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Strategies for Setting Rational MAC-based Limits; Part I – Reassessing the


Carryover Criterion

Article · January 2010

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New Perspectives on Cleaning.
Rizwan Sharnez ]
Strategies for Setting Rational
MAC-Based Limits Part II–
Application to Rinse Samples

Rizwan Sharnez, Angela To, and Laura Klewer

“New Perspectives on Cleaning” is an ongoing series shorter cycles and higher success rates for cleaning
of articles dedicated to cleaning process development, operations. It also facilitates the utilization of simpler
validation, and monitoring. This column addresses and more cost-effective non-specific assays, such as
scientific principles, strategies, and approaches associ- total organic carbon and conductivity. Part I of this
ated with cleaning that are faced in everyday work series applied this approach to samples for surface
situations. analysis. Part II deals with the application of this
Reader questions, comments, and suggestions are approach to rinse samples.
requested for future discussion topics. These can
be submitted either to column coordinator Rizwan INTRODUCTION
Sharnez at rsharnez@amgen.com or to managing edi- The maximum acceptable carryover (MAC) criterion
tor Susan Haigney at shaigney@advanstar.com. is used to set cleaning validation acceptance limits
for multiproduct (shared) equipment. It is based on
SUMMARY a worst-case mass balance (WCMB) for the previously
The maximum acceptable carryover (MAC) criterion manufactured product (1). The WCMB approach is
is widely used to set cleaning validation acceptance based on the conservative assumption that all the
limits for multiproduct equipment. The conventional residual contaminant in the cleaned equipment will
approach for setting cleaning validation limits based carryover into the next batch that is manufactured
on the MAC criterion results in acceptance criteria in that equipment.
that are much more stringent than necessary. This In Part I of this series we described how the con-
often results in cleaning validation limits that are ventional approach for setting MAC-based clean-
impractical to achieve and, in some instances, well ing validation limits is far more conservative than
below the limit of quantitation of the analytical the worst-case scenario that is physically possible
method. (2). This results in acceptance criteria for surface
In this series we describe strategies for setting ratio- analysis (e.g., swab samples) that are much more
nal MAC-based limits for multiproduct equipment. stringent than necessary. The resulting cleaning
The limits are used to justify more reasonable accep- validation limits are often impractical to achieve
tance criteria for cleaning validation. This results in and, in some instances, well below the limit of quan-

[
ABOUT THE AUTHORS
For more Author
Rizwan Sharnez, Ph.D., is principal engineer at Amgen, Colorado. He has more than 15 years of experi-
information,
ence in the pharmaceutical industry. He may be reached by e-mail at rsharnez@amgen.com. Angela To
go to
has a Bachelors degree in chemical engineering. Laura Klewer is senior engineer at Amgen, Colorado
gxpandjvt.com/bios
and has more than 10 years of experience in the pharmaceutical and biotech industries.

gxpandjv t.com Journal of Validation T echnology [Spring 2011] 43


New Perspectives on Cleaning.

