre and
they would be out of business if they did not implement a cleaning validation pro-
gram. Nevertheless, the difficulty when dealing with contractors resides in the fact that
their validation program would probably be different from yours. Understand their
cleaning validation rationale and verify the implementation of the cleaning validation
program. Audit raw data of the cleaning validation testing before your product is man-
ufactured, where all confidential and trade secrets have been blacked out. Check that
a procedure is in place when a new product is introduced to make the necessary cor-
rections to their contamination acceptance limit. Another approach is to require your
contractor to comply with your company's cleaning validation policy. A third approach
is to require the contractor to perform a cleaning verification of the equipment before
use with your product, using an absolute limit as described in Chapter 5.
10
Cleaning Validation Trends
INTRODUCTION
"What's the future of cleaning validation?" While it is difficult to be a prophet in the

regulatory field, we may make the unworthy prediction, based on the experience gained
with other regulatory issues, that cleaning validation is here to stay. The regulatory
requirements regarding cleaning validation would have forced the industry to look
again at cleaning procedures as an important way to ensure patient safety.
The resources allocated to cleaning validation represent an additional financial
burden and a significant investment of time, which otherwise could be allocated to the
research and development of new products. The approach proposed in this book will
alleviate the burden imposed on companies by making cleaning validation manageable
and cost effective. Yet, due to constraints related to the sampling and testing methods,
one has to be creative and explore new ways to achieve, in an efficient way and in a
shorter time, the purpose of ensuring patient safety. Following is a review of develop-
ments, some already available and one futuristic, which would provide the same safety
assurance level and additional operational benefits.
CONTAMINATION CONTROL
As we have shown in Chapter 1, contamination control is achieved by taking a series

of measures, after the manufacturing processes have been analyzed, to locate the sources
of contamination and implement procedures to prevent or at least minimize them. The
manufacturing process, the personnel, the equipment, and the cleaning procedure all
may contribute to the contamination carryover.
PERSONNEL
The role of the operator in ensuring the cleanliness of equipment has been emphasized
in Chapter 4. If it is crucial when using manual cleaning methods, it is not less criti-
cal with automated cleaning.
93
EQUIPMENT
Since the pharmaceutical industry is becoming more competitive while regulatory

requirements are becoming tougher, equipment manufacturers are expected to design
and construct machines which can fulfill the demand for economical cleaning perfor-
mance and yet give results of the desired quality (Faubel et al. 1990; Parikh 1998;
Hausmann et al. 1998; Baseman 1992).
Automation in manufacturing coupled with automation in cleaning, such as CIP, can
bring significant savings. In a conventional tablet press, the degree of dismantling is high
to allow cleaning of the hard-to-clean locations. Consequently, the cleaning process is
lengthy, a hardly acceptable fact in a multiproduct facility that can discourage frequent
changeover between different products, thus turning flexibility into wishful thinking only.
A tablet machine equipped with a CIP system and designed with these aspects in
mind has been developed (Hausmann et al. 1998). In this machine, the punches are
removed and then the CIP starts. Fluid bed dryers have been developed to ensure con-
formance to the user's predetermined cleaning validation criteria. These pieces of equip-
ment include new features such as CIP stainless steel filters instead of the classical fabric
filters which have to be dismantled and cleaned separately, sanitary and flush fittings
to prevent agglomeration of contaminants, and inflatable gaskets made of inert mate-
rial to prevent dust propagation. The cooperation between equipment manufacturers
and pharmaceutical companies will bring further developments.
It is expected that because of demand for CIP systems for complicated machines
such as tableting, encapsulating, and filling machines, the equipment design as well as
the design of the manufacturing areas will change. Only product contact parts of the
equipment will be located in the clean areas, while the machinery parts will be located
in sufficiently spacious technical areas, adjacent to the clean areas. With CIP systems
and washing machine for small equipment parts and ancillary equipment, space allo-
cated for washing could be reduced significantly.
Closed systems, whereby materials cannot contaminate the environment and are
not exposed to it during their transfer from a piece of equipment to another, already
exist. The application of the barrier isolation technology for oral solid dosage forms is
in its infancy and is expensive, but has a promising future.
CLEANING PROCEDURE
As mentioned before, CIP systems and washing machines will replace human labor.
However, the control and maintenance of the machine will still be performed by human
beings. Machines are not exempt from failures, and procedures shall be in place, includ-
ing alarms, to prevent and report malfunctioning.
CLEANING AGENTS AND TOOLS
The cleaning agent plays a critical role in manual or automated cleaning methods. The
importance of the cleaning agent is threefold: to perform efficient cleaning, to be non-
Cleaning Validation Trends 95
toxic to the patients, and to be environment friendly. In addition, the cleaning agent
must be detectable by usual analytical methods and must not interfere in the analyti-
cal procedure of the active ingredient. These attributes form the basis for the develop-
ment of new cleaning agents. The cooperation between cleaning agent manufacturers,
pharmaceutical companies, and the environmental agencies is essential to develop the
ideal cleaning agent.
SAMPLING TECHNIQUE
The swab sampling technique, preferred by the regulatory agencies, will remain an issue.
This technique is demanding, operator dependent, and requires well-trained operators.
As explained in Chapter 5, the rinse water technique, which is more rapid and much
more simple to use, is not acceptable. It is not expected that regulatory authorities will
change their mind on this issue. The only way to apply the swabbing technique in a
consistent manner is to give very detailed swabbing instructions and to train the oper-
ators.
The swabbing technique may be correlated to the detection method. Analytical
method developments may radically change the picture.
ANALYTICAL METHODS
The analytical detection method must be specific and sensitive. These are rational
requirements, but the presently acceptable methods are time consuming and instru-
mentation is expensive. The use of shorter HPLC columns alleviate these concerns in
some cases. The analytical detection methods should ideally be rapid, specific, and sen-
sitive. To achieve this purpose, new methods have to be developed. It may seem futur-
istic to envision the use of cleanliness sensors, similar in a way to the development of
the near infrared sensors for the identification and quantitation of active ingredients.
Yet, to the authors's minds, it seems to be the only kind of analytical technique, which
would obviate the need for swabbing. The development of such sensors will create a
breakthrough in cleaning validation and the authors urge analytical chemists and ana-
lytical instrument manufacturers to explore this possibility, for the benefit of all.
REGULATORY ISSUES
As shown in the discussion of the contamination limit, there is no consensus on which

considerations the limit should be calculated. Although the rationale to base the cal-
culation on toxicological effect seems to be extensively applied, there is clearly a need
for the regulatory agencies or for nonprofit pharmaceutical organizations to provide
more specific requirements. Now that experience has accumulated in the industry as
well as in the regulatory agencies, there is more insight and understanding on what the
acceptance criteria should be. As for other hot regulatory issues, it takes time to assim-
ilate and digest the experience gained in the industry. It happened more than once that
the industry itself shaped regulatory requirements, by publicly offering their know-how
in conferences and industry agency meetings. It is hoped that more specific guidance
will be issued by regulatory agencies in the near future to clarify their expectations.
Moreover, in our free trade world, harmonization of regulatory requirements is the word
of the day and an immediate must in the field of cleaning validation.
THE FUTURE
There is a saying, "The future is not a sure thing", and that is why there are mixed feel-
ings of apprehension and expectation about it.
As the future relates to cleaning validation, the bad news is that cleaning valida-
tion is here to stay. Pharmaceutical companies that did not start a cleaning validation
program must address the issue without delay. For companies which have already
implemented a cleaning validation program, the huge initial load is over. But they are
still dealing with this issue during regulatory agency inspections and repeating parts of
the cleaning validation studies for monitoring purposes or when introducing new prod-
ucts in their manufacturing lines.
The good news is not for the very near future. Yet, it is probable that once the reg-
ulatory agencies have enforced the implementation of cleaning programs in the indus-
try, they will issue specific guidance and may ease their requirements. The real good
news resides in the development of advanced analytical detection techniques, as men-
tioned, which will make a revolution in the field of cleaning validation. When this dream
is realized, cleaning validation will be reduced to a simple analytical exercise, just as
TOC has simplified the testing of purified water and water for injection in the phar-
macopeia! monographs. Cleaning monitoring could then be performed as an integral
part of the manufacturing process and give continuous assurance of the equipment
cleanliness level. What a wonderful dream, let us make it true!
Appendices
Cleaning and Cleaning

