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  • 1.  Cleaning Validation

    This message was posted by a user wishing to remain anonymous
    Posted 03-Apr-2020 08:33
    This message was posted by a user wishing to remain anonymous

    Hello RAPS members!

    Can anyone point me to the regulation/guidance that requires test articles for cleaning validations to be completed in triplicate, as  I have been unable to do so.  We have a semi-critical reusable medical device with limited patient contact in a non-sterile anatomical area. We have been asked to complete validation on three devices, three repeat cycles per device, plus a control article. I know this is common practice but wanted to be able to reference a regulation/guidance in our test report. Thanks in advance!


  • 2.  RE: Cleaning Validation

    Posted 10-Apr-2020 09:13
    We are going through cleaning validation.  Our device is a non-critical device with limited patient contact.  The testing lab that we are using cites AAMI-ST98, Cleaning validation of health care products – Requirements for development and validation of a cleaning process for medical devices. This is a new standard replacing AAMI TIR30.  There is also another draft standard that has not been released yet that also speaks to cleaning instructions from the manufacturer,  ISO 17664-2: Processing of health care products – Information to be provided by the medical device manufacturer for the processing medical devices – Part 2: Medical devices not intended for direct patient contact.  I have not seen a copy of the AAMI-ST98 yet so I can't speak for particulars.  Hopefully these will help!

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    Beth Foster
    Regulatory Affairs Manager
    Miami Lakes FL
    United States
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  • 3.  RE: Cleaning Validation

    Posted 11-Apr-2020 12:43
    Edited by Christopher Erwin 14-Feb-2022 11:58
    In a prior role at a medical device remanufacturer, the FDA guidance Final Guidance for Industry and FDA Staff: Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling was recommended to follow. 
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    Christopher Erwin
    Scottsdale AZ
    United States
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  • 4.  RE: Cleaning Validation

    Posted 11-Apr-2020 15:55

    First, I infer this is a medical device. If it were, say, cleaning production equipment for drugs between batches my questions would not apply.

    There are areas in your question that raise questions.

    First, what does semi-critical mean and why does it make a difference in cleaning validation?

    Because this is a reusable device, I infer the validation is for a cleaning process to include in the IFU. The intent is that the customer performs the cleaning process between re-uses of the device. Your goal is to ensure that it works.

    You say, "we have been asked …" Asked by whom?

    You are performing process validation for a process in which the customer cannot determine the output. In other words, following 820.75(a), the person performing the cleaning process cannot fully verify it by subsequent inspection and test. The user relies on the instructions in the IFU.

    You say, "validation on three devices, three repeat cycles per device, plus a control article". You go on to say, "I know this is common practice". I don't know that it is.

    Process validation is an application of design of experiments. You should determine the attributes that influence cleanliness. Then, determine the worst case for each attribute. You want to perform the cleaning validation at the worst-case conditions. Depending on the number of attributes, you are conducting either a full factorial or a fractional factorial experiment.

    Typically, you would conduct the validation at the two worst corners of the hyper-cube and the nominal point. This gives you the three devices. Presumably, you are doing three replicates at each worst-case corner and at the nominal point. This gives you information to understand the variability at each point.

    In the context, I don't understand the control article. Presumably you clean an uncontaminated device to verify that it is not contaminated. While useful, you need to have ensured that the measurement process for the contamination result produces correct results.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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