D-115

Environmental Monitoring of Air and Surfaces

Section D — Laboratory Operations and Specifications Revision 11 26 pages

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1.0 Purpose 
 The purpose of this procedure is to set guidelines for the microbiological Environmental
 Monitoring Program (EMP) of Ion Labs two buildings (Operations/Administration and
 Warehouse). This program is used to verify the effectiveness of the facility’s cleaning,
 maintenance and GMP programs at lon Labs Inc. The EMP will focus on environmental air and
 non-praduct contact surfaces within the plant processing areas during normal production periods.
 Scope 
 
 This procedure applies to all production areas and used to determine the effectiveness of the plant
 sanitation program, ‘This SOP outlines the sampling planto execute microbiological testing of air
 
 and non-product contact surfaces for an entire year, Samplepoints are defined by site location
 
 and testing type, with corresponding aleri/action limits established. All defined locations are
 tested at least once each quarter and test results are documented on the forms provided. A
 
 summary report is generated each quarter to summarize observed trends, excursions events and
 corrective action(s) taken during that period. 
 
 Responsibility 
 
 ttaoNt i itis the responsibility of QC Laboratory Analysts to follow this procedure,
 
 J itis the responsibility of QC Laboratory Mana gement to nnplement this procedure and to
 
 ensure that the procedure is being followed, 
 
 3.3 Itis the responsibility of OC Laboratory Management to keep this procedure aligned with
 
 current practices and to oversee validations and recovery studies.
 
 
 

[SOP 

 Standard Operating Procedure 1_ SOP No 
 .E nvironmental Monitwoeri ng of Ai; r and S—urf aces | Dn--L1I1S5 | u1 Pa°ge2 of 26
 
 4.0 Definitions 
 
 4] Fone 1: Praduct Contact Surface (PCS) — surfaces that come into direct contact with
 
 ingredients and/or product 
 
 42 Wen-product Contact Surface (Nen-PCS} — surfaces that do not come inte direct
 contact with the product and/or components 
 
 45 fone 2 ~ non-PCS adjacent to or within close proximity to the PCS; areas that, if
 contaminated, could reasonably lead to PCS contamination; examples include (hut are
 
 not limited to): 
 
 4.3.1 Exterior of equipment that is im contact with the product 
 
 ehw dat aS Conveyor belts, legs/framework in the filling process, and any areas of the filling
 equipment that is near floor drains 
 
 xa aeL oo[ Platforms and handrails in Blending 
 
 4.3.4 Equipment housing (panel buttons, operator control buttons) 
 
 + daL iaC Floor drains below conveyors 
 
 Work surfaces adjacent to unsealed product (i... tables}» ,eka og yO
 
 4.3.7 Ventilation and air handling equipment 
 
 “hat fone 3 ~ the arca that immediately that surrcunds Zone 2; areas that, if contaminated,
 
 could lead to PCS contamination with human intervention (.ec., employee using
 compressed air to clean floors or a piece of equipment): examples include (bat are not
 
 limited to}: 
 
 4.4.1 Permanently mounted air and water hoses 
 
 4.4.2 Floors and floer drains 
 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev Pave 3 of 6 
 Envir ronmental M” o* nit° oriv ng of Ais r andM4 S“u~ rfiag ces D-oo. US4 La, “a.e a REAP
 
 4.4.2 Damaged floors, Le., cracks, crevices, missing plece of concrete
 + 
 tan 
 444 Corridors 
 
 44.5 Walls 
 
 Zone 4 — the area immediately surrounding Zone 3, generally considered a remote area;
 
 area which, if contaminated with a pathogen, could lead ta contamination of Zone 3 via
 the actions of humans or machinery; examples include (but are not limited to):
 
