Validation Services Seminar Morven McAlister & Vanessa Merefield SLS Life Sciences Training May 12, 2006
Presentation Outline Overview of validation tests Parametric Approach Selection of worst case test parameters
Product bracketing Additional Validation tests Trends / Issues
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Pall Validation Sites
Validation Laboratory © Pall Corporation 2006
Validation Definition “…establishing documented evidence which provides a high degree of assurance that a specific process will consistently produce a product meeting its predetermined specifications and quality attributes.” FDA Guideline on General Principles of Process Validation, 1987
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Need for Validation (1) “ Filtration is a common method of sterilizing drug product solutions.” FDA Guidance for Industry Sterile Drug Products Produced by Aseptic Processing – Current Good Manufacturing Practice (2004) Chapter IX – Validation of Aseptic Processing and Sterilization
“ For sterile products, the validation of sterilising processes should be of the same standard as for products authorised for marketing” European Guide to Good Manufacturing Practices (1998) Annex 13 - Manufacture of investigational medicinal products
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Need for Validation (2) … …regulations regulationsare are changing changingwhich which result resultin inmore more intensive intensivevalidation validation and andincreased increased clinical clinicalresearch research
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… … have haveto to optimize optimizeour our processes processesdue dueto to cost costpressure pressure and andcompetition competition in ingeneric genericmarket market
… … may maynot notoften often have haveresources resources and andexpertise expertise which whichcreates creates bottlenecks bottlenecksin in pipeline pipelinefor forR&D R&D products products
Global Consequences Growth through mergers and consolidation: Can larger companies react swiftly enough to changes? Higher complexity and costs of clinical trials: Delay in bringing new compounds to market “…in the last four years (2000-2003) the US FDA on average has approved 22 new molecular entities (NME) per year compared to an average annual approval rate of 39 NMEs in the four prior years” Leslie Platt, Ernst & Young © Pall Corporation 2006
Need for Validation (3) “It is particularly critical to validate the efficacy of the (sterilizing) filtration process. “…ensure
that worst-case formulation and processing parameters are adequately studied, evaluated and documented.”
“This
data should be available during current drug pre-approval inspections and for already marketed products produced by sterile filtration.”
FDA Human Drug CGMP Notes (1995) © Pall Corporation 2006
Filter Validation Testing - Overview Bacterial Viability Establishes bactericidal properties Determines suitable flush protocols
Bacterial Retention Confirms sterilizing capability of process membrane under worst case conditions
Compatibility Confirms maintenance of filter integrity after exposure to worst case fluid and process © Pall Corporation 2006
Filter Validation Testing - Overview Extractables Provides quantitative and qualitative analyses of filter extractables in model solvent
Product-specific integrity test values (ITV) Establishes filter integrity test values for process filtration assembly wet with process fluid
Adsorption Testing Determines extent of adsorption of product components following filtration of product © Pall Corporation 2006
Product Information Sheet (PINS) / Process and Product Questionnaire (PPQ)
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PINS / PPQ Overview of customer’s fluid & process parameters Used to establish fluid / process-specific test protocols representing worst case test conditions
All information needed to complete full validation package Requires exact concentration (%) of each component and carrier solvent in fluid Used in determining model solvent for extractables test Allows determination of potential testing issues, e.g. – Bactericidal properties, Compatibility issues © Pall Corporation 2006
Execution of Validation Package (US) Customer completes Product Information Sheet
Pall writes protocols and sends to customer for approval Customer contacts Pall project managers directly with any questions Customer sends following items to Pall: -Signed/approved protocols -Sample product / MSDS / PO
Testing commences at Pall 6-8 weeks
Pall project manager write reports Reports reviewed and issued to customer
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Product Grouping / Selection of Worst Case Conditions
