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Some Regulations Governing the Test
21CFR211.94 Drug Product Containers and Closures2
(a) Drug product containers and closures shall not be reactive,
additive, or absorptive so as to alter the safety, identity, strength,
quality, or purity of the drug beyond the official or established
requirements.
(b) Container closure systems shall provide adequate protection
against foreseeable external factors in storage and use that can
cause deterioration or contamination of the drug product.
(c) Drug product containers and closures shall be clean and, where
indicated by the nature of the drug, sterilized and processed to
remove pyrogenic properties to assure that they are suitable for
their intended use. Such depyrogenation processes shall be
validated.
(d) Standards or specifications, methods of testing, and, where
indicated, methods of cleaning, sterilizing, and processing to
remove pyrogenic properties shall be written and followed for
drug product containers and closures.
Some Regulations Governing the Test
European Commission EudraLex- The Rules Governing
Medicinal Products in the European Union
Annex 1- Manufacture of Sterile Medicinal Products
• 117. “Containers should be closed by appropriately validated
methods. Containers closed by fusion, e.g. glass or plastic
ampoules should be subject to 100% integrity testing. Samples of
other containers should be checked for integrity according to
appropriate procedures.”1
• *Repeated in PIC/S PE 009-12 (Pharmaceutical Inspection
Convention)12
Volume 4- Part II Basic Requirements for Active Substances
used as Starting Materials
• 9.20. “Containers should provide adequate protection against
deterioration or contamination of the intermediate or API that
may occur during transportation and recommended storage.”3
Some Regulations Governing the Test
ICH Harmonized Triplicated Guideline, Quality of Biotechnological
Products: Stability Testing of Biotechnological/Biological Products
Q5C10
Sterility testing or alternatives (e.g. container/closure integrity testing)
should be performed at a minimum initially and at the end of the
proposed shelf-life. 10
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A Few Regulatory Observations Regarding
Container and Closure System Integrity Testing
FDA Warning Letter Dated 24Jun09:
This is a repeat violation of the February 2007 inspection.
Your QCU failed to establish an adequate stability testing
program designed to evaluate the integrity of the container-
closure system. Specifically, SOP-QC-XXXX does not include
the storage orientation for liquid products. The stability
samples for liquid products should be stored in an upright or
inverted orientation in order to test and evaluate the integrity
of the bottle seal.
A Few Regulatory Observations Regarding
Container and Closure System Integrity Testing
FDA Warning Letter Dated 20Jan11:
Your firm failed to ensure your container closure system
provided adequate protection against foreseeable external
factors in storage and use that can cause deterioration or
contamination of the drug product [21 C.F.R. § 211.94(b)].
• For example, your firm identified 542 incidences through consumer complaints of
product defects such as, leaks, bursts, and premature activation during the period of
January 2008 to August 2010. These are critical defects that can impact sterility and
stability of your product. Your firm identified that the probable cause was the result of
defective materials used in the manufacture of the container closure system.
• Your response is not adequate since the sampling plans described are
not based on appropriate statistical criteria to sufficiently identify
these known potential defects, especially given the history of the
supplier for this container closure system.
• Furthermore, your final product inspection procedure and use of a (b)(4) does not appear
to be effective in preventing shipments of product with critical defects to the
marketplace. Additionally, our data indicates there may be other cases of foreign
substances in products manufactured at your facility such as an insect found in the
intravenous solution of XXXX and dirt reported inside of (b)(4) and the (b)(4) of XXXXX®.
Please provide an evaluation of the suitability of any of these potentially affected lots.
A Few Regulatory Observations Regarding
Container and Closure System Integrity Testing
FDA Warning Letter Dated 31May13:
Your firm failed to ensure your container closure system
provided adequate protection against foreseeable external
factors in storage and use that can cause deterioration or
contamination of the drug product (21 CFR 211.94(b)).
For example, you received consumer complaints identifying at
least ten (10) membrane leaks and one hundred fifty-five
(155) inadequately-fitting blue caps during the period of
November 2011 to March 2013. These are critical defects that
can impact the sterility and stability of your products.