 4.5.1 Employee locker rooms 
 
 45.2 Warehouse 
 
 4.3.4 Hallways 
 
 4.6 EMP —~Environmental Monitoring Program 
 
 4.7 EM - Environmental Monitoring 
 
 48 TSA —Tryptic Soy Agar 
 
 49 SBA ~ Sabouraud Dextrose Agar 
 
 4,10 SMPTE —~No More Than 
 
 4.41 CRU ~ Colony Forming Units 
 
 442 QC - Quality Control 
 
 4re .J34 A. ler. t. Loie mi*t ~ i“ ndtie catasi on that. mic. robiwaol COUNT_ I# S cn reas« e i«n area
 
 
 

[SOP 

 Standard Operating Procedure — SOP Ne Rey 
 D-115 ii Page4 of 26 
 Environmental Monitoring of Air and Surfaces 
 ons 
 
 4.14 Avtion Limit — signals an apparent deviation from normal process conditions. Requires
 immediate action 
 
 Confirmed Positive — positive result determined using identification noa iw
 
 416 10 — Installation Qualification 
 
 4.17 OO — Operation Qualification 
 
 4.18 PQ -~ Performance Qualification 
 
 419 CAPA — Corrective and Preventative Action 
 
 4.20 (GMP -~ Good Manulacturing Practices 
 
 SG References 
 
 5.1 C-201, SOP, Deviation and Investigation Procedure 
 
 3.2 D-{01, SOP, Laboratory Housekeeping 
 
 yaC a C403, SOP, Change Control Procedure 
 
 Ai sp“ 4-106, Documentation Guidelines for cGMP Records 
 
 5,5 C-3501, SOP, Document Control 
 
 5.7 QS-108, SOP, Corrective and Preventative Action (CAPA) 
 
 5.8 C-105, SOP, Protocol and Report Documentation Requirements 
 
 39 PRTCL-21-0037, Protocol, Environmental Monitoring of Air and Surfaces
 
 5.10 The FDA's 202] draft guidance is a key resource for understanding how to control
 
 microbiological quality in non-sterile drag manufacturing. 
 
 
 

[SOP 

 Standa M rd o O n pe rating ‘ Procedure S D O 1 P 1 N 8 o | R i ev | Page o So n f 2 e 6
 
 Environmental Monitoring of Air and Surfaces 
 acr ra 
 reteet 
 ema 
 11 US. Pharmacopoeia, USP42-NP37 2S (2020). < 1116> Microbiological Evaluation of ae
 ; 
 Clean Rooms and Other Controlled Environments 
 5.12 Parenteral Drug Association Technical Report No. 13. (2014). Fundamentals of an
 Environmental Monitoring Program (Revised Edition) 
 
 130 D-115-F2, Form, Alert/Action and Positive Result Resarnple Log yt
 
 O-115-F 1, Form, Air and Surface Sampling Log yS sp 
 
 D-115-F3, Form, Preliminary Pathogen Screening Log. sS yaL 
 
 6.0 Required Supplies, Media, and Equipment 
 
 6.1 Sterile Swabs and/or Sponges 
 
 6.3 Sabouraud Dextrese Agar (SDA) plates and contact plates 
 
 6.4 20"C to 25°C and 30°C to 40°C Incubators (adjustable) 
 
 6.5 Biological Safety Cabinet 
 
 7.0 Procedure 
 
 7.1 Sample Labeling and Preparation 
 
 71 Obtain media and confirm it is net expired as of date of use.
 
 712 Label swabs, contact plates and air plates with corresponding site location,
 
 (See Attachment | and 2) 
 
 3~ aN Sampling Environmental Surfaces - Swab Sampling for TAPC and Yeast & Mold on
 
 
 

[SOP 

 | SOP No | Rev 
 Standard Operating Procedure Page 6 of 26 
 Environmental Monitoring of Aur and Surlaces D-TES : Bl “ | 
 
 7.2.1 Allow swab to acclimate to ambient temperature (21-25 °C) before use. Use
 
 thamb to break snap-valve by bending bulb, releasing liquid into tube and
 
 7.2.2 Drain swabbing should consisi of those surfaces that can harbor bactena and
 
 then be cortact transferred to other areas of the business. 
 
 Surface Drains eeS NM de 
 
 7.2.3.1 Before sampling, ensure that no probiotics are being actively handled an
 the site location. Do not sample processing roams running probiotics.
 
