Contamination Control Strategy
Contamination Control Strategy
What is Contamination?
The act of contaminating or polluting, including either intentionally or accidentally, unwanted, and potentially dangerous
substances or factors.
Also, simply the state of being contaminated (with something you don’t want and don’t expect to be present)
Contamination can be:
Physical – e.g. dust, fibres, human skin cells, particles
Chemical – e.g. cleaning agent residues, process gasses, molecules, vapour
Microbiological – e.g. bacteria, virus, yeast, mould
Where can Contamination Come From?
There is a multitude / massive amount of potential sources of contamination; some are listed below:
Buildings and Premises
Services and Utilities
Environment
Equipment
Starting and Packaging Materials
Process and Production
Sampling Procedures
Cleaning Agents
PIC/S Guide to Good Manufacturing Practice for Medicinal Products PE-009-16 Part I, clause 5.20 (part)
"The outcome of the Quality Risk Management process should be the basis for determining the extent of technical and
organisational measures required to control risks of cross-contamination."
PIC/S Guide to Good Manufacturing Practice for Medicinal Products PE-009-16 Part I, clause 5.21 (part)
Examples of technical measures:
Dedicated manufacturing facility
Design of manufacturing process, premises, and equipment
Dedicated equipment
Use of airlocks
Use of single-use technologies
Examples of organisational measures:
Supervision of working behaviour to ensure training effectiveness and compliance with relevant procedural controls
Recording of spills, accidental events or deviations from procedures
Cleaning verification
Specific processes for waste handling
PIC/S Guide to Good Manufacturing Practice for Medicinal Products PE-009-16 Part I Clause 5.18 (part)
CCS is a critical strategic document/plan that describes the contamination risk management strategy and associated governance
to decide the continuous improvements and investment plans to prevent contamination. Therefore, developing such a
document requires a cross-functional team of experts with good production, QRM, and regulatory knowledge.
Microbial contamination: This involves bacteria, viruses, fungi, and other microorganisms. These invisible invaders can
come from the environment, personnel, or raw materials and can potentially ruin your product.
Particulate contamination: This refers to physical particles like dust, fibers, or metal shavings that can contaminate the
Chemical contamination: Extractable and leachable contaminants are a concern for both sterile and non-sterile
products. It happens when unwanted chemicals are released into the product, either from the manufacturing process
it is important to the strategy should the strategy should documentation is regular reviews and
identify the potential outline the measures include clear key to a well- updates to the
including the types cross-contamination. sampling and testing strategy. The remains practical,
of products This may include to ensure that cross- strategy should be effective, and up-to-
site, and the cleaning procedures detected and in a written policy, the manufacturing
processes involved in for equipment, using addressed promptly. and all procedures process, equipment,
manufacturing/ dedicated areas for This should include should be or materials should
packing, storage, and specific processes, routine and testing documented in be evaluated for
manufacturing
process, including
involved.
What is CCS?
A contamination control strategy (CCS) is a comprehensive approach to prevent and manage contamination in the
manufacturing of pharmaceutical products. It involves a planned set of controls for microorganisms, Endotoxins / Pyrogens,
and particles, ensuring process performance and product quality.
The strategy is based on current product and process understanding and includes parameters and attributes related to
materials, facility and equipment operating conditions, in-process controls, finished product specifications, and the methods
and frequency of monitoring and control.
The CCS is a key element of Annex 1 of the EU GMP Guide, which emphasizes a risk-based and holistic approach. It requires
documenting all aspects of contamination control, including organizational, technical, and procedural measures, to ensure
comprehensive effectiveness.
This strategy helps identify, assess, and mitigate risks associated with contamination, aiming to enhance product quality and
patient safety.
A university degree or an equivalent diploma in the field of microbiology (or other natural sciences, or
medicine) together with a good understanding of the manufacturing processes under consideration are
required for the person in charge of supporting the design of manufacturing activities and environmental
monitoring.
As for raw materials, the need for microbiological testing should be evaluated taking into consideration
their nature and respective use in the process. All specifications should be discussed and justified in the
CCS.
As for extractables, the end user is expected to assess the data provided by the suppliers in order to define
A redundant filtration step through a sterile sterilising grade filter, to be included as close to the point of
fill as possible, is also encouraged, and its absence has to be justified. A risk analysis is required to justify
Separate AHU systems should be present for the manufacturing and aseptic areas (Critical and support
processing/manufacturing areas.
