Skip to main content Skip to search Skip to main navigation

Definition of Hygiene Zones

7 min. reading time | by Christine Oechslein, PhD
Published in LOGFILE 27/2022

“While there are clearly defined GMP requirements for particulate and microbial air cleanliness for the sterile manufacturing area, there are no concrete requirements for air cleanliness for the non-sterile manufacturing area. In pharmaceutical practice, terms such as "cleanroom Grade E or F", "grey or black area" and, more recently, the terms "CNC" (classified not controlled) and "NC" (not classified) have become common for non-sterile manufacturing“, explains GMP Senior Expert Christine Oechslein.

Read today's feature to find out how you can define hygiene zones, what requirements apply to D and E areas, and where to find information on the required air cleanliness in non-sterile operations.


The virtual company Peither Pharma GmbH produces exclusively solid forms according to the Site Master File (SMF). No narcotics, CMR substances (carcinogenic, mutagenic or reprotoxic substances), sensitising or highly active substances are processed. The present zone concept, material and personnel flows and all other measures to avoid contamination are adapted to this type of product. This includes the use of the terms "grey" and "white" for the middle or cleanest hygiene zone in the company, which is not standardised or normed. These terms are therefore used in the individual companies for different cleanliness classes and must be defined in the zone concept so that their concrete meaning is clear for internals and externals.

Companies that produce other pharmaceutical forms or process critical substances must adapt their zone concept not only to their own spatial conditions, but also to their own product spectrum!

Three zones are defined at Peither Pharma GmbH:

In the SMF of the virtual company Peither Pharma GmbH, "areas of Grade E and D" are defined as follows in the description of the air handling unit under point 4.1.1:

"4.1.1 Brief description of the air handling unit (AHU)
All areas for the open handling of raw materials and/or product are qualified in accordance with cleanroom Grade D. Secondary packaging is carried out in cleanroom Grade E."

The AHU is designed as a pure fresh air system (two-channel system with variable control of the air volume flows). The air is supplied as turbulent air flow via swirl inlets - the air is extracted via short-circuit-free ceiling and floor extraction points. Details are summarised in the following table:

However, since the last update of the SMF (version 03 of May 2018), the underlying recommendations of the expert bodies have been changed, so that no generally valid criteria for air cleanliness in non-sterile manufacturing areas are currently available.

An internal designation of the hygiene zones with letters (according to PIC/S or WHO) or numbers (according to ISO 14644) is therefore currently not clear and therefore not very helpful for employees.
In order not to confuse production staff when future guideline changes use different letters or numbers for zone designations, the virtual company has decided on a solution that is as simple as possible:

The hygiene zones are only differentiated in black, grey and white; the requirements behind them can then be adapted in the event of changes to the specifications, if necessary. The letters E and D refer to the design of the air handling unit (AHU) as described in the SMF. Since nothing has been changed in the AHU, the information in the SMF remains unchanged.

The air cleanliness requirements for the non-sterile manufacturing area are the subject of lively discussion among experts and authorities. While there are clearly defined requirements for particulate and microbial air cleanliness for the sterile manufacturing area (Annex 1 to the EU GMP Guide and in the Aseptic Guide of the US FDA), there are no concrete requirements for air cleanliness in the GMP regulations for the non-sterile manufacturing area.

In pharmaceutical practice, terms such as "cleanroom Grade E or F", "grey or black area" and, more recently, the terms "CNC" (classified not controlled) and "NC" (not classified) have become common for non-sterile manufacturing.

However, each company must determine for itself which requirements are associated with this.

Helpful indications or recommendations on the required air cleanliness, air exchange rates and monitoring frequencies, warning and action limits could previously be taken from the "Aide Memoire Qualification and Validation in Pharmaceutical Manufacturing and Quality Control" (AiM 07121105) published by the German GMP inspectorates. Unfortunately, these tables are missing in the follow-up document AiM 07121107. There, under 3.1.2, it is only stated in general terms: "Decisive for the quality of the manufactured medicinal products is a sufficient hygiene standard in these rooms, to be defined by the manufacturer. The hygiene standard can be defined, among other things, by limit values for the air and surface bacterial count. Appropriate controls must prove that this standard is permanently maintained (routine monitoring). The position of the measuring points must be determined on the basis of the results of the qualification. The microbiological and, if necessary, particulate air quality in production rooms for the manufacture of non-sterile medicinal products is to be defined within the framework of the control strategy. Following the cleanroom classification defined in Annex 1, the environmental conditions shall be selected in such a way that uncontrolled contamination is avoided. Acceptance criteria and appropriate intervals are to be defined for the operating condition ('in operation') on a risk basis as a component of the control strategy to avoid uncontrolled contamination."

