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:

ICH: Updated Q9(R1) Briefing Pack

ICH: Updated Q9(R1) Briefing Pack

The ICH has fully revised the Q9(R1) Briefing Pack (March/April 2026) to align with the updated ICH Q9 guideline.
Read more
EMA: New Plans for the EU GMP Guide

EMA: New Plans for the EU GMP Guide

EMA published the GMDP Inspectors Working Group’s new 2026-2028 work plan and its 2025 annual report.
Read more
EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA launched a pilot under which EEA GMP inspectors will assess how sites demonstrate the effectiveness of their pharmaceutical quality system for risk-based change management, and whether the EEA GMP certificate could serve as the main evidence of this effectiveness.
Read more
EMA: Updated Guideline on Active Substance Chemistry

EMA: Updated Guideline on Active Substance Chemistry

The EMA has updated guidance on the information required for the manufacture and control of active substances used in medicinal products, with a 1 September 2026 date of application.
Read more
EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA added a new GMP/Q&A section on its website and published a dedicated Q&A document on 3D printing (3DP) for solid oral dosage forms.
Read more
Microbiological Monitoring – Sources of Contamination

Microbiological Monitoring – Sources of Contamination

All pharmaceutical dosage forms must be manufactured under controlled microbiological conditions. This requires microbial monitoring. This applies not only to sterile manufacturing, but also to facilities that manufacture non-sterile products.
Read more
Previous
Next