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Sterile Drug Insp CPGM 7356-002A_ORA_LAO-NM 9-10-15_EMc LAO FINAL

Sterile Drug Insp CPGM 7356-002A_ORA_LAO-NM 9-10-15_EMc LAO FINAL
Sterile Drug Insp CPGM 7356-002A_ORA_LAO-NM 9-10-15_EMc LAO FINAL

FOOD AND DRUG ADMINISTRATION

PROGRAM 7356.002A COMPLIANCE PROGRAM GUIDANCE MANUAL

CHAPTER 56 – DRUG QUALITY ASSURANCE

FIELD REPORTING REQUIREMENTS:

Establishment Inspection Reports (EIRs) are to be created and filed electronically using the specific module in TurboEIR or replacement system that is accessible to both ORA and CDER.

For inspections of routine commercial manufacturing classified as Official Action Indicated (OAI) due to failure to comply with 21 CFR Part 210 and 211 Current Good Manufacturing Practice (CGMP) as they apply to sterile drug process inspections, submit advisory, administrative, or judicial action recommendations via MARCS-CMS in accordance with the Regulatory Procedures Manual (RPM). Districts should immediately report significant issues according to current FACTS, Panorama and CMS procedures. This includes promptly filing and changing OAI notifications.

During an inspection, if you obtain information pertaining to inadequate adverse drug experience (ADE) reporting, unapproved drug issues, or post-approval reporting violations (application supplements, Field Alert Reports (FARs), etc.), report in accordance with directions provided in the applicable compliance programs and under separate captions in the EIR. Data system information about these inspectional activities should be reported under separate Program Assignment Codes (PACs). Expansion of coverage under these programs into a CGMP inspection should be reported under this compliance program.

The Districts are requested to use this compliance program for all sterile drug process inspections. NOTE: Districts should assure that each operation performed by direction of this program circular is entered against the correct Product Code and Program/Assignment Code (P/AC).

TABLE OF CONTENTS

PART I BACKGROUND (4)

PART II IMPLEMENTATION (5)

2.1 Objective (5)

2.2 Program Management Instructions (5)

A. Strategy (5)

B. Inspection Planning (6)

C. Profile Reporting (6)

PART III INSPECTIONAL (7)

3.1 Types of Sterilization (7)

A. Terminal sterilization (7)

B. Aseptic processing (7)

3.2 Reporting (8)

3.3 Inspection Approaches (9)

3.4 System Inspection Coverage (11)

3.5 Quality System (11)

3.6 Facilities and Equipment System (13)

A. Facilities (13)

B. Equipment (14)

3.7 Materials System (19)

3.8 Production System (21)

3.9 Packaging and Labeling System (27)

3.10 Laboratory Control System (27)

3.11 Sampling (29)

PART IV ANALYTICAL (30)

PART V REGULATORY/ADMINISTRATIVE STRATEGY (31)

PART VI REFERENCES, ATTACHMENTS AND PROGRAM CONTACTS (33)

6.1 References (33)

6.2 Attachments (34)

6.2 Contacts (34)

PART VII CENTER RESPONSIBILITIES (36)

ATTACHMENT A .................................................................................................................A

[end Cover Page]

PART I - BACKGROUND

This program covers the manufacture and testing of all sterile drug products, including drugs that are sterilized by filtration or other means and aseptically processed, and drug products that are terminally sterilized. The type of products covered by this program include sterile bulk drugs, ophthalmic drugs, otic dosage forms, small volume parenteral (SVS) products for small molecule and licensed biological therapeutic drug products, large volume parenteral (LVP) products, and any other drug products required to be sterile or labeled as sterile. Center for Biologics Evaluation and Research (CBER) regulated products and veterinary drug products are excluded from coverage under this program.

The guidance information in this program is tailored to sterile manufacturing operations and should be used in conjunction with the Compliance Program for Drug Manufacturing Inspections (CP 7356.002).

In 2004, Food and Drug Administration (FDA) published the Guidance for Industry Sterile Drug Products Produced by Aseptic Processing-- Current Good Manufacturing Practice, which is referred to throughout this Compliance Program as FDA’s “2004 Aseptic Processing Guidance.” The document represents FDA’s current thinking on Current Good Manufacturing Practices (CGMPs) for aseptically processed drugs.

The Guidance for Industry does not establish mandatory requirements and should not be referred to as the justification for an inspectional observation. Justification for inspectional observations originates from the CGMP regulations, 21 CFR Parts 210 and 211.

Manufacturers who follow the 2004 Aseptic Processing Guidance are generally considered compliant with CGMP regulations. However, alternate approaches may be used if such approaches satisfy the requirements of 21 CFR Parts 210 and 211.

