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:

EMA: Revision of Annex 6 - Manufacture of Medicinal Gases

EMA: Revision of Annex 6 - Manufacture of Medicinal Gases

EMA and PIC/S have published a concept paper announcing a targeted revision of Annex 6 Manufacture of Medicinal Gases of the EU GMP Guide. The last update dates from 2010. The revision aims to reflect current manufacturing practice, technological progress and lessons learned from the COVID-19 pandemic.

Read more
EMA: Concept Paper on the Revision of Annex 15

EMA: Concept Paper on the Revision of Annex 15

EMA and PIC/S have published a concept paper outlining a targeted revision of Annex 15 (Qualification and Validation).

Read more
Human Resource Management as a Key to Success

Human Resource Management as a Key to Success

The pharmaceutical industry in Germany and other countries, too, faces considerable challenges in the area of human resource management. These problems have far-reaching implications for the competitiveness and innovative power of the industry.

Read more
What do Typical Manufacturing Processes for Sterile Products look like?

What do Typical Manufacturing Processes for Sterile Products look like?

Here's the answer:
Read more
EMA: Reflection Paper on the Qualification of Non-Mutagenic Impurities (NMIs)

EMA: Reflection Paper on the Qualification of Non-Mutagenic Impurities (NMIs)

The EMA has published a new reflection paper outlining its current thinking on the qualification of non-mutagenic impurities (NMIs). The paper addresses recommended approaches for evaluating the safety of new or increased impurity levels, particularly when such impurities exceed the ICH Q3A/Q3B qualification thresholds and are identified after completion of non-clinical toxicology studies.

Read more
EMA: Discussions on the Revised ERA Guideline

EMA: Discussions on the Revised ERA Guideline

During the second industry stakeholder webinar on the revised guideline on environmental risk assessment (ERA) for medicinal products for human use, the European Medicines Agency (EMA) addressed key implementation challenges observed during the first year of application.
Read more
Previous
Next