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[ The Aseptic Core.

Coordinated by Ed White

HEPA and ULPA Filters


Ed White

The Aseptic Core discusses scientific and regula- installations)


tory aspects of aseptic processing, with an emphasis on HEPA and ULPA maintenance typically includes peri-
aseptic formulation and filling. This column provides odic replacement of pre-filters, monitoring of pressure
practical advice to professionals involved in the qualifi- drop across the filters, periodic inspection of ductwork
cation of aseptic processes and the myriad support pro- upstream of the HEPA and ULPA filters, and periodic
cesses involved. The primary objective for this column: inspection of gaskets and gel seals.
Useful information.
Reader comments, questions, and suggestions are INTRODUCTION
needed to help us meet our objective for this column. HEPA and ULPA filters are found in every aseptic processing
Discussion topics and case studies related to aseptic pro- facility. They are necessary for almost every aseptic pro-
cessing submitted by readers are invited. Please e-mail cess, yet few people think much about them. This column
your suggestions to coordinating editor Susan Haigney provides an overview of HEPA and ULPA filters.
at shaigney@advanstar.com.
WHAT ARE HEPA AND ULPA FILTERS?
KEY POINTS HEPA and ULPA filters are designations for specialized
The following key points are discussed in this article: filters designed to filter dry air with a rated efficiency of
High efficiency particulate air (HEPA) filters and ultra- 99.97% or greater. They are not absolute filters, but instead
low penetration air (ULPA) filters are used in almost provide a rated reduction in particulate burden as verified
every aseptic process by a particulate challenge.
HEPA filters have an efficiency of at least 99.97% for HEPA and ULPA filters consist of the following
0.3-micrometer particles. ULPA filters have an effi- components:
ciency of at least 99.999% F
 ilter frame. The filter frame holds the filter media
HEPA and ULPA filters consist of a filter frame, fil- in place, provides a rigid frame to promote uniform
ter media, separators, bond material, and gasket air flow, and provides a surface for attachment of a
material gasket or gel seal. Filter frames can be constructed of
HEPA and ULPA filters work by the sieve effect, inertial many materials, including galvanized steel, stainless
impaction, interception, and diffusion steel, plywood, particle board, aluminum, or plastic.
Use of HEPA and ULPA filters in critical zones is man- Pharmaceutical HEPA filters are typically constructed
dated by US and international current good manufac- with an aluminum, stainless steel, or galvanized steel
turing practice (CGMP) regulations (non-critical application) frame; some biosafety hoods
HEPA and ULPA filter testing generally includes veri- or laminar flow hoods may have plywood or particle
fication of airflow velocity and installed filter leakage board frames.
testing F
 ilter media. The filter media is a fibrous material
HEPA and ULPA filter leak tests include the photom- typically constructed of randomly arranged and tightly
eter method (most commonly used method) and the packed glass or ceramic fibers. The filter media is typi-
discrete particle count method (used for specialized cally pleated to provide more filter surface area within

[
For more Author ABOUT THE AUTHOR
information, Ed White is a QA validation specialist at Baxter Healthcare Bioscience, Thousand Oaks, CA.
go to He may be reached at ed_white@baxter.com.
gxpandjvt.com/bios

48 j v t . c o m of Validation T echnology [Summer 2009]


g x p a nJdournal iv thome.com
Ed White, Coordinator.