Positive room pressurization is a necessity to ensure product contamination control. Adjacent rooms of
different grades should have pressure differentials of a minimum of 10 pascals. The controls around
The control of pressure regimes should be outlined in the site HVAC specification, where the pressure
HVAC systems are typically divided into separate Air Handling Units (AHUs) for control. Systems should be
designed, maintained, and classified according to ISO 14644 and operated according to a local HVAC
specification. Air handling plant (AHP) has been designed, installed and qualified to provide the requisite
Pre-filters / HEPA filters Grade should be mentioned in the documents (grade and location in AHU)
Planned Preventative Maintenance programme should be available and defined and periodically
reviewed.
Good design relates to both selecting a suitable grade of cleanroom together with a design intended to
minimize contamination. This includes the use of appropriate construction materials and spending time on
the suitability of the layout, covering elements like process and material flows.
Good Design Control process includes the elements of planning, defining inputs such as specifications and
The design sub-elements are the facility layout, cleanroom design and classification, cross-contamination
Qualified HVAC, pressure cascade, utilities, Pressure alarms setting should be available.
The Processing area / Rooms entry should be through change rooms that act as airlocks for personnel and
Cleanrooms and change rooms should be maintained to an appropriate cleanliness standard and supplied
Controls and monitoring should be scientifically justified and should effectively evaluate the state of
The various operations of component preparation, product preparation and filling should be carried out
with appropriate technical and operational separation measures within the cleanroom or facility to prevent
Restricted Access Barrier Systems (RABS) or isolators are beneficial in assuring required conditions and
minimizing microbial contamination associated with direct human interventions in the critical zone.
In cleanrooms and critical zones, all exposed surfaces should be smooth, impervious and unbroken in order
Materials used in cleanrooms, both in the construction of the room and for items used within the room,
should be selected to minimize generation of particles and to permit the repeated application of cleaning,
Ceilings should be designed and sealed to prevent contamination from the space above them.
Sinks and drains should be prohibited in the grade A and grade B areas.
The transfer of materials, equipment, and components into the grade A or B areas should be carried out via
a unidirectional process. Where possible, items should be sterilised and passed into these areas through
double-ended sterilisers (e.g. through a double-door autoclave or depyrogenation oven/tunnel) sealed into
the wall. Where sterilisation upon transfer of the items is not possible, a procedure which achieves the
effective transfer disinfection process, rapid transfer systems for isolators or, for gaseous or liquid
materials, a bacteria-retentive filter). The removal of items from the grade A and B areas (e.g. materials,
waste, environmental samples) should be carried out via a separate unidirectional process. If this is not
Cleanrooms should be supplied with a filtered air supply that maintains a positive pressure and/or an
airflow relative to the background environment of a lower grade under all operational conditions and
should flush the area effectively. Adjacent rooms of different grades should have an air pressure difference
of a minimum of 10 Pascals (guidance value). Particular attention should be paid to the protection of the
critical zone. The recommendations regarding air supplies and pressures may need to be modified where it
is necessary to contain certain materials (e.g. pathogenic, highly toxic or radioactive products or live viral or
bacterial materials). The modification may include positively or negatively pressurized airlocks that prevent
the hazardous material from contaminating surrounding areas. Decontamination of facilities (e.g. the
cleanrooms and the heating, ventilation, and air-conditioning (HVAC) systems) and the treatment of air
leaving a clean area, may be necessary for some operations. Where containment requires air to flow into a
critical zone, the source of the air should be from an area of the same or higher grade.
Airflow patterns within cleanrooms and zones should be visualised to demonstrate that there is no ingress
from lower grade to higher grade areas and that air does not travel from less clean areas (such as the floor)
or over operators or equipment that may transfer contamination to the higher grade areas. Where
When filled, closed products are transferred to an adjacent cleanroom of a lower grade via a small egress
point, airflow visualization studies should demonstrate that air does not ingress from the lower grade
Facilities should be designed to permit observation of production activities from outside the grade A and B
areas (e.g. through the provision of windows or remote cameras with a full view of the area and processes
to allow observation and supervision without entry). This requirement should be considered when
Advanced technology should be use to minimize the manual intervention during the production.
equipment's are non-reactive, smooth surface, easy to clean, free from scratches/cracks and qualified
Cleanrooms and clean air equipment such as unidirectional airflow units (UDAFs), RABS and isolators, used
for the manufacture of sterile products, should be qualified according to the required characteristics of the
environment.