Validation Procedures
Appendix A
Cleaning
POLICY
PROCEDURE
Policy
EQUIPMENT AND PROCESSING AREA CLEANING

Appendix A-Cleaning 103
The Rx Pharmaceutical Company POLICY
Edition No.: Validation Unit:
Supersedes: Equipment and Processing Production:

Area Cleaning
Effective Date: Quality Assurance:
page 1 of 4
Purpose
Manufacturing equipment and processing areas should be cleaned to avoid contami-
nation and cross contamination.
Responsibility
Quality assurance is responsible for drawing up a policy concerning cleaning processes
in accordance with GMP regulations.
R&D and production are responsible for developing cleaning procedures and stan-
dard operating procedures in accordance with this policy.
Operators, supervisors, and managers are responsible for working according to
cleaning procedures and standard operating procedures relating to this policy.
Quality assurance is responsible for verifying the proper implementation of the pol-
icy, cleaning procedures, and related standard operating procedures.
Frequency
Routinely, in accordance with the level of cleaning, defined as follows.

Area Cleaning
page 2 of 4
Procedure
Level of Cleaning
Two levels of cleaning are defined for manufacturing equipment and processing areas:
minor and major.
a. Minor Cleaning
Minor cleaning is defined as cleaning which is conducted between the
manufacture of
• Batches of the same product
• Batches of different strengths of the same product
b. Major Cleaning
Major cleaning is defined as cleaning which is conducted between the
manufacture of
• Different products
• A colored product followed by a white product with the same active ingredient
• For equipment cleaning after plant shutdown and when resuming work
Time Limitations
a. Time between end of manufacturing and start of cleaning is set as follows:
• For solid oral dosage forms: 3 calendar days
• For liquid and semisolid oral and topical nonsterile dosage forms: 1 calendar day
Interruptions for periods longer than these time limits require a major
cleaning. For products which require shorter time limits, their specific clean-
ing procedure should indicate the appropriate time limits.
b. Time between final rinse and drying should be kept to a minimum. Preferably,
the equipment is dried immediately after final rinse.

Area Cleaning
page 3 of 4
c. Time until major cleaning 1s conducted while manufacturing product in a

campaign
• For solid oral dosage forms: 14 calendar days
• For liquid and semisolid, oral and topical nonsterile dosage forms: 7 calendar days
d. Time until major cleaning is conducted for unused cleaned equipment: 30 cal-
endar days.
Cleaning Procedure
Major cleaning of manufacturing equipment and processing areas are carried out using
a specific "Equipment/Processing Area Cleaning Procedure". Minor cleaning is carried
out according to a general departmental procedure.
Detailed Procedures for a Major Cleaning

• Manual cleaning
a. Safety precautions to the operator
b. The approved cleaning solvents, materials, and tools
c. Degree of disassembly of the equipment and the hard-to-clean locations

d. Washing steps
e. Rinsing steps-final rinse is always conducted using purified water
f. Drying
g. Visual inspection and quantitative monitoring (if needed)
h. Reassembly
i. Storage conditions: closed, covered, storage room classification
• Automated cleaning
An automated cleaning procedure should contain a cleaning sequence. Usually

the relevant program contains all the relevant steps, such as: prewash, wash, rinse,
final rinse, and drying, which run automatically. The sequence should detail the

Area Cleaning
page 4 of 4
controlled process parameters, such as: temperature in each step, time, concen-
tration of the cleaning agent, volume of water, flow rate, and mixing speed.
Visual Inspection and Monitoring

a. At the end of a major cleaning and prior to assembly, the equipment cleanliness
is visually inspected and approved by the supervisor. Prior to manufacturing,
cleanliness is verified by visual inspection and recorded by the operator in the
manufacturing instructions of the next product to be manufactured.
b. For equipment which is periodically or routinely monitored for quantitative

residues, a control and follow-up system to manage the monitoring must be in
place. This monitoring will be carried out after cleaning and visual inspection.
Documentation
Specific Cleaning Procedure for Each Equipment/Processing Area

Equipment Storage
a. For equipment which is permanently located with all its ancillaries in a specific
processing area, a single "Equipment/Processing Area Use and Cleaning Log" is
used (Attachment I).
b. For equipment which is located in a storage room and used in different rooms,
separate documentation has to be kept, both for the processing area (Attachment
II) and the equipment (Attachment III).
Equipment Labelling
A "cleaned" label (Attachment IV) is attached to the equipment and/or the room or both.
ATTACHMENT I
Company Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Form _ _ _ _ Ed. _ _ __

Cleaning Procedure No.: _ _ _ _ _ _ _ _ _ _ __
Equipment/Processing Area Use and Cleaning Log

Processing Area Name: ID No: _ _ _ _ _ _ __
Equipment Name(s): ID No: _ _ _ _ _ _ __
----------- IDNo: _ _ _ _ _ _ __
----------- ID No: _ _ _ _ _ _ _ __
__________ ID No: _ _ _ _ _ _ __
_____________ IDNo: _ _ _ _ _ _ _ __
Date Product Name Batch. Cleaning Name and Signature

No. Level
Minor/Major Performed by Approved by
ATTACHMENT II
Company Name: _______________ Form _ _ _ _ Ed. _ _ __

Processing Area Use and Cleaning Log
Processing Area N a m e : - - - - - - - - - - - - ID No: _ _ _ _ _ _ _ _ __

No. Level
ATTACHMENT III
Company N a m e : - - - - - - - - - - - - - - - Form _ _ _ _ Ed. _ _ __

Equipment Use and Cleaning Log

Equipment Name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ ID No: _ _ _ _ _ _ _ _ __

No. Level
ATTACHMENT IV
Company Name: - - - - - - - - - - - - - - Form _ _ _ _ Ed. _ _ __
CLEANED
Product Name:
Batch No.:
Start Date:
Equipment Name:
Cleaning Date:
Signature: Date:
Performed by:
Checked by:
Previous Product:
End of Work Date:
Cleaning Procedure
HIGH-SHEAR MIXER (DIOSNA)

The Rx Pharmaceutical Company CLEANING PROCEDURE

High-Shear Mixer (Diosna)
Supersedes: Diosna I Production:
Diosna II
Effective Date: Diosna III Quality Assurance:
Equipment/Processing Area No.: Previous Product: Batch No.: Date End:
page 1 of 5
Safety Precautions: Wear gloves and goggles.
Materials: Detergent No. 1 for equipment
Detergent No. 2 for floors and walls
Detergent No. 3 for glass separations
Tools: Sponge
Soft hair brush
Hard-to-clean locations: See attached drawing of the equipment.
Equipment
1. Prewash
1.1 Remove all identification labels of previous product.
1.2 Connect the equipment to the drain system.
1.3 Wash the body and lid inside and outside with tap water while the equip-
ment outlet is open to the drain.
2. Wash
2.1 Close the equipment outlet to the drain.
2.2 Fill with hot tap water up to 20% of its full capacity.
2.3 Add 3 liters of Detergent No. 1.
2.4 Close the lid.
2.5 Operate for 15 minutes, Mixer Speed II; Chopper Speed II.
2.6 Drain.

