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Since 2002, at the end of each US Fiscal Year, CONCEPT HEIDELBERG
elaborates the Warning Letter Report, a comprehensive analysis of
warning letters issued during the previous twelve months. The data
evaluation for 2006 is now closed so that the overall results will be
published within the next two weeks. In advance, we have extracted
interesting results in the field of maintenance and cleaning of
equipment from the Warning Letter Report. They are as follows:
Maintenance and cleaning of equipment (211.67,
Subpart D) is among the top 3 areas for which the US-American
health authority FDA issued warning letters in 2006.
The most frequent deficiency that triggered warning letters in the
field of equipment in 2006 was insufficient maintenance. Filters gave
rise to complaints remarkably often, both in relation to cleanrooms and
as regards water equipment. Some of the complaints related to the fact
that HEPA filters were not clean, that filters were not changed within
the prescribed frequency or that filter integrity tests were not conducted.
Other complaints referred to insufficient cleaning or non-compliance
with the required cleaning procedures. The equipment in question were
buildings, process, filling or packaging equipment.
Another frequent deviation in the technical field was the missing
qualification of air handling systems for cleanrooms - first and
foremost the lack of proof that no cross-contamination can take place
over the HVAC system.
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