Cleanliness of the Product
[ISO 13485 Cl 7.5.2]
The organization shall establish documented requirements for cleanliness of the product if (a) the product is cleaned by the organization prior to sterilization and/or its use, (b) the product is supplied non-sterile to be cleaned before sterilization and/or its use, or (c) the product is supplied to be sterilized by another party or by the customer. If product cleanliness is of particular importance to device performance, the organization shall establish documented requirements and maintain the necessary cleanliness throughout product realization.”
The goal of this clause is to ensure that the product’s cleanliness meets defined requirements that are essential to its safety, performance, and intended use. In medical device manufacturing, contamination can compromise sterility, cause infections, or affect the device’s mechanical or functional performance. Therefore, the organization must define, control, and maintain cleanliness levels as part of product realization.
Key Requirements and Expectations
Define Cleanliness Requirements
The manufacturer must clearly specify when and how product cleanliness must be achieved and maintained.
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Define acceptable contamination limits (e.g., particulate, microbial, chemical residues).
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Include these limits in design specifications, work instructions, and inspection criteria.
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Ensure environmental controls (cleanrooms, filtered air, humidity, and temperature) are maintained where applicable.
Example: A surgical implant manufacturer defines maximum allowable particle counts on surfaces and verifies via surface cleanliness testing.
Control Cleaning Processes
If cleaning is part of the manufacturing process, the organization must:
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Validate the cleaning process to demonstrate it achieves required cleanliness levels.
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Maintain procedures describing cleaning agents, equipment, parameters (temperature, time, concentration), and verification methods.
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Keep records of cleaning and inspection.
Example: Reusable components are cleaned using validated ultrasonic cleaning cycles, with residue testing to confirm effectiveness.
Maintain Cleanliness After Cleaning
Once a product is cleaned, measures must be taken to protect it from recontamination:
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Control environmental conditions (clean area or controlled packaging zones).
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Use protective packaging, clean tools, and trained personnel.
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Label and handle the product carefully to maintain cleanliness until sterilization or delivery.
Example: Clean components are double-bagged and stored in a Class 10000 cleanroom before sterilization.
INTERNAL AUDIT TOOL
Frequently Asked Questions
What is the main objective of Clause 7.5.2 – Cleanliness of Product?
When does this clause apply to a medical device manufacturer?
This clause applies when:
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The product is cleaned before sterilization or use.
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The product is supplied non-sterile and must be cleaned before use or sterilization.
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The product is intended to be sterilized by another party or the end user.
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Cleanliness is critical to the product’s function or performance (e.g., implants, optical devices, catheters).
When does this clause apply to a medical device manufacturer?
This clause applies when:
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The product is cleaned before sterilization or use.
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The product is supplied non-sterile and must be cleaned before use or sterilization.
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The product is intended to be sterilized by another party or the end user.
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Cleanliness is critical to the product’s function or performance (e.g., implants, optical devices, catheters).
What are “documented requirements for cleanliness”?
Documented requirements define how clean a product must be for it to be safe and functional. This includes measurable criteria such as particulate limits, bioburden levels, and residue levels, along with specific methods, cleaning agents, and acceptance criteria used to achieve and verify those standards.
How should a cleaning process be controlled and validated?
A cleaning process must be validated to ensure it consistently achieves the defined cleanliness level. Validation involves confirming the cleaning parameters (temperature, concentration, duration, water quality, and equipment type), verifying residue removal, and maintaining records of validation and periodic revalidation.
How does the organization ensure cleanliness during manufacturing and assembly?
Cleanliness is ensured through controlled environments (cleanrooms or controlled areas), approved cleaning materials, operator gowning procedures, and environmental monitoring. Regular cleaning of production areas, tools, and equipment is also required to maintain consistent cleanliness levels.
What are examples of contamination that can affect product cleanliness?
Common contaminants include particulate matter (dust, fibers), microbial contamination (bacteria, fungi), and chemical residues (detergents, oils, adhesives). These contaminants can affect device performance or patient safety if not controlled.
What are auditors likely to check regarding product cleanliness?
Auditors typically review:
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The cleanliness specifications in product or process documentation.
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Validation evidence for cleaning processes.
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Records of cleaning activities and inspection results.
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Environmental controls in clean areas.
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Labeling and IFUs for non-sterile products.
They may also verify that training, segregation, and maintenance practices are effectively implemented.
What are common nonconformities found under Clause 7.5.2?
Typical findings include:
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Lack of validated cleaning procedures.
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Inadequate cleanliness specifications or undefined acceptance limits.
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Poor segregation between cleaned and uncleaned items.
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Missing or incomplete cleaning records.
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Contamination found during final inspection or environmental monitoring.
How does Clause 7.5.2 relate to sterilization (Clause 7.5.5)?
ISO 13485 Clause 7.5.2 focuses on cleanliness before sterilization, ensuring the product surface and components are free of contaminants that could interfere with sterilization effectiveness. Clause 7.5.5 deals with validation and control of the sterilization process itself. Both are critical for ensuring final product safety.