a given space. Some ULPA filters are constructed of or defined areas or such other control systems for the
expanded PTFE fluoropolymer (ePTFE). These filters firms operations as are necessary to prevent contami-
are typically used for specialized applications or in the nation or mix-ups during the course of the following
semiconductor industry, as they are incompatible with procedures: (10) Aseptic processing, which includes
polyalphaolefin (PAO). as appropriate: (iii) An air supply filtered through
S
 eparators. The separators are used to keep the pleats high-efficiency particulate air filters under positive
apart, maximizing the effective filter area of the HEPA. pressure, regardless of whether flow is laminar or
The separators can be constructed of corrugated alumi- non-laminar
num or be of the minipleat design. In the minipleat 21 CFR 211.46(c) (2) states, Air filtration systems,
design, shown in Figure 1 and Figure 2, pleated filter including pre-filters and particulate matter air filters,
media is separated by strips of filter media or adhesive. shall be used when appropriate on air supplies to pro-
This design allows the media to be more closely packed duction areas
than in a HEPA filter with aluminum separators. The The FDA aseptic processing guidance document (3)
majority of HEPA filters used in pharmaceutical facili- states, HEPA-filtered air should be supplied in critical
ties is of the minipleat design. areas at a velocity sufficient to sweep particles away
B
 ond material. The bond material is used to attach from the filling/closing area and maintain unidirec-
the filter media to the filter frame. The bond material tional airflow during operations. The velocity param-
may be made of several different adhesives, including eters established for each processing line should be
epoxy, silicone, and polyurethane. justified and appropriate to maintain unidirectional
G
 asket or gel seal. This ensures that air flows airflow and air quality under dynamic conditions
through, rather than around, the filter media. Filters within the critical area.
may have gasket seals or gel seals, depending on the EU GMP Annex 1 (4) states, The manufacture of sterile
installation type. Gaskets are either adhesive bonded products should be carried out in clean areas, entry to
to the filter frame or are formed in place. which should be through airlocks for personnel and/or
for equipment and materials. Clean areas should be
 el seal filters have special channels into which sili-
G maintained to an appropriate cleanliness standard and
cone or urethane gel is poured. When installed, the gel supplied with air, which has passed through filters of
channel mates with a knife edge installed in the ceiling an appropriate efficiency.
grid or filter module. A metal tab typically holds the
filter in place, allowing the knife edge to float in the The requirement for HEPA filtration of air entering asep-
gel. It is important that the knife edge stays above the tic process areas is critical to maintaining the cleanliness of
bottom of the gel channel to ensure a positive seal. the aseptic processing environment and in maintaining the
Figure 3 illustrates a typical gel seal. sterility of aseptically processed products. Because there is
no additional bioburden reduction for aseptically processed
HEPA and ULPA filters only differ in their efficiency products, a single contamination event will compromise
ratings. HEPA stands for high efficiency particulate air the sterility of the product. By supplying HEPA-filtered air
filter. A HEPA filter is capable of filtering out >99.97% to the aseptic processing area, the pharmaceutical manufac-
of particulate matter averaging 0.3 micrometers in diam- turer significantly reduces the probability of a contamina-
eter. ULPA stands for ultra-low penetration air filter. An tion event. The aseptic processing guidance (3) document
ULPA filter is capable of filtering >99.999% of particulate summarizes this concept in the following statement:
matter at the most penetrating particle size (MPPS). For To maintain product sterility, it is essential that
most filters, including HEPA filters, the most penetrat- the environment in which aseptic operations (e.g.,
ing particle size is in the range from 0.1 micrometers to equipment setup, filling) are conducted be controlled
0.2 micrometers. and maintained at an appropriate quality. One aspect
of environmental quality is the particle content of
WHY USE HEPA FILTERS? the air. Particles are significant because they can
The use of HEPA filtration in critical areas is mandated enter a product as an extraneous contaminant, and
in the US Food and Drug Administration and interna- can also contaminate it biologically by acting as a
tional regulations for critical processing areas, including vehicle for microorganisms. Appropriately designed
the following: air handling systems minimize particle content of
21 CFR 211.42(c) (1) states, There shall be separate a critical area.
gxpandjv t.com Journal of Validation T echnology [Summer 2009] 49
The Aseptic Core.

Figure 1: Typical minipleat filter construction.


HEPA FILTER CLASSIFICATIONS
HEPA filters are classified by the Institute for Environ-
mental Sciences and Technology (IEST) in their Recom-
mended Practice IEST-RP-CC001 (5) HEPA and ULPA filter
Pleated filter media
classifications range from Type A to Type K, but not all of
these classifications are commonly used in the pharma-
ceutical industry. HEPA/ULPA filter types C, D, and F are
commonly used in the pharmaceutical industry. Type J
and type K filters may be used in ultraclean applications
Strip of filter media or
adhesive used to maintain such as filling isolators or aseptic compounding. EN1822
separation between pleats types H14 and U15 are commonly used in Europe. The
Table lists some common filter types used in the United
States and Europe and their ratings.

