First Steps For Sustainable Bio/Pharma HVAC
by Norman Goldschmidt
August 1, 2009
The
bad news is that energy efficiency has understandably never been job
one in the pharmaceutical industry. The good news is that
opportunities abound for real progress as a new emphasis on
sustainability grows. The author offers more than a daily dose of
industry-specific insight while outlining why higher efficiency need
not be a bitter pill to swallow.
Historically,
pharmaceutical facilities have been designed with little regard to
energy efficiency. Product quality has, rightly, trumped all other
considerations. Systems have been designed for greatest assurance of
consistent environmental conditions, with constant volume / reheat
and high air change rates the order of the day. Steps to prevent
cross-contamination in multi-product plants have been draconian,
ranging from 100% fresh air/exhaust to multiple series HEPA filters
in supply and exhaust.
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1. Recent regulatory developments and the rise of the risk-based
approach. |
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Concerns
for sustainability and energy efficiency challenge these practices
and cause us to ask the question, “Can we protect the patient
without sacrificing the planet?” Developments in processing
equipment, isolation technology and a risk/science-based approach to
ensuring parameters of “strength, identity, safety, purity, and
quality,” open a new world of possibilities for HVAC in biotech and
pharmaceutical facilities.
In
this article, we will explore principles to apply in the first step
of the HVAC design process to yield greater energy efficiency.
Background
Global
regulators are leading the way by challenging the life sciences
industry to take a different approach to setting parameters for
product processing. Gone are the days of “risk avoidance,” when
designers were encouraged to eliminate every conceivable risk —
regulation now focuses on “risk management and product knowledge.”
Applying
this systems thinking to pharmaceutical manufacturing lowers the cost
of drug manufacturing while improving quality by focusing energy on
product knowledge and minimizing non-value added activities.
This
is great for sustainability. In the past, challenging HVAC practices
in biotech and pharmaceutical facilities at the most fundamental
level ran headlong into the desire to eliminate risk. Corporate
standards for environmental conditions, air change rates, percentage
of fresh air, etc., handcuffed the HVAC engineer by making
conservative rules of thumb mandatory.
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| Figure
2. Sterile manufacturing particle counts, in operation. |
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Now
more than ever, regulators and quality professionals are open to the
idea of managing the risks inherent in environmental control rather
than attempting to eliminate them (and creating new ones in the
process). This requires a cross-functional approach, engaging the
departments of quality, development, and manufacturing with
engineering in collaboration to establish a design that’s both
efficient and effective.
Statement
of Principles for Sustainable Pharmaceutical HVAC
- Don’t
apply standards blindly.
- Utilize
enough air to reliably produce the desired results, don’t focus
solely on air change rates.
- Turn
down airflows when not in use.
- Consider
all air filtration in caluclations to produce desired conditions.
- Recirculate
air whenever safe and practical.
- Broaden
temperature and rh limits as much as allowable by the product and
process.
- Use
micro-environments wherever practical.
The
following recommendations all come with the same caveat; as we’ve
outlined above, it’s incumbent on the user and designer to verify
the actual needs and risks of their process and prove the
effectiveness of the implemented system.
Air Change Rates
Historically,
rules of thumb for pharmaceutical cleanrooms have specified air
change rates starting at 20 ach for ISO 8 and 9 (Grade C and D) rooms
and increasing to 40, 60, and sometimes even 100 for ISO 7 (Grade B)
spaces. Real-world environmental monitoring, however, shows that
rooms operating at these air-change rates often achieve dynamic
contamination levels orders of magnitude cleaner than specified.
In
Figure 2, the cleanrooms achieve particle counts 1.5 to 2 orders of
magnitude better than specified.
Why
is this? One reason is that while air change rates relate inversely
to the recovery of a room and the time it takes to reach steady
state, it’s the particle generation rates and the diluting (or
displacing) airflow that really influence the particle count
achieved. If we neglect the contribution from supply air (which
should be small) the steady state concentration can be approximated
as:
Cf
= Ci+( (PGRp
x N) +PGRm)/Q )
Where:
Cf
= Room particle count (particles/volume)
Ci
= Initial particle count (particles/volume)
PGRp
= Particle generation rate from people (particles/person minute)
PGRm
= Particle generation rate from process (particles/minute)
N
= Number of people in the clean room
Q
= supply air volume/minute
Another
reason is that personnel are a key source of particulates, advances
in gowning, automation, and isolation have decreased how many people
are in the cleanroom and how much they shed, which has had a huge
impact on modern cleanroom performance.