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Selection of Worst-Case Conditions for Validation Testing “A set of conditions encompassing upper and lower processing limits and circumstances, including those within standard operating procedures, which pose the greatest chance of process or product failure when compared to ideal conditions” FDA Guideline on Sterile Drug Products Produced by Aseptic Processing, 1987
“Filter validation should be conducted using the worst-case conditions, such as maximum filter use time and pressure” FDA Guidance for Industry - Sterile Drug Products Produced by Aseptic Processing – Current Good Manufacturing Practice, 2004 © Pall Corporation 2006
Parametric Validation - Aim Determine any effect of the fluid on the filter and on B. diminuta or suspect bioburden isolate Bacterial viability and retention testing Compatibility testing
Determine any effect of the filter on the product formulation Extractables testing Adsorption testing © Pall Corporation 2006
Parametric Validation - Strategy
Product attributes Process parameters Scientific rationale Worst-case conditions Use of actual products wherever possible
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Selection of Worst Case Conditions for Validation Testing – Product Grouping As per 1987 Aseptic Processing Guideline, product “families” can be grouped
“Worst case” models must be justified by scientific rationale
Typically, highest concentration of active
under highest operating parameters (maximum process flow rate, differential pressure, temperature) represents “worst-case” model
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Selection of Worst Case Conditions for Validation Testing – Product Grouping Considerations for product grouping Product components Test fluid should represent maximum no. components present, including active
Concentrations of components Highest concentration of components typically tested Consider active and other constituents
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Selection of Worst Case Conditions for Validation Testing – Product Grouping Ionic Strength Affects surface charge of membrane and test
organism and potential adsorptive interactions
Osmolarity High osmolarity may cause shrinking of microorganisms
pH Affects surface charge of membrane and test
organism and potential adsorptive interactions Affects viability of test organism Test extremes of pH © Pall Corporation 2006
Selection of Worst Case Conditions for Validation Testing – Product Grouping Viscosity
High viscosity fluids usually require higher pressure and/or elevated temperature processing Typically also longer filtration duration
Surface Tension (incl. surfactants)
Presence of surfactants (> 0.5%) can reduce adsorptive capture
Nutrients
Low nutrient (oligotrophic) environments may reduce
bacterial cell size / change cell surface characteristics
Temperature Extremes of temperature range typically tested © Pall Corporation 2006
Bracketing of Products Process Parameter Volume
Time
Flow rate
Pressure
Temperature
0.25 mg/mL
50 L
45 mins
1.11 L/min
0.8 bar
20ºC
0.5 mg/mL
50 L
45 mins
1.11 L/min
0.8 bar
20ºC
1.0 mg/mL
100 L
60 mins
1.67 L/min
1.2 bar
20ºC
5.0 mg/mL
500 L
420 mins
1.19 L/min
0.5 bar
20ºC
10mg/mL
200 L
90 mins
2.22 L/min
0.7 bar
20ºC
20mg/mL
100 L
60 mins
1.67 L/min
1.2 bar
20ºC
Active concentration
© Pall Corporation 2006
Grouping of Products Parameter
Product
pH
Surface Tension
Viscosity
Osmolarity
Ionic Strength
A
5.83
73.4
1.2
277
0.153
B
6.63
72.4
1.3
233
0.164
C
5.13
71.14
8.4
150
0.083
D
6.47
71.9
1.2
249
0.171
E
5.51
72.6
8.9
138
0.080
F
5.94
71.7
9.6
281
0.177
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Bacterial Viability / Flush Testing (1) Test bacteria (~106 CFU/mL) inoculated into customer fluid and control fluid (sterile deionized (DI) water)
Bacterial concentration monitored in fluid and control over process time
Fluid & process established as bactericidal, moderately bactericidal or non-bactericidal © Pall Corporation 2006
Test Methodology
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Selection of Worst Case Conditions for Bacterial Viability Testing Actual product used Viability determined over total contact time of
product with filter Maximum process temperature (≤ ≤ 37oC) If process temperature >37oC, approach for moderately bactericidal products may be required Recirculate product at process temperature for maximum contact time, followed by bacterial challenge in product at ≤ 37oC
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Definition of Bactericidal Non-bactericidal A decline in viability of less than one log (<90%) in product over the process time
Bactericidal A decline in viability of greater than 1 log (>90%) within 60 minutes of exposure in product