 Surface drain monitoring testing will be conducted afier a major
 
 cleaning procedure is completed. 
 
 3.2 Pull swab out of nube and swab an area (44 inches) for flat surface and J SB
 7 
 a representative area size for uregular surfaces. 
 
 7.2.3.3 Replace swab in tube and deliver to lab for inoculation.
 
 724 Trench Drains (Gummy Lines) 
 
 7.24.1 Trench drains typically are comprised of multiple sections and individual
 
 COVers, 
 
 ¢24.2 Pull swab out of tube and swab an area (4x4 inches) for flat surface and
 
 a representative area size for irregular surfaces. 
 
 ]~~ "«3| Roaaqnptfiuczvee th“eO Yi ntem6raxyi or ofg hth e bi5 ologi7 cal sries afeeatt y cabi4 net as per Sa O5 P D1-10]
 
 Laboratory Housekeeping before plating. 
 
 T7I2S6 SShhaalkees ddeevwiccee 110 sCeOcLEaTnTEd sS to meiyxe an7 d poIuErP cPooynwtrkeenwtt i7 n 9+ 9ml bufofee red: peptone
 
 water Tor 17100 dilution. Vortex and place S00 uL in two Petri dishes.
 
 la i dw Pao ur “TPrerntyicep tic SGoayw AgAgaare aannadl SGaalb ora;n d Dext, rose Agar onto one of each plate and
 swirl gently to mix. 
 
 
 

[SOP 

 Standard Ooeratine Procedure SOP Ne | Rev _ 
 Standard Operating Proc nus | ou Page 7 of 26 
 } 
 Environmental Monitorme of Air and Surfaces ! i 
 i 
 a 
 728 Incubate TSA plates at 33°C + 2°C for 48-72 hours. Incubate SDA plates at
 23°C & 2°C for 5-7 days. 
 
 7.2.9 All data collected for swabbing testing of the drains will be documented on
 Farm D-1145-Fi Air and Surface Sampling Log. 
 
 7.3 Sampling Environmental Surfaces - Contact Plates Sampling for TAPC and Yeast &
 Mold 
 
 7.3.1 Allow contact plates (TSA and SDA) to acclunate to ambient temperature (21-25
 pate, 
 °C) before use, 
 
 7.3.2 Before sampling, ensure that no probiotics are being actively handled on the site
 
 location, Da mot sample processing rooms running probiotics. Surface
 monitonng testing will be conducted after a major cleaning procedure is
 
 compisted, 
 
 Remove cover, place contact plate directly on surface, and press sli.ghtly. Remove 23£ dei
 
 from surface and cover. 
 
 Incubate TSA plates at 33°C + 2°C for 48-72 hours. Incubate SDA plates at ~ oot ei
 
 23°C & 2°C for 5-7 days. 
 
 das doL A All data collected for contact plate testing will be documented on Form D-115-
 Pl Air and Surface Sampling Log. 
 
 74 Environmental Air ~ Settling Plate Sampling for TAPC and Yeast & Mald
 
 co7rd4.0 Allow plates (TSA and SDA) to acclimate to ambient temperature 21-25 °C)
 
 742 Delore sampling, ensure that no probiotics are being actively handled on the site
 
 location, Do not sample processing roorms running probiotics. Air monitoring
 testing will be conducted after a major cleaning procedure is completed,
 
 CONFUDENTLAL: For ABI Ton Labs use only 
 a, 
 

[SOP 

 S S t t a a n n d d a a r r d d O O p p e e r r a a t t i i n ng g Pro Pr c oc e dure S D O - P 11 N 5 o | : R e 7 v Pag§ eof 3 2 G 6
 Environmental Monitoring of Air and Surfaces 
 
 74.3 Place one prepared SDA Plate and one TSA plate in the sample site location
 with covers rernoved. 
 
 7.4.4 Leave the plate exposedfor a minimum of 1S minutes un cach location.
 
 7AS Incubate TSA plates at 33°Ca: 2°C for 48-72 hours. 
 