Frame
HEPA AND ULPA FILTER TESTING
HEPA and ULPA filters are typically tested as part of
Gasket certification of a cleanroom environment. Tests specific
Epoxy bond
to HEPA and ULPA filters only are discussed. Tests for
the larger cleanroom environment will be discussed in
HOW DO HEPA FILTERS WORK? an upcoming column. Tests specific to the HEPA and
Because of the filter media used, HEPA filters are more ULPA filters include the following:
analogous to depth filters than to membrane filters. Airflow velocity is mandatory for unidirectional
HEPA filters capture airborne particles through several cleanrooms or clean zones, optional for non-uni-
mechanisms including the sieve effect, impaction, inter- directional cleanrooms or clean zones
ception, and diffusion, as follows: Airflow volume is mandatory for unidirectional or
S  ieve effect. This effect occurs for large particles non-unidirectional cleanrooms or clean zones
(>5 micrometers in diameter). These particles are Installed filter system leakage test (ISO 14644-3,
just too large to fit through the open areas in the Clause B.6) for all cleanrooms.
filter media. Removal efficiency for large particles
due to the sieve effect is typically >99.9999%. Airflow Velocity Test
I nertial impaction. Inertial impaction occurs as For the airflow velocity test, the filter is checked for veloc-
particles are carried through the filter media by the ity at several points using an airflow velocity meter or
airstream. As the airstream shifts to flow around airflow hood. The filter is typically divided into a grid
fibers, inertia causes the particles carried by the of equal surface areas, not to exceed 4 ft2 or 0.4 m2. The
airstream to impact the fibers. This mechanism average velocity of each filter should be within the range
typically occurs for particles in the 0.5 micrometer of 0.37 meters/second to 0.54 meters/second (0.45 m/s
to 5 micrometer range. 20%). The relative standard deviation (RSD) across
I nterception. Smaller particles may be intercepted the filter bank (or filter for individual filter installations)
by the fibers when they come within 1 particle diam- should be 15% or less. The RSD is calculated by divid-
eter of a fiber when following the gas stream. This ing the standard deviation of the readings by the average
mechanism can be effective because of the high of the readings, and multiplying the result by 100. The
fiber density of HEPA and ULPA filter media. This airflow velocity for a particular clean room may differ
mechanism is effective in the 0.1 micrometer to 1 and should be based on maintaining a proper airflow
micrometer range. over critical zones. Higher or lower velocities may be
Brownian diffusion. Brownian diffusion occurs appropriate, especially in specialized installations such
with very fine particles that are small enough to be as isolators, depyrogenation tunnels, and depyrogena-
affected by collision with the gas molecules in the tion ovens.
airstream. Brownian motion causes these particles
to move randomly within the airstream, increasing Airflow Volume Test
the probability of the particles contacting a fiber. This test is typically performed using an electronic
micromanometer with an appropriate airflow hood.
50 Journal of Validation T echnology [Summer 2009] iv thome.com
Ed White, Coordinator.

Figure 2: Typical minipleat HEPA filter with gel seal.


It can also be performed by multiplying the average
airflow velocity of the filter by the effective surface
area of the filter. The airflow volume of each filter is
measured using the hood (this may require multiple
measurements for larger filters), and the total volume
of air supplied by all of the filters in a room is divided
by the volume of the room to determine the number
of air changes per hour in the room.