Moderately Bactericidal A decline in viability of less than 1 log over 60 minutes, in conjunction with a decline in viability of 1 log or more over the process time May allow for an in-product challenge after product recirculation © Pall Corporation 2006
Bacterial Viability / Flush Testing (2) Residual Effects (bactericidal fluid only) Removal of bactericidal fluid from test filter Fluid passed through test filter then rinsed with flush fluid (typically DI water) Additional volume of DI water passed through test filter disc, collected and inoculated with low concentration of test organism No. bacteria recovered from fluid must be within 30% of bacterial count recovered from control © Pall Corporation 2006
Bacterial Viability / Flush Testing (3) Recovery Flush (non-bactericidal fluids only) Removal of test fluid from recovery (“analysis”) filters Test fluid or control inoculated with a low concentration of test bacteria Vacuum filtered through recovery filter and flush scheme (typically DI water) applied No. bacteria recovered from test fluid must be within 30% of bacterial count recovered from control © Pall Corporation 2006
Options for Bacterial Retention Test Fluid Type Non-Bactericidal
Moderately Bactericidal
Challenge performed by inoculating bacteria in fluid directly (seeded challenge)
Fluid recirculated for process time followed by challenge using fluid inoculated with test bacteria
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Bactericidal Fluid recirculated for process time followed by flush and challenge using surrogate solution inoculated with test bacteria
Microbial Challenge – Bactericidal Fluids “In such cases, the fluid should simulate the product as closely as practical in terms of viscosity and other physical characteristics that are not antagonistic towards the microbial challenge” FDA Guideline on Sterile Drug Products Produced by Aseptic Processing, 1987
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Challenge Fluid Selection for Bactericidal Products Product (short term) with flush Modified product (no preservative) Modified product (reduced or no active) Placebo (where appropriate) Surrogate fluid (e.g. saline lactose broth) Similar chemical properties © Pall Corporation 2006
Microbial Challenge “The (challenge) microorganisms should be small enough to both challenge the filter's nominal porosity and simulate the smallest microorganism that may occur in production.” FDA Guideline on Sterile Drug Products Produced by Aseptic Processing, 1987
“The microorganism Brevundimonas diminuta (ATCC 19146) when properly grown, harvested and used, is a common challenge microorganism for 0.2 µm rated filters because of its small size (0.3 µm mean diameter)” FDA Guidance for Industry - Sterile Drug Products Produced by Aseptic Processing – Current Good Manufacturing Practice, 2004 © Pall Corporation 2006
SEM of 0.2 µm Membrane * Section View Challenged with 5 x 108 B. diminuta cells per cm2 Osumi et al., PDA J. Pharma. Sci. & Technol., v. 50: pp. 30-34, (1996)
20 µm Typical membrane thickness ~160 µm
* Pall Ultipor® Nylon 6,6 NR Grade © Pall Corporation 2006
Criteria for Bacterial Retention Testing of Sterilizing Grade Filters Brevundimonas diminuta (ATCC 19146) or other “worst-case” bioburden isolate Controlled culture conditions (ASTM F838-05) Minimal size (B. diminuta 0.3 x 0.8 µm) Monodispersed Demonstrate penetration of 0.45 µm rated control filter Simulate “worst-case" process conditions Total challenge ≥ 1 x 107 CFU/cm2 Analyze total effluent for sterility © Pall Corporation 2006
(Ref: ASTM-F838, PDA TR26)
Selection of Worst Case Conditions for Bacterial Challenge Testing (1) Operating parameters
Flow rate Differential pressure Filter throughput per cm2 Total challenge duration Temperature No. batches processed per filter assembly Filter sterilization conditions
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Typically, maximum values for each test parameter
Selection of Worst Case Conditions for Bacterial Challenge Testing (2) Flow rate and pressure are interdependent Validate highest flow and highest pressure to meet or exceed both process parameters Hydraulic shock – pulsing can be used B.diminuta inoculated into product wherever possible
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Selection of Worst Case Conditions for Bacterial Challenge Testing (3) Test Filter Same membrane family and pore size rating 47-mm membrane discs typically used from standard production Minimum production physical QC test limit “Low KL” discs Pall QBP (quantitative bubble point)
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Bacterial Challenge Challenge method dependent on fluid properties Bactericidal vs. Non-Bactericidal Bacterial retention is confirmed if no penetration of test membrane filter occurs under test conditions that mimic the full-scale process conditions