The WHO Guidelines on heating, ventilation and air-conditioning systems for non-sterile pharmaceutical products (Technical Report Series, No. 1010, 2018, Annex 8 and Technical Report Series, No. 1019, 2019, Annex 2) also provide neither proposals for cleanroom grades in the non-sterile area nor concrete information on warning and action limits for germs and/or particles. Obviously, it was not possible to agree on meaningful, worldwide standards, because in draft and previous versions, definitions for cleanroom Grades E and F for non-sterile dosage forms were still proposed and CFU/m³ concentrations for the status "at rest" and "in operation" were recommended. However, both are missing in the current documents.

Furthermore, of little help for the definition of air quality for the production of non-sterile medicinal products is ISO 14644 "Cleanrooms and associated controlled environments - Part 1: Classification of air cleanliness by particle concentration", because the ISO classification always refers to all particles - both "living" (germs) and "non-living" (dust, fibres, etc.). However, the ISO standard does not give any values for germ counts (CFU) - but this is exactly what would be required for pharmaceutical classification.

The transition from the black to the grey zone is only possible via personnel or material locks. The grey and white hygiene zones are separated by cleanroom doors.


The text is an excerpt from the German sample SOP 504 Zonenkonzept und Zutrittsberechtigung (zone concept and access authorisation).


Do you have any questions or suggestions? Please contact us at: redaktion@gmp-verlag.de

Christine Oechslein

You may also be interested in the following articles:

Swissmedic Updates Guidance on GMP Compliance of Foreign Manufacturers

Swissmedic Updates Guidance on GMP Compliance of Foreign Manufacturers

Swissmedic has revised its guidance document “GMP compliance by foreign manufacturers”. The new Version 7.0 has been valid since 7 September 2026. In particular, it introduces new provisions for demonstrating the GMP compliance of manufacturers inspected by the US FDA. 
Read more
Swissmedic Updates Requirements for Cooperation with Pre-Wholesalers

Swissmedic Updates Requirements for Cooperation with Pre-Wholesalers

Swissmedic has revised its Technical Interpretation “Market release and distribution in cooperation with a pre-wholesaler”. The document addresses market release and distribution where a Marketing Authorisation Holder works with a pre-wholesaler (logistics and distribution service provider).
Read more
News: Europe

IPEC Updates Two Guides on Pharmaceutical Excipients

The IPEC Federation has updated two key guides on pharmaceutical excipients. The IPEC Composition Guide for Pharmaceutical Excipients (Version 3, 2026) describes an approach for manufacturers to establish excipient composition profiles. The revised version now covers biotechnology- and fermentation-derived excipients, provides further details on component types and physicochemical characterisation, and includes an example composition profile template.
Read more
Applying the FDA’s 7-Step Model for AI/ML Validation in GMP Environments: One Year Later

Applying the FDA’s 7-Step Model for AI/ML Validation in GMP Environments: One Year Later

Artificial intelligence is becoming increasingly important in GMP-regulated environments, presenting companies with new regulatory challenges. This article summarizes the latest regulatory developments, introduces a validation framework based on the FDA's seven-step model, and outlines initial practical experience with AI/ML validation.

Read more
Question of the Week | GMP-Verlag

What are the General Requirements for Standard Documents?

Here's the answer:
Read more
News: Europe

EDQM: Revised Guidance on Sister File Applications

The European Directorate for the Quality of Medicines & HealthCare (EDQM) has revised its Guidance on applications for “sister files” (PA/PH/CEP (09) 141). The revision is intended to support consistent application of the procedure and provide greater clarity on the classification and assessment of the corresponding CEP applications.
Read more
Previous
Next

Related Products

Skip product gallery
GMP Compliance Adviser | Named User Licence | 12M

GMP Compliance Adviser | Named User Licence | 12M

The GMP Compliance Adviser is an online publication that covers all aspects of Good Manufacturing Practice (GMP) in one source.In the GMP Compliance Adviser you’ll find: GMP in Practice This part contains 21 chapters with GMP expert knowledge to base your decisions upon. It provides practical assistance with checklists, templates and SOP examples. It is written by more than 80 authors with hands-on experience directly linked to the industry. The individual chapters describe the different aspects of GMP in clear language. Technical, organizational and procedural aspects are covered.More than 700 checklists, templates and examples of standard operation procedures taken directly out of practice help you in understanding the GMP requirements.GMP RegulationsThese chapters cover the most important GMP regulations from Europe and the United States (CFR and FDA), but also PIC/S, ICH, WHO and many more.  Sample Documents In addition, the GMP Compliance Adviser contains many sample documents and practical examples that you can use.

