biotechnology-derived products do not themselves produce
raw materials, but depend on external suppliers. A certificate of
analysis indicating all tests performed, with results, and includ-
ing data on the adventitious agent testing should also be
obtained. A critical examination of the microbiological safety
testing carried out by the supplier is recommended. As this may
not be appropriate to satisfy the regulatory agencies, manufac-
turers may have to repeat and extend the adventitious agent
testing performed by the supplier to ensure that raw materials
meet the performance and safety requirements for the produc-
tion process. Alternatively, it may be appropriate for the
TEMPs manufacturer to demonstrate that their processing
methods reduce the risk to an acceptable level. Tissue culture
components are also discussed in Guide F2210.
5.4.3 Other raw materials should be tested to demonstrate
they are free of adventitious agents. In some cases, the testing
performed by the raw material supplier is sufficient. If a raw
material is available only as research grade, then the sponsor
should test that material for adventitious agents.
5.5 Transport—After packaging, the external surfaces of the
containers may need to be decontaminated or cleaned or both.
Container integrity and shipping validation are also important
elements for ensuring TEMPs with a minimized defined risk
from adventitious agent contamination are delivered to the
handlers and users of the final products.
5.6 Processing—Adventitious agents can be introduced into
the TEMPs during processing. The agents can be derived from
contaminated environments, personnel, raw materials, and
processing materials, including water, and cross-contamination
from previously or concurrently processed products. Process-
ing is addressed in detail later.
5.7 Storage—Adventitious agents can be introduced during
the storage of all materials. Storage of the starting tissues or
cells, raw materials, and final product requires a standardized
procedure. The outer surface of the container may need to be
decontaminated again prior to use.
6. Processing and Process Validation
6.1 Compliance with GMPs or GTPs, or both, when in
effect, is essential for the production of TEMPs that have a
minimized defined risk of transmitting adventitious agents.
One of the major considerations is aseptic processing. Aseptic
processing must be validated and then periodically revalidated
to prevent contamination by microbial contamination. Refs
(16-18)should be evaluated and applied to TEMPs, where
feasible. Relevant elements are raw materials testing; suitable
control of the processing environment and routine environmen-
tal monitoring; operator training; implemented documentation
systems; use of suitable, validated analytical test methods;
process design; equipment qualification and process validation;
and container-closure system validation. Guide F2210, GMPs,
and GTPs address many of these issues. Process design,
equipment qualification, and process validation are discussed
in the following sections.
6.2 Process Design:
6.2.1 Each step in the process should be evaluated for
potential exposure to environmental contamination, including
introduction of contamination by personnel. Processing
materials, such as water and buffers, should be free from
adventitious agents. Water quality should be evaluated. De-
pending on the intended use, either water for injection (WFI) or
sterile purified water may be appropriate. To ensure further
confidence in the process, where feasible, inactivation steps
that are suitable for adventitious agents should be incorporated
into the process, and decontamination and cleaning protocols
established for any contact surfaces.
6.2.2 When multiple processing steps are used, storage
conditions that protect the product intermediates from adven-
titious agents must be incorporated into the process scheme.
When multiple products are being processed in the same
environment, even more stringent environmental controls may
need to be implemented. The use of disposable equipment may
be advantageous for ensuring microbiological safety of the
TEMPs, but that equipment must be suitably disposed of so
that no other facilities or individuals are put at risk (19).
6.3 Equipment Design and Qualification—Where dispos-
able equipment is not appropriate, equipment design should be
considered to prevent contamination by adventitious agents.
Dead legs, crevices, and threaded fittings are likely sites to
harbor adventitious agents. Contact surfaces must be accessible
and compatible with decontamination and cleaning agents.
Equipment is qualified by performing a design qualification, an
installation qualification, and an operational qualification.
These qualification operations are defined in an ICH document
on good manufacturing practices for active pharmaceutical
ingredients (20).
6.4 Use of Suitable, Validated Analytical Test Methods—
Processes cannot be validated without the use of validated
assays. During development, those assays that provide the most
relevant information should be established and validated. In
some cases, the data from traditionally used assays for adven-
titious agents will not be available in time to release TEMPs
containing viable cells for patient use. Other, more rapid assays
may have to be validated against the traditional assays. Data
from in-process testing are particularly useful for the manu-
facture of products containing viable cells since final product
testing results may not all be available prior to product use.
Appropriate in-process testing is strongly recommended for
such products. For further guidance, see Reference (21).
6.5 Process Validation Issues Relevant to Adventitious
Agent and Contamination Control:
6.5.1 In the case of cellular- and tissue-based TEMPs, it
may be necessary to perform many more runs than the
traditional three to five consecutive runs to ensure the process
controls and outputs are sufficient to minimize the risks from
adventitious agents and their byproducts. For TEMPs, the use
of medium or a product reference standard may be the most
logical approach to maintaining a validated state. Medium or
the standard can be periodically run through the process to
provide documented evidence that the process provides a
product meeting specifications that are related to adventitious
agent control.
6.5.2 Information on process validation can be found in
several documents. FDA has published guides on general
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