|
Expanding
CIP System Functionality
to Meet FDA Requirements
Traditional
components provide the key to efficient clean-in-place (CIP) systems. |
Read
Hayward DST Controls
Mike
Shulim, DST Controls
Bruce
Watts, McGhan Medical

Keywords: Process
control & instrumentation Batch
control Programmable logic
controllers Level control Flow
control Clean
in Place |
|
What
do this cow and these lips have in common? Hint: It improves the lips’
appearance but does little for the cow.
Televised events,
such as the Grammys or Academy Awards, show the public more than a few
"baby boom" entertainers still sporting Generation-X faces. If
we asked how they do it, they might tell us it’s their relationship with
their personal trainer, a vegetarian diet, or yoga. But their real ally
against time, gravity, or "bad-face" genes is often
super-purified bovine collagen.
Collagen is an
animal protein found in the subcutaneous (just beneath the skin) tissues
of all mammals—though it is particularly abundant in cows. Collagen is a
safe and easily injected tissue thickener used in cosmetic and remedial
medicine. Its most common cosmetic uses are to enhance lip borders and
fill in wrinkles due to aging or injury. It is also used in sphincter
resizing as a treatment for stress-induced incontinence. Because it has
few side effects, is of "natural’’ origin, and relatively
inexpensive, collagen competes favorably with more invasive alternatives
such as surgery.
On the surface—no
pun intended—producing collagen is simple. Medical products company,
McGhan Medical (Fremont, Calif.), gets some cowhides, removes the hair;
chops the hide into fine pieces, soaks them in a series of emulsifiers at
the right temperatures for the right amount of time. This mixture is then
centrifuged to separate the collagen from the soup, which is then purified
to specification, packaged in disposable syringes, and shipped to
physician customers.
Once a batch is
complete, the process equipment must be thoroughly cleaned before a new
batch can be started. Interestingly, the Clean-In-Place (CIP) procedure
gets the same amount of attention as the rest of the process by the U.S.
Food and Drug Administration (FDA).
Taking the high
road
Because McGhan Medical needed to meet FDA product safety requirements
consistently, it decided against a minimally functioned CIP control system
for its collagen manufacturing line. McGhan opted for as much control and
data acquisition capability as possible that could be easily supported by
its in-house staff and third-party suppliers. The new CIP monitoring and
control system was expected to meet the following criteria.
- Ensure that the
CIP system works reliably, rendering the process vessels and piping
molecularly spotless after every product run—or alarm loudly if it
isn’t second.
- Verify CIP
reliability by documenting the system’s operational and production
history, and archive this information in FDA-acceptable formats for
periodic comparisons with original IQ/OQ benchmark documentation. (See
accompanying sidebar.)
- Allow for process
expansion to include new products or increased product outputs.
Multiple (as many as
10) wash and rinse cycles are required to thoroughly remove leftover
material from 36 locations in the process piping and vessels. Each
location, which can range from a 2-ft pipe section with a 2-in. diameter
to a 1,000 gal tank, requires its own set of cleaning recipes. The key
component in the rinse cycles is water pure enough for human injection or
Water For Injection (WFI).
Critical CIP
parameters controlled include pressure, temperature, flow, and solution
conductivity (mS or µS). Conductivity values determine cycle times and
indicate presence of either cleaning solution or process material in
"neutral" WFI.
CIP
process
This Clean-In-Place process has four parts.
Step one—the
CIP system performs a test WFI rinse cycle to ensure safe piping
installation and proper valve orientation. The control system monitors
required parameters, alarms any nonconformance, validates the
configuration, and triggers the next step.
Step two—piping
and tanks are washed with a low-concentrate acid solution. During this
cycle, the system precisely measures the amount of solution used and its
electrical conductivity. If the conductivity threshold is met, the control
system advances the CIP to the next step. If not, this step is repeated.
Step three—piping
and vessels are neutralized and cleaned with steam-heated caustic
solution. The control system now monitors this solution’s temperature,
conductivity, and flow rate. When all parameters are satisfied, the system
moves to the next step in the cycle.
Step four—this
last step is a series of WFI rinses, monitored for time and conductivity.
Steps one through four are repeated as long as conductivity values
indicate process residue or nonconforming pH levels.
Flexibility
in an inflexible world
System security is vital in pharmaceutical manufacturing. Maintaining
security while increasing flexibility may seem oxymoronic, but flexible
security is just what McGhan wanted. Hence the project’s system
integrator, DST
Controls (Benicia, Calif.), designed into the system three levels of
critical access security. Each security level (administration,
engineering, or operation) allows only personnel logged-in and cleared for
that level to perform associated actions. All critical operational changes
require someone from each security level to be on hand. Additionally, a
database stores every authorized and unauthorized system login or logout.