Appropriate cleanliness levels in the “at rest” and “operational” states should be maintained.
The microbial contamination level of the cleanrooms should be determined as part of the cleanroom
qualification. The number of sampling locations should be based on a documented risk assessment and the
results obtained from room classification, air visualization studies and knowledge of the process and
The requalification of cleanrooms and clean air equipment should be carried out periodically and the
- Air velocity test (Note: For grade B, C and D the air velocity test should be performed according to a risk
assessment documented as part of the CCS. However, it is required for filling zones supplied with
unidirectional airflow (e.g. when filling terminally sterilised products or background to grade A and RABS).
For grades with non-unidirectional airflow, a measurement of recovery testing should replace velocity
testing).
The maximum time interval for requalification of grade A & B areas, is 6 months.
The maximum time interval for requalification of grade C & D areas, is 12 months.
Water supplied under continuous positive pressure in a plumbing system for the free of defects that could
Sterile pathways should be covered during setup, removing covers only at the end
Mechanical and electrical adjustments designed should be made outside the aseptic processing area .
All Equipment designs result in slopes for drainage and there is no any chance of stagnate of water or
material .
Source air for air-break filters on autoclaves or lyophilizers drawn from the cleanroom rather than from
Electronics are covered or provided with a wipeable surface that is resistant to disinfectants (e.g.,
C. Personnel
People are the major variable within pharmaceutical processing.
The manufacturer should ensure that there are sufficient appropriate personnel, suitably qualified, trained
and experienced in the manufacture and testing of sterile products, and any of the specific manufacturing
technologies used in the site’s manufacturing operations, to ensure compliance with GMP applicable to the
Only the minimum number of personnel required should be present in cleanrooms. The maximum number
of operators in cleanrooms should be determined, documented and considered during activities such as
All personnel including those performing cleaning, maintenance, monitoring and those that access
cleanrooms should receive regular training, gowning qualification and assessment in disciplines relevant to
This training should include the basic elements of microbiology and hygiene, with a specific focus on
cleanroom practices, contamination control, aseptic techniques and the protection of sterile products. For
Example : The Personnel should be trained on Basic microbiology , Personnel flow and associated
requirements. , Material and waste flow. , Environmental control , Cleaning and disinfection , Process
design.
The Adequate training and qualification of all people which are working in grade A and B areas, including
The personnel accessing grade A and B areas should be trained for aseptic gowning and aseptic behaviours.
Compliance with aseptic gowning procedures should be confirmed by assessment and periodic
reassessment at least annually, and should involve both visual and microbial assessment (using monitoring
locations such as gloved fingers, forearms, chest and hood (facemask / forehead).
The Personnel variables should be minimized through good training and educational programs. Included
Sufficient personnel are qualified, trained and experienced in the manufacture and testing of
Unqualified personnel should not enter Grade B cleanrooms or Grade A zones in operation
be present
As a personnel represent the primary source of contamination in any production process, personnel
training is very important and the regular training programme should be present.
All personnel who access cleanrooms should receive regular training, gowning qualification, and
assessment in disciplines relevant to the correct manufacture of sterile products. Specific elements of the
training should include: Microbiology, personal hygiene ,aseptic technique ,Cleanroom practices ,
Training should cover a broad range of areas ranging from personnel movement and behaviour in
cleanrooms to the impact of cleanroom behaviours on the quality of the finished product.
Personnel training should be practical, frequent, and continuous and should cover theoretical, practical and
cGMP aspects with the curriculum including basic microbiology, personal hygiene, and aseptic technique.
Training should cover a broad range of areas ranging from personnel movement and behaviour in
cleanrooms to the impact of cleanroom behaviours on the quality of the finished product.
Presented By : Arvind Kumar Srivastava , Mobile No. :9817039581
Manager - Quality Assurance , Beta Drugs Limited , Baddi , India , Email ID : arvindsrisri82@gmail.com
A documented program should also be established to provide the criteria that disqualifies personnel from
cleanroom entry based on insufficient gowning technique and/or exceeding established microbial counts
The procedure for should be available for disqualification of Operators if the observation of poor aseptic
/cleanroom behaviour and return to accessing cleanrooms based upon appropriate corrective actions being
Results for critical parameters and critical quality attributes of high risk utilities like Purified Water , Water
for Injection , Pure Steam Generator should be subject to regular trend analysis to ensure that system
Pipes, ducts and other utilities should not be present in cleanrooms. If unavoidable, then they should be
installed so that they do not create recesses, unsealed openings and surfaces which are difficult to clean.
