Tag Archives: FDA

ORAL SOLID DOSE – Architectural Considerations

Hello good people of the world! Today we’re talking about architectural considerations in the design of oral solid dose (OSD) manufacturing facilities.

In addition to normal architectural standards, the following must be considered for OSD manufacturing facilities:

  • Manufacturing process flow
  • Personnel flow
  • Equipment flow (clean and dirty)
  • Waste flow

Risks to consider when mapping flows include:

  • Risk of contamination from outside contaminates
  • Risk of cross-contamination
  • Risk of mix-up

Risk mitigations should consider:

  • Process containment
  • Isolators
  • Environmental controls
  • Room size
  • Transition spaces and airlocks
  • Personnel controls such as gowning
  • Administrative controls such as frequency of operation

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Oral Solid Dose – Isolation and Containment

Hello good people of the world! Today we’re going to talk about isolation and containment considerations in oral solid dose manufacturing. The purpose of isolation and containment is to control the level of pharmaceutical ingredient exposure to personnel and the environment. It is typically not possible to eliminate all exposures, so we try to reduce it to a tolerable level, which must be defined.

The CFRs and other regulations require manufacturers to limit exposure to customers of any undesirable substance. Limits have been established by industry group and regulatory bodies, and quantify things such as Allowable Daily Exposure (ADE).

Things to look at when considering isolation and containment include:

  • Material flow
  • Personnel flow
  • Operator interventions
  • Sampling
  • Waste flow
  • Maintenance procedures
  • Utility interactions

Isolation and containment risks must be evaluated and mitigated to get a solid handle on the implications. A multi-disciplinary approach must be used. Migations may include:

  • Physical barriers
  • Air control
  • Cleaning procedures
  • Disposables
  • Training

What considerations come in to play in your isolation/containment strageties? Comment below!

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ORAL SOLID DOSE – Supporting Equipment and Systems

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about supporting equipment and systems. The main equipment in unit operations get the spotlight when it comes to manufacturing Oral Solid Dosage forms, but they cannot work without supporting equipment and systems.

Supporting Equipment:
Typical supporting equipment in a OSD manufacturing process includes:

  1. Air Systems: all modern manufacturing processes use air systems for process, instruments, and environment. HVAC helps control environmental conditions, including particulate (viable and nonviable) counts, temperature, and humidity. Compressed air systems may be used in the process to cool or cover product, such as with nitrogen, or operate unit operation steps, such as in fluid bed drying. Automated systems will use compressed air to pneumatically control valves and other components.
  2. Dust Collection: compared to biotech and other pharmacuetical processes, OSD processes have the added complication of dust collection. OSD material movement and processes can create a lot of dust, which can be a risk from a product quality point-of-view, but also a safety point-of-view, since dust can lead to fires and even explosions. Dust collection equipment must be employed to minimize and control dust.
  3. Vacuum Systems: vacuum systems may be used for cleaning, dust collection, and also in process steps such as vacuum drying.

Supporting Systems:
Typical supporting systems include:

  1. Change Control: it is expected that engineering changes are controlled with quality oversight through a formal process.
  2. Preventive Maintenance: it is expected that regular preventive maintenance be performed and documented formally.
  3. Calibration: it is expected that “critical” instruments are calibrated at regular intervals traceable to an international standard. Calibration procedures and results must be formally documented. The method to determine and results of the determination of critical instruments must be documented.

What supporting equipment and/or systems do you use in your OSD manufacturing process? Comment below!

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ORAL SOLID DOSE – Unit Operations

Granulator at an OSD Plant in Vietnam

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about unit operations typical in a oral solid dose manufacturing process.