For additional
safety, alarms report system failures, hardware failures, process warnings
and failures, and system-resource (CPU load, archive space, etc.)
warnings. On one screen, alarms display chronologically by importance and
system-impact. Alarm acknowledgements, and when-cleared, are also logged
into the alarm database. Report capability includes daily summary, user
logins, alarms, messaging, process and batch data, and user activities.
In case of system
malfunction, unsafe conditions and unknown states are prevented by the
system’s ability to trigger specific behavior for each control system
level. These levels include the I/O modules, PLC, operator stations,
including the computer system, its power source, data storage, and
printer. Additionally, the system is designed to execute a series of
actions (status check of sensors, valves, and pumps) that prepare the
process for a safe and efficient restart in case of an in-process
shutdown.
The system’s PLC
continually monitors the PC’s "heart beat." If, for any
reason, the PLC doesn’t sense the PC’s presence, ordered shutdown is
commenced so that the process won’t continue without FDA-required data
acquisition. In case of power failure, an uninterruptible power supply
provides a minimum of five minutes of continued system power. This allows
a safe shutdown, prevents data loss, enables storage of current
configuration data, and properly auto-configures various I/O devices for
the eventual re-start.
Help
and communication
The CIP system is equipped with messaging, on-line help, user prompts, and
"entry validity checks." This support structure leads users
through correct operation, assists in training new staff, and minimizes
"pilot error" and consequent shutdowns. As messages prompt users
through necessary process steps and advise them on current system
conditions, the HMI system’s embedded safety interlocks prevent users
from overlapping (covering) a more critical screen with a less critical
one. This is especially helpful on those rare occasions when "stuff really
happens."
The control system
also performs validity checks of process values and user-entered set
points. For example, if a set point entered by a user is out of range, the
system rejects the entry and restores the default value. The user is then
notified on-screen with an explanation of the rejection. All attempted
invalid entries and process values are logged and reported.
Additionally, DST
Controls provided complete FDA-ready validation packages for the IQ and OQ.
These packages included test protocols, formal change control procedures,
and factory and site-acceptance tests for installation and operation.
System
specifics
An Intellution (Norwood, Mass.) Fix Dynamics package tracks 300 tags
via 20 process screens, including alarm, login, tending, and recipe
selection screens. A Microsoft Visual Basic application interface sends
data to and from a Microsoft Access database, serves as data acquisition
software, and provides an operator interface for the recipe engine.
The Rockwell
Automation/Allen-Bradley (Mayfield Heights, O.) SLC 505-based control
system, for CIP functions, consists of 350 analog and digital I/O points.
PLC communications with the I/O screens, remote I/O modules, and the
manufacturing process are through Data Highway 485 and Ethernet
communications. The PLC executes variable recipes, monitors alarm
conditions, and controls output devices.
The Microsoft
Windows NT- based system maintains data generated by the process and runs
on an Intel Pentium 300 industrial computer with 256 Mb RAM and two
redundant 800 Mb (RAID-1) hard drives. The visual interface is handled by
two color touchscreens mounted in custom NEMA-4X stainless steel panels. A
redundant second screen allows remote CIP start/run/stop and monitoring
from the manufacturing process’ clean room.
So, what do this cow
and these lips have in common? For patients in need, or those just
aesthetically so inclined, collagen products manufactured using this
system offer a less invasive alternative to the surgeon’s scalpel or
laser knife. In either case, this control solution ensures that
alternative is safe—and provides the data to prove it.
|
Protecting
the medical consumer
|
|
Two
regulatory mechanisms the U.S. Food and Drug Administration (FDA)
uses to ensure pharmaceutical product quality and safety are the
Installation Qualification (IQ) and the Operations Qualification (OQ).
IQ requires
complete documentation of all system components immediately upon
installation. This "photograph" of the physical system
becomes the process benchmark to which the FDA holds the user
responsible. Once the IQ documentation or "validation"
has been submitted to the FDA, any component change requires all
parts of the affected system to be revalidated.
OQ dictates
that all software functions and instructions are also reduced to a
defining documentation package to be approved and archived by the
FDA. As with the IQ, no functional OQ changes can be made without
voiding FDA approval and triggering a new validation process
before sellable product can be run. This micro-scrutiny ensures
that once a pharmaceutical process is proven to consistently
produce acceptable (i.e., safe) product, it is not allowed to
drift out of its FDA-approved configuration, which could call
output quality into question.
|
|
|
Read
Hayward is VP Sales and Marketing and Mike Shulim, is Engineeing
Director, for DST Controls, a systems integrator located in
Benicia, Calif. Bruce Watts is project leader for McGhan
Medical, a medical products manufacturer, located in Fremont,
Calif.
|
|