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Terminal sterilization   31


              cycle conditions, such as heat up, temperature, and cool down. The intent is
              to determine the resistance level the normal microbial flora present on the
              product and packaging has to the sterilization process.
                 By knowing the bioburden population (count) and relative resistance of
              that population from the subprocess studies, an extrapolation can be made
              as to the final processing conditions required to deliver the required SAL.
                 A terminal sterilization process established using the bioburden-based
              approach is sensitive to changes in microbial population and resistance. For
              this reason, a robust bioburden monitoring program should be implemented
              with routine sterilization process checks. In radiation, routine sterilization
              process checks are accomplished through the dose audit process. The dose
              audit involves exposing product samples to a dose selected based on the
              bioburden or established in the incremental studies, which is referred to as
              the verification dose. The verification dose is based on the expected resistance
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              of the bioburden population to deliver an SAL of 10  or 10  (based on the
              method used to establish verification dose). The samples are then submitted
              for tests of sterility, with the results either supporting continued effectiveness
              of the overall sterilization process or indicating that investigation is required
              into the validity of the sterilization dose. Similarly, an EO process validated
              with the bioburden-based approach should include routine monitoring of
              the effectiveness of the sterilization process by exposing the product sam-
              ples to fractional process conditions with subsequent product sterility testing.
              Heat sterilized product with the bioburden-based approach (probability of
              survival approach) should include routine presterilization bioburden moni-
              toring to ensure that there has not been a shift in bioburden level or micro-
              bial resistance to temperature. The monitoring of key equipment and process
              parameters should also be conducted routinely for all sterilization processes.

              3.2.3.2  Bioburden and BI-based approach
              The bioburden and biological indicator approach introduces a surrogate BI
              to validate and routinely monitor the process for EO sterilization. Radiation
              validation does not use BIs and focuses only on the   bioburden-based
              approach.
                 As with the bioburden-based approach, the bioburden and BI-based
              approach requires strong knowledge and control of the product bioburden.
              Bioburden fluctuations could have a significant impact on the effectiveness
              of the validated sterilization process. The bioburden recovery method and
              frequency of monitoring should be effective at detecting shifts in the mi-
              crobial flora.
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