Diosna II
page 2 of 5
3. Disassembly
3.1 Remove the sleeve.
3.2 Remove the impeller and put it in a parallel position.
3.3 Wash the sleeves, scrub the impeller and underneath the impeller and the
chopper with the detergent solution and the brush.
4. Rinse
Rinse with hot tap water.
• Sleeve
• Impeller
• Body and lid, inside and outside
• Outlet pipe
5. Final Rinse
Rinse with purified water.
• Sleeve
• Impeller
• Body and lid, inside
Outlet pipe
6. Dry
6.1 Attach the hot air hose to the equipment chimney.
6.2 Dry for 20 minutes while the equipment outlet is open.
Ancillary Equipment
1. Wash
1.1 Dilute 2.5 liters of detergent No. 1 in 7.5 liters of tap water.

Diosna II
page 3 of 5
1.2 Use sponge and diluted detergent to clean.
• Hoses (used for water, granulation solutions or pastes, vacuum hoses)
• Ladder and stand
• Mixer and stainless steel container used for granulation solution or paste
preparations
1.3 Fill with hot tap water 1/2 capacity of the stainless steel container and add
detergent No. 1 to 1/8 capacity of the container. Operate the mixer for 10
minutes on full speed to clean the mixer.
2. Rinse
Rinse with tap water.
3. Final Rinse
Final rinse with purified water.
Process Area
1. Wash
1.1 Dilute 2.5 liters detergent No.2 in 7.5 liters of tap water.
1.2 Use a brush to clean the ceiling, walls, floor, and the glass separators.
2. Rinse
Rinse the ceiling, walls, floor, and the glass separators with tap water.
3. Dry
Use a fabric to dry the surfaces.
Use detergent No. 3 and dry fabric to shine the glass separators.

Diosna II
page 4 of 5
Visual Inspection
If clean, mark",/" in the box. If not clean, mark "x" in the box.
a. EQUIPMENT
Body-inside 0
Lid-inside 0
Chopper-blades and underneath 0
Impeller-blades and shaft 0
Outlet pipe 0
Equipment-outside 0
b. ANCILLARY EQUIPMENT
Hoses 0
Ladder and stand 0
Mixer and container 0
c. PROCESS AREA
Ceiling 0
Walls 0
Glass separations 0
Floors 0
Reassembly
If the equipment is clean, reassemble to allow proper function. 0
Status Label
Fill the "Clean" label with the relevant details. Attach the label to the
clean equipment. 0
Storage Conditions
Cover the equipment. 0

Diosna II
page 5 of 5
Summary
The equipment, ancillaries, and the process area are all clean and dry.
Signature: Date: _ _ __
Manager's Signature: _ _ _ _ _ _ _ _ _ _ _ _ _ Date: _ _ __
Figure 11.1. Drawing of the Equipment
l. Body
2. Lid
3. Chopper
4. Impeller
5. Discharge chute
Hard-to-clean locations are marked with a bullet ( •)
Documentation
Document the cleaning in the "Equipment/Processing Area Use and
Cleaning Log" Form. 0
Appendix B
Cleaning Validation
POLICY
PROCEDURE
Policy
CLEANING VALIDATION
Supersedes: Production:
Cleaning Validation
page 1 of 5
Purpose
The objective of cleaning validation is to attain documented evidence which provides
a high degree of assurance that the cleaning procedure can effectively remove residues
of a product and of the cleaning agent from the manufacturing equipment to a level
that does not raise patient safety concerns.
Responsibility
1. Validation unit: Prepare validation protocol, conduct the study, and prepare a final
report.
2. Production: Approve the validation master plan and participate in the study as
required.
3. Engineering: Provide drawings with calculation of product contact area.
4. Quality assurance: Approve the validation master plan, the validation protocol, and
the validation report.
5. Analytical R&D: develop and validate the analytical method.
6. Quality control: test samples.
123
Cleaning Validation
page 2 of 5
Frequency
Cleaning Validation Study

On the worst -case piece of each group of equipment.
On three consecutive major cleanings of batches of the chosen worst case product.
Maintenance of Validation
The effect of changes on the effectiveness of the cleaning procedure should be evalu-
ated and when required, a revalidation study on 3 consecutive batches after major clean-
ing (on different batches) will be performed. The changes can be related to
• Product
• Equipment
• Cleaning procedure
• Cleaning validation methods
Monitoring:
Once a year after a major cleaning of one batch on each validation group of equipment.
Procedure
The cleaning validation policy is based on
• Selecting the worst-case equipment
• Selecting the worst-case product
• Calculating the contamination acceptance limits for the active ingredient and for
the cleaning agent
• Selecting the sampling method
• Selecting and developing the analytical method

Appendix B-Cleaning Validation 125
Cleaning Validation
page 3 of 5
Selecting the worst-case equipment

• Equipment grouping which is based on the following criteria:
• Identical, interchangeable pieces of equipment with the same cleaning procedure.
• Equipment with the same operating principles and the same cleaning proce-
dure, but with different product contact surface area.
• The worst case is represented by the equipment with the larger surface area. The
products matrix that should be considered is the matrix, which includes all the
products manufactured in all the pieces of equipment in the group.
• The cleaning validation studies should take into account the hard-to-clean loca-
tions in each selected piece of equipment, in addition to the main parts of the
equipment.
• Cleaning validation on dedicated equipment includes studies on residual clean-

ing agents only. This also includes dedicated fluid bed dryer filter bags.
Selecting the worst-case product

A database containing product characteristics and manufacturing parameters such as:
product name, active ingredient, dose weight, batch size, solubility, LTD, and daily dose
should be created for each equipment group. The worst-case product is selected from
this database based on the lowest solubility of the active ingredient in water (if the clean-
ing procedure is water based), or in the relevant cleaning solvent.
Calculating the contamination acceptance limits for the active ingredient and for
the cleaning agent:
• Contamination limit for the active ingredient

The maximum allowable amount of contaminant (MC) in mg per swab, for a
specific piece of equipment is calculated by selecting the worst-case values for
parameters listed for the products in the matrix.
Cleaning Validation
page 4 of 5
LTD/1 000 Wb Ss
MC(mg/swab) = x-x-x R Equation 1
D Wt Se
LTD Lowest therapeutic dose (mg)
D Highest maximal daily dose (dose units)
Wb Smallest batch size (g)
Wt Highest unit dose weight (g)
Ss Swab area (cm 2 )
Se Equipment product contact surface area (cm 2 )
R Recovery factor of active ingredient with lowest solubility (%)
• Contamination limit for the cleaning agent:
LDS0/1000 Wb Ss
MC(mg/swab) = x-x-xR Equation 2
D Wt Se
LD50 = Lethal dose of 50% of animal population (mg/kg)
The sampling method

