The Media Fill Approach an Update

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    In September 2004, after 17 years in existence, the FDA replaced older guidelines with an updated document,‘Guidance for Industry – Sterile Drug Products Produced

    by Aseptic Processing – Current Good Manufacturing Practices’. The world was a very different place when theoriginal guidance was issued. AIDS was a relatively new illness, few had heard about ‘Mad Cow Disease’, theInternet was unheard of, and genetic fingerprinting wasnot yet in use in criminal investigations. Throughout the1980s and 1990s, technological advances continued to bemade, but the pharmaceutical industry kept a conservativeapproach to their processes. Also in September 2004,Europe made some changes to the ‘EC Guide to Good Manufacturing Practice, Annex I, Manufacture of SterileMedicinal Products’. Together, these documents initiated

    meetings, conferences, discussions and debate. Many areashave seen little amendments or increased regulatory clarity; however, aseptic process simulations haveundergone significant changes.

    Within a short time of the new guidance being issued,a UK vaccine manufacturer found itself in trouble with theregulators. The production facility was shut down, causing a huge shortfall in flu vaccines available to patients. This

    was a timely reminder of the importance of processcontrol in critical manufacturing environments.

    STERILITY ‘Sterile’ is a powerful word, with harsh legal implicationssurrounding non-compliance. Global regulatory authorities

    would define sterile as ‘free of viable organisms’, and sterility assurance has become one of the most scrutinised areas of pharmaceutical and medical device manufacture. Thefavoured method of production of sterile pharmaceuticalproducts includes a terminal sterilisation process, such asautoclaving or irradiation. Since it is not practical toexamine every unit for confirmation of sterility, terminalsterilisation processes use biological indicators (BIs) toprovide levels of sterility assurance. BIs are substrates

    Biotechnology

    90 Innovations in Pharmaceutical Technology

    The Media Fill Approach: An Update The design and execution of rugged process simulations – together withthe use of high quality growth media – will help ensure that the risk of contamination of aseptic processes is kept within acceptable limits.By Phil Smith at Oxoid Ltd

    carrying high loads of resistant micro-organisms, at levels fargreater than the bioburden of the load being sterilised. If everything on the BI is killed, it is reasonable to assume that

    the load is also free of viable organisms and can be deemedsterile. However, many therapeutic agents would not withstand terminal sterilisation, so aseptic manufacture andaseptic filling processes are required.

    Aseptic processing used to produce sterile parenteraldrug products and Active Pharmaceutical Ingredients(APIs) involves the handling of pre-sterilised productsin a highly controlled environment. Using the BIcorrelation approach is not applicable here, as asepticprocessing involves ensuring a great deal of processcontrol, with sensitive handling of products until they are sealed within their final containers.

    All efforts are made to minimise the risk of contamination:

    Filling and support areas are engineeredto minimise contamination

    Air in critical areas is supplied at point-of-useas high-efficiency particulate air (HEPA) filtered,laminar flow air at a velocity sufficient to sweepparticles away from the filling and closing areasPositive air pressure is used to prevent ingressof airborne contamination: anything that can

    be sterilised must be rendered sterile before it canbe taken into the clean area where the processis performedHuman intervention is kept to a minimumCleaning is thorough and validatedDisinfection practices are tight and validatedMonitoring is done to prove the processand environment are under control

    Despite such measures, contamination is an ever-presentthreat, since there will always be a risk that materials andsurfaces may carry organisms, and inefficiencies in air

    Phil Smith is Pharmaceutical Marketing Manager at Oxoid Ltd (Basingstoke, UK). One of his responsibilities at Oxoid is to ensurethat the company’s products meet the changing needs of the pharmaceutical industry and the constraints imposed by regulatoryrestrictions. Mr Smith has 15 years’ experience in the pharmaceutical and regulated industries, working largely on sterility issues andaseptic applications. Prior to joining Oxoid in 2004, he worked for STERIS Corporation, where he was involved in developing theirdisinfection and critical cleaning portfolio for the pharmaceutical industry in Europe, the Middle East and Africa.

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    91Innovations in Pharmaceutical Technology

    Type of products being filledLot/Batch sizesContainer and closure configurationFill volumeLine speedOperator shifts and fatigueFilling line configurationSterile hold times

    Number of units filled (productionvs simulation)Number and frequency of runs

    Acceptance criteria Run durationInterventions – atypical and typicalOther elements that could impact uponsterility assurance

    Also, worst-case conditions are used in many forms of validation, including process simulations. This does not

    mean waiting for a tornado to rip off the cleanroom roof before the media fill, but undertaking the simulation atthe limits of a normal process.

    GROWTH MEDIAThe selection of the correct growth medium to be usedin the process simulation is a very important step. Themedium needs to support the growth of a wide variety of micro-organisms, including aerobic bacteria, yeasts andmoulds. The broad range of organisms being lookedfor is consistent with organisms tracked through thefirm’s environmental monitoring programme. The FDA

    filtration may pose a risk. The largest source of potentially viable contamination comes from people – the operatorsrunning the filling process. Aseptic processing is a processbeing operated in a controlled – but not sterile –environment; the probability of non-sterility cannot be

    calculated. The industry works to recognised, acceptedcontamination levels, so the probability of viablecontamination is recognised and calculated. Routinesampling for sterility testing is not sensitive enough todetect such low level contamination. Sample numbers aretoo small, and only gross contamination is likely to bedetected. Pharmaceutical manufacturers, therefore, needother means of guaranteeing the quality of their product.This is why process simulations (media fills) – supportedby environmental monitoring and other related processes– are required. These are used to demonstrate control of

    the process to the industry standard for allowablecontamination levels.