delivery time appr. 2-5 workdays after receipt of payment
€1,368.00 net excl. VAT
GMP:KnowHow Pharma Logistics (GDP) | Named User Licence | 12M

GMP:KnowHow Pharma Logistics (GDP) | Named User Licence | 12M

Your knowledge portal for GDP-compliant pharmaceutical logistics.  It is important that you as a logistics service provider, but also as a client in the pharmaceutical industry, comply with regulatory requirements. The GMP:KnowHow knowledge portal guides you through the complex regulatory landscape of the pharmaceutical and logistical supply chain! The knowledge portal gives you an easy-to-understand overview of all the important topics. Interactive graphics help you navigate all areas covered by the EU GDP Guidelines (2013/C 343/01). You also have the relevant passages of the regulations directly at hand for each topic. This allows you to compare the requirements directly and saves valuable research time.One thing is certain: the knowledge portal answers your questions about the supply chain of medicinal products, active pharmaceutical ingredients and medical devices. You don't have to be an expert. Yet.You will find answers to your questions in the GMP:KnowHow Pharma Logistics (GDP). Where does GDP begin, where does GMP end? What does GDP-compliant mean? When do I also have to take GMP requirements into account? What permits do I need for certain activities? What requirements do I have to fulfil? What is the current legal basis? How am I covered? What authorizations do I have for my work, e.g. from my employer? Who is responsible — the client or the contractor? And many more What is the difference to the GMP Compliance Adviser? GMP:KnowHow Pharma Logistics (GDP) is a practical knowledge portal dedicated to Good Distribution Practice (GDP). It is a product that is independent of the GMP Compliance Adviser and concentrates on content that is essential for carriers of medicinal products, active pharmaceutical ingredients and medical devices as well as for logistics clients. The focus is on practical knowledge and how to apply it in your daily business. If necessary, the relevant regulations can be called up immediately alongside the practical knowledge, and you can see the relevant paragraphs at a glance. In addition, sample documents are available to help you make immediate progress. AuthorSimone Ferrante, currently Director Quality at Fisher Clinical Services, previously served as Head of Quality Control and Responsible Person (GDP) for the Grieshaber Group. She is also a long-standing author and GDP expert at GMP-Verlag.

delivery time appr. 2-5 workdays after receipt of payment
€610.00 net excl. VAT
E-Learning GMP:READY | Specialist Knowledge GMP for Engineers

E-Learning GMP:READY | Specialist Knowledge GMP for Engineers

Why are GMP rules important for technicians and engineers? Technicians and engineers play a key role in ensuring compliance with Good Manufacturing Practice (GMP) standards. They are involved in critical activities such as: planning and construction of ventilation systems, maintenance of water treatment plants, calibration of measuring sensors. Therefore, they are jointly responsible for the quality of medicines and must ensure that their work complies with GMP standards.Your advantages: Fast familiarization with GMP topics in approx. 2 hours, time- and location-independent online training, printable personal certificate, 12-month access for initial and follow-up training, automatic updates in case of legal changes,content compliant with Article 7(4) of Directive 2003/94/EC.The Author This e-learning course was developed with the collaboration of Dipl.-Ing. Andreas Nuhn (D & B Pharmadesign GmbH).

delivery time appr. 2-5 workdays after receipt of payment
€245.00 net excl. VAT
GMP Fundamentals | A Step-by-Step Guide

GMP Fundamentals | A Step-by-Step Guide

This handbook is a practical and easy to read guideline, giving you a quick and comprehensive overview of the complex world of Good Manufacturing Practice (GMP) without the need of previously acquired knowledge. Some topics are: GMP: Purpose and basic pharmaceutical terms Laws, licenses and inspections Personnel: Responsibility and hygiene Standard Operating Procedures (SOP) and documentation Design of rooms and facilities Processing and packaging Quality control and market release Suppliers, storage and logistics (Good Distribution Practice = GDP) Alphabetical index and abbreviations Using practical examples and comparisons to every-day life will help to easy understand GMP regulations.GMP Fundamentals is a helpful guide which facilitates the entry into the GMP world and teaches the necessary basics.

delivery immediately after receipt of payment
€44.90 net excl. VAT