Yes, unfortunately the extent of the FDA in helping assign limits is still 21 CFR 820 where a Quality Procedure should define the product/process. This is less than useful.
I have been involved in some studies looking at sterile closure cleanliness and in particular following the USP <381> test. This requires a cleanliness function that uses turbidity as the means to measure, however once on gets as far as turbidity you are not dealing with individual particles but a cloud of particles. Testing must therefore remain the same as we discussed last year, i.e. test sufficient of your own products to verify that an acceptable baseline exists (USP<1086> allows for certain impurities to exists providing they do not have an undesirable biological reaction) and then use this 95% confidence level as your limit for release.
Malvern Instruments (a sister company to Particle Measuring Systems, part of the Specris PLC Group) has a product called Spraytec that has particle size analysis for inhalants. If the testing above proves that residual particles of a certain size are present then this product would determine its function on overall particle distribution of finished, filled, delivered product.
That is the limit of business to date, unfortunately the emphasis is still on you the manufacturer to prove it is safe rather than have legislation drive the process.
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