Define dirty and clean hold times
Account for both pre-cleaning and post-cleaning storage intervals.
CV-REQ-000003
EU GMP Annex 15: Qualification and Validation§ 10.8
TOPIC EXPLORER
Hold Times
The intervals before cleaning and between cleaning and equipment reuse.
2 connected references
Control time before cleaning
Residue drying can affect the effectiveness of a cleaning procedure.
CV-REQ-000012
Validation of Cleaning Processes§ Evaluation of cleaning validation
Practical guidance
PIC/S Publishes PI 006-4: A New Qualification and Validation Recommendation Takes Effect in October
PIC/S has published PI 006-4, the revised Recommendations on Qualification and Validation, superseding the 2007 PI 006-3 and entering into force on 1 October 2026. Cleaning validation now occupies a full chapter, with HBEL-driven scope, explicit limits on visual inspection and a clear position against continued test-until-clean practice.
What FDA Has Been Citing in Cleaning Validation: The Recurring Themes of 2025–2026
Twelve FDA warning letters issued between 3 December 2024 and 24 July 2026 cite cleaning and cross-contamination control. Read together rather than case by case, they stop looking like twelve incidents and start looking like one audit checklist: worst-case selection, hold times, recovery, MACO justification, visual-only strategies, sampling locations, change control and lifecycle management — in that order of frequency.
Annex 15 Corrigendum: Small Text, Big Consequences for Cleaning Teams
EMA and PIC/S reissued the January 2026 Annex 15 concept paper in July 2026 with a new reference number and a substantially longer timetable. Nothing about cleaning validation itself changed — but the dates most teams are planning against did.
EU and PIC/S Start the Next Revision of Annex 15 — What Validation Teams Should Watch
A joint EMA–PIC/S concept paper proposes extending Annex 15 to active substance manufacturers and aligning it with ICH Q9(R1). The current Annex 15 stays in force, and the earliest a revised text could be published is 2028.
When the Cleaning Validation No Longer Matches the Factory
FDA's December 2025 letter to Medinatura New Mexico records a firm acknowledging that its cleaning validation was not reflective of current operations after years of buying new equipment and adding new products. What the gap looks like from the inside — and what it asks of change control.
A Cleaning Validation Can Age: What Happens When Products Change but the Study Does Not
The FDA's August 2025 warning letter to ABBE Laboratories describes a 2009 cleaning validation still standing while a harder-to-clean product was introduced onto the same shared kettle — and no change-control step that caught it.
When MACO Is Not Enough: What the Granules India Warning Letter Really Teaches
The FDA rejected a retrospective MACO argument in a February 2025 warning letter — not because the arithmetic was wrong, but because the cleaning it assumed had not been performed. What cleaning-validation teams can take from it.
When Shared Equipment Has Never Been Cleaning-Validated: Lessons From an FDA Warning Letter
An FDA Warning Letter to Indian API manufacturer Micro Orgo Chem describes non-dedicated equipment that had never been cleaned under a validated procedure, cleaning SOPs that were not followed, and no evidence that the rinse and swab samples required by the firm's own procedure were ever collected or tested.