titation (LOQ) of the analytical method. To address


this issue, we proposed an alternate approach based RRF = M R /MS [Equation 1]
on setting rational MAC-based limits. The proposed
approach is based on a WCMB; however, failure Conceptually, the RRF is similar to a swab recovery
limits are established for the equipment or lot as a factor, with the rinse being analogous to the swab. It
whole, but not for specific surface sampling sites. is determined by spotting coupons with the soil that
Instead, failure limits for specific surface sampling is being cleaned, and subjecting them to a simulated
sites are set based on process capability, visual rinse at small scale that is representative of the final
inspection, and default limits, such as the 10-ppm rinse at full scale (3).
criterion. This results in more reasonable acceptance As the efficiency of the rinse step increases,
criteria for swab samples. For a typical pharmaceu- M R → M S, and RRF → 1 (or 100%). Conversely, as
tical process, swab limits based on the proposed the efficiency of the rinse step decreases, M R → 0,
approach were shown to be about an order of mag- and RRF → 0. Thus, RRF can vary between the limits
nitude higher than those based on the conventional of 0 and 1, which represent 0 and 100% recovery,
approach. respectively.
In this discussion we apply the above concepts to
the practice of verifying MAC limits through rinse Rinse Volume-Weighted Approach
sampling. The analysis indicates that, with the pro- For an equipment train that is shared between two
posed approach, it is possible to justify acceptance products A and B, the maximum acceptable carryover
criteria for rinse samples that are an order of mag- of A into a manufacturing batch of B (MAC AB) is given
nitude higher than those based on the conventional by the following equation (2):
approach. This results in more efficient cleaning cycles
and fewer unwarranted cleaning validation failures. MAC AB ≤ (TDMIN, A /SF) (BB, MIN /DB, MAX)
Higher rinse limits also facilitate the elimination of [Equation 2]
complex product-specific assays (PSAs) in favor of
simpler and more cost-effective non-specific assays, Where, TDMIN, A is the minimum therapeutic dose
such as total organic carbon (TOC) and conductivity. of A, BB, MIN is the smallest integral batch of B (worst-
This strategy is particularly useful for biological active case) that is manufactured in the facility, DB, MAX is
pharmaceutical ingredients (APIs) for which product- the largest (worst-case) dose of B (DB, MAX), and SF is
specific immunoassays (PSIA), such as EIA and ELISA, the safety factor.
can be misleading and difficult to develop for cleaning It should be noted that the estimate of BB, MIN must
applications. For instance, PSIAs can result in false account for any splits during processing. For instance,
negatives because the epitopes that these assays are if the batch is split into S equal sublots before being
designed to recognize are often destroyed when the filled, then the limit calculated on the basis of the
API is exposed to extremes of pH and temperature sublots should be multiplied by S to get the actual
during cleaning. MAC limit for the shared equipment train.
The above MAC-based limit can be expressed in
MAC-BASED ACCEPTANCE terms of acceptance criteria for rinse samples. The
CRITERIA FOR RINSE SAMPLES rinse samples are collected from the final rinse of
This section describes the conventional and proposed each of the cleaning cycles. If the shared equip-
approaches for deriving the MAC-based acceptance ment train consists of N cleaning circuits, and if
criteria (AC) for rinse samples. AC based on the pro- V i (i=1-N) represent the final rinse volumes for the
posed approach (ACP) is substantially greater than N circuits, then the total volume of all the final
the AC based on the conventional approach (AC C), rinses is V T = ∑V i.
and the difference increases exponentially with the The acceptance criteria for the previous product
rinse recovery factor. A in the rinse for each of the N circuits is derived
by distributing MAC AB across the shared equipment
Rinse Recovery Factor train. For rinse sampling, the optimal solution is
The mass of component A in the rinse (M R) is corre- obtained by using the following rinse volume-weight-
lated to the mass of component A on the surface that ed approach (4):
is being rinsed (MS) by the rinse recovery factor (RRF):
44 Journal of Validation T echnology [Spring 2011] iv thome.com
Rizwan Sharnez.

MS, i = MAC AB (V T/∑) (i=1-N) [Equation 3] final rinse is (MS, i + M R, i), and so the rinse recovery
factor for A (RRF) can be expressed as:
Where, MS, i, the mass of A on the surface of the ith
circuit, is the maximum allowable carryover of A for RRF = M R, i/(MS, i + M R, i)  [Equation 1c]
the ith circuit. Note that by definition, ∑ MS, i = MAC AB.
Also, M R, i, the mass of A in the effluent rinse for Note that unlike the conventional approach, the
the ith circuit, is given by, proposed approach accounts for the mass that is
removed by the final rinse. As shown below, this
M R, i = V i • Ci  [Equation 4] results in higher acceptance criteria for the rinse
samples.
Where V i is the volume of the final rinse for the ith
circuit, and Ci is the concentration of the previous Substituting for MS, i and M R, i from Equations 3 and
product A in V i. When MS, i is given by Equation 3, 4a, respectively, into Equation 1c gives:
Ci becomes the acceptance criterion for the ith circuit
(ACi), and Equation 4 becomes: ACi = (MAC AB/V T) [RRF/(1- RRF)] [Equation 5c]

M R, i = V i • ACi [Equation 4a] In Equation 5c, ACi represents the acceptable limit
of A in the rinse for the ith circuit (i.e., the acceptance
Conventional Approach criterion for the ith rinse sample).
The conventional approach is based on the premise
that MS, i, defined by Equation 3, is the mass of A on the Because the RHS of Equation 5c is independent of
surface of the ith circuit before the final rinse step. Thus, i, the subscript i can be dropped. Thus,
in accordance with Equation 1, the rinse recovery factor
for A (RRF) can be expressed as: ACP = (MAC AB/V T) [RRF/(1- RRF)] [Equation 5d]

RRF = M R, i/MS, i [Equation 1b] Where the subscript P denotes the proposed
approach.
Substituting for MS, i and M R, i from Equations 3 and The above analysis indicates that the rinse volume-
4a, respectively, gives: weighted approach results in a uniform acceptance
criterion for all the rinse samples. This results in
RRF = ACi • V T/MAC AB [Equation 4b] the highest possible acceptance criterion that can
be justified for rinse samples (4). Thus, the rinse
In Equation 4b, ACi represents the acceptable limit volume-weighted approach represents an optimal
of A in the rinse for the ith circuit (i.e., the acceptance solution for deriving the acceptance criteria for rinse
criterion for the ith rinse sample). Thus, samples.