For technical questions and unusual circumstances encountered during an inspection, investigators are encouraged to contact their District, ORA Office of Medical Products and Tobacco Operations/Division of Medical Products and Tobacco Program Operations and/or CDER for consultation. For questions concerning microbiological analysis, sterility and related sampling concerns, contact ORA Office of Regulatory Science/Medical Products and Tobacco Scientific Staff.

[end Part I]

PART II - IMPLEMENTATION

2.1 OBJECTIVES

The primary objective of this program is to provide guidance for conducting inspections of manufacturers of sterile bulk1 and sterile finished dosage drug products to determine compliance with the Food, Drug, and Cosmetic Act and the Current Good Manufacturing Practice Regulations (CGMPs), Title 21, CFR Parts 210 and 211.

Other objectives include:

?Obtain information on operations impacting on sterility, to identify areas for improvement and correction.

?Evaluate current good manufacturing practices in the sterile drug industry.

?Initiate appropriate action against manufacturers observed to be out of compliance.

2.2 PROGRAM MANAGEMENT INSTRUCTIONS

A. STRATEGY

(1) Inspection of Systems

Inspections of drug manufacturers should be made and reported using the system definitions and organization in this compliance program. Focusing on systems will increase inspection efficiency because the systems are often applicable to multiple profile classes. The selection of the system(s) for coverage will be made by the District Office based on the firm’s specific operation, previous coverage, compliance history, or other priorities determined by the District Office.

The inspection should normally result in a determination of acceptability or non-acceptability for all profile classes. Coverage of a system should be sufficiently detailed, i.e., select an example of each profile class, so that the conclusion about the system’s state-of-control applies to all the profiles classes. However, the determination that a system is adequately controlled for one profile class can be extended to another profile class(es) even if that other profile class(es) was not specifically reviewed. The lead Investigator must consider the uniqueness of the various manufacturing situations at the plant and use their best judgment when selecting profile classes to review.

Selecting specific areas unique functions within a system will be at the discretion of the lead Investigator.

The options for system coverage are described in CPGM 56002. Any given inspection need not cover every system. See P art III - Inspectional.

Complete inspection of one system may necessitate further follow up of some items within the activities of another system(s) to fully document the findings. Such follow up does not constitute full coverage of the other system (and cannot be reported as such in FACTS); nor does that follow up obligate the investigator to perform full coverage of the other system.

1

(2) Inspectional Scope

Inspections of sterile product drug manufacturers are performed as either Full Inspections or Abbreviated Inspections using the systems strategy outlined in Part II –Implementation, of Compliance Program 7356.002, Drug Manufacturing Inspections.

See Part III – Inspectional, of this program for a complete discussion of the coverage requested under these inspection options.

B. INSPECTION PLANNING

Implement this program when sterile drug manufacturers are inspected as part of a regular statutory inspection. CDER will identify firms for inspection based on the risk-based prioritization model on annual performance goals, as part of the initiative to ensure risk-based prioritization of inspection coverage.

Consider using a team approach for conducting inspections when appropriate. Utilize investigators familiar with sterile drug manufacturing and aseptic processing and consider the participation of a microbiologist with expertise in microbial controls. Specifically,

?All team members should be very familiar with FDA’s Guidance for Industry Sterile Drug Products Produced by Aseptic Processing – Current Good Manufacturing Practice (September

2004).

?Investigators or team members should be well qualified in sterile product manufacturing, and have completed formal training courses in parenteral drug manufacture, aseptic technique,

sterilization methods, and related procedures and equipment. Microbiologists involved should

have experience in sterility, endotoxin testing, and evaluation of microbial controls in

manufacturing.

C. PROFILE REPORTING

Update all applicable profile classes in the profile screen of the FACTS coversheet based on inspection findings. The following is a list of sterile product profile classes effective at the time this program was implemented. Use the codes corresponding to the product and process type covered.

FULL DESCRIPTION

PROFILE

CLASS

LVP Large Volume Parenterals are sterile injectable drugs packaged in containers labeled as containing more than 100 mL. Most are terminally sterilized, but some can be sterilized by

filtration and aseptically processed.

SVT Small Volume Parenterals are sterile injectable drugs packaged in containers labeled as containing less than 100 mL that are terminally sterilized.

SVS Small Volume Parenterals are sterilized by filtration and aseptically processed.

SVL Small Volume Parenteral are sterilized by filtration, aseptically filled and lyophilized.

SLQ Sterile liquid (other than suspensions and emulsions)

SON Sterile ointment

SPW Sterile powder

CSS Sterile bulk drugs that are made by chemical synthesis.

CFS Sterile crude drugs made by fermentation.