If
we design cleanrooms by evaluating the particle generation rates and
providing enough diluting (or displacing) airflow, rather than using
rules of thumb for air changes, we can create more efficient
cleanrooms and may save 10% to 30% of cleanroom energy consumption.
Airflow and Environmental Setbacks
Office
and laboratories often benefit from an off-hours or unoccupied
setback of environmental conditions. These schemes usually include a
reduction in airflow (sometimes a shutdown of AHUs altogether) and a
relaxation of temperature and rh setpoints for energy savings. Can
these energy-saving schemes be applied to pharmaceutical
manufacturing?
When
tested “at rest” (without people), cleanrooms typically perform
one to two orders of magnitude better than “in operation.” In
fact, Annex 1, the European guidance for “Manufacture of Sterile
Medicinal Products” specifies this level of performance at rest.
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| Figure
3. Typical cleanroom recovery performance. |
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In
addition, Annex 1 requires that sterile manufacturing areas be tested
“in operation,” “at rest,” and that the “recovery” time
be recorded (the time required for the transition) (Figure 3).
We
can leverage the exceeding performance when at rest to establish a
protocol for reduced airflow and relaxed environmental controls
during idle periods. What’s more, recovery testing suggests a
method of test (MOT is found in ISO 14644-3) for proving the
restoration of manufacturing conditions.
We
suggest the following parameters be considered in establishing an
idle “setback” for environmental conditions in pharmaceutical
manufacturing facilities:
- Do
not store product or product contact materials open within the space
during setback periods;
- Maintain
sufficient ventilation to offset heat gains;
- Maintain
design pressure differentials to adjacent spaces for contamination
control;
- Consider
mold and microbial growth conditions when arriving at relaxed rh
setpoints (exceeding 80% rh is not recommended );
- Consider
thermal inertia in equipment and construction when arriving at
relaxed temperature setpoints;
- Verify
the time required to restore environmental conditions after an idle
period via EM testing.
It
is clear that many pharmaceutical cleanrooms can maintain conditions
when at rest with a fraction of the airflow needed during operation.
Establishing a setback scenario for idle periods may allow for
significant savings without impacting product quality.
Filtration
The
prevention of cross-contamination of facilities engaged in concurrent
manufacturing of multiple products has driven the prevalence of
double HEPA filtration in this application and in some single product
plants (this includes multi-product campaign facilities). Double HEPA
filters are a very positive method of controlling the HVAC system as
a path of cross-contamination. But is there a lower energy
alternative?
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Figure
4. A composite efficiency profile of MERV-rated filters related by
particle size, based on initial conditions. (Graph courtesy of NAFA,
Summer 2002 issue of Air
Media.
Author(s): W. J. Kowalski, P.E., Ph.D. and W. P. Bahnfleth, P.E.,
Ph.D., The Pennsylvania State University.)
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When
considering cross-contamination, it is the mass of “Drug A” that
could contaminate “Drug B” that is of critical importance, not
the particle count. This mass-based approach is similar to that used
in personnel safety calculations, where environmental contamination
produced by the process (usually expressed in mcg/m 3)
is mitigated by a series of controls and compared to an acceptable
operator exposure. Similarly, cleaning validations typically
performed set an acceptable residual mass of a product which might be
carried into another product. Leveraging these techniques, we can
evaluate the ability of our HVAC system to stop airborne mass
cross-contamination.
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| Table
1. Particulate generation by gowning and activity stated in
particles/min. |
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HVAC
systems are usually equipped with an array of filters designed
primarily to clean outdoor air. In typical outdoor air it’s
estimated that are more than 90% of particles and are less than 1.0
micron in size, low-efficiency filters do a good job at removing
large particles, but miss the larger number of these small particles
(Figure 4).
However,
since the mass of a particle increases as roughly the cube of its
size, particles less than 1 micron represent less than 30% of the
total mass and particles under 0.5 microns represent less than 1%!
Due to this cubic relationship our low-efficiency filters can be very
effective at removing mass (Table 2).
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| Table
2. These comparisons of filter rating systems are only approximate as
the test methods are different.