 7.4.6 Incubate SDA plates at 23°<C 2°C for 5-7 days. 
 
 3w AW data collected for air testing will be documented on Porm D-113-F1 Ag and aE
 
 Surface Sampling Log, 
 
 7.5 Reporting Results 
 
 7.5.1 Count coloniesand recorasd CFU/plate. 
 
 ea 43C 2 Ifne colonies appear on the plate, the result should be reported as “ND”,
 
 73.3 if TNTC results are ohtamed on sites where probiotics were processed, thes
 results should be invalided and a new sample must be collected. The location site
 
 should be sanitized prior to re-sarnpling. 
 
 7.5.4 If growth is observed on TSA or SDA, further isolate colonies with distinctive
 
 morphologies, if applicable. Non-selective media such as TSA or Blood Agar
 
 should be used for bacteria, and SDA for yeast isolation. Mold screening is not
 ane 
 required and isolation from TNTC plates is not performed. 
 
 ~~ kat tP bach isolated growih will be labeled a8 sample location (See Atiaclanent 1 ~
 Saniple Site Rey) + colony isolated (A, B. C...3. 
 
 7.5.5.1 For instance, B5-9A plate will refer to Blending Room 5 ~ Table, and the
 letter A is assigned to the firstisolated colony from BS-9 environmental
 
 plate. If multiple colonies are isolated from same plate, next isolation
 
 plate willbe B5-9B, B5-9C., 
 
 
 

[SOP 

 ynn nnnenn 
 eroy1 
 , 
 Standard Operating Procedure SOP No | Rev 
 Environmental Monitoring of Air and Surfaces 
 i eeb pis 11 Page 9 of 26
 
 fw nc 
 Incubate TSA or Blood Agar at 33°C + 2°C for 24-48 hours. 
 Incubate SBA plates at 23°C sb 2°C for 5-7 days. 
 Inveulate the isolated growth onto pathogen specific media to determine the
 presence of pathogens. Refer SOP D-715.0 Microbial Limit Testing using Agar
 Plates. Commercially prepared chromogenic media may be used as supporting
 media for presumptive identification. Follow vendor instructions for incubation
 time and temperatures. 
 7.5.8.1 Alternatively, identification can be performed directly from growth
 
 isolated on TSA, Blood Agar or SDA, to confirm presence or absence of
 
 specific pathogens. Reference SOP D-1016 Microbial Identification via
 Biolog Microstation for identification instructions. 
 
 Tf typical growth is observed on the pathogen specific media, then this growth
 requires a contirmatery identification. Reference SOP D-LO016 Microbial
 
 identification via Biolog Microstation for identification mstractions.
 
 if ne growth or atypical growth 1s observed report as “ND for specific pathogen
 
 screening and no more testing is required. Document results on Form D-115-F3
 
 Preliminary Pathogen Screening Log. 
 
 &.0 Specifications 
 
 5.1 Environmental Monitoring of Air and Surfaces for Alert/Action Limits specifications:
 
 Air 8&8 
 | QNI 
 ab 
 laW 
 so 
 daC surlace (Contact) BL
 x 
 Surface (Drains) 2022 - . 2869 
 domae aoh+ Positive results are obtained with the conlinned identification of one of the following
 organisnis: 
 
 
 

[SOP 

 Standare Operating Procedure SOP Ne | Rev | — 
 _ - D-115 11 | Page 10 ef 26 
 Environmental Monitoring of Airand Surfaces 6 4"" a 
 
 L. monocytogenes Negative 
 
 8.3 Any presumptive positive or typical growth observed, should be identified to the species
 
 level to continm absence or presence of the organisms listed above. Reference SOP 1-
 1016 Microbial Identification via Biolog Microstation for identification instructions.
 
 *.0 Corrective Action 
 
 9.4 Exceeded Alert Limit 
 
 9.1.1 When results exceed the specified alert limit, a member of operational management
 
 must be notified, and the affected area resampled.The location site should be
 sanitized prior io resampling. Document on form D-115-F2 Alert/Action and
 
 Positive Result Resample Log. 
 