ACi = (MAC AB/V T) RRF  [Equation 5a] Comparison of Conventional


and Proposed Approaches
Note that RHS of Equation 5a is independent of i, Combining Equations 5b and 5d gives:
and so the subscript i can be dropped. Thus,
ACP/ACC = 1/(1- RRF) [Equation 6]
ACC = (MAC AB/V T) RRF [Equation 5b]
Because RRF varies between 0 and 1 (i.e., 0 ≤ RRF ≤
Where the subscript C denotes the conventional 1), Equation 6 indicates that the acceptance criterion
approach. obtained with the proposed approach (ACP) is always
greater than or equal to that obtained with the con-
Proposed Approach ventional approach (ACC). As RRF → 0, ACP → ACC;
The proposed approach is based on the premise that and as RRF → 1, ACP → infinity. Thus, as RRF increases
MS, i, defined by Equation 3, is the mass of A on the from 0 to 100%, the ability of the final rinse to remove
surface of the ith circuit after the final rinse. Thus, the any residue of product A increases exponentially as
mass of A on the surface of the ith circuit before the shown in the Table.
gxpandjv t.com Journal of Validation T echnology [Spring 2011] 45
New Perspectives on Cleaning.

Table: Acceptance criterion (AC) for final rinse the approach described here can be extended to other
samples as a function of the RRF. Subscripts applications, such as the carryover of cleaning agents.
P and C denote proposed and conventional
approaches, respectively.
RRF (%) ACP/ACC REFERENCES
→ 100 → infinity 1. Fourman, G. L., and M. V. Mullen, “Determining Clean-
ing Validation Acceptance Limits for Pharmaceutical
90 10
Manufacturing Operations,” Pharmaceutical Technology
80 5 14 (4): 54-60, 1993.
70 3.33 2. Sharnez, R., “Strategies for Setting Rational MAC-based
60 2.5 Limits: Part I-Reassessing the Carryover Criterion,”
50 2 Journal of Validation Technology, p. 71-74, Winter 2010.
3. Sharnez, R. and Klewer, L., “Parametric Release for
25 1.33
Cleaning Part I: Process Characterization,” Journal of
→0 →1
Validation Technology, Summer 2009.
4. Sharnez, R., Unpublished results. JVT
CONCLUSION
MAC-based acceptance criteria for cleaning validation ACKNOWLEDGEMENTS
are derived with the assumption that all the residual The authors would like to thank Sushil Abraham for
mass of the previously manufactured product A that helpful suggestions and support.
is on the cleaned surfaces of the equipment train
will carryover into the next batch of B. This repre- SUBSCRIPTS
sents a worst-case scenario from the standpoint of C Conventional
contamination. i Cleaning Circuit Number
The conventional approach for setting MAC-based P Proposed
limits for rinse samples is far more conservative than R Rinse
the worst-case scenario that is physically possible. This S Surface
results in acceptance criteria that are much more strin- T Total
gent than necessary. The resulting cleaning validation
limits are often impractical to achieve or significantly ARTICLE ACRONYM LISTING
below the LOQ of the analytical method. A Product A
The proposed approach is based on a realistic AC Acceptance Criteria
worst-case mass balance, and provides more rea- API Active Pharmaceutical Ingredient
sonable acceptance criteria for rinse samples. For a B Product B
rinse recovery of 90%, limits based on the proposed BB,MIN Smallest batch size of B
approach are shown to be about an order of magni- DB,MAX Largest (worst-case) dose of B
tude higher than those based on the conventional LOQ Limit of Quantitation
approach. An important benefit of justifying higher M Mass
cleaning validation limits is that complex product- MAC Maximum Acceptable Carryover
specific assays can be replaced by relatively simple MAC AB Maximum Acceptable Carryover of A into a
and more cost-effective non-specific assays, such Manufacturing Batch of B
as TOC or conductivity. It also can be leveraged N Total Number of Cleaning Circuits
to develop more efficient cleaning cycles to reduce PSA Product-Specific Assay
cleaning validation failures. PSIA Product-Specific Immunoassays
The analyses presented in this series are based on RRF Rinse Recovery Factor
the carryover of one product into another (i.e., cross- SF Safety Factor
contamination of multiproduct equipment); however, TDMIN,A Minimum Therapeutic Dose of A
the underlying principles for converting MAC-based TOC Total Organic Carbon
limits to acceptance criteria for cleaning validation V Volume
samples are the same for most contaminants, and so WCMB Worst-Case Mass Balance

46 Journal of Validation T echnology [Spring 2011] iv thome.com

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