Installed Filter Leakage Test


The installed filter leakage test may be performed using
one of two methods: the photometer method or the
discrete particle count method. In both methods, a
challenge aerosol is introduced upstream of the filter,
and the filter is scanned to detect leakage >0.01% of
the upstream concentration.
Figure 3: Typical gel seal installation.
Installed Filter System Leakage Test Filter media
Ceiling grid
Photometer Method or filter Filter frame
The photometer method is the most accepted method in housing
the pharmaceutical and biotech industries. In this meth-
od, an aerosol challenge, typically Polydisperse PAO, is
introduced upstream of the filter in such a way that the
challenge is uniformly distributed across the filter. An
upstream concentration is taken, and the aerosol generator
is adjusted to achieve a challenge level of approximately 10
g/L to 90 g/L. The aerosol photometer is adjusted to read Knife edge
100% at the upstream concentration, and then it is used to
scan the filter. Any measurement >0.01% of the upstream Wing nut
concentration is considered a designated leak, assuming
a photometer sampling rate of 1 cubic foot/minute (28.3 Adhesive
L/min). The leak may be repaired using silicone sealant Metal tab
if the repair is less than 1.5 inch (3.8 cm) in any direction
and if the repairs cover less than 3% of the filter surface.
If either of these criteria is exceeded, the filter should be Protective screen
replaced. Whether the filter is repaired or replaced, the leak Silicone or
urethane gel
test should be repeated. The aseptic processing guidance
(3) states, A single probe reading equivalent to 0.01 percent
Acorn nut
of the upstream challenge would be considered as indica-
tive of a significant leak and calls for replacement of the
HEPA filter or, when appropriate, repair in a limited area. tion of silicon wafers with PAO. This method is generally
A subsequent confirmatory retest should be performed in limited to specialized applications such as depyrogenation
the area of any repair. tunnels and ovens where burn off of PAO after certification
procedure is a concern. Large installations of gel-seal filters
Installed Filter System Leakage Test are also of concern because PAO can interact with gel seals
Discrete Particle Count Method causing hardening or liquifaction of the gel-seal material.
The particle count method is little used in the pharmaceuti- This method can use polystyrene microspheres instead of
cal and biotech industries because of the somewhat greater PAO, or may use PAO in much lower concentrations than
complexity of the test, and the greater acceptance of the the photometer method.
photometer method by regulatory agencies, especially FDA. In this method, a challenge aerosol consisting of polysty-
This method is widely used in the semiconductor industry rene microspheres or PAO with a count median diameter
because of industry concerns about molecular contamina- (CMD) between 0.1 m and 0.3 m is introduced upstream
gxpandjv t.com Journal of Validation T echnology [Summer 2009] 51
The Aseptic Core.

Table: IEST RP-CC001 and EN1822-1 filter classifications typically used for pharmaceutical
and biotech applications.
Filter Minimum % Particle
Integrity Test Method Application
Type Efficiency Size m

B 99.97% 0.3 MMD Two flow leak test HEPA filters for low classification areas

C 99.99% 0.3 MMD Photometer-Polydisperse PAO General use HEPA filters


General use HEPA filters; critical zone
filters; isolator applications; large
D 99.999% 0.3 MMD Photometer-Polydisperse PAO
installations where hot aerosol
generators are needed
Particle count or photometer-
Critical zone filters; isolator applications;
0.1-0.2 or Aerosol challenge may be
F >99.999% large installations where hot aerosol
0.2-0.3 polydisperse PAO or polystyrene
are needed
microspheres (polystyrene latex beads)

0.1-0.2 or Particle count or photometer-Polydis-


J 99.99% High airflow installations
0.2 to 0.3 perse PAO

Critical zone filters; isolator applications;


0.1-0.2 or Particle count or photometer-
K 99.995% large installations where hot aerosol
0.2 to 0.3 polydisperse PAO
generators are needed

H14
99.995% MPPS Photometer-polydisperse PAO General use HEPA filters
(EN1822)

General use HEPA filters; critical zone


U15 filters; isolator applications; large
99.9995% MPPS Photometer-polydisperse PAO
(EN1822) installments where hot aerosol
generators are needed
*MMD: Mass Median Diameter; MPPS: Most Penetrating Particle Size; PAO: Polyalphaolefin

at a concentration of approximately 106 particles/ft 3. HEPA FILTER MAINTENANCE AND


Challenge concentration is measured using a particle REPLACEMENT
counter with an appropriate measuring range for the Other than periodic recertification, HEPA filters require
particulate challenge. Because the particle counting little maintenance. The types of maintenance required
range is outside the operating range of the particle may include the following:
counter, the sample must be diluted using a special Periodic replacement of pre-filters upstream of the
instrument that uses a capillary tube to provide a HEPA/ULPA filters prevents premature loading of
precise and repeatable dilution factor. The particle the HEPA/ULPA filters by reducing the particle load
count is multiplied by the dilution factor to obtain reaching the filters.
the concentration of the aerosol in particles/ft 3. The Monitoring of the pressure drop across the filters using
downstream side of the filter is scanned with a particle a differential pressure sensor. When the differen-
counter with a specialized probe. Any particle count tial pressure reaches or exceeds the manufacturers
>0.01% of the upstream concentration is considered a recommended pressure drop, the filters should be
designated leak. In practice, any count >3 particles/ft 3 replaced.
encountered during scanning should be verified by Periodic inspection of the ductwork upstream of
a stationary scan. the HEPA filter to ensure that there is no buildup of
IEST Recommended Practice IEST-RP-CC034.2 and particulate matter or debris that could damage the
ISO 14644-3 give more detailed instructions on how HEPA filters.
to perform the discrete particle count method and Periodic inspection, where possible, of gaskets or gel
the photometer method. seals for evidence of deterioration.
52 Journal of Validation T echnology [Summer 2009] iv thome.com
Ed White, Coordinator.