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Bacterial Challenge (Non-Bactericidal Fluid)
Recirculation with Seeded Challenge Solution © Pall Corporation 2006
Product Recirculation (Bactericidal Fluid)
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Bacterial Challenge (Bactericidal Fluid)
Seeded Challenge Solution © Pall Corporation 2006
Adsorption Testing To quantify the amount of components adsorbed from the product onto the filter after passing through test filters
Enables calculation of volume of product which should be flushed through process filter to ensure saturation of the filter
Pall collects filtrates and customer performs analysis
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Adsorption Testing Peristaltic pump
Tubing Test filter disc in housing
Product Reservoir © Pall Corporation 2006
Filtrate sample collection vials
Selection of Worst Case Conditions for Adsorption Testing
Maximum temperature Maximum flow rate Small batch size Maximum filter throughput Maximum contact time © Pall Corporation 2006
Compatibility Testing Demonstrates compatibility of specific filter with customer process fluid Filter exposed to process fluid for specified period under pre-determined conditions Compatibility determined by performing integrity tests on filter pre- and post-fluid exposure and visual examination of filter © Pall Corporation 2006
Selection of Worst Case Conditions for Compatibility Testing Testing uses actual customer fluid Filters sterilized under maximum
conditions (time/temperature) prior to product exposure Testing conducted at maximum process temperature Exposure time must be equal to process time minimally © Pall Corporation 2006
Extractables Testing Potential sources: Hardware, support layers, membranes, wetting agents, casting additives, etc. Solvent
Additives
Polymer Chain
Polymer Surface SURFACE INTERFACE
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Oligomer
Extractables Testing
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Extractables Assessment
Filter reciprocated in extracting solvent
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Pre-weighed Crucible
Solvent transferred to Rotary Evaporator
Extractables Assessment
Non-Volatile Residue (NVR)
Quantity © Pall Corporation 2006
Fourier Transform Infra-red Spectroscopy (FTIR)
Identity
Extractables Testing Qualitative and quantitative analyses of extractables from process filter Non-volatile residue (NVR) UV-Vis, FTIR Model solvent used based on process fluid characteristics Test conditions reflect process temperature and time © Pall Corporation 2006
Advantages of NVR/IR Model System Wide range of models available NVR detects all nonvolatile material Flexible, widely applicable IR
characterization; good for unknown identification/investigation Self-Validating; negative and positive controls minimize “method validation blues”
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Additional Analytical Methods UV-Visible spectroscopy for transparent
solvents TOC for aqueous solutions GC-MS for volatiles/semi-volatiles LC or LC/MS for nonvolatiles or heatsensitive compounds ICP/MS (Inductively Coupled Plasma/Mass Spectrometry) analysis for metallic extractables, if necessary.
© Pall Corporation 2006
Selection of Worst Case Conditions for Extractables Testing (1) Model Solvent Approach Determines contribution of filter components to fluid effluent Customer fluid - type and concentration of components Increase solubility & concentration of low MW weight substances in fluid due to chemical attack? Typically, components <10% volume do not exert significant solubility/compatibility effects Fluid pH considered independently © Pall Corporation 2006
(Ref: Weissman)
Selection of Worst Case Conditions for Extractables Testing (2) Process Parameters Temperature Testing conducted at temperature equal to or greater than process temperature Filter duration (total contact time) Minimum of two extraction cycles (24 hours per cycle) No. extractions completed is equal to or greater than total contact time of filter with product
© Pall Corporation 2006
Product-wet Integrity Test Values
Gas Source Air, N2
Gauge Pressure Regulator Test Filter
Bubble Point Forward Flow Pressure Hold © Pall Corporation 2006
All three test are based on the same physics, the flow of gas through a liquid-wetted Bubbles membrane under applied pressure
Product-wet Integrity Test Values Determine test parameters appropriate for
establishing integrity of a filter when wet with customer fluid Values determined for filter wet with customer fluid and correlated to reference fluid-wet value Reference fluid-wet values correlated to bacterial retention (published in Filter Validation Guide).
