Qvents

Qvents

Discussion forum for Pharma Quality events, Regulatory Actions

Warning letters, 483s, Recalls, Import Alerts, Audit observations

Forums Quality Assurance (QA) Contamination Control Betalactams, Cytotoxic Contaminations Reply To: Betalactams, Cytotoxic Contaminations

Up
0
Down
::

    A: For beta-lactams, including penicillins, non-penicillin beta-lactam antibacterials, as well as non-antibacterial beta-lactam drugs, APIs, and intermediates, regulatory expectations mandate complete and comprehensive physical separation of manufacturing, packaging, and other operations. This includes the implementation of a robust contamination control strategy involving:
    • Separate air handling units (AHUs)
    • Dedicated equipment
    • Controlled waste flow
    • Management of exhaust systems
    • Separation of utilities and vacuum systems
    • Defined flows for personnel, materials, and gowning
    • Separate entry and exit points
    • Effective decontamination procedures
    These measures are essential due to the highly sensitizing nature of beta-lactams, the difficulty in determining sensitization potential, and the absence of reliable animal testing models to predict human sensitivity. Consequently, documents from beta-lactam manufacturing and operational areas should have a dedicated document archival and documentation cell, not shared with general products documentation archival.
    FDA guidance, Non-Penicillin Beta-Lactam Drugs: A CGMP Framework for Preventing Cross-Contamination, allows for alternate cross-contamination prevention strategies for non-antibacterial beta-lactams. However, this approach is challenging and requires robust data to demonstrate either the absence of contamination incidents or the establishment of a safe threshold below which adverse reactions are unlikely.
    Similarly, for other molecules such as cytotoxic or high-potency drugs, dedicated document archival systems are recommended, especially for products categorized under OEB (Occupational Exposure Band) 4 or OEB 5. Nevertheless, alternate strategies may be considered, provided they are supported by robust data. Such strategies include:
    • Decontamination protocols
    • Use of air showers at operational exits
    • Protective covers and containers for documents
    • Procedural controls for document handling in designated areas
    Any alternate approach must demonstrate that contamination risks are maintained well below defined acceptable levels, such as by adhering to a well-defined PDE (Permitted Daily Exposure) as per the European Medicines Agency (EMA) guidelines on setting health-based exposure limits.
    Reference: USFDA Guidenance: Non-Penicillin BetaLactam Drugs: A CGMP Framework for Preventing Cross-Contamination (https://www.fda.gov/media/159358/download)