VALIDATION IMPLICATIONS airborne particles. This is the familiar cleanroom particle


It is impossible to validate a critical processing environ- counter. A DPC used for filter leak testing should be able
ment without ensuring that the supply air to the environ- to count particles at 0.3 micrometers or greater.
ment is properly filtered and that the filters have been
installed properly. The validation of HEPA and ULPA HEPA (high efficiency particulate air) filter: A dry, ex-
filters should provide this assurance. The installation tended media filter in a rigid frame, having a minimum
qualification (IQ) should include proper installation of particle collection efficiency of 99.97% for 0.3 m mass
the filters, including inspection of the associated equip- median diameter particles of PAO.
ment (e.g., prefilters, excessive particulate in ductwork,
etc.). Gel seals and gaskets should be inspected. Testing, Laskin nozzle aerosol generator: An aerosol generator
including pressure drop testing, should be conducted. using a specialized nozzle (Laskin nozzle) to generate a
Requirements for the preventative maintenance program heterogeneous (polydisperse) aerosol from liquid PAO,
are specified in the IQ. The operational qualification using compressed air as a source (compressed nitrogen
(OQ) would include filter certification testing, including should be used for a hot aerosol generator). For smaller
airflow velocity, airflow volume, and system leakage. Filter installations, a cold aerosol generator that generates the
performance qualification (PQ) testing will be discussed aerosol directly using a Laskin nozzle may be used. For
as part of qualifying the cleanroom environment in a large installations, a hot generator that superheats the
future column. vapor generated by the Laskin nozzles then re-condenses
HEPA and ULPA filter testing is crucial to any validation the vapor as a cold polydisperse aerosol is used.
program, whether this testing is performed by the valida-
tion department, maintenance department, or an external Mass median diameter (MMD): Mass median diameter is
service. Review of the HEPA certification program should the 50th percentile of the mass distribution of the aero-
be part of the initial qualification or requalification of an sol.
aseptic environment. Qualification and requalification
of an aseptic processing environment will be covered in Monodisperse aerosol: Monodisperse aerosol is one hav-
the next issue of The Aseptic Core. ing a relatively narrow distribution of particle sizes. Poly-
styrene microspheres are an example of a monodisperse
GLOSSARY aerosol.
Aerosol photometer: Aerosol photometer is an instrument
that measures mass concentration of aerosols using the Most penetrating particle size (MPPS): MPPS is the particle
forward light scattering principle. size at which a HEPA or ULPA filter has its lowest efficiency.
The MPPS represents the worst-case filter challenge for
Challenge aerosol: Aerosol generated from a selected efficiency testing.
aerosol source material to be used as an upstream chal-
lenge for HEPA and ULPA filter leak testing. PAO: PAO stands for polyalphaolefin, which is a synthetic
oil commonly used in the pharmaceutical industry. A Poly-
Count median diameter (CMD): CMD is the median di- disperse aerosol of PAO is commonly used as a challenge
ameter of the numeric distribution of the challenge aero- material for leak testing of HEPA and ULPA filters.
sol50% of the particles in the challenge distribution are
larger than the CMD, and 50% of the particles are smaller Polydisperse aerosol: Polydisperse aerosol is one having a
than the CMD. broad distribution of particle sizes. An example of a Poly-
disperse aerosol is a PAO aerosol generated by a hot or
Designated leak: A designated leak is a leak that should cold aerosol generator.
be detectable during scanning of a filter. A leak greater
than or equal to 0.01% of the upstream concentration Polystyrene latex (PSL) beads: PSL beads are a uniform sus-
(when using an aerosol photometer) or upstream particle pension of polystyrene microspheres in water, usually with
count (when using a discrete particle counter) should be a small amount of surfactant to ensure stable dispersion of
detectable. the microspheres. PSL is used as an alternative challenge to
PAO when using the particle count method for leak testing
Discrete particle counter (DPC): Discrete particle counter ULPA filters.
is an instrument capable of counting and sizing individual

gxpandjv t.com Journal of Validation T echnology [Summer 2009] 53


The Aseptic Core.