This is a repeat violation
A Few Regulatory Observations Regarding
Container and Closure System Integrity Testing
FDA Warning Letter Dated 02Nov15:
FDA investigators also noted CGMP violations at your facility,
causing your drug product(s) to be adulterated within the
meaning of section 501(a)(2)(B) of the FDCA. The violations
include, for example:
• Your firm failed to establish adequate written procedures designed to
assure batch uniformity and integrity of drug products that describe
the in-process controls, and tests, or examinations to be conducted on
appropriate samples of in-process materials of each batch (21 CFR
211.110(a)).
• Your firm failed to ensure container closure systems provide protection
against foreseeable external factors in storage and use that can cause
deterioration or contamination of the drug product (21 CFR 211.94(b)).
A Few Regulatory Observations Regarding
Container and Closure System Integrity Testing
FDA Warning Letter Dated 21APR16:
Puncturing a container compromises the integrity of the container closure
system, and each puncture increases the chances of contamination.
In response to our observation regarding (b)(4), you indicated that you
developed a container closure integrity test for the (b)(4) and plan to
demonstrate the sterility of the (b)(4) throughout its expiry. However, this
test only confirms the sampled portion is sterile and does not validate the
integrity of the container. Additionally, the tested portion may not have
detectable microbial contamination after the (b)(4) container loses
integrity, but the amount of bacterial endotoxin may still increase. Your
proposed corrective action is not adequate to demonstrate container
closure integrity. Therefore, your response does not indicate how you will
ensure your finished product is sterile and the amount of endotoxin is
within an acceptable limit after multiple punctures to the (b)(4)
containers.
Examining Some of the Various Testing Methods
Container closure integrity testing can be performed in
many different ways.
All methods have pros and cons.8
Some containers, such as ampoules, require 100% integrity
testing.4
New proposed changes to USP Chapter <1207> describes
several methods the user and experiment with.
The proposed update removes the requirement to
compare the results of other container closure integrity
(CCI) assays to the microbial ingress challenge.
The updated chapter series is expected to become official
in August 2016.
Examining Some of the Various Testing Methods
The chapter (proposed USP <1207>) divides the tests
into two major categories.
Deterministic- less subject to error and provide
quantitative results8
Probabilistic- more uncertainty in assay results,
includes traditional methods8
Testing methods included in the chapter were chosen
from peer reviewed articles and are supported by the
American Society for Testing and Materials (ASTM) 8
The user may choose from the methods listed or even
methods not listed as long as the final method is properly
validated and optimized for the closure system.8
Examining Some of the Various Testing Methods
Deterministic methods include:
Electrical Conductivity and Capacitance Test
(HVLD)
Laser-based Gas Headspace Analysis
Mass Extraction
Pressure Decay
Tracer Gas (vacuum mode)
Vacuum Decay
http://www.cincinnati-test.com/pressure-decay-test-systems.html
Examining Some of the Various Testing Methods
Deterministic Test Time
Package Content Package Leak Size Class Effect of Method
Leak Test Measurement Outcome and Data Analysis Order of
Requirements Requirements (Detection Range) on Package
Technologies Magnitude
Electrical Liquid (with no combustion Less electrically 3 to 6 Quantitative measure of electrical current Nondestructive, Seconds
conductivity and risk) must be more conductive than passing through the test sample: provides an although product
capacitance electrically conductive liquid product. Range varies with indirect determination of leak presence as stability studies
(high-voltage leak than package. product–package, shown by a drop in test sample electrical are recommended
detection) instrument, test resistivity, with a resultant increase in voltage to verify effect of
Product must be present sample fixturing, reading above a predetermined pass/fail limit. exposure.
at leak site. and method
parameters.
Laser-based gas Gas volume, path length, Transparent or 1 to 6 Quantitative measure of gas headspace Nondestructive Seconds
headspace and content must be translucent, content of the test sample by laser-based gas
analysis compatible with amber or Detection of analysis, for product requiring a headspace of
instrument’s detection colorless. smallest leakage low oxygen concentration, low moisture vapor
capability. rates is a function concentration, and/or low absolute pressure.
of time span
between analyses. To calculate the leak rate of the test sample,
one can use results compiled as a function of
time.
Mass extraction Gas or liquid must be Rigid, or flexible 3 to 6 Quantitative measure of mass flow rate Nondestructive Seconds to
present at leak site. with package resulting from test sample headspace escape minutes
Presence of liquid at leak restraint Range varies with or liquid product volatilization within an
site requires test mechanism. product–package, evacuated test chamber housing the test
pressures below vapor instrument, test sample.
pressure. Porous package fixtures/chamber,
requires masking and method Leak rate of the test sample may be estimated
Product must not clog leak to limit gas flow parameters. by comparing the mass flow results of the test
path. through porous sample to tests performed using leak rate
material. standards and positive controls.