 9.2 Fesceeded Action Limit or Confirmed Pasitive 
 
 9.2.) Corrective actions must be taken when results exceed Action limits, or a confirmed
 
 positivies foundin any zone. Verified presence of a pathogen listed in this SOP is
 an action linvit fatlare. 
 
 So to 9.2.2 Operational and Quality management must be immediately notified and the even
 
 9.2.3 QC personnel initiate a deviation after confirmation of the initial action limit failure
 result is obtained. Corrective actions will he documented on forms C-201-F 1. Refer
 
 to SOP C-201 Deviation and Investigalion Procedure. Deviations for an event
 
 exceeding action limits may inchide risk assessment and/or CAPA, Alternatively,
 initiation of a CAPA following SOP QS-108 Corrective and Preventative Action
 
 
 

[SOP 

 Standard Operating Procedure SO G P E N N o | Re+ v || Page” 11 of 26
 Environmental Monitoring of Air and Surfaces : D-HS i i - } 
 | 
 (CAPA) may be performed. DEV or CAPA number assigned Gf applicable), will be
 
 documented on Form D-115-F2 Alert/Action and Positive Result Resample Log,
 
 Any product produced in the impacted area should be identified and documented on ep o,b nitkaa‘
 sP 
 Deviation or CAPA initiated, along with the disposition decision based on the
 associated risk assessment. 
 
 O.2.5 Frequency of sampling of the impacted area and the areas directly surrounding the
 
 impacted area will be increased from once per quarter to once per business day until
 
 at least three consecutive results are below the action limits. Areas should be
 sanitized prior re-sampling gets started. Ail resamples taken will be documented on
 
 Porm D-L{5-F2 Alert/Action and Positive Result Resampie Log. 
 
 9.2.6 Increased sampling rates described above do not need to occur on days where there
 
 is no activity other than corrective actions intended to rescive the observed result(s).
 Whether the area is used for actual production activity depends on assaciated risk
 
 assessment. 
 
 2.7 After achieving three consecutive results below the action limits, resume the regular
 
 sampling frequency. 
 
 92.8 Tf re-sampling and/ or the areas directly surrounding the impacted area still show
 concerning or pasitive results then alternative corrective action(s) should be
 
 explored to correct any GMP deficiencies based on the findings. These may include:
 
 22.81 Review of microbiological sampling methods and techniques
 
 9.2.8.2 Reinforce or retrain hygienic practices with appropriate employees
 
 9.2.8.3 Revision of the sanitization program, inclading selection of
 
 antimicrobial agents, application methods, and frequencies
 
 9.2.8.4 Eliminate water if present 
 
 
 

[SOP 

 Standard Operating Procedure S p O i P s No | > R i ev | Page i — ofl
 i , 
 Environmental Monitoring of Air and Surfaces 
 
 92.8.5 Repair damaged floors/walls and other structural damage
 
 9.2.8.6 Re-examine traffic patterns. Where necessary and feasible, limit traffic
 
 flows (employee and equipment) through the area, restrict forklift truck
 movement, redirect high-risk traffic patterns from adjacent areas, etc.
 
 92.8.7 To verify the effectiveness of corrective actions taken, sampling
 
 frequency of these sites will be increased as previously described in
 sections 9.2.5to 9.2.7. Document on Form 2-115-P2 Alert/Action and
 
 Positive Result Resample Log. Then resume the regular sampling
 frequency. 
 
 92.8.8 Tf any of the re-samples do not micet specification, follow procedure
 again from the beginning of this section. 
 
 o3 Consecutive Alert/ Action Level or Pasitive Results 
 
 9 Consecutive Alert/Action Level or positive results may indicate the primary source aL
 
 is a harborage site (where the organism may have been established and multiplying).
 
 9.3.2 Map the contamination sites on a layout of the facility to aid in locating the source oB
 
 of contamination. 
 
