Revised
International Clean room Standard By Piyush Tripathi
How do we classify Clean room? Clean room guidelines are
having lot of loop holes as its still not so absolute to be acceptable as thumb
rule. Speaking to industrial experts every individual has different opinion
about the clean room standard, Classification and its construction. Few common
questions that each will answer differently and as per the conditions prevail. Revised
international clean room standards discussion is a constant updates that are
punched on web and pharmacopeia as revisions. Major changes and standards discussions
and clean room designed for one and later revised to non conformance. To overcome
this new this we need to have an approach which is acceptable. Understand the
process flow of material from one form the other.
Latest
updates show a reasonable change in the classification of the clean room or aseptic
condition building. As described in Pharmacopeia it states: A clean room, as
defined in USP <797>, is a room in which the concentration of airborne
particles is controlled to meet a specified airborne particulate cleanliness class.
Microorganisms in the environment are monitored so that a microbial level for air,
surface, and personnel gear are not exceeded for a specified cleanliness class.
797>
Depending
on the nature of the operation, work is performed in different clean room classes.
Recommended Action Levels for Microbial
Contamination
Process
Area
|
Classification
|
Particle
Count
(maximum
no. particles 0.5u or larger per m3 air
|
Air Sample
(Cfu
per cubic meter {1000 ltrs} of air per plate)
|
Fingertip
Sample
(CFU
per pair of hands)
|
Surface
Sample
(Contact
Plate)
CFU/plate
|
Filling
Zone
|
ISO
Class 5
|
3,520
|
> 1
|
>
3
|
>
3
|
Buffer
Zone
|
ISO
Class 7
|
3,52,000
|
>
10
|
N/A
|
> 5
|
Entrance
|
ISO
Class 8
|
35,20,000
|
> 100
|
N/A
|
>
100
|
Clean
rooms and associated controlled environments – Part 1: Classification of air
Cleanliness
USP<797>
Pharmaceutical Compounding: Sterile Preparations US Pharmacopoeia.797>
CFU-
Colony Forming Units
Filling Zone In ISO Class 5 Area.
Applications
|
USP<797>
Requirement797>
|
Glove
Cleaning
|
Routine
Application of Sterile 70% IPA
|
Surface
Cleaning
|
Wiping
with residue free disinfecting agent such as Sterile 70% IPA
|
Dry
Wiping & Spill Control
|
Low
Shedding Wipes discard after one use
|
Isolator
& Hood Cleaning
|
Cleaning
and disinfecting surfaces frequently
|
Disinfecting
|
Compatible,
effective non residual disinfectant solution
|
For Buffer Zone ISO Class 7 & Entrance
ISO Class 8 Areas
Applications
|
USP<797>
Requirement797>
|
Hand
Washing
|
Hand cleansing
procedure before gowning
|
Glove
Cleaning
|
Disinfection
of contaminated gloved hands
|
Decontamination
of Cleaning supplies for filling Zone
|
Wipe
outer surface with Sterile 70% IPA
|
Surface
Cleaning
|
Low
shedding wipes, discard after one use
|
Dry
Wiping & Spill Control
|
Low
Shedding wipes, discard after one use
|
Floor
Mopping (Small Space)
|
Non
shedding mop hands, preferably discard after one use
|
Floor
Mopping (Large Space)
|
Non
shedding mop hands, preferably discard after one use
|
Disinfecting
|
Wipe
Supplies removed from cartons with a suitable disinfecting agent.
Clean
Floor with disinfectant Solution.
|
Section
211.42 (design and construction features) requires, in part, that aseptic
processing operations be performed within specifically defined areas of
adequate size. There shall be separate
or defined areas for the firm’s operations to prevent contamination or mix-ups. Aseptic processing operations must also include,
as appropriate, an air supply filtered through high efficiency particulate air
(HEPA) filters under positive pressure, as well as systems for monitoring
environmental condition, and maintaining any equipment used to control aseptic
conditions.
Section
211.46 (ventilation, air filtration, air heating and cooling) states, in part,
that equipment for adequate control over air pressure, microorganisms, dust,
humidity, and temperature shall be provided when appropriate for the
manufacture, processing, packing or holding of a drug product. This regulation also states that air
filtration systems, including pre-filters and particulate matter air filters,
shall be used. Appropriate filtration level to be maintained on air supplies to
production areas.
Some known or assumed Air
Classifications chart.
Clean Area Classifications
|
> 0.5 um particles/Ft3
|
> 0.5 um particles/m3
|
Micro biological
Limit
|
|
100
|
100
|
3,500
|
<
1
|
<3 span="">3>
|
1,000
|
1000
|
35,000
|
< 2
|
< 7
|
10,000
|
10,000
|
3,50,000
|
< 5
|
< 18
|
1,00,000
|
1,00,000
|
35,00,000
|
< 25
|
< 88
|
Section
211.42 states that flow of components, drug products containers, closures, labelling,
in-process materials, and drug products through the building or building shall
be designed to prevent contamination. HEPA filtered air as appropriate classification
and as per area required to be facilitated, as well as floors, walls and
ceilings of smooth, non-particle shading surfaces that are easily cleanable are
some additional requirements of this section.