CRX API sterile or API intermediate/NEC inorganic/mineral

[end Part II]

PART III - INSPECTIONAL

3.1 TYPES OF STERILIZATION

There are two broad methods to produce a sterile drug product:

?Terminal Sterilization

?Aseptic Processing of sterilized unit components

There are basic differences between the production of sterile drug products using aseptic processing and production using terminal sterilization. Terminal sterilization should be utilized when the product and container/closure system are able to withstand the terminal sterilization process.

A. TERMINAL STERILZATION - The terminal sterilization process usually involves filling and sealing product containers under high quality environmental conditions designed to minimize microbial and particulate contamination of the product. This minimization of upstream bioburden reduces the challenge to the subsequent sterilization process. In most cases, the product, container, and closure have low bioburden, but are not sterile at the time of filling. The product is then subjected to a sterilization process in its final container.

There are various methods of terminal sterilization including:

?Moist Heat Sterilization

?Irradiation

?Ethylene Oxide (typically for assembled components/kits)

Types of sterilization cycles include:

1. Overkill method:

o Generally used for heat stable materials.

o Designed to provide a significant level of sterility assurance regardless of the number and resistance of the actual bioburden organisms in the load.

o Results in greater heat/exposure input to the product or items being sterilized.

2. Bioburden Based cycle:

o Requires studies to determine the number and resistance of the microorganisms found in the product and the bioburden load of the incoming components and containers/closures.

o Cycle development to destroy the microbial load, but not degrade the product.

o Routine bioburden monitoring of batches and ongoing knowledge of the heat/exposure resistance of organisms found in product bioburden, container/closure bioburden and

environmental monitoring samples.

Reference to terminal sterilization: PDA Technical Report No. 1 (Revised 2007) Validation of Moist Heat Sterilization Processes: Cycle Design, Development, Qualification and Ongoing Control.

B. ASEPTIC PROCESSING - Aseptic processing presents a higher risk of microbial contamination of the product than terminal sterilization. In an aseptic filling process, the drug product, containers and

closures are sterilized separately and then brought together under an extremely high quality environmental condition designed to reduce the possibility of a non-sterile unit. Aseptic processing involves more variables than terminal sterilization. Any manual or mechanical manipulation of the sterilized drug, containers, or closures prior to or during aseptic filling and assembly poses the risk of microbial contamination.

Some types of aseptic processing involve manual manipulations of sterile components, containers, and closures in addition to routine operator interventions in the critical area. Humans are a significant source of contamination in traditional aseptic processing, especially in production lines that require operators to routinely enter critical areas (Class 100, ISO 5, or Grade A) of the filling line. Aseptic processing systems based on more advanced control-based technologies, such as Restricted Access Barrier Systems (RABS) and Blow-Fill-Seal systems, are designed to reduce human interventions in the critical areas of the fill line while an isolator system completely separates the aseptic filling line from the external environment and minimizes employee interaction with the critical area.

Note: More information about Isolator Technology and Blow-Fill-Seal systems is found

in FDA’s 2004 Aseptic Processing Guidance.

When conducting inspections of sterile drug manufacturers, it is important to cover systems and areas within systems that present the greatest risk of product contamination and/or require strict control of processing parameters. For example, if a firm has several aseptic processing lines, cover the line(s) that require the most manual manipulations in the Class 100 (ISO 5) areas. If the firm terminally sterilizes a number of products, review one that is sensitive to heat and requires a product specific (bioburden based) sterilization cycle.

Note: For terminal sterilized products that are aseptically filled prior to terminal sterilization, less rigorous aseptic controls can be considered.

Because of the time limitations often associated with foreign inspections, careful inspection planning is particularly important. Prioritize areas for coverage based upon their potential impact on product quality.

3.2 REPORTING

Follow instructions in the current editions of the IOM (Investigations Operations Manual) and Guide to International Inspection and Travel in preparing the inspection report.

Use Turbo EIR for all reports, both domestic and international, even if a FDA-483 was not issued or was issued outside of Turbo EIR. The “Manufacturing / Design Operations” section of the report should be organized by the systems described in this program that were covered during the inspection. Briefly summarize your review of each covered system in accordance with the key elements outlined in this Compliance Program. Add more details and supporting evidence for the systems found to be deficient.

3.3 INSPECTION APPROACHES

If the sterile drug products to be inspected are radioactive drugs, then Compliance Program 7356.002C, Radioactive Drugs, should be followed as supplementary guidance. This program should not be used for the inspection of Positron Emission Tomography (PET) Drug. Compliance Program 7356.002P is specific for PET drugs.

This program (CP 7356.002A) should also be used in conjunction with Compliance Program

7356.002M, Inspection of Licensed Biological Therapeutic Drug Products for the inspection of sterile licensed biological products.

