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Cleaning Validation (Chapter 6) HBEL Approach in Pharma

The HBEL (Health-Based Exposure Limit) approach in cleaning validation sets acceptance limits using a science-based estimate of how much of a residue a patient can safely be exposed to per day without appreciable health risk. HBELs are typically expressed as a PDE (Permitted Daily Exposure) or equivalent value and are now the preferred basis for carryover limits instead of older fixed limits (e.g., 10 ppm or 1/1000 dose), except where scientifically justified.

1) Build the toxicological basis (PDE/HBEL)

A qualified toxicologist (or trained SME per procedure) reviews:

  • Pharmacology and toxicity data (NOAEL/LOAEL, clinical safety data)
  • Genotoxicity/carcinogenicity, reproductive toxicity, sensitization
  • Route of administration (oral, parenteral, inhalation), duration, special populations
    Using recognized methodology, a PDE is derived by applying adjustment factors (e.g., interspecies, variability, duration).

2) Convert HBEL into a carryover limit (MACO)

Once PDE is available, calculate MACO (Maximum Allowable Carryover) into the next product, considering:

  • Minimum daily dose of the next product (worst-case patient exposure)
  • Maximum batch size of the next product (dilution effect)
    A common expression is:
    MACO (mg) = PDE (mg/day) × Batch size of next product (mg) ÷ Minimum daily dose of next product (mg/day)

3) Convert MACO to practical sampling limits

Translate MACO into:

  • Surface residue limits (e.g., µg/cm²) using total shared product-contact surface area
  • Rinse limits (e.g., mg/L) using final rinse volume, if rinse sampling is used
    Include swab recovery factors when justified and ensure method LOQ is below limits.

4) Apply to equipment and worst-case selection

Use HBELs to select worst-case products (lowest PDE/high potency, poor solubility, sticky matrices) and worst-case equipment locations (gaskets, valves, dead legs). Group products into families when justified, but document rationale.

5) Control strategy and lifecycle

Execute PQ (often 3 successful runs), trend routine verification data, and manage changes (new product, new PDE, equipment changes, cleaning agent changes) through change control. HBEL-based limits provide defensible, patient-safety-focused cleaning validation across the product lifecycle.

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