The cleaning validation studies are based on the swabbing technique. The selected
swabs should be characterized for their suitability and a recovery test should be per-
formed prior to the validation studies. The validation studies include swabbing of the
main surface area as well as the hard-to-clean locations. Swabbing is carried out for the
active ingredient and the cleaning agent.
The testing method

Validated selective and sensitive analytical methods should be used to determine
the active ingredient and cleaning agent residues.
Acceptance criteria
a. The equipment should be inspected and found to be visually clean.
b. The maximum allowable amount of active ingredient contaminant in a piece of

equipment cleaned with the cleaning procedure should be not more than the limit
calculated in equation 1.
Cleaning Validation
page 5 of 5
c. The maximum allowable amount of cleaning agent residue should be not more than
the limit calculated in equation 2.
d. For maximum allowable amount of active ingredient and/or cleaning agent which
can be visually inspected, a lower limit should be set so that at the new limit no
contaminant can be observed.
Corrective action
In case of failure to demonstrate values as calculated for the contaminant limits, an
investigation into the cause of failure should be conducted. Considerations such as
improving the cleaning procedure and revalidation should be considered.
Standard Operating Procedure
CLEANING VALIDATION
The Rx Pharmaceutical Company STANDARD OPERATING PROCEDURE
Cleaning Validation
page 1 of 5
Purpose
The objective of cleaning validation is to attain documented evidence which provides
a high degree of assurance that the cleaning procedure can effectively remove residues
of a product and of the cleaning agent from the manufacturing equipment to a level
that does not raise patient safety concerns.
Responsibility
Validation unit
• Prepare validation master plan, working plan, and protocol
• Calculate the contamination limit for the active ingredient and the cleaning agent
• Conduct validation study including sampling
• Prepare validation report
• Approve validation study
Production
• Approve validation master plan, working plan, and protocol
• Verify accuracy of the cleaning procedure
• Identify the equipment hard-to-clean locations
• Perform cleaning
• Approve validation study
Production planning
• Provide all information to build database
Cleaning Validation
page 2 of 5
Engineering
• Verify accuracy of drawings and calculate product contact area
• Assist in the identification of equipment hard-to-clean locations
Quality assurance
• Approve validation master plan, working plan, and working protocol
• Approve the validation study
R&D analytical development

• Develop and validate the analytical method
Quality control
• Perform the recovery study
• Test samples and prepare analytical report
Frequency
• The cleaning validation is performed on each piece of equipment which was
selected as representative of its group according to the equipment list
• The cleaning validation studies are conducted after three consecutive major
cleanings of the selected product
• Maintenance of validation and monitoring are performed as described in the

"Cleaning Validation-Policy"
Procedure
The equipment list should include all the equipment which is used in the manufactur-
ing plant. The equipment should be listed according to the technology and grouped
according to the principles listed in the "Cleaning Validation Policy".
Cleaning Validation
page 3 of 5
The validation unit prepares the specific equipment cleaning validation protocol
for the relevant equipment group including:
a. Review and attach the equipment list
b. Review and attach of the cleaning procedure of the equipment
c. Attach the equipment diagram prepared by the engineering department. List the
parts of the selected equipment.
d. Attach the drawings of the parts of the equipment and the calculated surface area
of the parts as prepared by the engineering department, including:
• Sampling locations, including the hard-to-clean locations
• Swabbing area for the active ingredient
• Swabbing area for the cleaning agent

• Swab type used for sampling of the active ingredient
• Swab type used for sampling of the cleaning agent
The validation unit reviews the product list and makes sure that it is updated and
contains all the following parameters for all the products manufactured on the pieces
of equipment included in the relevant equipment group.
a. The parameters in the list include:
• Product name
• Active ingredient in the product
• Solubility of the active ingredient in water (mg/mL)
• Lowest therapeutic dose (LTD) (mg)
• Batch size (g)

• Dose weight (g)
• Daily dose (maximum units/day)

Cleaning Validation
page 4 of 5
b. The worst-case product due to the lowest solubility of its active ingredient in water
is selected from the product matrix.
c. The cleaning agent used in the cleaning procedure is listed.
The validation unit attaches the following documents to the specific protocol:
a. The analytical method for quantitative determination of the active ingredient.
b. The analytical method validation report of the quantitative determination of the

active ingredient.
c. The analytical method for quantitative determination of the cleaning agent.
d. The analytical method validation report for the quantitative determination of the
cleaning agent.
e. The sampling recovery study report performed according to the working instruc-
tions. Record the sampling recovery yield in the specific protocol.
f. The swab characterization study according to the working instructions.
The validation unit calculates the maximum allowable amount of active ingredi-
ent and cleaning agent (MC) in mg per swab, for the piece of equipment according to
the following equation:
LTD/ 1000 Wb Ss
MC(mg/swab) = X - x -x R
D Wt Se
where the parameters are selected from the product matrix as follows:
a. The lowest LTD for the active ingredient or LD50 for the cleaning agent
b. The highest maximal daily dose (D)
c. The smallest batch size ( Wb)
d. The highest unit dose weight (Wt)

Cleaning Validation
page 5 of 5
The equipment cleaning validation specific protocol is prepared and signed by the
validation unit. It is then approved by the production manager and the quality assur-
ance manager.
After production of the virtual worst-case product in the worst-case piece of
equipment selected from the group equipment, major cleaning of the equipment is exe-
cuted by the production worker using the cleaning procedure. The cleaning is approved
by the supervisor as stated in the cleaning procedure. When the equipment is approved
as clean, the validation unit will inspect the equipment for visual cleanliness, includ-
ing all components of the equipment as listed in the protocol-"Visual Inspection and
Sampling". The visual inspection is documented on this form.
The listed parts are sampled both for the active ingredient and the cleaning agent-
from different locations-as described in the working instructions. The sampling is doc-
umented in the "Visual Inspection and Sampling" form.
Any deviations or unusual events are documented under "Remarks".
All the samples are transferred immediately after sampling to the analytical labo-
ratory for analysis.
This procedure is repeated after two additional and consecutive major cleanings
of the same piece of equipment after manufacturing the worst-case product.
The analytical laboratory tests the samples using the relevant analytical method
to determine the residual amounts of the active ingredient and of the cleaning agent
per swab.
The validation coordinator summarizes all results in a cleaning validation report.
Documentation
Cleaning validation protocol and report.
Standard Operating Procedure
CLEANING VALIDATION-CHANGE CONTROL

Supersedes: Cleaning Validation- Production:

Change Control
page 1 of 1
Purpose
The purpose of this document is to define a procedure which ensures that all the
changes which might affect equipment cleaning are reviewed and evaluated in relation
to equipment cleaning validation.
Responsibility
Manufacturing and engineering departments are responsible for informing the valida-
tion unit of any changes related to equipment cleaning validation.
The validation unit is responsible for filling out the Change Control Form, change
the database and recalculate the MC limits when required, and to evaluate the effect
of the change on the status of the equipment cleaning validation for each relevant
equipment.
Quality Assurance is responsible for approving the changes in the databases and
the decisions related to revalidation.
Frequency
When a change is made.
Procedure
Changes in products, equipment, cleaning procedures, or cleaning validation methods
may affect the status of the equipment cleaning validation. On any change related to
these subjects, as listed in the "Decision Tree" (Attachment I), production and engi-
neering departments should inform the validation unit.
The validation unit reports the change and categorizes it according to the list
detailed in the "Decision Tree" on the "Cleaning Validation-Change Control Form"
(Attachment II). The validation unit also details the change.
According tothe change, the relevant databases are updated as detailed in the "Deci-
sion Tree" and the "Cleaning Validation-Change Control Form". If the equipment
and/or product grouping are changed due to the change, a new grouping should be per-
formed by the validation unit. If the parameters in the contamination limit calculation
equation are changed, the MC values should be recalculated.
The validation unit has to evaluate, according to the "Decision Tree," the effect of
the change on the status of the equipment cleaning validation and justify the activities
that should be taken, such as revalidation. This decision has to be reported on the
"Cleaning Validation-Change Control Form". The form has to be signed and dated
and sent to Quality Assurance.
Quality Assurance should evaluate the decision which was suggested and sign and
date the form. Only then the activities which have to be done can be initiated.
Documentation
"Cleaning Validation-Change Control Form". Attachment II.
ATTACHMENT I
Decision Tree
A 1--1 B 1-- C
Categorize the Change Change the Databases Evaluate the effect on
the validation
1. Check if worst case

1. Products
product changed
. Product list
a Introduction of new product
b Deletion of a product . Product grouping t

yes no
t
c Change in existing product
+
revalidation
+
(follow 2)
2. Equipment
2. MC changed
a Introduction of new equipment . Equipment list I I
yes no
b Change to another equipment . Equipment grouping
c Change in the equipment (surface + +
Evaluate if the No further
area, hard-to-clean location)
equipment is activities
still validated
3. Cleaning Procedure
a Addition of a step
b Deletion of a step
c Change in the cleaning parameters

Evaluate and Justify:
d Change in the cleaning agent
Minor _ _ __ no revalidation
Major _ _ __ revalidation
4. Cleaning Validation Methods
a Change in sampling method
b Change in testing method
c Other
ATTACHMENT II
Change Control No.: _ _ _ _ __
Cleaning Validation-Change Control Form
A. Report Change and Categorize
Change
0 1. Product Name: _ _ _ _ _ _ _ _ _ _ _ _ _ Catalog No.: _ _ _ __
0 0 0 0
New Deletion Change in existing product Other
0 2. Equipment Name: _ _ _ _ _ _ _ _ _ _ _ _ Inventory No.:

0 0 0 0
New Deletion Change in existing equipment Other
0 3. Cleaning Procedure:------------ No.: _ _ _ _ _ _ _ __

0 0 0 0 0
New step Deletion of step Parameter: Cleaning agent Other
0 4. Cleaning Validation Method

0 0 0
Sampling Testing Other
Detail the c h a n g e s : - - - - - - - - - - - - - - - - - - - - - - - - -
Signature Date
B. Change the Databases
0 l. The following database is changed:

0 0 0
Product list Active ingredient list Cleaning agent
0 0 0
Equipment list Equipment surface area Cleaning procedure

0 2. The following grouping is changed:

0 0
Product grouping Equipment grouping
0 3. The new MC values: 0 active

0 cleaning agent
C. Evaluation of Change and Decision
Validation unit Quality Assurance

Signature/ date Signature/ date
Work Instructions-Swab
SAMPLING FOR CLEANING VALIDATION

The Rx Pharmaceutical Company WORK INSTRUCTIONS
Supersedes: Swab Sampling for Production:

Cleaning Validation
page l of 2
Safety
Wear powder-free gloves and goggles.
Equipment and Materials

• Swab: Use approved swabs, such as Texwipe or Whatman paper.
• Solvent: For the active ingredient, use the solvent prescribed in the specific clean-
ing validation protocol. For the cleaning agent, use purified water USP/EP.
• Sampling frame: For flat surfaces, use a 5 em X 5 em stainless steel frame with
a handle.
• Pincers
• Glass Erlenmeyer flasks
Procedure
Note: Extreme care should be taken to prevent swab contamination
during handling.
Active ingredients:
l. Using clean pincers, soak the swab in the solvent and hold it until dripping stops.
2. Rub the saturated swab manually over the sample surface area designated in the
equipment diagram appearing in the specific cleaning validation protocol. For flat
surfaces, use the stainless steel frame. For smaller surfaces and hard-to-reach loca-
tions, rub the whole surface.
Swabbing is performed in a controlled fashion by striking the sample surface
area as indicated in the Figure 12.1.
Supersedes: Swab Sampling for Production:

Cleaning Validation
page 2 of 2
3. Transfer the swab into a labeled glass Erlenmeyer flask and seal the flask.
4. Repeat the procedure for each location indicated on the equipment diagram and
record the sampling on the sampling form of the cleaning validation protocol.
5. Submit samples for analysis.
6. Cleaning agents: Proceed as indicated for the active ingredient using purified
water USP/EP.
Acceptance Criteria
Not applicable.
Documentation
Cleaning validation protocol sampling form.
Figure 12.1. Swab Sampling
f""" .... ...........
t.......... L .......
Work Instructions-Swab
CHARACTERIZATION FOR CLEANING VALIDATION

Supersedes: Swab Characterization for Production:

Cleaning Validation
page 1 of 2
Safety
• Wear powder-free gloves and goggles.
• Use a fume cupboard while working with organic solvents.

• Swabs to be tested.
• Analytical balance equipped with a printing device.
• Analytical instrumentation.
• Mechanical shaker.
• Pincers.
Glass Erlenmeyer flasks.
• Purified water USP/EP.
• Solvent to be used to saturate swab.
• Solvent to be used to extract the swab according to the specific cleaning valida-
tion protocol.
Procedure
Swab absorption capacity

1. Individually weigh 10 unused dry swabs.
2. Soak each swab in the solvent.
3. Using pincers, remove the swab from the solvent, hold it until dripping stops, and
place it immediately on the balance pan.
4. Individually weigh the 10 saturated swabs and calculate the swab solvent absorption
capacity.
5. Repeat the same procedure using purified water instead of the solvent and calculate
the swab water absorption capacity.
Supersedes: Swab Characterization for Production:

Cleaning Validation
page 2 of 2
Swab interference
1. Place one unused dry swab in Erlenmeyer flasks, each containing one of the following
solvents:
• Purified water USP/EP
• Swab saturating solvent
• Swab extracting solvent to be used in the analytical test method
2. Shake for 10 minutes at 150 strokes/minute.

3. Repeat the procedure with 4 additional swabs for each solvent.
4. Test the extraction solvent by the analytical methods to be used to determine the
active ingredient and the cleaning agent, respectively, and calculate the swab inter-
ference response, to be taken into account in the analytical determination.
Acceptance criteria
The swab suitability is based on the following considerations:
• No change in swab appearance and color.