Microbial
Challenge by Immersion and Dye Ingress
are the most recognized leak test methods.
USP<1207> Series is encouraging a move toward
the deterministic methods.
Examining Some of the Various Testing Methods
Probabilistic Test Time
Package Content Package Leak Size Class Measurement Outcome and Data Effect of Method
Leak Test Order of
Requirements Requirements (Detection Range) Analysis on Package
Technologies Magnitude
Bubble emission Gas must be present at Rigid, or flexible 4 to 6 Qualitative measure by visual inspection of Destructive Minutes
leak site. with package bubble emission caused by escape of test
restraint Range varies with sample headspace while sample is
Product (especially liquids mechanism. product–package, submerged and exposed to differential
or semi-solids) must not test sample fixturing pressure conditions. Alternatively, sample
cover package surfaces to and positioning, surfaces may be exposed to surfactant.
be leak tested. method parameters,
and analyst technique Continuous bubble emission indicates
and skill. presence of a leak, its location, and its
relative size.
Microbial Growth-supportive media Able to tolerate 4 to 6 Qualitative measure by visual inspection of Destructive Weeks
challenge, or product. pressure and microorganism growth inside test samples
immersion immersion Range varies with filled with growth-supportive media or
exposure Presence of liquid at the challenge. container-closure, product, post immersion in heavily
leak site required for test sample fixturing contaminated challenge media while
method reliability. Rigid, or flexible and positioning, exposed to differential pressure conditions,
with package challenge condition followed by incubation to encourage
restraint severity, and inherent microbial growth.
mechanism. biological variability.
Growth in the test sample indicates the
presence of test sample leak site(s)
capable of allowing passive or active entry
of microbes.
Examining Some of the Various Testing Methods
Probabilistic Test Time
Package Content Package Leak Size Class Measurement Outcome and Data Effect of Method
Leak Test Order of
Requirements Requirements (Detection Range) Analysis on Package
Technologies Magnitude
Tracer gas Tracer gas must be added Leak site 3 to 6 Quantitative measure by spectroscopic Nondestructive, Seconds to
detection, sniffer to package. accessible to analysis of tracer gas near the outer although access to minutes
mode probe. Range varies with test surfaces of the tracer-flooded test package interior for
Tracer gas must have sample, method sample, sampled using a sniffer probe. tracer gas
access to package surfaces Limited tracer gas parameters, test sample introduction may
to be tested for leaks. permeability. fixturing, and analyst Tracer presence above a pass/fail limit compromise test
technique and skill. indicates presence and location of a leak sample barrier.
Smaller leak detection site.
may be possible under
optimum test conditions.
Tracer liquid Contents must be Rigid, or flexible 4 to 6 Measure of tracer in test sample Destructive Minutes to
compatible with liquid tracer. with package previously submerged in tracer-charged hours
restraint Able to tolerate liquid liquid while exposed to differential
Product must not clog leak mechanism. immersion. pressure conditions. Alternatively, tracer-
path. charged test samples may be submerged
Compatible with Smaller leak detection in tracer-free collection fluid.
liquid tracer may be possible under
detection mode. optimal test conditions Tracer presence indicates leak site(s)
employing chemical capable of allowing tracer passage, and
analysis tracer detection. tracer magnitude may indicate relative
leak size (assuming a single-leak
Range varies with pathway).
container-closure, test
sample fixturing and Tracer migration measurement may be
positioning, challenge quantitative (by chemical analysis;
condition severity, and preferred approach for small leak
tracer liquid content. detection) or qualitative (by visual
inspection).
aThe leak size class detection range cited for each technology allows for method-to-method comparison. The leak sizes actually detected by a fully developed and validated deterministic method
may deviate from these ranges, as noted.