Typical OSD processes may include some combination of weighing/dispensing, material transfer, blending, granulation, drying, milling/sieving, compression, encapsulation, and coating. Some considerations around each step may include:

  1. Weighing/Dispensing: includes sampling for quality purposes. Materials to be sampled typically include: APIs, excipients, primary and secondary packaging, cleaning agents. Sampling areas must be protected from contamination.
  2. Material Transfer: material flows should be documented and reviewed, with the intention of minimizing any contamination.
  3. Blending: materials are typically blended to ensure a uniform composition, prior to downstream process steps. Many methods exist, including: tumble blending, bin blending, and agitator mixers.
  4. Granulation: granulation is the process of combining particles into a granule. Many methods of granulation exist: wet massing/extrusion, high shear, spray, speronization, and hot melt extrusion, for example.
  5. Drying: the purpose of the drying step is to remove any excess moisture from the drug product. Drying methods include: tray , fluidized bed, and spray drying.
  6. Milling/Sieving: the purpose of this process step is to reduce granule size to conform to specification. Some methods include: impact/hammer mills, conical mills, and oscillating horizontal screens.
  7. Compression: compression is used to create tablets.
  8. Encapsulation: encapsulation is used to create capsules.
  9. Coating: coating is used to apply a coat to tablets

In the next post we’ll cover supporting equipment and quality systems. What process steps do you use in your OSD process? Comment below!

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Oral Solid Dose – Material Handling

Hello good people of the world! Continuing the series on oral solid dosage forms, today we’re going to talk about material handling. Oral solid dose manufacturing is typically a batch process, which means materials need to be transferred from step-to-step. Sometimes there is direct conveyance between steps, but often transfer is performed via Intermediate Bulk Container (IBC).

In terms of design, IBCs should be able to handle the worst-case (lowest) density material in the process. IBCs should be cleanable, especially if a single container will support many product manufacturing processes. IBCs should be designed in such a way that they drain easily. Charging/discharging must be considered.

IBCs may be transported on wheels, or by a pallet truck.

Discharging may be facilitated by applying vibrations to the IBC, either internally or externally.

For direct conveyance, gravity, pneumatic conveyance, and mechanical conveyors are options.

What considerations around material handling do you have in your OSD lines? Comment below!

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Oral Solid Dose – Equipment

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Hello good people of the world! Today’s post is the third in the series covering the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. This post covers the equipment used to manufacture these products.

Considerations include: materials of construction, sampling, and cleanability.

  1. Materials of Construction: it is critical that equipment materials do not react with or otherwise adulterate the product being manufactured. Materials of construction may be metals (e.g. 316L stainless steel), plastics, or elastomers. Other considerations include design documentation, surface finish including at welds, and any certification required.
  2. Sampling: equipment must be designed so that sampling is facilitated where required. Sampling is typically a mitigation for product quality failure modes such as content uniformity in granulation, over/under drying in drying, failed particle size distribution in milling, leakage in encapsulation, and over spray in coating, among others.
  3. Cleanability: automated clean-in-place (CIP) cleaning procedures are preferred where practical. Manual cleaning and sterilization may also be considerations.

What do you think about in terms of your OSD manufacturing equipment?

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Oral Solid Dose – Quality Risk Management Considerations

Hello good people of the world! Today’s post is the second in the series covering the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. This post covers quality risk management.

Quality Risk Management is performed per the principles outlined in ICH Q9. The management process may then be divided up into six (6) steps:

  1. Determine risk areas. These are typically safety, product quality, schedule, cost, etc.
  2. Identify the risks for each area defined in step 1. For example, microbiological contamination may be a risk to product quality, APIs may be a risk to personnel safety.
  3. Identify the failure modes which contribute to the risks identified in step 2. For example, pests contribute to microbiological contamination risk, and HVAC failure could be a vector by which personnel are exposed to an API.
  4. Analyze failure modes and identify mitigations. In our examples procedures around pest control and qualification of HVAC systems could be mitigation to the failure modes identified.
  5. Implement monitoring and CAPA (corrective and preventative action) processes.
  6. Apply a continuous improvement plan to periodically review risks, risk assessments, and mitigation.

There are many tools which may be used to document the process, such as: FMEA, HAZOP, PHA, etc.

How do you execute your quality risk management process?

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Oral Solid Dose – Critical Properties

Hello good people of the world! Today’s post is the first in a series covering considerations around the commissioning, qualification, and validation of facilities, systems, and equipment involved in the manufacture of oral solid dose (OSD) products. OSD is a wide-spread method of pharmaceutical delivery, including well known medicines such as aspirin, Viagra, and many antibiotics. Solid doses can take the form of powders, tablets, capsules, pills, lozenges, granules and more.