    MEDIA FILLSMedia fills utilise culture media in place of product toevaluate contamination levels. However, such media fills area snapshot in time, and subtle changes can incur changes incontamination levels. It is therefore of paramountimportance that process simulations are designed toaccurately represent the aseptic process. The new FDA guidelines pay particular attention to this aspect of asepticprocessing, and it is becoming an area requiring more work

    and focus to satisfy the regulators. The media fill should bedesigned to mimic, as closely as possible, the asepticprocesses used in practice. The media fill design is oneelement within the overall considerations to be made in thevalidation of an aseptic process. Areas of focus include:

    Facility and room designDesign of the filling machineProcess flow Heating, ventilation, and air-conditioning design and validation

    Utility design and validationResponse to deviationsTrends in environmental monitoring data Contamination control programmeQuality assurance and quality control systemsProcess simulationsPersonnel training and qualification

    An appreciation of the many factors influencing thevalidation programme allows a process simulation to beeffectively designed. Key elements in the simulation to betaken into account include:

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    Guidance notes the use of soybean casein digest medium,also known as ‘Tryptone Soya Broth’. With concernsabout prion contamination from components of animalorigin found within such media, it is vitally importantthat the medium supplier can provide the necessary

    certifications and documentation for confirming materials are sourced from ‘BSE-free’ countries (such asOxoid Cold Filterable Tryptone Soya Broth – a highly nutritious general purpose medium which is ideal formicrobiological media fills). An alternative approach

    would be to use a medium derived from vegetablematerials such as Oxoid’s Cold Filterable VegetablePeptone Broth, which is a vegetable alternative and issuitable for use in place of Tryptone Soya Broth.

    The guidance also indicates that if the product isbeing filled in anaerobic conditions, usually in a nitrogen

    environment, an anaerobic medium (such as fluidthioglycollate) is used. As already noted, the new guidelines recommend that

    media fills mimic the actual aseptic process as closely aspossible. One of the main areas where this is implicated is

    where the culture medium is introduced into the process.In the past, manufacturers have made up and sterilised themedium outside of the controlled area, and introduced itdirectly into the filling line. In order to more closely mimicthe process, the culture medium should be filtered into theprocess – just as would occur to a liquid pharmaceuticalproduct. This creates several concerns:

    Dried culture media is usually supplied in anon-sterile form and carries a high bioburden,preventing it from being taken directly into a controlled area. It would be preferential to sourcemedia that has been irradiated.For liquid fills, many holding vessels upstream of filtration do not have the capability to heat culturemedia to a temperature adequate to dissolve thepowder into a solution. Even those that have thisability take up time and energy in heating and

    cooling. Sourcing a medium that dissolves atambient temperature would negate such problems.Mycoplasma can be a concern with culture media;therefore assurance of irradication of mycoplasma

    would be favoured.Broths traditionally used for media fills do nothave good filterability characteristics, and could‘blind’ the sterilising filters. This would invalidatethe process simulation. It would be advantageousto understand the filterability profile (such as V max or V cap) of the microbial growth medium, to ensurefilter sizing can tolerate the said medium.

    PROCESS SIMULATIONSGrowth promotion testing must be undertaken on thegrowth medium used for process simulations. There issome confusing guidance as to when to perform this.The FDA Guidance document does not make

    specification on the timing of the test and the EU Annex 1 document does not even ask for a growth promotiontest. However, both the PICS (PharmaceuticalInspectorate Cooperation) and ISO documents ask thatgrowth promotion testing is performed upon conclusionof the incubation period (usually 14 days). Whilst thelatter initially seems to be the more sensible option, italso increases the holding time prior to release, asproduct is waiting for the growth promotion tests to beincubated and analysed.

    Many pharmaceutical manufacturers prefer to run

    growth promotion testing in parallel with the mediafill samples. Randomly removing samples from theprocess simulation run has little basis for detecting contamination. Contamination of the filling line being challenged is a random event, and such samples areunlikely to show all of the contamination present. Inorder to meet the various regulatory guidance ‘half-way’,a compromise would be to fill additional units at the endof the process simulation, and use these for the growthpromotion test. These are then incubated under identicalconditions as the process simulation samples. Thisapproach both ensures that the process simulation units

    and growth promotion test units are separated, and theoverall time of the process simulation project is reduced.

    Any units that are incubated should be inspectedprior to incubation. Any defects that compromise thecontainer closure or non-integral units are rejected. Allrejections should be documented, with reasons forrejection and the number of units rejected. Incubation isthen performed for 14 days at 20-350C (+/-2.50C). Theseparameters have been accepted by the global regulatory authorities and should allow the growth of bacteria,yeast and moulds. Units are incubated in an inverted

    position for the first half of the incubation period,and then returned to an upright position for theremainder. Also, isolates that are seen in the firm’senvironmental monitoring programme need to bepicked up by a media fill run, and data confirming thisshould be made available.

    Through the thorough design and execution of a rugged process simulation, and the use of a high quality growth promotion medium, meticulous challenge of theaseptic process is achieved.

    The author can be contacted at [email protected]

    92 Innovations in Pharmaceutical Technology