Installation should allow cleaning and disinfection of outer surface of the pipes.
The water generation system , that should be designed to allow for routine sanitisation and/or
disinfection. Procedures are needed to define regular preventive maintenance of the reverse osmosis
More stringent controls are needed for the sampling of water-for-injection distribution systems, including
Regular ongoing chemical and microbial monitoring of water systems should be performed to ensure that
the water continues to meet compendial expectations. Alert levels should be based on the initial
qualification data and thereafter periodically reassessed on data obtained during subsequent re-
qualifications, routine monitoring, and investigations. Review of ongoing monitoring data should be carried
WFI systems should include continuous monitoring systems such as Total Organic Carbon (TOC) and
conductivity.
Gases used in aseptic processes should be filtered through a sterilising grade filter (with a nominal pore size
as product vessel vent filter, then the filter should be integrity tested and the results reviewed as part of
When gases are used in the process, microbial monitoring of the gas should be performed periodically at
The monitoring of the process gas should be performed as close as possible before the sterilisation filter.
Feed water to a pure steam (clean steam) generator should be appropriately purified. Pure steam
generators should be designed, qualified and operated in a manner to ensure that the quality of steam
Water-for-Injection (WFI) storage tanks should be equipped with hydrophobic bacteria retentive vent
filters, the filters are sterilized, and the integrity of the filter tested before installation and after removal
following use.
Gases used in aseptic processes need to be filtered with a sterilizing grade filter at the point of use.
Microbial monitoring of the gas should be performed periodically at the point of use.
Separate change rooms should be available to remove street wear and wear clean factory linen.
Gowning and de gowning procedure should be in place and displayed in respective processing area where
The Material transfer to Grade A/B should be through Dynamic Pass box followed by effective cleaning and
sanitization.
Materials entering into the aseptic areas should be sterilized by using autoclaves, depyrogenation tunnels,
The movement or “flow” of personnel, material, and wastes should be established using QRM principles.
People are the primary source of microorganisms in cleanrooms, so personnel flow is critically important to
contamination control.
Gowning and behaviour are key controls to limit contamination from personnel so these things are very
Personnel involved in the manufacture of sterile products should be instructed to report any specific health
conditions or ailments that may cause the shedding of abnormal numbers or types of contaminants and
Health conditions and actions to be taken with regard to personnel who could be introducing an undue
microbial hazard should be provided by the designated competent person and described in procedures
warehouse personnel should be check the details of approved vendor and verify the received materials
The Vendor management system should be available for RM , Excipients & miscellaneous items and
qualify periodically.
All Raw Materials/ PPM tested prior to use for chemical and micro/ BET test and Re-tested as definite
quality agreements should be in place between the firm and the vendor.
Once qualified and approved, vendors should be audited on a frequency commensurate with the criticality
Routine vendor audits should be present for both API and Excipients and the vendor’s practices should be
All manufactured drug product tested as per approved method of analysis against In-process and Finished
product specification.
OOT/OOS handling procedure should be in case of any abnormal results , which is against the pre-defined
specification limit.
H. Monitoring systems The purpose of the environmental monitoring programme is to provide data that can be used to
assess the adequacy of contamination controls in the cleanroom or manufacturing area.
An environmental monitoring programme, which provides assurance of compliance with regulatory
requirements is established. This programme also is designed to detect excursions from environmental limits
triggering investigation and assessment of risk to product quality (annex 1, 2022). The environmental
interactions in the preparation process. In addition, results should be considered in conjunction with air
According to ICH Q9 (R1), the frequency of the risk review should be based on the level of risk determined
for the specific process under consideration, as well as on the level of uncertainty of previous assessments.
For the new plants is to review the risk assessment after the first year of operations, so to take into due
consideration the acquired experience. The document also suggests cases where more stringent action
limits may be needed, and the type of statistics to be used to establish alert levels.
The Environmental Monitoring (EM) program for a facility is used to monitor and determine the type and
sampling locations that represent the areas of highest contamination risk in the cleanroom.
