Introductionto ASTME3418
Introductionto ASTME3418
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cleaning processes. This is the first comprehensive guide to setting limits for use in
cleaning validation that includes all types of chemical residues, bioburden residues,
endotoxin residues, and visual residues with example calculations for swab and rinse
sample limits for pharmaceutical and medical devices applications. This new standard
now joins the four previously published standard guides that have been developed by
the ASTM E55 Cleaning Team to support the ASTM E3106 Standard Guide1 along with
several others that are currently in development or planned (see Figure 1). This ASTM
Work Item was balloted, and approved by, the ASTM E55 Pharmaceutical Standards
Committee and is now available on the ASTM website. It should be noted that this is the
first such standard published in more than 10 years and provides a comprehensive view
of all the possible situations arising in the field of measuring cleaning process efficiency.
The authors assert that the ASTM E3418 supersedes all currently available industry
guidance on this subject.
Pharmaceutical Discussion
The origins of the calculation of cleaning validation limits for pharmaceuticals date back
to the 1980s with the publication of an article in 1984 that stated that "limits must be
safe and acceptable and in line with residual limits set for various substances in
foods.”4 A second article in 1989 expanded upon these ideas, adding that an "effect
threshold" should be established in collaboration with toxicology and medical
authorities (or, alternatively, an appropriate safety factor, e.g., 10X or 100X, could be
superimposed) and finally that limits for surface residue levels could then be calculated
based on a smallest batch size/maximum dose combination. This article further
mentioned that this calculation leads to many limits that could be verified through
visual inspection.5 A third article in 1993 proposed the use of a combination of limits,
suggesting that carryover of product residues needed to meet these three criteria:
• No more than 0.001 dose of any product will appear in the maximum daily dose
of another product.
• No more than 10 ppm of a product will appear in another product.
• No quantity of residue will be visible on the equipment after cleaning procedures
are performed.6
Many companies, but not all, adopted this approach wholly or in part. Some companies
even opted to alter this approach and use 0.01 dose or 100 ppm based on early
recommendations in the PDA Technical Report 29 initially published in 1998.
Also in July of 1993, the FDA issued a guide for its inspectors that mentioned these
three criteria; it is important to understand that FDA does not endorse or impose these
limits but simply stated that they “have been mentioned by industry representatives in
the literature or in presentations.” The guide ultimately required that "the basis for any
limits must be scientifically justifiable."7
acceptable daily exposure (ADE).11 The demonstration of adequate cleaning and control
against ADE derived limits could avoid facility or equipment dedication. Several articles
were published discussing why the dose-based and median lethal dose (LD50) should no
longer be used and should be replaced with the limits based on the ADE.12-15
In 2014, EMA issued a guidance requiring the use of health based exposure limits
(HBELs) in calculating cleaning limits.16 This requirement has now been incorporated
into the European and Pharmaceutical Inspection Co-Operation Scheme Good
Manufacturing Practices17, 18 and has been adopted by Health Canada19 China20 and the
World Health Organization.21
For example, cleaning acceptance limits for implantable medical devices have been
based historically on testing after the cleaning process is completed by doing biological
safety assessments that show that the final packaged product is safe and effective.22-
25 Initial cleaning limits might be derived from historical data on the same types of
devices using the same manufacturing processes and materials as a starting point and
coupling that with clinical history that shows the devices produced using this
methodology are safe and effective. Then biological safety testing, which would include
any extractables, is performed on devices exposed to the validated, controlled cleaning
process.
The biological safety testing (which includes extractables) also shows that the limits that
were established for other manufacturing residuals that carry over on the part after
cleaning are at levels low enough to eliminate any local or systemic adverse reaction.
(This may be a toxicological risk assessment of the extractables test data as well as
biological testing.)
While many medical devices use the approach described above, some medical devices
can benefit from using an HBEL approach similar to that used for pharmaceuticals. If an
HBEL approach is used with a medical device, a risk assessment (this could be the
HBEL Monograph developed from ASTM E321926) should address other potential risks
(e.g., patient exposure at the tissue level) from residue levels on the device beyond the
general toxicological risk assessments typically performed for pharmaceuticals.
(Figure 2). The procedures in this standard practice for calculating safe limits of
chemical residues are based on the practices outlined in ASTM E3219.26
Pharmaceutical Residues
This includes active pharmaceutical ingredients (APIs); dosage forms; and over-the-
counter, veterinary, biologics, and clinical supplies. This guide is also applicable to other
health, cosmetics, and consumer products.
Chemical Residues
This standard practice applies to all types of chemical residues, including intermediates,
cleaning agents, processing aids, machining oils/lubricants, etc. that could remain on
manufacturing equipment product contact surfaces or on medical devices that have
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undergone all manufacturing steps, including cleaning. This standard practice does not
cover extractables and leachables (see ISO 10993-18, 2023.)24
Microbiological Residues
This standard practice applies to microbiological and endotoxin residues that may be
present on manufacturing equipment product contact surfaces or on medical devices
that have undergone all manufacturing steps, including cleaning, but does not cover
disinfection, sterilization, or depyrogenation. It is important to separate the cleaning
process from disinfection, sanitization, and sterilization processes, as cleaning comes
before these later operations.
Visual Residues
This standard practice applies to visual residues that may be present after cleaning
pharmaceutical or medical device manufacturing equipment surfaces or medical
devices’ surfaces. ASTM E3418 references and supports the principles described in
ASTM E3263 Standard Practice Guide.27
standard does not recommend calculating a single limit for all cleaning processes, for all
equipment and manufacturing trains, within a facility.