© Pall Corporation 2006
Membrane Filter Integrity Testing Membrane filter wetted with water or product Pressurized with air or N2 at validated pressure Flow of air through wetted membrane measured Atmospheric pressure
Test Gas Pressure
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Low diffusive gas flow through small wetted pores (integral membrane) High convective gas flow through large pores, e.g. defective membrane areas
Liquid-wetted Membrane
Multi-point Forward Flow Curve Flow (ml/min) 25 20 15 10 5
• • • • • • • 1
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2 Pressure (bar)
3
• • • •
“Bubble Point” Transition Region 4
KL Value Determination Transition from diffusive flow to open pore flow
Bulk gas flow through open pores
Gas Flow Pressure
Diffusive flow
(Q/P)
Pressure
KL
KL is the pressure at which the two dotted lines cross © Pall Corporation 2006
Diffusive Flow Spectrum Product wet Water wet
Flow 2
1
1 © Pall Corporation 2006
KL(P) 2 Pressure
KL(W)
3
Product Wetted Integrity Pressure Determination of test pressure KL in product
KL in water
Product KL Curve Gas Flow Pressure
x (Q/P)
Calculated Test Pressure
Water KL Curve x
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FF test pressure in water P (mbar)
Selection of Worst Case Conditions for Product-Wet Integrity Testing Product Surface Tension If surface active agents present in product,
surface-tension derived test pressure used
Viscosity Viscous products may require extended equilibration or test dwell times
Process Parameters Temperature © Pall Corporation 2006
Effect of Area on “Bubble Point” Flow (ml/min) 250 200 150
High area cartridge
Low area disc
100 50 0 Pressure (psi) 40
“BP”
50
“BP”
60
Cartridge “bubble points” are typically lower than © Pall Corporation 2006 “bubble points” using the same membrane disc
Critical Testing Parameters
Compatibility
ITV
Adsorption
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Considered for “worst-case”
Evaluated for information only
Sterilization Conditions
Extractables
Temp
Bacterial Challenge
∆P
Viability
Flow Rate
Time
Filter Throughput
Surface Tension
Osmolarity
Viscosity
Ionic Strength
pH
Composition
Test Type
Additional Validation Testing
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Kleenpak Connectors Soiling Test Ability of KPC to produce sterile connection after intentional contamination with bacterial spores Male & female connector soiled with Geobacillus stearothermophilus Challenge level > 105 CFU per device
© Pall Corporation 2006
Kleenpak Connectors Extractables Testing Model Solvent Approach Compatibility Tensile Strength
© Pall Corporation 2006
Disposable Systems Tubing, bags etc Extractables FTIR, GCMS, UV Bioburden 14 day incubation period 2 growth media Endotoxin If product shelf-life study, qualification of assay with product required Sensitivity 0.005 EU/mL © Pall Corporation 2006
Pallchek Extensive validation required Protocols currently under developments Various test fluids (water, buffers, media etc) Various ATCC bacterial strains Potential for product-specific validation as part of Validation services
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Preparation for an audit
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Preparation for an Audit (1) SLS Labs are not working to GMP Audit Hosts QA & SLS Lab and project managers present SLS procedures must be available and show documented evidence that they are followed Training Records Must be updated with current SOP revisions Evidence of competency © Pall Corporation 2006
Validation Services – Goals / Issues
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Trends in Validation Services (US) Increase in projects from biotechnology
companies and universities Increase in generic drugs Increase in projects from S.America Increase in extractables projects for pre-filters Decrease in project turnaround times
© Pall Corporation 2006
Trends in Validation Services -EU Customers requesting PWIT testing performed in triplicate Contract manufacturers requesting product groupings 10-15% increase in filter validations / year More interaction with filter manufacturer and customer Increased interest in extractables
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Goals - Validation Services PINS/PPQ Incomplete PIN sheets frequently submitted Customers often lack understanding of process PM calls / visits customer to obtain full details Illegible handwriting on PIN/PPQ Currently PM calls for clarification
“Typeable” PINS now complete PINS/PPQ to be submitted via Pall web site Target Date – August 2006 © Pall Corporation 2006
Goals - Validation Services During customer routine QC Product Analysis unidentified peaks reported Traced to Pall filter cartridges 3 recent occurrences FDA/PDA recommend all extractables are identified More detailed analysis required GCMS installed in PW on May 02, 2006 IQ/OQ currently being performed by manufacturer Training scheduled immediately after IQ/OQ Estimated target date for use in customer work – mid June 2006 Global team needs formed to prioritize testing needs © Pall Corporation 2006
Goals - Validation Services Globalization Need to standardize test SOPs based on best practise globally Ensure data interpretation same globally Review validation testing prices globally Ability to easily communicate with global team Shared resources (e.g. extractables reports) Validation Team Room Shared global objectives V.Merefield (Europe), M.McAlister (W.Hemisphere), H. Nomura (Asia) First meeting held Jan 2006. Each group working on action items © Pall Corporation 2006
Shared Issues - Validation Services Customers requesting data to support pre-filters (API) Compatibility & Extractables Data SLS UK and US have performed extractables studies for a range of pre-filters & solvents How do we confirm compatibility?