• Swab durability without signs of disintegration, fibers, or sediments.
• Swab solvents and water absorption capacity is not less than the volume of sol-
vent or water needed to dissolve the calculated amount of residual active ingre-
dient and cleaning agent, respectively.
Documentation
Swab Characterization Report, to be attached to the cleaning validation protocol.
Work Instructions-Sampling
RECOVERY TEST
Sampling Recovery Test
page 1 of 3
Safety
o Wear powder-free gloves and goggles.
o Use a fume cupboard while working with organic solvents.
Equipment
Stainless steel surface 10 em X 10 em or coupon made of the same material as
the equipment construction material which should be sampled
o Swab used as the sampled location in the equipment: Name _ _ _ _ _ __
o Swab used for cleaning agents sampling: Name _ _ _ _ _ __
o Suitable glass Erlenmeyer flasks.
o Powder-free gloves
o Clean pincers
Materials
o Extracting solvent for active material sampling:
Choose the appropriate solvent taking into consideration the solubility of the con-
taminant active ingredient(s) in it. The toxicity of the solvent should also be
considered. The most useful solvent is ethanol:
o Purified water USP/EP for cleaning agents sampling.
o Active ingredient(s) of the product to be validated for cleaning.
o Cleaning agents used for the relevant cleaning procedure.

page 2 of 3
Procedure
The aim of this test is to determine the reliability of the sampling method, and to take
into account loss due to sampling limitation.
This test is to be performed for the predetermined active ingredient(s) and clean-
ing agent(s) in accordance with the specific protocol for the equipment.
Method for Active Materials

1. Using the appropriate solvent, prepare a stock solution/dispersion calculated to yield
the approximate amount of the active material as calculated for the maximal allow-
able contamination level (but not more than X 3 of the calculated value) per 0.5 mL.
2. Apply a measured amount of the stock dispersion/solution to the test surface

(10 X 10 em) and dry it in an oven (37°C).
3. Allow the sample to cool to room temperature.
4. Wear gloves and take at least 2 swab samples (using new gloves and a different swab
wetted with the extracting solvent) from the test surface.
5. Transfer each swab into a suitable labeled glass Erlenmeyer flask and protect it from
external contamination. The sampling must be completed as quickly as possible to
prevent solvent evaporation and contaminant redeposition on the sampled surface.
6. Submit the labeled sealed glass Erlenmeyer flask to the analytical laboratory imme-
diately along with the blank sample (one swab wetted with the extracting solvent)
and the appropriate analytical request form.
7. The sampling recovery value is the ratio between the measured values and the
expected values.
Method for cleaning agents

This test will be performed for the cleaning agents being used in the equipment clean-
ing procedures.
1. List all cleaning agents used to clean the equipment.

page 3 of 3
2. Using purified water USP/EP, prepare a stock solution calculated to yield the approx-
imate amount of cleaning agent as calculated for the maximal allowable contami-
nation level (but not more than X 3 of the calculated value).
3. Apply a measured amount of the stock solution to the test surface (1 0 x 10 em) and
dry it in an oven (37°C).
4. Wear gloves and take at least two swab samples (using new gloves and different swab
wetted with purified water USP/EP) from the test frame.
5. Apply each wipe into a suitable labeled glass Erlenmeyer flask.
6. Submit the labeled sealed glass Erlenmeyer flask to the analytical laboratory along
with the blank sample (one swab wetted with purified water USP/EP) and the appro-
priate analytical request form.
7. The sampling recovery value will be the ratio between the measured values and the
expected values.
Acceptance Criteria
o The overall sampling yield value of swabs should be not less than 70o/o.
o In cases where low results are obtained in a reproducible manner, the sample sur-
face area may be sampled again using a second swab and the results obtained from
both swabs summed up.
Documentation
o Request for Laboratory Control
o Sampling Recovery Study Report to be attached to the cleaning validation

protocol.
Protocol and Report
CLEANING VALIDATION
The Rx Pharmaceutical Company

Supersedes: Cleaning Validation Production:

Protocol & Report
page 1 of 13
Equipment Group No.
Equipment
Inventory No.
Equipment Name
Contents:
• Approval Sheet
• Protocol/Report
• Attachments
Reference: Cleaning Validation Master Plan, Edition no. , dated
Date: _ _ _ _ __
APPROVAL SHEET


Protocol & Report
page 2 of 13
This study has been performed according the cleaning validation protocol by:
Name Signature Date
and has been reviewed and approved by:
Name Signature Date

Validation unit
Name Signature Date

Production
Name Signature Date

Quality assurance
PROTOCOL


Protocol & Report
page 3 of 13
Purpose
The purpose of this cleaning validation protocol is to demonstrate that the cleaning pro-
cedure used to clean Equipment no. X, selected as the worst-case equipment of Group
no. Y, can effectively remove residues of the products manufactured in Equipment X
and of the cleaning agent K used to clean Equipment X, to a predetermined level that
does not raise patient safety concerns.
Responsibility
Validation unit:
Prepare the cleaning validation protocol
• Conduct the validation study, including sampling
• Prepare and approve the cleaning validation report
Production:
• Approve the cleaning validation protocol
Perform cleaning
• Approve the cleaning validation report
Quality assurance:
Approve the cleaning validation protocol
• Approve the cleaning validation report



Protocol & Report
page 4 of 13
Frequency
The cleaning validation study is performed after three consecutive major cleanings of
Equipment X after the manufacture of Product A which contains the most insoluble
of the active ingredients of the group of products manufactured in Equipment X.
Procedure
Follow the instructions of SOP No. _ _ Cleaning Validation. Prepare, review, and
attach the following documents:
1. Equipment:
• Equipment database 0
• Equipment drawings and sampling locations 0
2. Product and cleaning agent databases 0
3. Calculation of the contamination limits 0
4. Visual inspection and sampling 0
5. Analytical results 0
6. Analytical studies 0
7. Conclusion 0
Contamination limits
Documentation
The cleaning validation report consists of the filled-in cleaning validation protocol and
attachments.


Protocol & Report
page 5 of 13
EQUIPMENT DATABASE
List of Equipment:
Group Equipment Equipment Operating Product Contact Hard-to-Clean

No. No. Name Principle Surface Area Locations
Selected Equipment Group and Worst-Case Equipment:
Cleaning Procedure:
No. Edition no. _ _ _ Verified by _____ Date _ _ _ __
Signature _ _ _ _ _ _ _ _ _ _ __ Date _ _ _ _ _ _ _ __


Protocol & Report
page 6 of 13
EQUIPMENT DRAWING AND SAMPLING LOCATIONS
Equipment Part Drawings
1.
2.
3.


Protocol & Report
page 7 of 13
EQUIPMENT PART DRAWING (CONTINUED)
4.
5.
Sampling Locations and Swab Sampling Areas

Active Ingredient Cleaning Agent
Part Name Part Surface Sampling Swab Area Sampling Swab Area
Area (cm 2 ) Location Ss (cm 2) Location Ss (cm 2 )
1
--- ------- ------------· -· r-- --- - --------~-- ------- ·-·--· -- --- ---- ··-
Signature _ _ _ _ _ _ _ _ _ _ __ Date _ _ _ _ _ _ _ _ __


Protocol & Report
page 8 of 13
PRODUCT AND CLEANING AGENT DATABASE
List of Products
Group Equipment Equipment Product Active Solubility LTD Daily Unit Batch
No. No. Name Name Ingredient In water (mg) Dose Dose Size
(mglml) D (units/day) Weight Wb(g)
Wt(g)
List of Cleaning Agents
Group Equipment Equipment Cleaning Active Solubility LTD Virtual Virtual Virtual
No. No. Name Agent Ingredient In water (mg) Product Product Product
(mglml) Daily Unit Batch
Dose Weight Size
D Wt Wb
(units/day) (g) (g)
Selected Worst Case Product:
Selected Worst Case Cleaning Agent:
Signature _______________
Date------------


