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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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