For pharmaceuticals and medical device products that use the HBEL, the equations
used for calculating safe and scientifically justified swab and rinse sample limits are
composed of three sub-equations:
Subsequent sections discuss the various parameters used in the calculation of these sub-
equations, how these parameters should be determined or derived, and how they
interact with each other. The first three sub-equations are generally combined into one
general equation that calculates a safe analytical limit, usually a swab or rinse limit.
The E3418 is a comprehensive guide containing details for each of the following
sections.
Calculating Health Based Exposure Limits – This section contains guidance and
references on the derivation of HBELs using ASTM E321926 and also includes a
discussion on:
Calculation of the Safe Limit in Analytical Samples – This section discusses how
safe swab limits can be calculated from the MSSR and the following parameters.
Calculation of the Rinse Sample Safe Limit – This section discusses how safe
rinse limits can be calculated from the MSSR and the following parameters.
Percent Organic Carbon Content (%C) – This section discusses how the
percentage of organic carbon in a compound is calculated and how to apply it to adjust
either acceptance limits or to adjust swab/rinse data.
Recovery Factors (Swab/Rinse) – This section discusses how the factors from swab
or rinse recovery studies are derived and how to apply them to adjust either acceptance
limits or to adjust swab/rinse data.
Setting Safe Limits for Cleaning Agents – This section discusses approaches for
setting safe limits for cleaning agents and provides an example calculation.
Setting Safe Limits for Organic Solvents - This section discusses approaches for
setting safe limits for organic solvents using ICH Q3C (R5) and provides an example
calculation.
Setting Safe Limits for Bioburden – This section discusses approaches to setting
safe limits for bioburden for the following situations:
Setting Safe Limits for Endotoxin – This section discusses approaches to setting
safe limits for endotoxin.
Setting Safe Limits for Visual Inspection – This section discusses approaches for
setting safe limits for visual inspection following ASTM E326325 and provides an
example calculation using the visual detection index (VDI) method.
Summary
The authors believe that the new ASTM E3418 standard provides the first
comprehensive guide to setting limits for use in cleaning validation for all types of
chemical residues, bioburden residues, endotoxin residues, and visual residues for both
pharmaceutical and medical devices applications and should become the main reference
for any cleaning subject matter expert (SME) involved in the calculation of cleaning
limits.
Peer Review
The authors wish to thank Sarra Boujelben, Gabriela Cruz, Ph.D., Mallory DeGennaro,
Andreas Flueckiger, MD, Ioanna-Maria Gerostathi, Ioana Gheorghiev, MD, and Ajay
Kumar Raghuwanshi for reviewing this article and for providing insightful comments
and helpful suggestions.
References
1. American Society for Testing and Materials E3106-18e1 Standard Guide for
Science Based and Risk Based Cleaning Process Development and
Validation www.astm.org.
2. American Society for Testing and Materials G121-18 Standard Practice for
Preparation of Contaminated Test Coupons for the Evaluation of Cleaning
Agents www.astm.org.
3. American Society for Testing and Materials G122-20 Standard Test Method for
Evaluating the Effectiveness of Cleaning Agents and Processes www.astm.org.
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9. EMA Concept paper dealing with the need for updated GMP guidance concerning
dedicated manufacturing facilities in the manufacture of certain medicinal
products. Doc. Ref. EMEA/152688/04. Feb 2, 2005
12. Walsh, A., “Cleaning Validation for the 21st Century: Acceptance Limits for Active
Pharmaceutical Ingredients (APIs): Part I,” Pharmaceutical Engineering, Vol. 31,
No. 4, July/August 2011, pp. 74–83, available from:
https://ispe.org/pharmaceutical-engineering-magazine.
13. Walsh, A., “Cleaning Validation for the 21st Century: Acceptance Limits for Active
Pharmaceutical Ingredients (APIs): Part II,” Pharmaceutical Engineering, Vol. 31,
No. 5, September/October 2011, pp. 44–49
14. Walsh, A., Ovais, M., Altmann, T., and Sargent, E. V., “Cleaning Validation for the
21st Century: Acceptance Limits for Cleaning Agents,” Pharmaceutical
Engineering, Vol. 33, No. 6, November/December 2013, pp. 12–24
15. Walsh, Andrew, Michel Crevoisier, Ester Lovsin Barle, Andreas Flueckiger, David
G. Dolan, Mohammad Ovais (2016) "Cleaning Limits—Why the 10-ppm and
0.001-Dose Criteria Should be Abandoned, Part II," Pharmaceutical Technology
40 (8)
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20. National Medical Products Administration Food and Drug Audit and Inspection
Center Guidelines for Quality Risk Management in Co-Line Manufacturing of
Pharmaceuticals March 2023
21. World Health Organization Technical Report Series 1033 -WHO Expert
Committee on Specifications for Pharmaceutical Preparations (Annex 2).
22. ASTM F3127-22 Standard Guide for Validating Cleaning Processes Used During
the Manufacture of Medical Devices www.astm.org.
24. ISO 10993-18:2020 Biological evaluation of medical devices - Part 18: Chemical
characterization of medical device materials within a risk management process
25. ISO 10993-1 Part 1: Evaluation and testing within a risk management process
26. American Society for Testing and Materials E3219-20 Standard Guide for
Derivation of Health Based Exposure Limits (HBELs) www.astm.org.
27. American Society for Testing and Materials E3263-20 Standard Practice for
Qualification of Visual Inspection of Pharmaceutical Manufacturing Equipment
and Medical Devices for Residues, www.astm.org.