Viral Risk Management

While rare, viral contamination events can have severe consequences, potentially impacting product quality, patient safety, and company reputation. And while a consent decree is a good way to grow your skills, I tend to prefer to avoid causing one to happen.

Luckily, regulatory bodies have provided comprehensive guidelines, with ICH Q5A(R2) being a cornerstone document. Let’s explore the best practices for viral risk management in biotech, drawing from ICH Q5A and other relevant guidances.

The Three Pillars of Viral Safety

ICH Q5A outlines three complementary approaches to control potential viral contamination:

  1. Selection and testing of cell lines and raw materials
  2. Assessment of viral clearance capacity in production processes
  3. Testing of the product at appropriate stages for contaminating viruses

These pillars form the foundation of a robust viral safety strategy.

Cell Line and Raw Material Control

  • Thoroughly document the origin and history of cell lines
  • Implement comprehensive testing programs for cell banks, including master and working cell banks
  • Carefully assess and control animal-derived raw materials
  • Consider using chemically-defined or animal-free raw materials where possible
  • Implement stringent change control and quality agreements with raw material suppliers

Viral Clearance Capacity

  • Design manufacturing processes with multiple orthogonal viral clearance steps
  • Validate the effectiveness of viral clearance steps using model viruses
  • Aim for a cumulative viral reduction factor of at least 4 log10 per the USP guidelines
  • Consider both dedicated viral inactivation steps (e.g., low pH treatment) and removal steps (e.g., nanofiltration)
  • For continuous manufacturing, assess the impact of process dynamics on viral clearance

In-Process and Final Product Testing

  • Develop a comprehensive testing strategy for in-process materials and final product
  • Utilize state-of-the-art detection methods, including PCR and next-generation sequencing (NGS)
  • Consider replacing traditional in vivo assays with molecular methods where appropriate
  • Implement a testing program that covers a broad spectrum of potential viral contaminants

Risk-Based Approach

The revised ICH Q5A(R2) emphasizes a risk-based approach to viral safety. This involves:

  • Conducting thorough risk assessments of the entire manufacturing process
  • Identifying critical control points for viral contamination
  • Implementing appropriate mitigation strategies based on risk levels
  • Continuously monitoring and updating the risk assessment as new information becomes available

Prior knowledge, including “in-house” experience, plays a crucial role in viral risk assessment and management for biopharmaceutical manufacturing. Here’s how it can be effectively utilized:

Leveraging Historical Data

  • Review past viral contamination events or near-misses within the organization
  • Analyze trends in raw material quality and supplier performance
  • Evaluate the effectiveness of previous risk mitigation strategies

Process Design and Optimization

  • Apply lessons learned from previous manufacturing campaigns to improve process robustness
  • Use historical data to identify critical control points for viral contamination
  • Optimize viral clearance steps based on past validation studies

Cell Line Susceptibility

  • Use accumulated data on cell line susceptibility to various viruses to inform risk assessments
  • Apply knowledge of cell line behavior under different conditions to enhance contamination detection

Risk Assessment Approach

The risk assessment process should take a holistic approach, focusing on:

  • Raw material sourcing and testing
    • Identifying high-risk materials, especially animal-derived components
    • Assessing chemically-undefined components like hydrolysates and peptones
    • Evaluating materials produced or stored in non-controlled environments
  • Cell substrate selection and characterization
    • Documenting the derivation and source history of the cell line
    • Testing cell banks extensively for adventitious agents
    • Assessing the cell line’s susceptibility to various viruses
  • Process design for viral clearance
    • Designing manufacturing processes with multiple orthogonal viral clearance steps
  • Facility design and operations
    • Implementing robust cleaning and sanitization procedures
    • Ensuring proper facility layout and air handling systems to prevent contamination spread
  • Personnel training and practices
    • Training on proper gowning procedures and personal protective equipment (PPE) usage
    • Policies on illness reporting and exclusion of sick employees from critical areas

Preparedness and Response

While prevention is key, being prepared for a potential contamination event is crucial:

  • Develop a comprehensive viral contamination response plan[6]
  • Regularly practice and update the response plan through mock drills
  • Establish clear communication channels and decision-making processes
  • Prepare strategies for containment, decontamination, and facility restart