Protocol & Report
page 9 of 13
CALCULATION OF THE CONTAMINATION LIMIT
Active Ingredient
LTD/ 1000 Wb Ss
MC (mg/swab) = x - x -x R
D Wt Se
MC (mg/swab) = _ _ _ __
(active)
Cleaning Agent
LD50/l 000 Wb Ss
MC (mg/swab) = x - x -x R
D Wt Se
MC(mg/swab) = - - - - - -
(cleaning agent)
Signature----------- Date _ _ _ _ _ _ _ __


Protocol & Report
page 10 of 13
VISUAL INSPECTION AND SAMPLING
Product Name: ___________________________________________________

Batch No.: ______________________________________________________
Part Name Visual Inspection Sampled for

Clean Unclean Active Ingredient Cleaning Agent
l. 0 0 0 0
2. 0 0 0 0
3. 0 0 0 0
4. 0 0 0 0
5. 0 0 0 0
Remarks: _______________________________________________________
Signature: --------------------- Date: _____________
Product Name: ___________________________________________________

Batch No.: -----------------------------------------------------
l. 0 0 0 0
2. 0 0 0 0
3. 0 0 0 0
4. 0 0 0 0
5. 0 0 0 0
Remarks:
Signature: --------------------- Date: _____________

Product Name: ____________________________________________

Batch No.: ----------------------------------------------
1. 0 0 0 0
2. 0 0 0 0
3. 0 0 0 0
4. 0 0 0 0
5. 0 0 0 0
Remarks: ------------------------------------------------------
Signature: -------------------- Date: _______


Protocol & Report
page 11 of 13
ANALYTICAL RESULTS
Product Name: Batch No.

Equipment Active Pass Fail Cleaning Pass Fail
Part Ingredient Agent
(mg/swab) (mg/swab)
1 0 0 0 0
2 0 0 0 0
3 0 0 0 0
4 0 0 0 0
5 0 0 0 0

(mg/swab) (mg/swab)
1 0 0 0 0
·-
I
2 0 0 0 0
3 0 0 0 0
4 0 0 0 0
5 0 0 0 0
Contmued on next page

(mg/swab) (mg/swab)
1 0 0 0 0
2 0 0 0 0
3 0 0 0 0
4 0 0 0 0
5 0 0 0 0
Signature _ _ _ _ _ _ _ _ _ _ __ Date _ _ _ _ _ _ _ _ __


Protocol & Report
page 12 of 13
ANALYTICAL STUDIES
Attach the following documents:
IAnalytical Report No. - - - - - - - - Date _ _ __
Analytical Method
Active ingredient Cleaning agent

Analytical Method No.
Edition No.
Method Validation
Edition No.
Detection Limit (DL)
Quantitation Limit (QL)
Recovery study
o/o Recovery o/o Recovery

Active Ingredient Cleaning Agent
Recovery Study
No.
Date
Swab Characterization Study
IStudy Report No. jnate
Dme _ _ _ _ _ _ _ _ __
Signature-----------


Protocol & Report
page 13 of 13
CONCLUSION
The results obtained do not exceed the calculated contamination limit. The cleaning
procedure of all pieces of equipment in Equipment Group no. X effectively removes
residues of all the products manufactured in this equipment and is therefore deemed
validated.
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Index
absolute limit, 46 automated cleaning, 28, 29

acceptable daily intake (ADI), 44, 45
acceptance criteria, 9, 84, 126, 152, 157, 164 batch size, 86, 125, 133, 134
acceptance limits, 57-64, 124 bioavailability, 46
acidic solvents, 31 bioburden, 4, 89
acidic/alkaline materials, 24 biocontamination, 4, 89-90
active pharmaceutical ingredients (API), 11, biotechnological products, 36
18,24,36,44, 78,89,91 blanket specification, 46
industry, 52
manufacturing, 27 change control, 87
process, 17 chemical contamination, 3-4
acute inhalation, 45 chemical reaction, 15, 16
Agalloco, J., 40 Cholestyramine Resin USP, 7
air flow patterns, 4 chromatographic methods, 54, 55
alkaline agents, 25 dean-in-place (CIP) system, 10, 11, 13, 21,
Allan, W., 91 23,27,29,30,31, 85,94
analytical detection method, 49, 50 methods, 23
analytical method, 8, 10, 11, 46, 53-56, 95, procedures, 32
124, 134 process, 40
implementation, 56 sequence, 29
survey, 54 cleaning agents, 3, 24, 26, 57, 78, 94
validation, 55 cleaning mechanisms, 15-16
appropriate design, 7 cleaning procedure, 21-32, 94, 105
approved pharmaceutical dosage forms, 44 cleaning process, 3
183
cleaning tools, 25 European Union, 7

cleaning validation Good Manufacturing Practice (GMP), 11
maintenance, 85-87 execution, 65-84, 80
methods, 87 extraction solvents, 51
objective, 36
policy, 35-56, 123-176 facilities, 4
procedures, 97-118, 123-176 FDA, 7, 10, 11, 12, 27, 43, 60, 62, 90
protocol, 80, 83 FDA Cleaning Validation Mid Atlantic Region
protocal and report, 159-175 Inspection Guide, 9
report, 84 FDA Good Manufacturing Practice (GMP)
trends, 93-96 regulations, 3, 91
Code of Federal Regulations (CFR), 11 FDA Guidance for Industry, Manufacturing,
colony forming units (CFU), 90 Processing or Holding of Active
contamination acceptance limit, Pharmaceutical Ingredients, 35
calculation, 78, 80 FDA Guide to Inspection of Bulk Pharma-
contamination control, 3-6, 93 ceutical Chemicals, 8
contamination limit, 40-48, 53 FDA Guide to Inspections of Validation of
dose-related, 45 Cleaning Processes, 35
contamination types, 3-4 FDA Human Clinical Good Manufacturing
contract manufacturing and packaging, 91 Practice (CGMP) Note, 91
Control Procedures in Drug Production, 8 FDA Valid Documentation Inspection Guide,
cross contamination, 3, 13, 23, 25, 29 9
Food Drug & Cosmetic Act, 15
database, 68, 165, 168 Forsyth, R. J., 47
equipment, 80 Fourier Transform Infra Red (FTIR), 50
product, 80 Fourman, G. L., 47
decision tree, 139, 140, 141
dedicated equipment, 17, 35 "The Gold Sheet", 12
Deeks, T., 91 Good Manufacturing Practice (GMP), 8, 11
detergency, 15, 24 concerns, 21, 22
dispersants, 16 regulations, 7, 12, 15, 103
dissolution, 15 gowning, 6
documentation, 30, 31, 106, 135, 148, 152, Guide to Inspections of Validation of Clean-
157, 164 ing Processes, 9
dose weight, 133
"DRUG GMP Report", 12 Hakimipour, F., 91
duration of exposure, 45 hard-to-clean locations, 21, 22, 23, 32, 39, 40,
41,4~57,61, 62, 74,94,125
emulsifiers, 16 Haynes, D. V., 47

