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Effectively Using Contamination Control Strategies

Michelle Heiter, laboratory and quality control specialist, and Susan J. Schniepp, distinguished fellow, Regulatory Compliance Associates, a Nelson Labs Company, discuss how to effectively use contamination control strategies in your operations.

 

Key Takeaways

  • A CCS is mandated by EU and US regulations and ICH guidelines to ensure product safety and compliance in pharmaceutical manufacturing.
  • Key CCS elements include monitoring, validation, contamination controls, and fostering a quality culture through personnel management.
  • Risk assessments identify and prioritize contamination risks, enabling targeted preventative measures and resource allocation.
  • A robust CCS enhances product quality, patient safety, and regulatory compliance, fostering continuous improvement and company reputation

Q. What is a contamination control strategy (CCS) and how does it support sustainable compliance and continuous improvement?

A. A CCS is required in pharmaceutical manufacturing to ensure product safety, regulatory compliance, and efficient operations. The updated EudraLex, Volume 4, Annex 1 (1) mandates a CCS for sterile manufacturing in the European Union, aligning with similar FDA requirements (2, 3) in the United States, as well as International Council for Harmonisation (ICH) Q9 Quality Risk Management (4) and ICH Q10 Pharmaceutical Quality System (5) guidelines.

 

A review of FDA 483s and FDA Complete Response Letters (CRLs) highlights areas for improvement in pharmaceutical manufacturing. Citations have been issued for deficiencies related to microbial contamination, environmental monitoring, and aseptic practices. Addressing these observations is required for drug approvals and to strengthen a CCS.

 

A CCS is a holistic approach to minimizing contamination by evaluating good manufacturing practices (GMPs). A CCS provides a proactive method for identifying, controlling, and scientifically evaluating quality risks designed to reduce contamination and enhance product safety and quality.

 

Elements of a CCS include the following (6):

  • Monitoring controls—personnel, in-process, materials, environmental, utilities, and pest controls
  • Validation controls—qualification/requalification of personnel, process, analytical methods, facility, utilities, and equipment
  • Contamination controls—personnel training, hygiene and gowning, process design, vendor material, consumable containers, equipment design, cleaning and sanitization
  • Personnel awareness/quality culture
  • Quality risk management and risk assessment identify potential contamination sources and assess their impact on product quality and safety
  • Scientific and technical knowledge to prevent contamination
  • Personnel management to empower personnel through training. Staff education, awareness, and skills play a crucial role in maintaining contamination control.

 

A strong CCS serves as an invaluable quality tool, ensuring regulatory compliance while safeguarding product quality, safety, and enhancing the company’s reputation. Let’s embrace its power!

 

Q. Why is a risk assessment required for a CCS?

A. Conducting a risk assessment is critical for a successful CCS. It helps to proactively identify contamination sources and their effects, enabling implementation of targeted preventative measures that safeguard both products and the well-being of patients.

 

A risk assessment is key to:

  • Identify hazards and risks before they turn into real problems.
  • Prioritize control measures based on the severity and likelihood of each risk to enable the allocation of resources to the areas vulnerable to contamination.
  • Regulatory compliance and a commitment to product quality and safety are essential for meeting regulatory standards in our industry.
  • Fostering continuous improvement by gathering insights, streamlining processes, and embracing innovative technologies. A proactive approach reduces risks and drives growth. This approach enables us to maintain control at every stage of the product lifecycle.
  • Encouraging a culture of safety that involves cross-functional team members in the risk assessment process. This approach helps everyone understand and take responsibility for contamination control.

 

A robust CCS begins with a risk assessment. By proactively identifying and addressing contamination risks, we improve product quality, prioritize patient safety, and confidently meet regulatory standards.