Non- viable particle monitoring is performed using Isokinetic probes and a laser particle counter to assess
the number of non-viable particles in the air and are also used for classification purposes as per ISO 14644.
The sampling locations for both viable and non-viable monitoring are selected using a documented risk
based approach that is reviewed and repeated periodically to account for any changes in the process or the
cleanroom.
Appropriate alert levels and action limits should be set for the results of viable and non-viable particle
monitoring. Alert levels should be established based on results of cleanroom qualification tests or trend
Define adequately the sampling points. We will conduct a risk analysis to define the type, sampling
Define sampling plans. That is, routine control plans, batch-related plans, at-rest control plans, control
plans after cleaning and/or disinfection, aseptic filling plans and, finally, define sampling patterns for
Set alert and action limits. These limits should allow to react to changes in results trends.
Controls to be considered within this element of the CCS for the viable particles :-
Frequency of monitoring – include continuous monitoring for non-viable particles and pressures
sound, modern methods that optimise the environmental detection of environmental contamination,
and do not pose a risk of contamination to the product – Rapid Micro Methods (RMM)
Acceptance criteria
The microbiological contamination control strategy covers CAPA associated with repeated results above
4) Media used – provide a description and refer to product specifications for settle plates, contact
5) Refer to alert and action limits noted in (ii) Premises and equipment
6) Alert and action limits. For Grade A – no growth i.e. every recovery requires an investigation.
9) Trending also applies to microbial speciation, A/B should be identified, C/D recommended
10) Media growth promotion – reference micro-organisms used / representation of facility flora / use of
5) Refer to alert and action limits noted in (ii) Premises and equipment
9) Trending also applies to microbial speciation, A/B should be identified, C/D recommended
Presented By : Arvind Kumar Srivastava , Mobile No. :9817039581
Manager - Quality Assurance , Beta Drugs Limited , Baddi , India , Email ID : arvindsrisri82@gmail.com
10) Describe environmental monitoring training
The Risk Assessment related to Process Personnel , Environment, Equipment , Utilities should be prepared.
Remove any residue or debris that would detrimentally impact the effectiveness of the disinfecting
agent used.
Minimize chemical, microbial and particulate contamination of the product during the process and
prior to disinfection.
The Periodic verification of the effectiveness of the controls for aseptic processing through Media fill
Validation should be in place by using a sterile nutrient media and/or surrogate in place of the product.
The effectiveness of the aseptic process should be determined through process design, adherence to the
pharmaceutical quality system and process controls, training, and evaluation of monitoring data. Selection
of an appropriate nutrient media and/or surrogate should be made based on the ability of the media
and/or surrogate to imitate physical product characteristics assessed to pose a risk to product sterility
APS should be performed as part of the initial validation, with at least three consecutive satisfactory
simulation tests that cover all working shifts that the aseptic process may occur in, and after any significant
modification to operational practices, facilities, services or equipment which are assessed to have an
impact on the sterility assurance of the product (e.g. modification to the HVAC system, equipment, changes
to process, number of shifts and numbers of personnel, major facility shut down). Normally, APS (periodic
revalidation) should be repeated twice a year (approximately every six months) for each aseptic process,
each filling line and each shift. Each operator should participate in at least one successful APS annually.
Consideration should be given to performing an APS after the last batch prior to shut down, before long
Typically, two disinfectants are used in rotation, one of which is often a sporicide (capable of destroying
bacterial endospores and fungal spores). The frequency of cleaning and disinfection must be risk based,
review.
Disinfectants that are selected for disinfection of a facility must be validated prior to use.
Validation of disinfectants includes surface challenge testing in which coupons of the surface materials
used throughout the facility are inoculated with a known quantity of representative microorganisms,
exposed to the disinfectant for a specified contact time followed by calculation of the log reduction of the
Personnel who perform cleaning and disinfection of cleanrooms should undergo a tailored training
program that includes specific cleaning techniques that prevent contamination such as use of the triple
bucket system, basic Microbiology training and training on the action of the disinfectants selected for use.
L. Preventative maintenance
To improve the cleanroom contamination control strategy, is to schedule regular maintenance on all
equipment.
Regular Preventive maintenance Programme for the equipment and Utility system should be available and
it is the key to preventing failures of the cleanroom environmental control systems (HVAC) and production
equipment and ensuring the cleanrooms and equipment are operating in their validated state.