The term polystyrene latex beads is somewhat mislead- ucts in the European UnionVolume 4EU Guidelines to Good
ing, as this material does not contain any natural rubber Manufacturing PracticeMedicinal Products for Human and
latex. The term latex in this case refers to a stable, uniform Veterinary Use, Annex 1: Manufacture of Sterile Medicinal
suspension of particles in an aqueous medium. Because of Products (corrected version), 2008.
the confusion between polystyrene latex and natural rubber 5. Institute of Environmental Sciences and Technology, Recom-
or plant-based latex, the term polystyrene microspheres is mended Practice, IEST-RP-CC001, 2005. JVT
becoming a common synonym for PSL.

Scanning: Method of testing for leaks in HEPA or ULPA fil- GENERAL REFERENCES
ters. During a filter scan, an aerosol photometer or discrete Institute of Environmental Sciences and Technology, IEST-RP-
particle counter sampling probe is slowly moved across the CC001.4, HEPA and ULPA Filters, 2005.
filter in a series of parallel overlapping strokes. The sampling IEST, IEST-RP-CC006.3, Testing Cleanrooms, 2004.
probe is typically kept about 1 inch away from the filter sur- IEST, IEST-RP-CC007.2, Testing ULPA Filters, 2007.
face. When a potential leak is detected, the probe is held IEST, IEST-RP-CC021.2, Testing HEPA and ULPA Filter Media,
stationary for a short period of time to verify the leak. 2005.
IEST, IEST-RP-CC034.2, HEPA and ULPA Filter Leak Tests,
Standard leak penetration: Standard leak penetration is 2005.
the leak penetration measured by a stationary probe using International Organization for Standardization (ISO). ISO
a particle counter or photometer with a flow rate of 1 cubic 14644-1, Cleanrooms and associated controlled environ-
foot per minute (28.3 liters per minute). ments, Part 1: Classification of Air Cleanliness, 1999.
ISO, ISO 14644-2, Cleanrooms and associated controlled envi-
ULPA (ultra-low penetration air) filter: An ULPA filter is a ronmentsPart 2: Specifications for testing and monitoring
dry extended media filter in a rigid frame, with a minimum to prove continued compliance with ISO 14644-1, 2000.
particle-collection efficiency of 99.999%. Depending on the ISO, ISO 14644-3, Cleanrooms and associated controlled en-
filter, the particle-collection efficiency can be measured at vironmentsPart 3: Test Methods, 2005.
0.3 m or at MPPS. ULPA filters can be used in most applica- European Committee for Standardization. EN 1822-1:1998:
tions where HEPA filters are used. High efficiency air filters (HEPA and ULPA) Part 1: Classifica-
tion, performance testing, marking, 1998.

REFERENCES
1. FDA, Code of Federal Regulations, Title 21Food And Drugs, ARTICLE ACRONYM LISTING
Chapter IFood And Drug Administration, Department CGMP Current Good Manufacturing Practice
Of Health And Human Services, Subchapter CDrugs: CMD Count Median Diameter
General, Part 211Current Good Manufacturing Practice FDA US Food and Drug Administration
For Finished Pharmaceuticals, Subpart CBuildings and HEPA High Efficiency Particulate Air
Facilities, Sec. 211.42 Design and construction features, IEST Institute for Environmental Sciences and
Revised as of April 1, 2008. Technology
2. FDA, Code of Federal Regulations, Title 21Food And Drugs, IQ Installation Qualification
Chapter IFood And Drug Administration, Department ISO International Organization for Standardization
Of Health And Human Services, Subchapter CDrugs: MMD Mass Median Diameter
General, Part 211Current Good Manufacturing Practice MPPS Most Penetrating Particle Size
For Finished Pharmaceuticals, Subpart CBuildings and OQ Operations Qualification
Facilities, Sec. 211.46 Ventilation, air filtration, air heating PAO Polyalphaolefin
and cooling, Revised as of April 1, 2008. PQ Performance Qualification
3. FDA, Guidance for Industry: Sterile Drug Products Produced by RSD Relative Standard Deviation
Aseptic ProcessingCurrent Good Manufacturing Practice, 2004. ULPA Ultra-Low Penetration Air
4. European Commission: Enterprise and Industry Director-
ate-General, EudraLexThe Rules Governing Medicinal Prod-

54 Journal of Validation T echnology [Summer 2009] iv thome.com

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