 

References

  1. European Commission. EudraLex–Volume 4–Good Manufacturing Practice (GMP) Guidelines: Annex 1–Manufacture of Sterile Medicinal Products (2022 revision).
  2. FDA. Code of Federal Regulations Title 21, Parts 201 and 211. Current Good Manufacturing Practice for Drugs. 2023.
  3. Parenteral Drug Association. Technical Report No. 90: Contamination Control Strategy Development in Pharmaceutical Manufacturing (PDA, 2023).
  4. ICH. Q9 Quality Risk Management (ICH, 2005).
  5. ICH. Q10 Pharmaceutical Quality Systems (ICH, 2008).
  6. Chakraborty, S. and Baseman, H. Contamination Control Strategies: A Path for Quality and Safety. PDA.org, May 8, 2022, pda.org/pda-letter-portal/home/full-article/contamination-control-strategies-a-path-for-quality-safety (accessed Jul. 21, 2025).

Article details

Pharmaceutical Technology®
Vol. 49, No. 7
Page: 34

 

Citation

When referring to this article, please cite it as Heiter, M. and Schniepp, S. Effectively Using Contamination Control Strategies. Pharmaceutical Technology 2025 49 (7).

FDA Expands Unannounced Inspections for Foreign Manufacturing Facilities

Posted on by Brandon Miller

Regulatory Compliance Associates® (RCA) Executive Pharma Compliance Expert & Principal Consultant, Anita Michael, recently shared important FDA updates impacting pharmaceutical manufacturers. With over 25 years of global regulatory and quality experience—including 16 years as the FDA’s Global Pharmaceutical Expert—Anita emphasizes the need for heightened inspection readiness.

 

Key FDA Updates

  • Unannounced Inspections Abroad: The FDA will now conduct unannounced inspections at foreign manufacturing facilities, similar to those already performed in the U.S. This expansion ensures drug substances, finished products, and critical excipients entering the U.S. meet safety and quality standards.
  • Rigorous Reviews: Expect science-based audits across manufacturing operations and quality systems. Companies should ensure their
  • six quality systems (Quality, Production, Laboratory, Facilities & Equipment, Materials, and Packaging/Labeling) are fully inspection-ready.
  • Pre-Approval Program Updates: The FDA has refined its pre-approval inspection focus to include:
    • Readiness for commercial manufacturing (QMS and six systems)
    • Conformance to application and data integrity requirements
    • Commitment to quality and pharmaceutical development
    • Audit preparedness and documentation management

Preparing for Compliance

  • To stay ahead, companies should:Conduct robust internal and external audits
  • Maintain a centralized FDA document repository
  • Ensure subject matter experts are prepared to address complex regulatory questions

 

Why It Matters

These changes highlight the FDA’s commitment to protecting U.S. patients by ensuring consistent global manufacturing standards. Proactive preparation will be critical for pharmaceutical companies with international facilities or partnerships.

 

Need support preparing for FDA inspections or audits? Contact RCA today to speak with our compliance experts and ensure your organization is inspection-ready.

Integrating Device Design into a Biosimilar Program

Background

An established pharmaceutical company with a strong background in biologics and biosimilars was preparing to enter Phase 3 clinical trials with a biosimilar product. While their drug development and manufacturing teams were experienced and well-resourced, the organization had no prior experience with medical devices.

With the introduction of FDA’s combination product regulations and 21 CFR Part 4, the company realized they needed to house their drug product in a drug delivery system—triggering a set of new design and regulatory requirements. Despite their mature quality system aligned to 21 CFR Parts 210/211, they lacked the internal expertise and infrastructure to integrate device development, design controls, and risk management into their QMS.

RCA Approach

Regulatory Compliance Associates® (RCA). was brought in to establish a compliant and sustainable combination product development framework. The engagement began with a comprehensive gap assessment to evaluate the client’s current quality system against the regulatory requirements in 21 CFR Part 820 and Part 4.

While foundational systems like CAPA were already robust, gaps were identified in design controls, risk management, and supplier controls. RCA worked closely with the client to integrate these new requirements into the organization’s operations.

