Skip to main content Skip to search Skip to main navigation

MHRA inspections: Deficiencies and expectations on HBELs and cross contaminations – PIC/S AiM and Q&A provide answers

On its Inspectorate Blog, the UK MHRA (Medicines and Healthcare products Regulatory Agency) has critically reviewed the implementation of the requirements on HBELs and the prevention of cross contamination in shared facilities. What are the expectations to be met and what deficiencies have been identified in recent inspections?

According to the MHRA Inspectorate Blog, answers can be found in these two PIC/S documents:

The two documents were published in June 2020 (we reported).  They address the requirements for setting health-based exposure limits (HBELs) and quality risk assessment to control cross contamination. Through this blog, pharmaceutical manufacturers are now to be made aware of critical deficiencies that arose during recent remote inspections. These are directly linked to the expectations described in the PIC/S documents.  

Here are some shortcomings that occurred during MHRA inspections:

Reference: PIC/S Q&A 3:
It was noticed that companies conducted risk assessments without reference to the required HBEL levels, required to control. Often the HBELs are only used to establish acceptance criteria for cleaning validation. However, HBELs reflect the relationship between residue levels at both batch and unit dose level needing to be controlled. The MHRA proposes a pictorial representation of critical HBELs as well as a clearly defined documented process.  

Reference: PIC/S Q&A 4:
It is noticeable that although all HBELs have been completed within the company, they were generated by employees without the necessary experience and without toxicological expertise. The PIC/S Q&A question 4 clarifies the expectations on the qualification of the personnel.

Reference: PIC/S Q&A 7 and 8:
It was noticed that with product changeover in a shared facility, analytical testing is often omitted. Instead, only visual checks are carried out. This visual control during product change is usually not sufficient to detect product contamination and to safely maintain the HBEL. Especially in case of manual cleaning, this is a high-risk procedure. The PIC/S HBEL Q&A describes situations where a visual control is sufficient in questions 7 and 8.

The MHRA refers pharmaceutical manufacturers to the PIC/S documents in order to clarify the requirements to control cross contamination.  It should be critically examined whether the current cleaning validation used in a company is really reproducible and consistent, especially when performing manual cleaning. In the past year there have been violations in several companies which required actions.


Source:

MHRA: Inspectorate Blog

Meet the GMP Compliance Adviser

The GMP Compliance Adviser is the world's largest knowledge portal for quality management in the pharma business. 

The demo access is non-binding and ends automatically.

Test it now for free

You may also be interested in the following articles:

FDA: Draft Guidance on Responding to Form 483 Observations

FDA: Draft Guidance on Responding to Form 483 Observations

The US Food and Drug Administration (FDA) has issued a draft guidance on responding to Form FDA-483 observations following drug CGMP inspections. The document provides recommendations on how manufacturers should structure their responses and what information they should include.
Read more
Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Which Quality and Process Parameters must Typically be Taken into Account During Process Validation for Terminally Sterilized Products?

Here's the answer:
Read more
Veterinary GMP 2026: The New Regulatory Framework

Veterinary GMP 2026: The New Regulatory Framework

Implementing Regulations (EU) 2025/2091 and 2025/2154 consolidate the GMP requirements for veterinary medicinal products into a distinct and legally binding framework for the first time. While establishing regulatory independence for the veterinary sector, they remain substantively aligned with the EU GMP Guide.
Read more
Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB: Opportunities and Concerns in the MDR/IVDR Revision

Team-NB, the European association of medical device Notified Bodies, sees the proposed MDR and IVDR revision as an opportunity to improve efficiency, transparency and predictability in conformity assessment.
Read more
EMA: GMP Documentation for the Sterilisation of an API

EMA: GMP Documentation for the Sterilisation of an API

The EMA Q&A on the quality of medicines has been updated with a new question: “What kind of GMP documentation is required for an API manufacturer performing sterilisation of an active substance?”

Read more
EMA: Updated Q&A on OOS Batches of ATMPs

EMA: Updated Q&A on OOS Batches of ATMPs

The EMA has revised its questions and answers on the use of out-of-specification (OOS) batches of authorised cell- and tissue-based ATMPs (“Questions and answers on the use of out-of-specification batches of authorised cell/tissue-based ATMPs”, Rev. 1, 2026).
Read more
Previous
Next