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The
final factor to include in our calculations is the additive nature of
filter efficiency. Each filter presents a lower concentration of
particulate to the succeeding filter in an array, making the total
cascade the product of the efficiency of the component filters. With
these factors in mind and using the ASHRAE 52.1 arrestance as the
gravimetric mass efficiency, we can approximate the
cross-contamination protection provided by a typical filter
arrangement of MERV 7, 11, and 16 as providing greater than a
four-log reduction in mass. What’s more, a high-capacity MERV 13
and HEPA yields a six-log reduction with lower pressure drop.
While
the ever-increasing potency of compounds imposes an escalating burden
of care in the prevention of cross-contamination, accounting for the
protection afforded by all filters in a system allows for lower
pressure drops than dual HEPAs and further energy savings.
Recirculation
Conditioned
fresh air can consume two to five times the energy of recirculated
air. The effectiveness of filtration in removing the mass of
contaminants reveals another opportunity for energy savings. By
employing appropriate filtration, we can trade fan horsepower for the
much larger chiller, cooling tower, pump, and boiler horsepower. The
application of systems like those outlined above or double HEPA
filtration produces an 8-log reduction in mass. With this high
reduction in mass, a failure of any single element, the system will
retain a 2- to 4-log protection, which may be sufficient for lower
potency products.
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| Figure
5. Central station outside air AHU with local recirculation. |
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Of
course, when using highly potent compounds, the risk of
cross-contamination is increased. This risk can be abated by an air
handling configuration that employs a central station air handler for
fresh air with multiple recirculation units, dedicated to a
particular room or suite for by-products (Figure 5).
Using
this scheme, we can achieve the product separation that potent
multi-product plants require, with 50% to 80% less energy usage than
systems using 100% outside air (OA).
Broad Temperature and RH limits
In
the setting of temperature and rh setpoints, we have also seen the
prevalence of application of rules of thumb which may not be linked
with the product or process requirements. The conservatism is well
appreciated, and failure to recognize a product/process rh
requirement could result in significant product quality and
processing problems. To avoid these repercussions, some companies
default to operating “Oral Solid Dose” manufacturing suites at
30% to 40% rh and even as low as 15% to 20% rh.
Where
processes are closed or product/process restrictions are beyond the
ambient temperature range, controlling the growth of microorganisms
may become the primary acceptance criterion, with human comfort (and
associated shedding) the secondary requirement. The acceptable range
of temperatures and relative humidities varies broadly by region,
gowning, and activity (see Chapter 9 in the 2005 ASHRAE Handbook –
Fundamentals). Acceptable ranges for pharmaceutical operators are
often as broad as 64°F to 78° and 30% to 60% rh. Some have
successfully operated with setpoints as high as 70% rh, but operation
above 80% rh is not recommended.
Again,
the energy savings potential can be great. A facility running at 30%
rh or lower likely employs an desiccant dehumidifier, which would not
be required if humidity were closer to the 50% range. The savings
from relaxing humidity requirements of 30% to 40% rh up to 50% to 60%
may reduce energy usage by 10% to 25%.
Microenvironments
One
of the most significant sustainability developments in pharmaceutical
processing in recent years has been the rise of the closed processing
in contained microenvironments. Technologies such as sterile barrier
and containment isolation, blow-fill-seal, contained process
equipment, and “dustless” transfers via split butterfly valves,
continuous liners, inflatable seals, and numerous others have
redefined pharmaceutical HVAC.
While
intended for operator protection, improved sterility assurance, or
yield enhancement these technologies have effectively moved the
critical environment closer to the process. They have made the
occupied environment a secondary zone, reducing the need for
contamination control via dilution from HVAC.
As
one prominent architect put it when referring to a new sterile
processing suite containing a complete barrier isolation line: “We’re
just building the garage to park the process team’s Ferrari in …”
As
these technologies continue to reduce the need for highly controlled
room environments, the opportunities for greater energy savings will
continue to expand.
Conclusion
As
the drive for sustainability and energy efficiency across the world
continues, clever engineers will find ways to improve systems and
reduce the energy consumption of HVAC for pharmaceutical
manufacturing. But engineered systems can’t generate savings as
large as can be achieved by collaboration with a cross-functional
team to set well-reasoned and scientifically sound goals. ES
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