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234   Assurance of sterility for sensitive combination products and materials


          The choice of an alternative SAL and the support of that choice depend on
          risk assessment and the applicable regulatory authority. The document does,
          however, provide much guidance associated with options for achieving a
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          maximal SAL of 10 . Some of the options presented in the document that
          might be pursued in determining whether a product can be sterilized to a
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          maximal SAL of 10  include assessment of product design, materials, vali-
          dation approaches, sterilization methods, and bioburden reduction. One or
          more of these options might allow a sterilization process that can achieve a
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          maximal SAL of 10 .
             A significant inclusion in the document is a flow chart that guides the
          user through the process of determining whether a product can be steril-
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          ized to a maximal SAL of 10  and, if not, what should be done to support
          the selection of an alternative SAL. Risk management is a main theme in
          supporting the choice of an alternative SAL and guidance is given for areas
          to be addressed, including risk management considerations and risk man-
          agement output. In addition, ISO TS 19930 contains a section on Label
          Claims that discusses the regulatory requirements that apply for a product
          to be labeled sterile and again emphasizes that labeling a product as sterile is
          typically subject to national or regional regulations or standards.
             The ISO TS 19930 guidance points out that clinical benefit must be
          weighed against other technical and logistical factors in order to determine
          whether a product can or should be sterilized to a maximal SAL other than
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          10  SAL.
          9.5.4  Documents pertaining to aseptic processing
          and assurance of sterility

          The introduction of ISO 13408-1, as well as the decision tree provided in
          the EMA guidance on sterilization of medicinal products, clearly indicate
          that terminal sterilization is the preferred method of providing assurance of
          sterility, and, if terminal sterilization cannot be achieved, aseptic processing
          should be used. Terminal sterilization is preferred because it applies a pro-
          cess that inactivates microorganisms rather than using procedures that pre-
          vent the introduction of microorganisms. Consequently, an active process
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          that ensures a maximal sterility assurance level of 10 , 10 , or 10  could
          be considered as an option to using aseptic processing.
          9.5.5  ISO 13408 series
          The ISO 13408 series of standards specifically addresses aseptic process-
          ing and the many requirements associated with that approach to provide
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