IPCD and ePCD

hoanght2

Registered
Hello everyone,

So our company is planning to perform a full sterilization validation for 1 of our key product which is the coronary stent. However, we are very new to this process and still have a lot to learn. I have read ISO 11135 and watched a lot of youtube tutorials on how to perform a sterilization validation, but there are many things that i'm still confused, so I hope that I can received some guidance from you all. So here are my questions:
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To my understanding, 1 of the main purposes of the whole sterilization validation process is to prove that the resistance of natural bioburden on the product is less than the resistance of the selected iPCD, and the resistance of the iPCD is less than that of the ePCD ( product < iPCD < ePCD ).

The purpose of using an iPCD is to prove that the sterilization cycle can achieve SAL = 10^-6, and the purpose of using an ePCD is to provide a reliable, easy-to-retrieve monitoring tool for routine cycles. For our product, the use of an ePCD is neccesary because 2 reasons. First, because our product is quite expensive and because in order to create 1 iPCD we basically have to sacrifice 1 product, it's is economically impractical to use iPCDs for monitoring routine cycles. Second, it's very difficult to inoculate our product and it's equally hard to retrieve the BI, thus we want to develop an ePCD so that we can easily retrieve the BI to monitor routine cycles.

(1. How to develop a proper ePCD?) .To create an iPCD, we decided to inoculate our product (stent) by inserting a mini BI spore strip into the most difficult place to sterilize in the product which is between the stent and the balloon. However, i don't know how to develop an appropriate ePCD. Is there any standard guidance or instruction on how to develop a proper ePCD? I just plan on inserting a BI tube into the barrel of a capped syringe. This system, to my evaluation, poses the hardest challenge for sterilization as a capped syringe bascially has no clear entrance/path for EO gas to go into its barrel, thus the only way is the EO gas has to penetrate through the syringe body to reach the BI tube in its barrel. Do you think this is a good choice of ePCD ? I do realize that there are some available commercial ePCDs, however their prices are relatively high, so we prefer developing a cheaper self-made ePCD if possible.

(2. How to prove the resistance of iPCD < the resistance of ePCD?) Also, i don't know how to prove the resistance of iPCD is less than the resistance of ePCD ( iPCD < ePCD ). I know how to prove (product < iPCD). To do this, I have to run a sub-lethal (fractional) cycle, and the result should be all product is sterile and some growth on iPCD. But does this same method apply to prove (iPCD < ePCD)? I was guessing the way to do it is to run another fractional cycle to achieve a result in which the number of sterile iPCDs is more than the number of sterile ePCDs. So for example, i use 10 iPCDs and 10 ePCDs, and I need to run multiple fractional cycles until I get a result of ,let's say, 7 iPCDs are sterile and 2 ePCDs are sterile. But again, i'm not really sure about this.

(3. What result do I need to get for half-cycle?) Assuming I am able to prove (iPCD < ePCD) using fractional cycles, so do all ePCDs need to be sterile after half-cycle ? Because the requirement from ISO 11135 is achieving SAL = 10^-6, and we can prove this by having all iPCD sterilized after half-cycle. But because the resistance of iPCD < ePCD,there is a chance that not all ePCDs are sterile after half-cycle. So do we need to find a set of half-cycle parameters that can sterilize all ePCDs ?

(4. Loading?) Can we use the same load again and again for all the cycles? I know, optimally, we should use a new load for each cycle. But again our product is quite expensive, and even if we use similar products (dummy load) the cost is still high.
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I know it's a long posts and there are a lot of basic questions. So thank you in advance for helping me!
 

planB

Super Moderator
[...] we are very new to this process and still have a lot to learn. I have read ISO 11135 and watched a lot of youtube tutorials on how to perform a sterilization validation [...]

A word of caution not intended to hamper your enthusiasm: You may want to seek professional support for your validation because you might potentially not catch all requirements without prior exposure to EO sterilization validation. Plus, at least notified bodies are starting to require evidence of involvement of a "sterilization specialist" pursuant to ISO11135:2014, section 3.51, and Annex D.

ad (1). No, there is no standard guidance (yet) how to develop an ePCD, other than the rather general recommendations given in ISO 11135, section D.7.1.6. The design you propose might be an option that has to be experimentally confirmed in sublethal/fractional cycles.

ad (2). Your proposed approach seems to be valid. You could add confidence by actually performing a quantitative measurement of the spore log reduction in your PCDs, respectively, instead of an (attributive) test of sterility.

ad (3). Have a look into ISO 11135, section 9.4.2.5.

ad(4). Have a look into tof ISO 11135, section 9.4.1.8. and document your rationale for reusing your load accordingly.

HTH,
 

hoanght2

Registered
Thanks so much for your response! It helps a lot!

Also, do you have any news article or citations supporting your statement "Plus, at least notified bodies are starting to require evidence of involvement of a "sterilization specialist" pursuant to ISO11135:2014, section 3.51, and Annex D" ? I'm asking because I want to show it to my colleagues. I have been suggesting to them that we should hire a sterilization expert to help us perform this validation, but because of some budget issues, my suggestion has not been approved by the upper management.

Another thing is , if possible, can you recommend some companies that have good consulting service for sterilization validation? So far, I only know Nelson Lab and Steris.
 

planB

Super Moderator
sterilization specialist: you may want to query ISO11135:2014 for the term "sterilization specialist" and show the results to your colleagues. Plus, notified bodies, FDA and other regulators all employ dedicated sterilisation expert reviewers an auditors. So without matching internal (or closely affiliated) resources you will probably embark on a bumpy journey.

The companies you mentioned both belong to Sotera, and are big players in this field. Cannot really tell, whether they would be a match for you.
 

chris1price

Trusted Information Resource
I'll echo PlanBs comments, there is a lot of resource (time, effort and especially cost) that goes into EtO validation, with potential to make mistakes or require additional work. If you are not 100% sure of the processes, the cost of a consultant is likely to be significantly less than getting it wrong.
 

Manuel Grandy

Registered
sterilization specialist: you may want to query ISO11135:2014 for the term "sterilization specialist" and show the results to your colleagues. Plus, notified bodies, FDA and other regulators all employ dedicated sterilisation expert reviewers an auditors. So without matching internal (or closely affiliated) resources you will probably embark on a bumpy journey.

The companies you mentioned both belong to Sotera, and are big players in this field. Cannot really tell, whether they would be a match for you.

Steris does not belong to Sotera, instead Sterigenics does. You can talk to them about your project and needs and then decide if they can cover all your needs or you would need further support by a consultant.
 

planB

Super Moderator
@pseudoazurin, I guess you are referring to the number of survivors after sub-lethal exposure? If yes - these numbers are only relevant on a relative scale, i.e. number of survivors: (product) ≤ (iPCD) ≤ (ePCD) with the product typically being sterile after sub-lethal exposure. After all, absolute numbers of survivors heavily depend on your specific cycle and the actual exposure time you set for your sub-lethal cycle. At most, these numbers might give you some confidence/hint whether you can expect complete inactivation of at least the iPCDs in your half cycle.
 
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