TABLE I

Control Strategy Points to Consider for Cell Therapy Production

Input MaterialsManufacturing FacilitiesManufacturing Process
• Cell harvesting, for example, leukapheresis• Design• Personnel qualification and training
• Raw materials control, including in-process• Equipment• Design
• Product containers and closures• Utilities• Process risk assessment
• Vendor approval (key component suppliers, sterilization of components and single-use systems, and services)• Preventative maintenance—maintaining equipment and premises (planned and unplanned maintenance) to a standard that will not add significant risk of contamination• Process simulation
• For outsourced services, such as sterilization, sufficient evidence should be provided to the contracting organization to ensure that the process is operating correctly• Cleaning and disinfection
• Monitoring systems—including an assessment of the feasibility of the introduction of scientifically sound, modern methods that optimize the detection of environmental contamination
• Prevention—trending, investigations, corrective and preventive actions (CAPA), root cause determination, and the need for more robust investigational tools
• Continuous improvement based on information from the above systems