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Shared Issues - Validation Services Test Discs Urgent considerations: Global sourcing of 47-mm discs Low spec media – both layers? Certification of 47-mm discs Considered a priority by global validation team SOP written by Chris Lewis….under review List of manufacturing sources for discs underway © Pall Corporation 2006
Additional Questions?
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Reference Documents (1) 1.
2. 3. 4. 5. 6. 7. 8. 9.
Bowman, F., M.P. Calhoun and M. White, “Microbiological methods for quality control of membrane filters”, J. Pharm. Sci., v. 55; p. 818 (1967) Pall, D.B., “Quality Control of Absolute Bacteria Removal Filters,” Bull. Parenteral Drug Assoc., 29, 392-204 (1975). Howard, G. and R. Duberstein. “A case of penetration of 0.2 µm rated membrane filters by bacteria.” Journal of the Parenteral Drug Association., v. 34; p. 95 (1980) HIMA (now AdvaMed), “Microbiological Evaluation of Filters for Sterilizing Liquids,” draft doc. No.3 Vol. 4, April, 1982 (obsolete) ASTM, “Standard Test Method for Determining Bacterial Retention of Membrane Filters Utilized for Liquid Filtration,” Standard No. F838-83 (1983, No. F838-05, rev. 2005) FDA Guideline on Sterile Drug Products Produced by Aseptic Processing, 1987 FDA CDER Perspective on Isolator Technology, ISPE Barrier Technology Conference, Dec. 1995 FDA Guidance for Industry for the Submission Documentation for Sterilization Process Validation in Applications for Human and Veterinary Drug Products, 1994 FDA Human Drug CGMP Notes, Dec. 1995
10. PDA Technical Report No. 26, “Sterilizing Filtration of Liquids,” PDA J. Pharmaceutical Science and Technology, 52 (3) Supplement, 1-31, 1998 © Pall Corporation 2006
Reference Documents (2) 11. FDA Guidance for Industry - Sterile Drug Products Produced by Aseptic Processing – current Good Manufacturing Practice, 2004 12. Weitzmann, C. The use of model solvents for evaluating extractables from filters used to process pharmaceutical products, Pharmaceutical Technology, 21 (#4), 72-99 (1997) 13. Pall Corp., “Determination of product wet integrity test values for Pall filter cartridge,” Publ. No. USTR 1471(1) 14. Sundaram, S. et al., Considerations in Using "Bubble Point" Type Tests as Filter Integrity Tests, Part I: Effect of Test Methodology on Filter Cartridge “Bubble Point” Measurements and Implications for the Use of “Bubble Point” Type Tests as Correlated Tests, Pharmaceutical Technology, Sept., 2000 15. Sundaram, S. et al., “Considerations in Using "Bubble Point" Type Tests as Filter Integrity Tests, Part II: Effect of Filter Area on “Bubble Point” Measurements and Implications for the Use of “Bubble Point” Type Tests as Correlated Tests,” Pharmaceutical Technology, Oct., 2000 16. Pall Corp., “Validation Guide for Pall 0.2 micron Ultipor N66 and N66 Posidyne Membrane Cartridges,” (1980) 17. USP General Information Chapter <1227>, Validation of Microbial Recovery from Pharmacopeial Articles, USP 27, USPC, Inc., Rockville, MD, 2004, p. 2625 18. Osumi, M., N. Yamada and M. Toya, “Bacterial retention mechanisms of membrane filters,” PDA Journal of Pharmaceutical Science and Technology, v. 50; pp. 30-34, (1996) © Pall Corporation 2006
Thank you for your attention!