Continuous Improvement

Viral risk management is an ongoing process:

  • Stay updated on emerging technologies and regulatory guidance
  • Participate in industry forums and share best practices
  • Invest in employee training and awareness programs
  • Continuously evaluate and improve viral safety strategies

By implementing these best practices and adhering to regulatory guidances like ICH Q5A, we can strive to significantly mitigate the risk of viral contamination. While no approach can guarantee absolute safety, a comprehensive, risk-based strategy that leverages cutting-edge technologies and emphasizes preparedness will go a long way in protecting patients, products, and the industry as a whole.

Viral Controls in Facility Design

Facility design and control considerations for mitigating viral contamination risk is a holistic approach to facility design and controls, considering all potential routes of viral introduction and spread. A living risk management approach should be taken to identify vulnerabilities and implement appropriate mitigation measures.

Facility Considerations

  • Segregation of areas: Separate areas for cell banking, small-scale and large-scale upstream cell culture/fermentation, downstream processing, media/buffer preparation, materials management, corridors, and ancillary rooms (e.g. cold rooms, freezer rooms, storage areas).
  • Traffic flow: Control and minimize traffic flow of materials, personnel, equipment, and air within and between areas and corridors. Implement room segregation strategies.
  • Air handling systems: Design HVAC systems to maintain appropriate air quality and prevent cross-contamination between areas. Use HEPA filtration where needed.
  • Room Classifications
    • For open operations:
      • Open sterile and aseptic operations must be performed in an environment where the probability of contamination is acceptably low, i.e. an environment meeting the bioburden requirements for a Grade A space.
      • Open bioburden-controlled processing may be performed in an ISO Grade 8/EU Grade C or EU Grade D environment as appropriate for the unit operation.
      • Open aseptic operations require a Grade A environment. Maintaining a Grade A cleanroom for large bioreactors is not feasible.
    • For closed operations:
      • Closed systems do not require cleanroom environments. ICH Q7 states that closed or contained systems can be located outdoors if they provide adequate protection of the material.
      • When all equipment used to manufacture a product is closed, the surrounding environment becomes less critical. The cleanroom requirements should be based on a business risk assessment and could be categorized as unclassified.
      • Housing a closed aseptic process in a Grade C or Grade B cleanroom would not mitigate contamination risk compared to an unclassified environment.
      • For low bioburden closed operations, the manufacturing environment can be unclassified.

Equipment Considerations

Closed vs. open processing: Utilize closed processing operations where possible to prevent introduction/re-introduction of viruses. Implement additional controls for open processing steps.

Closure LevelDescription
Closed EquipmentSingle use, never been used, such as irradiated and autoclaved assembles; connections are made using sterile connectors or tube wielders/sealers
Functionally closed equipment: cleaned and sterilizedOpen vessels or connections that undergo cleaning and sterilization prior to use and are then aseptically connected. The connection is then sterilized after being closed and remains closed during use.
Functionally closed equipment: cleaned and sanitizedOpen vessels or connections that are CIPed including bioburden reducing flushes, but not sterilized before use and remain closed during use
OpenConnections open to the environment without subsequent cleaning, sanitization or sterilization prior to use

Operational Practices

  • Personnel controls: Implement rigorous training programs, safety policies and procedures for personnel working in critical areas.
  • Cleaning and sanitization: Establish frequent and thorough cleaning protocols for facilities, equipment, and processing areas using appropriate cleaning agents effective against viruses.
  • Material and equipment flow: Define procedures for disinfection and transfer of materials and equipment between areas to prevent contamination spread.
  • Storage practices: Implement proper storage procedures for product contact materials, intermediates, buffers, etc. Control access to cold rooms and freezers.

Additional Controls

  • Pest control: Implement comprehensive pest control strategies both inside and outside facilities, including regular treatments and monitoring.
  • Water systems: Design and maintain water systems to prevent microbial growth and contamination.
  • Process gases: Use appropriate filtration for process air and gases.
  • Environmental monitoring: Establish environmental monitoring programs to detect potential contamination early.