Regular Preventive maintenance activities can also pose contamination if not done correctly.
a triple-cleaning and disinfection cycle followed by EM before releasing the areas for routine operation
M. Prevention mechanisms
All applicable QMS elements like Deviation , Change Control , Incident , CAPA , OOS , OOT should be
As part of prevention mechanism, trend analysis, incident/ deviation, detailed investigation & root
cause analysis using different tools i.e. 5 WHY, Fish bone etc. and corrective and preventive actions
Trending of all QMS elements i.e. incidents , deviations , Market Complaint , Change Control should be
Before any sterilisation process is adopted, its suitability for the product and equipment, and its efficacy in
consistently achieving the desired sterilising conditions in all parts of each type of load to be processed
should be validated notably by physical measurements and where appropriate by Biological Indicators (BI).
subject to periodic revalidation. Maximum and minimum loads should also be considered as part of the
The validity of the sterilizing process should be reviewed and verified at scheduled intervals based on risk.
Heat sterilization cycles should be revalidated with a minimum frequency of at least annually for load
patterns that are considered worst case. Other load patterns should be validated at a frequency justified in
the CCS.
Routine operating parameters should be established and adhered to for all sterilisation processes, e.g.
There should be mechanisms in place to detect a sterilisation cycle that does not conform to the validated
parameters. Any failed sterilisation or sterilisation that deviated from the validated process (e.g. have
Suitable BIs placed at appropriate locations should be considered as an additional method to support the
Sterilisation records should be available for each sterilisation run. Each cycle should have a unique
identifier. Their conformity should be reviewed and approved as part of the batch certification/release
procedure.
If the product cannot be sterilised in its final container, solutions or liquids should be sterilised by filtration
through a sterile sterilising grade filter (with a nominal pore size of a maximum of 0.22 μm that has been
appropriately validated to obtain a sterile filtrate) and subsequently aseptically filled into a previously
sterilised container.
The selection of the filter used should ensure that it is compatible with the product and as described in the
marketing authorization
follow the appropriate cleanroom behaviours like Move carefully , Minimize conversation , Maintain
unidirectional airflow (“first air”) , Perform interventions carefully ,Position body means keeping the entire
body out of the path of the unidirectional airflow , Maintain proper gown control ,Protect sterile parts ,
the generation of particles, and does not introduce bioburden into the process through inappropriate
Aseptic operator trainees should only be permitted to perform interventions upon successful participation
The operator has been initially qualified, the facility should schedule an annual refresher training program
The retraining and requalification, reassignment, or permanent removal of operator from the cleanroom
should be available.
P. Failure Management
Preventive maintenance program should be in place.
Trained engineering staffs should be involved in the good engineering practices (GEP).
Environmental monitoring (EM) programs should be in place to monitor and control the environment
and the data being trended, reviewed, and acted upon to ensure the manufacturing operation is
Qualified integrity tester should be used to test the integrity of the gloves.
Microbiological testing of finished products performed for the products being manufacture in the
facility.
R. Waste Management
Facility design should minimize the movement of material and waste and separate them from the flow of
The separate and dedicated pathways will also help prevent cross-contamination between products.
based on information from the current PQS and quality risk management processes. It is important that there are systems
in place to continually review and identify where improvements are required for ongoing quality of Products and that
Change Management
Presented By : Arvind Kumar Srivastava , Mobile No. :9817039581
Manager - Quality Assurance , Beta Drugs Limited , Baddi , India , Email ID : arvindsrisri82@gmail.com
Site self-inspection program, quality and sterility assurance field observation, global quality audits
Management review of the quality systems and process/product performance and quality metrics
SOURCES OF CONTAMINATION
The possible origins of contamination sources:
Inadequate personnel management (ineffective personnel qualification systems, insufficient personnel monitoring,
Poor process design (material and personnel flows, insufficient monitoring tools, non-representative aseptic process
simulation…).
Insufficient cleaning and disinfection systems (insufficient cleaning validation, frequency, rotation of disinfectants, etc.).
Inefficient sterilization processes (inadequate sterilisation systems, insufficient sterilisation validation, loss of control of
Insufficient management of quality events (recurrence of deviations, poor root cause analysis, inadequate OOS or OOT
References: Summarise the same through Some Paper through Google Search , PDA TR - 90 , PICS , EU GMP , WHO TRS