The Harmonization of the Microbial Limits Tests - Pharmaceutical Technology

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The Harmonization of the Microbial Limits Tests

Pharmaceutical Technology

Table IIa: Aspects of the current and harmonized microbial limits tests (enumeration).
The demonstration of method suitability should be performed using the challenge organisms listed (see Tables IIa–b) in accordance with the recommendations found in USP Chapter ‹1227› (9). Growth promotion is an area of some ambiguity in the compendial text. Although media-growth promotion is not described in the tests, it is required. USP Chapter ‹1117› (10) provides assistance in designing the studies using 10–100 CFUs of the challenge organisms.

Table IIb: Aspects of the current and harmonized microbial limits tests (enumeration).
A major concern of many quality control workers is whether the changes in the harmonized chapter will necessitate the revalidation of existing assays to meet harmonized test requirements. Several considerations might lead to revalidation: a required change in media, in the volume of material required for testing, or in general testing conditions. It is difficult to determine whether all product types would require revalidation, and thus a summary table (see Tables IIa–b) is included in this article to describe the critical aspects of the current "Microbial Limits Tests (Enumeration)" and the draft harmonization text. This table is provided only as an aid. The decision of whether or not revalidation is necessary rests with each individual facility for its particular products.

USP ‹62› "Absence of Specified Microorganisms"

There is a significant controversy in the United States over the intent of this evaluation. FDA is bound by the concern expressed in the Code of Federal Regulations (21 CFR 211.113 and 21 CFR 211.165) relating to the importance of "objectionable microorganisms." This issue is addressed in the final section of this review because the harmonized Chapter ‹1111› deals with "other organisms."

Table IIIa: Absence of specified microorganisms.
Tables IIIa–c presents the existing "Microbial Limits—Absence of Specified Microorganisms" tests from the current USP and Pharm Eur, as well as the harmonized document. It is presented as an aid to evaluation, and may assist in determining whether revalidation of method suitability studies is needed. It should be noted that this harmonized chapter represents a true compromise by all parties, with (at least in the author's opinion) significant changes from the current USP, Pharm Eur, and JP chapters. Table IV provides guidance about the media-growth promotion expectations of the new chapters.

As the reader reviews these sections, it is reasonable to consider the current validation (or microbial recovery or method suitability) studies performed for currently marketed products. It is very likely that many of these studies may need to be performed again to meet the expectations of the harmonized procedure.


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