Your firm failed to follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes (21 CFR 211.113(b)).
贵公司未能遵循旨在防止无菌药品发生微生物污染的适当书面规程,并且未包括对所有无菌和灭菌过程的验证(21 CFR 211.113(b))Poor Aseptic Practices。
During the inspection of your facility, we observed poor practices and behaviors in ISO 5 areas during the manufacturing of sterile (b)(4) drug products. These poor practices included, but were not limited to:
In 2022, your firm identified contamination in two media fill batches one on the “(b)(4)” aseptic filling line and another on the “(b)(4)” aseptic filling line. You identified the root cause as poor aseptic behavior. These contamination events along with the poor aseptic practices observed during our inspection indicate your aseptic manufacturing operations may lack adequate control. Your firm did not perform a sufficiently comprehensive evaluation of aseptic behavior of operators as part of this recurrent trend.
We also note that open door interventions required a large door to be opened. On numerous occasions, the door remained opened for extended periods of time while the line was still in-operation. When opened, the door was exposed to the ISO 7 area, and when being closed, there was a significant risk of the lower quality room air sweeping into the ISO 5 aseptic processing area. Empty sterile containers were located extremely close to the door. In addition, operators did not adequately disinfect the open door. While spraying disinfectant on the (b)(4), operators failed to consider open sterilized bottles on the line, exposing them to potential contamination.
Inadequate Smoke Studies and Cleanroom Design
不充分的烟雾研究和洁净室设计
Your smoke studies did not adequately demonstrate unidirectional air flow in the ISO 5 classified areas used for the aseptic filling of ophthalmic drug products on the “(b)(4)” and “(b)(4)” aseptic filling lines. For example:
We also note that there were multiple aspects of your cleanroom and aseptic processing line design which represented fundamental contamination risks:
我们还注意到,您的洁净室和无菌生产线设计中存在多个方面的基本污染风险:
The ISO 5 area is critical because sterile product is exposed and therefore vulnerable to contamination. Your aseptic filling process should be designed, and operations executed, to prevent contamination hazards to your sterile product. The flawed design of the filling line and execution of the aseptic operations promote influx of contamination into the critical filling areas.
学习心得:
邵丽竹
何发
2025-04-10
2025-03-04
2025-03-27
2025-03-11
2025-04-15
2025-03-04
2025-03-31
本文以某制药产线的灌装机设备为研究对象,采用计算流体动力学(CFD)仿真技术对充氮装置的充氮性能进行分析,并结合分析结果对氮幕结构进行了优化设计。随后,针对优化方案进行性能仿真验证,结果显示优化后的顶空残氧量降低至0.252%。为了进一步验证优化方案的实际效果,将优化方案应用于实际产线进行性能测试,测得的顶空残氧量为0.68%,这一结果满足了小于1%的要求,表明其充氮保护性能已达到国际先进水平。
作者:王志刚、刘依宽、刘佳鑫
评论 0
正在获取数据......