Key activities included:

  • Developing and revising SOPs: 
    • Multiple SOPs were created covering design controls, risk management, and management responsibilities. 
    • Existing SOPs (such as Purchasing Controls) were updated to reflect device-specific needs. 
  • Training cross-functional teams: 
    • RCA conducted training sessions for QA, regulatory affairs, manufacturing operations, and marketing on combination product regulations and new procedures. 
  • Establishing design documentation: 
    • Created complete design history files (DHFs) using new SOPs. 
    • Developed design and development plans, design input requirements, and detailed design specifications for all components, packaging, and labeling. 
    • Facilitated risk assessments through cross-functional collaboration. 
  • Technical and manufacturing support: 
    • Integrated device tests into ongoing stability studies. 
    • Worked with external vendors on component specifications. 
    • Helped develop and qualify an in-house final assembly process and supported manufacturing process qualifications for new equipment. 
    • Conducted and documented a design transfer to manufacturing. 
  • Verification & validation (V&V): 
    • Executed comprehensive testing, including: 
      • Container Closure Integrity 
      • Delivered Volume 
      • Break Loose and Glide Force 
      • Human Factors (Formative and Summative) per IEC 62366 
  • Regulatory support: 
    • Assisted in authoring the Device Section of the BLA, ensuring alignment with FDA expectations. 

Result

Thanks to RCA’s support, the company was able to initiate its Phase 3 clinical trials on schedule, with a fully compliant combination product. 

Over the next two years, the organization successfully launched three commercial combination products—two prefilled syringes and one vial kit—all of which passed FDA audits. The quality system enhancements and DHFs stood up to regulatory scrutiny, and the trained internal teams were able to carry the work forward independently. 

RCA also temporarily stood up a Device Development Department, mentoring internal staff and ensuring a seamless handoff post-acquisition. The company has since maintained compliance and continues to expand its biosimilar product portfolio with confidence. 

A Regulatory Roadmap for Combination Product Submissions

Posted on by Brandon Miller

Combination product submissions require a tailored regulatory strategy that blends device, drug, and biologic requirements. The complexity increases when multiple FDA centers could be involved.

 

The journey begins with identifying the product’s primary mode of action (PMOA). This determines which FDA center will lead the review:

  • CDER: Center for Drug Evaluation and Research
  • CBER: Center for Biologics Evaluation and Research
  • CDRH: Center for Devices and Radiological Health

If the PMOA is unclear, companies can submit a Request for Designation (RFD) to the Office of Combination Products.

 

Once the lead center is determined, companies must ensure their submission addresses the regulatory requirements of both drug/biologic and device frameworks. This includes integrating device GMPs (21 CFR Part 820) with existing pharma QMS (21 CFR Part 210/211).

 

Key requirements typically include:

  • Quality system alignment with 21 CFR Part 4
  • Documentation of design controls, CAPA, and purchasing controls
  • Evidence of human factors testing for design validation
  • Management responsibility and risk management processes

Recent FDA draft guidance (e.g., on essential performance outputs) further clarifies what must be demonstrated in combination product submissions. The focus is shifting toward system-level outputs that directly impact drug delivery and therapeutic performance.

 

For companies planning international expansion, the regulatory roadmap extends beyond the U.S. CE marking under the EU MDR often requires a Notified Body Opinion confirming that the device component is adequately controlled.

 

Success starts with early planning and cross-functional alignment. Regulatory, quality, and product development teams must work together to:

  • Identify regulatory gaps
  • Align SOPs and systems
  • Develop submission-ready documentation
  • Engage proactively with regulatory bodies

Navigating the regulatory maze of combination product submissions is complex but manageable—with the right roadmap, tools, and expertise in place.

 

Work with RCA to Streamline Your Submission Process Regulatory Compliance Associates helps companies navigate the complexities of combination product submissions in both U.S. and global markets. From regulatory strategy to documentation support, RCA is your trusted partner. Reach out today to get started.