Examining Some of the Various Testing Methods
Advantages
Microbial Challenge by Immersion • Widely used for
decades11
Suitable for any container-closure system that can • Industry and
withstand immersion and pressure changes.17 regulatory
familiarity11
• Readily incorporated
Test article is immersed in a broth containing the test into media fills11
organism. 17
Disadvantages
• Brevundimonas diminuta, Serratia marcescens, • Less sensitive11
Escherichia coli and other organisms have been used • Detection
probabilistic for
for this test. 17 small-size defects
(i.e. <20 µm) 11
This test may be static (no pressure or vacuum) or • Destructive11
dynamic (pressure and vacuum are applied, typically to
simulate air transport) 17
Key test factors include: bacterial size and motility,
differential pressure, challenge media, exposure time,
and viable count in the challenge media. 17
Examining Some of the Various Testing Methods
Advantages
Tracer Liquid Tests (e.g. Dye Ingress) • Widely used for
decades11
The dye leak test is the most common liquid tracer • Industry and
test.15 regulatory
familiarity11
• The container is immersed in a methylene blue solution
and pressure and vacuum are applied to the container. 15 Disadvantages
• Less sensitive11
• The container inspected visually or via • Detection
spectrophotometry (preferred method). 15 probabilistic for
small-size defects
Key factors include differential pressure, compatibility (i.e. <20 µm) 11
• Destructive11
of the dye with the product, liquid viscosity and
surface tension, inspector training and experience (for
visual inspection) or assay sensitivity (for
spectrophotometry). 15
Qualitative and destructive17
Examining Some of the Various Testing Methods
Bubble Tests
The item under test is pressurized to about 3 psig and
immersed in a bath containing water or water and
surfactant (e.g., polysorbate 80).15
• This test can detect leaks as small as 10-5 mbar-L/sec.15
Key test factors include differential pressure, test
time, immersion fluid surface tension, visible
inspection conditions (e.g., light intensity,
magnification, and background), and visual
inspector training and experience.15
Qualitative and destructive17
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Examining Some of the Various Testing Methods
Tracer Gas (Sniffer Mode)
Test samples are flooded completely or partially with the
tracer gas via one of several options. 17
• Piercing a closed test sample to introduce pressurized tracer
gas (sealant is applied to close the puncture site) 17
• Flooding the test sample before package closure17
• “Soaking” a closed test sample by pressurizing with tracer gas
(most applicable to larger leak detection) 17
Test samples are checked for leakage by scanning the outer
package surfaces using a vacuum wand17
The use of negative and positive controls along with the test
samples provides evidence of test method limit of
detection.17
The sniffer mode is generally chosen when the leak location
must be identified. 17
Developing and
Validating the Method
Developing a Method
Package integrity verification occurs during three product
life cycle phases:14
1. The development and validation of the product-
package system
2. Product manufacturing
3. Commercial product shelf-life stability assessments
Testing needs to show the complete picture of container
CCI over the lifecycle of the product.
Any leak test requires optimization for each product-
package application.13
Developing a Method
All methods have limitations, but the following aspects
should be considered.11
Methods must be suitable for its intended use
Methods must be applicable to the specific drug product- Other Criteria
package (e.g. drug products can interact with CCI defects) • Liquid or solid product?
• Headspace gas?
Methods must detect leaks effectively • Headspace vacuum?
• No Headspace?
Non-destructive CCI testing • Package design?
•
Choose a preliminary method following vendor’s •
Rigid or flexible package?
Moveable components?
recommendations or literature research. • Polymeric materials?
• Metallic materials?
Choice of method depends on specific desired outcomes14 • Transparent or Opaque
1. Detecting the presence of leak paths materials?
• Porous materials?
2. Determining the location of leak paths • Multi-dose systems?
http://www.rxpax.com/training-services/
Developing a Method
USP <1207.1> and ICH Q2 (R1) describes how to
determine and establish a limit of detection (LOD) for
the method chosen. 14
The LOD is the smallest leakage rate or leak size that the
method can reliably detect, given the product-package of
interest.14
During method development trials all negative controls must
pass and all positive controls with leaks at or above the
claimed limit of detection must fail. 14
The LOD for a given method is defined as the smallest-leak
positive control subset that consistently demonstrates
leakage in 100% of the positive-control subset units at that
defect size and larger. 14
• The percentage of positive controls to be detected must be specified
in the validation study protocol by the end user. 14
Multiple methods are available to determine limit of
detection criteria.
Developing a Method
USP <1207.1> also describes the need to verify the
largest leak detection capability or upper limit of
detection.
All analytical methods have optimum measurement ranges. 14
All leak test method selection should also take into account the largest
leak sizes likely to occur in the sample population. 14