engineering, 65, 66, 87, 123, 132 highest maximal daily dose, 61, 74
environmental monitoring program, 4 highest unit dose weight, 60, 61, 74
equipment, 5, 94 hydrolysis, 16
equipment design, 21-22 hypochlorite, 31
equipment grouping, 39, 68, 80
equipment labelling, 106 ICH guidelines, 55
equipment logs, 7 insoluble, 40
equipment product contact surface area, 61
equipment storage, 106 lethal dose (LD50), 44, 45, 47, 61, 78
equipment train, 62 level of cleaning, 16, 104
Index 185
line clearance, 6 piping and instrumentation diagrams

lowest therapeutic dose (LTD), 45, 57, 59, 61, (P&ID), 50
74, 86, 125, 133 placebo method, 52
planning, 65-84
major cleaning, 16, 17, 32, 104 policy, 101-110
manual cleaning, 27 Principles of Qualification and Validation in
manufacturing process, 22 Pharmaceutical Manufacture, 11
Martindale-The Extra Pharmacopoeia, 59 "Procedures for detecting and Measuring
material and waste flow, 6 Penicillin Contamination in Drugs",
materials and tools, 24 91
control, 25 product grouping, 38, 74, 80
maximum allowable amount of contaminant production planning, 65, 66, 131
(MC), 125 production, 65, 66, 87, 103, 123, 131, 163
maximum contamination level, 47, 48
maximum daily dose, 57, 60, 86, 134 quality assurance, 65, 66, 87, 103, 123, 132,
mechanical action, 15 163
method for active materials, 156 quality control, 56, 65, 67, 123, 132
method for cleaning agents, 156
microbial contamination, 18, 19 R&D, 65, 67, 87, 103, 123, 132
microbiological contamination, 3, 4, 17, 18, recovery factor of active ingredient, 61
89 regulatory authorities, 43, 53
minor cleaning, 16, 17, 18, 32, 104 regulatory issues, 95
monitoring, 19, 85, 96, 106, 124 regulatory requirements, 7-12
Mullen, M. V., 47 relative humidity, 4
multipurpose equipment, 35 Rhodehame, H., 8
rinse sample method, 51, 90
neurotoxicity, 45 Rote Liste, 59
no-observed-effect level (NOEL), 44, 45 route of exposure, 45
nonpharmaceuticals, 91
safety factors, 43, 53, 155
Occupational and Safety Health Organization sample surface area, 51
(OSHA), 44 sampling and testing, 84
operator training, 23 sampling locations, 50
organic solvents, 24 sampling method, 10, 48-53, 57, 124, 126
organization, 65-67 sampling recovery test, 153-157
oxidation, 16 sampling technique, 95, 170
oxidative agents, 31 direct method, 10
rinse solutions, 10
penicillin contamination, 43, 90-91 single limits, 46
personnel, 6, 93 smallest batch size, 60, 61, 74
pharmaceutical dosage form process, 17 sodium hypochlorite, 16
Pharmaceutical Inspection Convention solid oral dosage forms, 23, 74
(PIC), 11 solubilizers, 16
Pharmaceutical Inspection Convention, Phar- soluble dye, 40
maceutical Inspection Co-operative solvents, 24, 26
Scheme (PIC-PIC/S), 11 specific ion meter, 54
pharmacological limit, 46 spectrophotometric methods, 54
physical contamination, 3, 4 standard operating procedure, 129-144
Physician's Desk Reference, 59 subchronic toxicity, 45
surface sampling, 90 unit dose weight, 86, 134

swab absorption capacity, 49 USA vs. Barr, 8, 9
swab area, 61
swab characterization, 49, 134, 149-192 validation, 10, 11, 12, 13, 16, 123
swab interference, 49 maintenance, 124
swab recovery, 50 master plan, 78
swab sampling, 95, 145-48 policy, 80
swab saturation, 51 unit, 66, 131, 163
swabbing method, 48 Vidal, 59
swabbing technique, 51 virtual worst case product, 74, 78
visibly clean, 8
temperature, 4 visual inspection, 30, 32, 47, 106, 116, 170
teratology, 45
testing method, 126 warning letters citations, 13
thin layer chromatography (TLC), 54 water quality, 26
time limitations, 17-19, 104 water soluble, 40
"Tolerances for Pesticides in Food Adminis- Webster's New World Dictionary, 28
tered by the Environmental Protec- wetting agents, 16
tion Agency", 46 working plan, 80
tools, 26 World Health Organization (WHO), 7
total organic carbon (TOC), 50, 55, 96 GMP, 12,25
toxicological data, 44 worst case equipment, 39-40, 70, 80, 124, 125
training, 6 worst case product, 37-38, 60, 74, 80, 124,
125, 134, 135
ultraviolet (UV) light, 40 written procedure, 7

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CLEANING

No claim to original U.S. Government works

International Standard Book Number-13: 978-1-4200-2603-0 (eBook - PDF)

3. CLEANING BASIC CONCEPTS 15

5. CLEANING VALIDATION POLICY 35

Selecting the Worst Case Related to the Product 37

Selecting the Scientific Basis for the Contamination Limit 40

Selecting the Sampling Method 48

Selecting the Analytical Method 53

6. CONTAMINATION ACCEPTANCE LIMITS 57

Lowest Therapeutic Dose (LTD) 59

7. CLEANING VALIDATION PLANNING AND EXECUTION 65

Cleaning Validation Master Plan 78

Cleaning Validation Protocol 83

8. CLEANING VALIDATION MONITORING AND MAINTENANCE 85

9. SPECIAL CLEANING VALIDATION ISSUES 89

10. CLEANING VALIDATION TRENDS 93

Policy-Equipment and Processing Area Cleaning 101

Cleaning Procedure-High Shear Mixer (Diosna) ll1

APPENDIX B-CLEANING VALIDATION ll9

Policy-Cleaning Validation 121

Standard Operating Procedure-Cleaning Validation 129

Standard Operating Procedure-Cleaning Validation-

Work Instructions-Swab Sampling for Cleaning Validation 145

Work Instructions-Swab Characterization for Cleaning

Cleaning Validation Protocol and Report 159

Drug contamination types may be classified in three categories: chemical contamina-

Figure 1.1. Contamination Control

Material and Waste Flows

a. Written cleaning procedures should be established. Attention should

b. Procedures on how validation will be performed should be in place.

c. Who is responsible for performing and approving the study.

d. Acceptance criteria should be set.

e. Procedures dealing with the subject of when revalidation is required,

f. Validation protocols should be prepared before each validation study

g. Study should be conducted according to the protocol.

h. Approved report should state the validity of the cleaning process.

• While cleaning validation is intended for procedures for product con-

• The term "bracketing" is mentioned here for validation. "It is consid-

• At least three consecutive applications of the cleaning procedure should

• The difference in raw materials sources and characteristics should be

• Revalidation in cases of changes in equipment, product, or process, and

• Analytical methods used for cleaning validation must be validated.

The trend in harmonizing regulations internationally can be clearly seen in two

Table 2.1. Cleaning and Cleaning Validation Warning Letters Citations,

1. Equipment cleaning procedures

2. Adherence to cleaning SOP

4. Cleaning of equipment at appropriate intervals

7. Cleaning of packaging rooms and equipment

8. Cleaning of repackaging equipment

10. Aseptic area/equipment cleaning and disinfecting

11. Cleaning logs

12. Contamination prevention

13. Controls to prevent product mix-ups and cross contamination

14. Validation of sterilization-in-place or clean-in-place processes

15. Cleaning validation

16. Cleaning validation for dedicated equipment