 9.3.3 Reinforce GMP training and hygienic practices and provide additional attention to
 sanitation practices. 
 
 43.4 Visnally inspect areas for potential niches. Intensify cleaning activities around these
 areas, 
 
 9.3.5 Observe handling practices (production, sanitation, maintenance, material handling)
 and correct non-hygienic employee practices. 
 
 2.3.06 Review equipment cleaning and preventative maintenance protocols and revise if
 
 
 

[SOP 

 | SOPNo | Rey | 
 Standard Operating Procedure 
 | opts | if | Page 13 of 26 
 
 iG.G Issui 
 
 iQ] 
 
 [Q.2 
 
10.3 eeB seo emM AC
 
 Construction or New Equipment 
 O4.1 Construction or new equipment installation in the processing areas may affect the
 PCS. Assess plant traffic controls, sanitation activities, etc. during construction
 activities. Assess envirommental monitoring requirements within protocols initiated
 at time of consirtuction or new equipment installation G.e. 1Q/OO/PQ for those
 processes}, 
 ng, Reporting, and Piling 
 Attachment 1 through 2 will be utilized for each sampling plan to execute the
 Environmental Monitoring of Air and Surfaces for an entire year. 
 Document all mutine samples taken and results obtamed on forms D-LES5-F1 Au and
 Surface Sampling Log. 
 All resamples taken, CAPAs, or DEV numbers assigned Gf applicable), and results
 obtamed will be documented on form 0-115-F2 Alert/Action and Pasitive Result
 Resample Log. 
 A summary report will be generated of each quarter with testing and trending to
 Document Control wrth an issued Report number. Refer to SOP C-105 Protocol and
 Report Documentation Requirements. This quarterly review should be documented
 within sixty calendar days of the end of each subject quarter. 
 Quarterly reports will summarize the monitoring data for the quarter and will contain
 trend reports for a rolling year. The reports will include: 
 10.5.1 Summation of the data collected 
 10.3.2 Evaluation of the adequacy of the current sampling plans 
 10.5.5 Evaluation of the adequacy of established alert and action limits
 10.3.4 All seports will be approved by a minimum of four (4) si gnatures to melude:
 

[SOP 

 SOPNo | Rev 
 Standard Operating Procedure 
 Page 14 of 26 
 Environmental Monitoring of Air and Surfaces 
 
 10.5.4.) Author 
 
 10.5.4.2 QC Laboratory Management 
 
 10.5.4.3 Head of Quality or Quality designee outside the QC Laboratory
 
 10.5.4.4 Head of Operations or designee 
 
 11.0 Revisions 
 
 11.4 Review specifications for alert/action limits annually or as needed.
 
 li.i.) A risk-based unpact assessment should be conducted to understand each process
 
 and identity where microbial contamimation could occur. The level of contral
 should be on product-specific characteristics (e.g., dosage form, water activity,
 
 antimicrobial properties} and manufacturing process elements that are more likely
 to introduce bioburden or objectionable microorganisms. 
 
 Li..2 The level ef potential contamination should be adiusted, with consideration to the
 J ~ > 
 processing conditions withim cach area. These conditions include, but are not limited to,
 product's exposure, personne! traffic, material flow, and the effectiveness of cleaning and
 sanitization procedures. Example shown below, 
 
 Areu Risk Factor | Processing Conditions 
 
 Blending Room | High Open product, high personnel traffic 
 
 Packaging Line | Medium Product enclosed, moderate traffic 
 
 Warehouse Low | No prodact exposure 
 
 
 

[SOP 

 Standard Operating Procedure SOP No Rceove eye| oe 
 D115 it | Page 1S of 26 
 Environmental Monitoring of Air and Surfaces 
 i wot 
 11.1.3 Once each area has been assessed, alert and action limits will be calculated based
 on trend analysis of data collected over the previous calendar year. The microbial
 
 baseline level will be defined using updated historical data to ensure continued
 representation of the processes sormal operating range and to reflect any
 
 iL.i.4 The caleulation is performed using the average and the standard deviation of the
 
 analyzed data as follows: 
 
 Action Limit = Average + 3 Standard Deviations 
 
 {1.2 Adpust sampling plans throughout the year as necessary to accommodate added locations
 and new equipment installations, 
 
 11.3 Follow SOP C-403 Change Control Procedure to process all revisions made io sampling
 plans, 
 
 12.0 Documentation Requirements 
 
 f2.1 ATP documentation will be distributed and maintained as outlined in SOP €-401
 
 Document Control and SOP C-502 Record Storage, Retention, and Destruction.
 
