Requirements for Validation of Cleaning Procedures:
Where cleaning procedures are part of a defined prerequisite plan to control the risk of a specific hazard, the cleaning and disinfection procedures and their frequency shall be validated and records maintained.
What is Cleaning?
- Cleaning is a physio-chemical process involving a number of factors
- Objective – prevent contamination and cross[1]contamination
- Elimination or reduction – hazards
- Variety of hazards to be considered
- Biological, Physical, Chemical and Allergens
- Residuals remaining from detergents
Hazards
- Biological
- Bacteria, yeasts, moulds, viruses, etc
- Physical
- Wood, metal, plastic, etc
- Chemical
- Environmental, process, ingredients, etc
- Allergens
What is Cleaning Validation?
- Validation means Proof that the approved cleaning procedure is capable of producing safe food
- Food businesses by law need to clean and sanitize their facilities. This is required to produce safe and legal food products and remove hazards such as pathogens, allergens and chemicals.
- Food businesses employ Standard Sanitizing Operation Procedures (SSOP) to achieve this.
- In order to ensure that these methods are in fact capable of removing the hazards and reducing the risk to an acceptable level – validation of the cleaning procedure is often required. Particularly for High-Risk unit operations.
- Simply setting up a procedure and checking it a few times (e.g., ATP, swabbing and culturing, residual testing etc.) is not enough to validate a cleaning method as it will not account for the possible variation from employees, chemicals and other parameters. Validation of cleaning methods can be conducted statistically using a capability study.
When is Cleaning Validation Required?
- When risk assessment or legislation requires it
- Critical cleaning, e.g., between manufacturing of one product and another or specific contact surfaces
- Not necessarily for non-critical cleaning, e.g., between batches of the same product or of floors, walls, the outside of vessels
Cleaning Validation Pre-requisites:
- Before any validation can be conducted, you must first put in place certain requirements
- Validation is basically setting up an experiment to prove an hypothesis
- In this example we are looking to prove that a cleaning procedure is in fact capable of achieving the objective of producing safe and legal food
- All this should be documented in a procedure for conducting the validation
Cleaning Validation Procedure:
- Cleaning SOPs for cleaning processes in place
- Cleaning schedules should also be in place
- Cleaning Validation Procedure required:
-
- contact surfaces
- cleaning after product changeover
- between batches in campaigns
- categorizing products for cleaning validation and
- periodic evaluation and revalidation of the number of batches manufactured between cleaning validations.
- Objectives & responsible people
- Cleaning SOP’s
- Cleaning chemicals, concentration, solution volume, water quality
- Time and temperature
- Flow rate, pressure and rinsing
- Number of cleaning cycles
- Description of the equipment – make, model, complexity of design
- Training of operators
- Equipment used for monitoring (e.g., conductivity meters, pH meters)
- Sampling procedures (e.g., direct sampling, rinse sampling, in process monitoring and sampling locations) and the rationale for their use
- Analytical methods
- Acceptance criteria (with rationale for setting the specific limits)
- Revalidation requirements
Cleaning Chemicals
- Solubility of the materials to be removed
- Design and construction of the equipment and surface materials to be cleaned
- Minimum temperature and volume of cleaning agent and rinse solution
- Manufacturer’s recommendations
- Released by quality control and meet food standards or regulations
- Composition known
- Easily removed with rinsing – demonstrated – with acceptable limits defined
- If persistent residues – avoided
- Consider also detergent breakdown
Categorising
- Very similar cleaning procedures for products and processes – no need for individual validation
- “Worst case” may be acceptable and should be justified
- Representative product – most difficult to clean
- Equipment – only when it is similar or the same equipment in different sizes (e.g., 300 l, 500 l and 1000 l tanks).
Cleaning Validation Reports
- The relevant cleaning records – (signed by the operator, checked by production and reviewed by quality assurance) – and source data (original results) should be kept
- The results of the cleaning validation should be presented in cleaning validation reports stating the outcome and conclusion
Equipment
- Cleaning of contact surfaces to be validated. Critical areas should be identified
- Dedicated equipment for:
- products which are difficult to clean,
- equipment which is difficult to clean,
- products with a high safety risk
- The design of equipment may influence the effectiveness of the cleaning process
- Which are the critical areas for sampling?
- What would be considered an appropriate approach for cleaning validation for this piece of equipment?
- What is important about cleaning validation for components / parts of equipment?
- Consider also the different materials, e.g., stainless steel contact surfaces, silicon seals and others
Sampling
- Two methods of sampling:
- direct surface sampling and
- rinse samples
- Combination of the two – most desirable
- Resampling
- May indicate residue presence and poor cleaning procedure
Direct Surface Sampling (direct method)
- Most commonly used method
- Use “swabs” – type of sampling material should not interfere with the test
- Factors to be considered include:
- supplier of the swab,
- area swabbed, number of swabs used, whether they are wet or dry swabs,
- swab handling and swabbing technique
- Other factors include:
- location from which the sample is taken (including worst case locations)
- composition of the equipment (e.g., glass or steel)
- Critical areas (hardest to clean)
- g., in semi-automatic/fully automatic clean-in-place systems
- Use appropriate sampling medium and solvent
Rinse Samples (indirect method)
- Allows sampling of:
- a large surface
- areas that are inaccessible or that cannot be routinely disassembled
- Provides an “overall picture“
- Useful for checking for residues of cleaning agents
- In combination with other sampling methods such as surface sampling
Analytical Methods
- Validated analytical methods – able to detect residuals or contaminants:
- specific for the substance(s) being assayed
- at an appropriate level of cleanliness (sensitivity)
- Sensitive and specific – may include:
- ELISA
- Specific Allergen Testing
- Non-Specific Testing
- Validation of the analytical method should include:
- limit of detection (LOD)
- Reproducibility
Establishing Acceptable Limits
- Limits: Practical, achievable and verifiable
- Rationale: Logical, based on knowledge of materials
- Each situation assessed individually
- There should be no residue from:
- Previous product
- Reaction by-products and detergents
- Cleaning process itself (e.g., detergents or solvents)
- Remember: Uniform distribution of contaminants is not guaranteed
- The limit-setting approach:
- be product-specific
- group products into families and choose a worst case product
- group products into groups according to risk
- Limits may be expressed as:
- a concentration in a subsequent product (ppm),
- limit per surface area (cfu/cm2), or
- in rinse water as ppm.
- Visual
- Certain allergenic ingredients and highly potent material should be undetectable by the best available analytical methods
Cleaning Validation Sample Procedure
- No absolute or correct way to do validation
- The following is a good generic example of how a validation may be conducted
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