Published on 07/12/2025
How to Qualify Trolley, Bin & Storage Equipment Cleaning in Pharma
Introduction
Cleaning qualification of non-product contact equipment like trolleys, bins, and storage containers is increasingly recognized as a critical component of GMP compliance in pharmaceutical manufacturing. Although not always in direct contact with active pharmaceutical ingredients (APIs), these equipment types can indirectly contribute to contamination, cross-contamination, or data integrity issues if not properly cleaned and qualified.
This article outlines the practical steps and regulatory considerations involved in qualifying the cleaning process for trolleys, bins, and storage equipment. The focus is on protocol design, swab and rinse sampling, acceptance criteria, and documentation practices. The guidance is aligned with expectations from regulatory agencies such as the FDA, EMA, WHO, and PIC/S.
Regulatory Expectations
Although not explicitly listed as critical equipment, regulators expect companies to validate cleaning of all items that could impact product quality. This includes transport and storage equipment. Key references include:
- FDA 21 CFR Part 211.67: Equipment cleaning and maintenance shall be performed and documented to prevent contamination.
- EMA Annex 15: All cleaning procedures shall be validated. The scope includes equipment used for storage and internal transport.
- WHO TRS 1019 (Annex 3): Cleaning programs must
Failing to qualify storage or transfer equipment could result in cross-contamination observations, especially when handling different product batches in shared facilities. For related cleaning SOP templates, visit PharmaSOP.in.
Scope of Cleaning Qualification
The cleaning qualification for trolleys, bins, and storage vessels applies to various types:
- Stainless steel or plastic mobile trolleys
- Granule or powder holding bins (IBC containers)
- Drum trolleys used for raw material movement
- Material dispensing and sampling carts
- Storage racks and staging containers in cleanrooms
The level of qualification required depends on risk. For example, containers exposed to open product must follow stricter limits than closed bins used only for packaging materials.
Cleaning Methodology Overview
The cleaning process may be manual, semi-automatic, or automated (e.g., bin washers). In all cases, the process must be documented with clear steps such as:
- Pre-cleaning inspection and removal of gross residue
- Detergent application (validated type and concentration)
- Rinse with purified water or WFI
- Visual inspection for cleanliness
- Drying with filtered air (if applicable)
Cleaning should be reproducible and traceable. If cleaned manually, the qualification must include operator variability, cleaning aids, and detergent residue removal studies.
Cleaning Validation Protocol Elements
A robust cleaning qualification protocol must include the following:
- Objective: To demonstrate effective and consistent cleaning of bins, trolleys, and storage containers.
- Equipment description: List equipment ID, location, material of construction, and usage pattern.
- Cleaning procedure reference: Attach the relevant SOP number.
- Worst-case selection: Choose the dirtiest equipment (e.g., bin exposed to APIs) for validation.
- Sampling plan: Define the number and location of swab and rinse samples.
- Acceptance limits: Based on MACO, PDE, and TOC thresholds.
- Analytical methods: TOC, HPLC, UV, or microbiological swabbing.
- Documentation: Protocol, data sheets, deviation records, and summary report.
Sampling Techniques and Strategy
Surface cleanliness is verified using swab sampling and rinse sampling:
- Swab Sampling: Performed on hard-to-clean areas such as corners, lids, or joints. Swab 25 cm² per location using pre-validated TOC swabs.
- Rinse Sampling: Used when internal surfaces are inaccessible. Collect rinse samples post-cleaning and analyze for residual actives or TOC.
- Microbiological Sampling: Especially for equipment used in aseptic or cleanroom areas. Sample pre- and post-cleaning using contact plates or swabs.
Sample locations must be justified as worst-case sites. Swab recovery efficiency must be validated and documented. For reference recovery studies, visit StabilityStudies.in.
Calculation of Acceptance Criteria
Acceptance limits are calculated using product-specific and cleaning-specific parameters. The two most common approaches are:
1. MACO (Maximum Allowable Carryover)
MACO ensures that traces of the previous product do not cause adverse effects in the next product. Formula:
MACO (mg) = (Minimum batch size of next product × PDE of previous product) / Maximum daily dose of next product
Example:
- Minimum batch size of next product = 100,000 tablets
- PDE of previous product = 10 mg/day
- Max daily dose of next product = 4 tablets/day
- MACO = (100,000 × 10) / 4 = 250,000 mg = 250 g
2. TOC or Analytical Residue Limit
For general cleaning verification, a TOC limit of ≤10 ppm (parts per million) or residue ≤1 µg/cm² is typical.
| Equipment Type | Max Residue (µg/cm²) | TOC Limit (ppm) |
|---|---|---|
| SS Bin (closed) | 1.0 | 10 |
| Plastic Trolley (open) | 0.5 | 5 |
| Drum Cart (non-contact) | 2.0 | 15 |
Example Study Results Summary
| Sample ID | Location | TOC Result (ppm) | Acceptance |
|---|---|---|---|
| TROL-001 | Trolley corner weld | 3.2 | Pass |
| BIN-002 | Bin inner lid | 8.9 | Pass |
| STOR-005 | Storage drum base | 12.3 | Fail |
Handling Failures and CAPA
If cleaning fails to meet the acceptance limits, a structured root cause and corrective action must follow:
- Re-clean and re-test the failed equipment
- Investigate cleaning SOP compliance, detergent concentration, operator technique
- Revise training or sampling methodology if variability is high
- Document failure in deviation management system
- Assess impact on batches produced with unqualified cleaning
For deviation templates and CAPA forms, explore pharmaregulatory.in.
Documentation Requirements
The entire cleaning qualification should be supported by clear, traceable documents:
- Validation protocol and test plan
- Executed sampling forms
- Swab and rinse test data (TOC, HPLC, micro)
- Equipment ID log and calibration records
- Analytical method validation summary
- Final report with QA approval
Lifecycle Requalification Strategy
Cleaning qualification is not a one-time activity. The following triggers require requalification:
- Change in cleaning agent, detergent supplier, or method
- Equipment modification or replacement
- Multiple cleaning failures or CAPAs
- Extension of equipment usage to a different product class (e.g., cytotoxics)
Checklist for Cleaning Qualification of Bins and Trolleys
- [ ] Has each equipment type been identified with a unique ID?
- [ ] Is there a risk-based rationale for equipment inclusion?
- [ ] Are all cleaning agents validated for efficacy and removal?
- [ ] Has the worst-case equipment been selected for the study?
- [ ] Have swab and rinse sampling plans been justified and documented?
- [ ] Are recovery studies available for each method?
- [ ] Is the final report reviewed and approved by QA and validation?
Conclusion
Cleaning qualification of trolleys, bins, and storage containers is a key GMP requirement that ensures materials handling does not become a contamination risk. Regulatory scrutiny is increasing in this area, especially in shared facilities and multi-product plants. A structured approach to protocol design, analytical testing, documentation, and lifecycle updates is essential for audit readiness and compliance.
To explore cleaning protocols and validation forms, check PharmaGMP.in and PharmaSOP.in.