 ]2.2 All decumemation will be completed as outlined in SOP A-106 Documentation
 Cruidelines for cGMP Recards. 
 
 i3.0 Revision History 
 Revision Date Description of Chanzes CCR H By 
 0 O3/04/19 | New procedure. NVA L. McWade 
 
 | Added plans for each ream including drains. Added flow 
 OMOZ/21 | chart for gram stain and additional testing to identify positive CO-2 4-023 G. Shaw
 Lipdated numbering of keys. Adjusted eummy room to 
 quarterly testing scheme, 
 CCl~2)-0420 G. Show 
 03/21/22 Added shck pack rooms to schedule, Clarified testing and 
 CO-22-0086 G. Shaw 
 aiaps. Slt R&D, 
 
 
 

[SOP 

 “SOP No 
 Standard Operating Procedure Rev 
 Page 16 of 26 
 Environmental Monitering of Air and Surfaces 
 D-115 
 O4/28/22 i Annnal recalculation of alert and action Himits, t, Shaw 
 
 Kept drains on for temporary alert and action limits. Added 
 s O9/30/22 | layout and sites for the new warehouse building, meluding CU~22-03 90 r. Shaw
 sampling booths. 
 | Added new testing for gummy lines and assaciated liquid 
 6. 04a/2n0i/m2 3 | aGInNd paBcAkCKaQsEiInNgG roTOOmTS. s. DeLAlSteetiiec d uUnNnTeEcCeEsSSsAaTrYy contenCONEETE. t. NewINGW CC+- 2A3S- G14Al5as Go.g Syhaw
 form D-P15-P3 Guowy Line Air and Surface Sarnpling Log 
 Added mop sinks and log for all sinks. Adjusted plan to be 
 7 OTI4 just one that is followed quarterly. Added reference to drain CC-23-63.40 G. Shaw
 sampling log. Added documentation requirements. Updated. 
 format. 
 | Revised to clarify current practices. Removed pathogen 
 testing for gummy reoms. Clarified corrective actions. J. Sassman
 Added alert and action limits for drains. Added Drain Map. 
 Revised to reflect current practices. Undated sample plan 
 testing. Removed reference fo obsolete forms. Added new CC-24-0158
 forms D-11S-Fl and D-1 15-23, 
 Revised to reflect current practices. Updated sample plan 
 testing. Clarified preliminary procedure for selective 
 10 09/09/24 pathogen screening. Minor changes on forms D-]1S-F i and 
 -Lt3-F2, Added new form D-115-F3 Preliminary Pathogen 
 Screening Log, 
 deN da 9/2 /2: 
 t t 
 Revised io reflect current practices. Updated sample plan 
 testing, Annual recaloulation of alert and action Hmits. 
 14.0 Attachments 
 
 Idi Attachment | ~ Sample Site Key | 
 
 14.2 Attachment 2“”y ~ Quarterly Sampling Plan 
 
 .o Attachment 3 ~~ Site Map 
 
 4 Attachment 4 —~ Layout for Kitting and Sanipling Booths 
 
 Attachment 5 ~ Drain Maps 
 
 CONTIDENTIAL: For HBI Ion Labs use only 
 

[SOP 

 Standard Operating Procedure SOP Ale Rev | 
 D-115 i | Page Wot 
 Environmental Monitoring of Air and Surfaces 
 
 ATTACHMENT 1 ~ SAMPLE SITE KEY 
 
 Week Number 
 1-12 
 
 Repms 
 B = Blending (Aone 2} 
 
 SB = Sampling Booth (Zone 4) 
 