Here we’re going to cover the physical and chemical properties that should be considered in equipment design.

First, environmental factors:

  1. Temperature and Humidity: temperature and humidity should be controlled even if the product is not sensitive, as most processes are susceptible to flow issues in the extreme temperature and/or humidity ranges.
  2. Light: some OSD products are light (especially UV light) sensitive and must be protected from sunlight and even indoor light in some cases.
  3. Oxygen: some products may also be sensitive to oxygen exposure.

Second, process factors:

  1. Particle size and size distribution: powders inevitably have some variation in particle size that must be understood and controlled
  2. Particle shape: similarly to size, particles will have variation in shape
  3. Surface properties: are the particles smooth or rough? Do they stick together? Do they readily absorb moisture? Surface properties must be understood
  4. Particle strength: particles will break down under enough force. Particle strength must be understood and undue stress avoided in manufacturing processes.
  5. Density, porosity, and packing: how does a particle pack? Things like minimum bulk density, poured bulk density, and tapped bulk density should be understood.
  6. Cohesion in powders: related to surface properties, how to particles stick together? Magnetic, electrostatic, and intermolecular forces may be in play and should be understood.

What factors do you consider in your OSD manufacturing process?

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Validation Program Tenets

Hello good people of the world! What are the overarching tenets that you go to when making decisions related to your validation program? The regulations and guidance from industry only go so far and you will be regularly tasked with situations unique to your program. How do you know what is the right way to go in the grey areas? I like to keep these tenets in mind:

  1. The manufacturing process should be the most complex process on the site. Reduce complexity everywhere else. Reduce the number of deliverables. Reduce the number of process steps.
  2. Requirements feed specifications feed test protocols. Remember that you should always be able to trace a test case to a requirement through the specifications.
  3. Compliance is not binary, you are accepting degrees of regulatory risk. Make sure you understand the risk and that you accept it.
  4. Good Manufacturing Practices are not just from the CFRs. World-wide best practices need to be considered and applied where applicable.
  5. It’s all about documentation. If it’s not documented it didn’t happen. Create a logical narrative, and you’re already mostly there.
  6. Our primary purpose is to create documentation for agencies. Take any kind of writing class, and one of the first things you’ll learn is: know who your audience is and write for them. While it’s great the validation documentation can be used for commissioning, process improvement, etc. that must not come at the cost of it’s primary purpose.

What are some of your go-to tenets?  Comment below.

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Validation Project Plans

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Hello good people of the world! Today’s post is about Validation Project Plans, which is a specific type of project plan for projects in the pharmaceutical, biotechnology, and medical device regulated industries. This post covers Validation Project Plans for pharmaceutical/biotechnology industries in particular.

Often I’ve see Validation Project Plans contain a lot of fluff but little meat, making them of less value to the project team. A good project plan clearly documents the following, at a minimum:

  1. What facilities, systems, and equipment are in scope of the plan
  2. What are the expected activities and deliverables
  3. Who is responsible for what
  4. What is the validation approach and rationale for that approach
  5. What happens after the validation scope covered in the plan is completed (i.e. ongoing requirements)

Note I do not include project cost or schedule in a project plan, because these are often changing rapidly and should be maintained in a less controlled, more flexible manner, e.g. with scheduling software for a schedule.

The plan itself should be controlled (i.e. approved and revision controlled) as soon as possible in the project but early enough so that scope will not change (too much).

Additional things to think about when drafting your plan:

  1.  Commissioning versus Qualification versus Validation. If your project has multiple phases (and any decent-sized project should), be sure to clearly state responsibilities and deliverables at each stage.
  2. Include references to regulations, industry guidance, and site procedures that govern your plan. Make it clear to everyone who reads the plan what framework you are working inside.
  3. The purpose and scope of the document should be clear and up front.
  4. Get buy-in from all functional groups by having them approve the document.
  5. Like all controlled documents, the plan should have version/revision history.
  6. Use tables to clearly present information.

I put together a quick template here:

Validation Project Plan Template MWV

What do you feel is necessary in a Validation Project Plan? Comment below.

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