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Operators working inside the aseptic core during the manufacture of (b)(4) batches
were observed wearing goggles that had not been adequately sterilized and had two
openings on the top.
The goggles currently worn in the Class 100 area are not sterilized but rather sanitized. Your
disinfectant qualification document “Validation of in-use efficacy of (b)(4) on production
surfaces” does not describe specific studies to demonstrate effective recovery of organisms
from the goggles. The qualification study’s acceptance criteria following disinfection are < (b)
(4) cfu/contact plate of Aspergillus brasiliensis and < (b)(4) cfu/contact plate for all other
organisms. Our expectation is that gowning components, including goggles, be sterilized before
use in an aseptic processing area. However, disinfection may be appropriate if your firm
demonstrates full decontamination. Provide data to support the effectiveness of the disinfection
of the goggles.
Additionally, the investigator noticed that the goggles used in the aseptic core were observed
with two openings of approximately (b)(4) cm x (b)(4) cm. Your firm’s response indicated
that you are evaluating a redesign of the goggles. However, your redesign does not appear to
consider the use of goggles with more protective venting mechanism for operators working in
the aseptic core. Please clarify whether you plan to use the goggles suggested in your firm’s
response or you will explore implementation of more suitable goggles for use in the aseptic
areas. Regardless of the design you ultimately select, it is your responsibility to demonstrate
that it is an appropriate design and the goggles used are not a contamination source. |
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