Section
211.63 states that equipment shall be of appropriate design, adequate size, and
suitably located to facilitate operations for its intended use and for its
cleaning and maintenance.
Section
211.65 states that equipment shall be constructed so that surfaces that contact
the components, in-process materials, or drug products 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.
Section
211.113 states that appropriate written procedures, designed to prevent
microbiological contamination of drug products purporting to be sterile, shall
be established and followed.
Sections
211.22 states that, quality control unit shall have the responsibility for
approving or rejecting all procedures or specifications impacting on the
identity, strength, quality, and purity of the drug product.
Section
211.113(b) addresses the procedures designed to prevent microbiological
contamination, stating that written procedures, designed to prevent
microbiological contamination of drug products purporting to be sterile, shall
be established and followed.
Section
211.25, Personnel Qualifications requires that each person engaged in manufacture,
processing, packing or holding of a drug product shall have education, training
and experience, or any combination thereof, to enable that person to perform
the assigned functions. Adequate number of qualified personnel to perform and
supervise the manufacture, processing, packing or holding of each drug product.
Section 211.25 also requires that continuing training in CGMP shall be
conducted by qualified individuals on a continuing basis and with sufficient
frequency to assure that employees remain familiar with CGMP requirements
applicable to them. The training shall
be in the particular operations that the employee performs and in current good
manufacturing practice, as they relate to the employee's functions.
Section
211.28, Personnel Responsibilities states, Personnel engaged in the
manufacture, processing, packing or holding of a drug product shall wear clean
clothing appropriate for the duties they perform. It also states that personnel
shall practice good sanitization and health habits and specifies that protective
apparel, such as head, face, hand, and arm coverings, shall be worn as
necessary to protect drug products from contamination. It also states that any
person shown at any time (either by medical examination or supervisory
examination) to have an apparent illness or open lesions that may adversely
affect the safety or quality of drug products shall be excluded from direct
contact with components, drug product containers, closures, in-process
materials, and drug products until the condition is corrected or determined by
competent medical personnel not to jeopardize the safety or quality of drug
products. All personnel shall be
instructed to report to supervisory personnel any health conditions that may
have an adverse effect on drug products.
Restrictions
on entry into limited access areas: Only personnel authorized by supervisory
personnel shall enter those areas of the buildings and facilities designated as
limited access areas.
Section
211.42 requires the establishment of a system for monitoring environmental
conditions.
Guidelines and Classification of Class
and Gradations
WHO GMP
|
US 209E
|
US Customary
|
ISO/TC (209) ISO
14644
|
EEC GMP
|
Grade
A
|
M 3.5
|
Class
100
|
ISO 5
|
Grade
A
|
Grade
B
|
M 3.5
|
Class
100
|
ISO 5
|
Grade
B
|
Grade
C
|
M 5.5
|
Class
10,000
|
ISO 7
|
Grade
C
|
Grade
D
|
M 6.5
|
Class
1,00,000
|
ISO 8
|
Grade
D
|
Observations
on the Clean Room Standards and revisions:
As summarized above for the process, production, packing and material areas clean
room conditions are defined based on the process flow and its identifications. It’s
not mandatory to have air locks to segregate or buffer the area, if area
restrictions are there we can any time create a buffer area hold for man and
material movement change the air present in the area and then move forward. Seems
surprising but yes it is a possible solution for areas where space constraints
and process limitation does not permit. This is entirely personal view. Why not?
Logic
why do we create Air Lock? Answer to this is to obstruct person, media, product
to enter another higher or lower classified area and ensure that the same is
not contaminating or mixing up with or creating cross contamination. If we
ensure that the sufficient amount of buffer is provided air lock and lot of
space can be saved.
Modern
method of aseptic processing are adapting to isolation principals that enables
or isolates the processing area and the overall running cost of the process
side can be minimized. Viz. processing area is isolated by making cubical which
is entire process line is placed and outside area is normal Grade D. this helps
to reduce the load of AHU of Grade A and due to lesser area overall running cost
of the plant goes down. But selection of such principle is completely
individual choice. Designing such area has to go through or counter lot of
thumb rule followers who believe that the area should as prescribed in USP, IP,
BP or any other pharmacopeia, it’s a matter of individual choices. People do
think out of box but are forced to close the box as its one step that would
require lot of explaining to do but there is always a first step.
Conclusion to revision in Clean Room
Standards
By
concentrating more on process requirements area can be designed to its absolute.
Exploring possibilities with what we have is always the solution. Man has
evolved and has made larger changes than what we are thinking of. Following law
does not mean that one process can be done one way. SME organization, Job work
organizations and individual local companies most of the time back off and does
not explore the possibilities to upgrading their facilities as Law is often misinterpreted
and misled. This blog is first “Thought to Explore”
“Thought
to Explore”
First
Step