 Air Samnle Sites 
 
 = Far end of room )esra 
 L, = Liquids (Zone 2) WC = Walk-in Cooler (Zone 4) 
 CT = Coating (Zone 2} CR = Cold Room Hone 2 
 P= Packaging (Zone 2} ER = Locker Room (“one 4) 
 FP = Final Pack (Zone 3} Ko Kitting Zone 4) 
 SA = Sanitation (Zone 3) R&D = Research and Development Lab (Zone 4)
 R- Right 
 Surface Sample Sites 
 6 = Misc or Mix 3 Kettle (Zone 2) 
 7 = Main Equipment or Mogul Dispenser (Zone 2) 10 = Drain (Zone 2 or Zone 3} 
 8 = Conveyor or Cooling Tunnel (Zone 2) 
 Ccumimy Lines 
 GL2 = Gummy Line 2 GLDRI = Gurumy Line Drying Room | 
 
 GL3 = Gumovy Line 3 GLDR2 = Gammy Line Drying Room 2 
 GL4 = Guomy Line 4/Gummy Line Packaging GLDE3 = Gummy Line Drying Room 3 
 
 GLSA = Gummy Line Sanitation 
 
 
 

[SOP 

 Standard Operating Procedure 
 SOP No 
 17 | «Page I ofl6 | 
 Environmental Monitoring of Air and Surfaces D-115 
 
 Wi 
 Wi 
 
 LIP S-1/6,7,9(a} 
 LIF B-1/6,97a,) 
 
 w2 GLDRI-1 
 ~GLDR2-1 
 (a) Liguid Rooms back only get air samphne 
 
 P3-1,2,3/6,7,8 
 
 Ww 
 
 SAI-7 
 BI-1/6.7.9 
 SAI-8 
 
 We B5-1/6,7,9 
 
 Ww 
 
 
 

[SOP 

 y: Standard Operating Procedure SGP No | Rev 
 p.115 {1 Page 19 of 26 
 '‘tt( Environmental Monitoring of Air and Surfaces 
 
 ATTACHMENT 2 - QUARTERLY SAMPLING PLAS (CONTINUED) 
 
 Ws C1-1/6,7,9 | SAL-10 
 WS 8 16,7,9- B3 
 
 Ws C3-1/6,7,9 oT3 
 
 Wé6 : P8-12,5/6,7,8 | CTd 
 
 WEG 3 CR-1/6 LSF.B 
 WE GLDR3 -1 : 
 
 W7 GL4 ~ 1,2,3/8 SA2-2 
 
 W7 TS-1/6,7,9 
 
 WS iE P/6.7,9 
 
 “Ws - [34 — 1/6.7,9 
 
 
 

[SOP 

 SOPNo | Rev — 
 Standard Operating Procedure 
 pis 6 i Page 20 of 26 
 ':ii 
 { 
 Environmental Monitoring of Air and Surfaces 
 ATTACHMENT 2 —- QUARTERLY SAMPLING PLAN (CONTINUED) 
 
 Wo CS- 1/6. 7,9 
 
 C6-1/6,7,9 
 wo 
 CF-1/6,7,9 
 CS-1/6,7,9 
 WY 
 
 WO 
 
 LR-1/6 
 SAL-LG 
 WHO 
 — SA2-1/6 
 W10 
 WO 
 
 Wl K1-1/6 (b) | 
 
 Wi 
 Wii K4-1/6 (b) 
 SB-R-1 (b) 
 Whi 
 WIL 
 WC- 16 (b) 
 (b}) Sarnpling done at Belcher 
 
 SA Mop Sink 
 2 ~ 1/6,7,9 L. Mop Sink 
 B3 ~ 1/6,7,9 
 B4 ~ 1/6,7,9 
 
 B6 — 1/6,7 
 
 
 

[SOP 

 Standard Operating Procedure 
 Page 21 of 26 
 Environmental Monitering of Air and Surfaces 
 H 
 tiy 
 
 b r a Sa ERS A B P y CT N R ae E ST tpan esep eos
 Boe pSet Pebbhes 
 
 Lares) 
 e eltiao 
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