The CGMP Compliance Program 7356.002 provides general information on the system based approach to conducting inspections of drug manufacturers. It describes the six systems (Quality, Facilities and Equipment, Materials, Production, Packaging and Labeling, and Laboratory) and the two inspection options (Full Inspection and Abbreviated Inspection). It also provides guidance on when each option should be selected and discusses what “state of control” means in relation to the systems inspected. Inspections of sterile drug manufacturers are performed as either Full or Abbreviated inspections using the systems strategy outlined below.

Full Inspections include surveillance or compliance inspections and provide a comprehensive evaluation of the firm’s compliance with CGMP. A Full Inspection will normally include an inspection of at least four systems, one of which must be the Quality System. Under this program, a Full Inspection should include the Facilities & Equipment, and Production Systems due to the critical role these systems play in the sterility assurance of finished product.

Full Inspections (PAC 56002A) are conducted

?when initial inspection of the drug firm is to be conducted;

?when it is the first inspection conducted as a follow-up to a Warning Letter, regulatory action, or significant FDA 483 findings;

?when information obtained during the Abbreviated Inspection reveals significant deficiencies with the firm’s practices and procedures in one or more system areas;

?when there have been significant changes in the firm’s operations since the last inspection; or ?for surveillance purposes at the District’s discretion because the firm has a history of recurring violations, fluctuating in and out of compliance, or when other information (samples,

complaints, Field Alerts, recalls, etc.) calls into question the firm’s ability to produce quality

products.

Abbreviated Inspections (PAC 56002I) may be appropriate if the following two conditions are satisfied:

1. the firm has implemented a formal risk management program that assures effective design and

control (including maintenance). This includes a risk mitigating design of their processing lines that incorporates a modern separation and automation approach (e.g., isolators, closed RABS), and upstream bioburden controls. The responsiveness of the firm’s quality system to potential

hazards is also part of the evaluation, including whether the firm’s program provides robust

daily assurance and effective consumer protection through a formal lifecycle quality risk

management program that proactively uncovers and corrects issues in accord with ICH Q9.

2. the firm has a record of sustained acceptable compliance history and a strong risk management

program.

o the firm produces finished drug products that are terminally sterilized using robust sterilization methods. (Note: Terminal sterilization provides a much more robust process to

ensure sterility); or,

o the firm has implemented robust risk management that provides daily assurance through their overall design and control program;

o at the start of the inspection, conduct an extensive review of sterility assurance data since the last Full Inspection. The review of media fills, sterility testing data, recalls,

defect/adverse event complaints, and reports reveals no findings of sterility failure of a

distributed batch, and

o the firm has a record of satisfactory CGMP compliance (e.g., two consecutive NAI or no more than one VAI inspection), with no Class 1 recalls.

Microbial controls and sterility assurance should be the main focus of an abbreviated sterile drug inspection. The following critical elements of each system (other than the Quality System) should be covered in an Abbreviated Inspection under this program:

?Facilities and Equipment:

o cleaning and disinfection

o facility/equipment layout and air handling system for preventing viable and non-viable contamination

o material flow

o quality control of classified areas, including air pressure balance and HEPA filtration

o trending data supporting the adequacy of clean room quality

o documented investigation into discrepancy

?Materials:

o microbial and bacterial endotoxin control of incoming materials and components

o quality of water supply, maintenance, qualification

o operation of the systems that provide the requisite water and process gases

o documented investigations into OOS, deviations, and discrepancies

?Production:

o observation of adequacy of operator behavior and aseptic techniques during manufacturing o production line operations and interventions

o personnel training in aseptic techniques

o major production line repair or maintenance issues

o risk assessment on microbial and bacterial endotoxin controls, including hold times of critical steps

o validation of sterilization of equipment, container-closures and supplies

o media fills design and results

o documented investigations into, deviations, discrepancies, and OOS results

?Laboratory:

o investigations into OOS, deviations, and discrepancies

o test methods and controls, including adherence to validated methods

o training and qualifications of laboratory personnel

o trending of water system test results

o systems used for recovery, identification and trending of environmental monitoring isolates 3.4 SYSTEM INSPECTION COVERAGE

Compliance Program 7356.002, Drug Manufacturing Inspections, lists the areas that should be covered when inspecting each of the six systems. This program provides additional guidance, by system, for areas of specific concern for sterile drug products.

Attachment A is a list of questions intended to be an aid in conducting inspections and obtaining information needed to assess a firm’s operations. The answers do not have to be reported in the EIR unless they are relevant. The list of questions covers: moist heat sterilization; dry heat

sterilization/depyrogenation; aseptic filling; lyophilization; isolators; environmental monitoring; and biological indicators.

3.5 QUALITY SYSTEM

As noted in Compliance Program 7356.002, the inspection of the quality system is two-phased. The first phase is to evaluate whether the Quality Unit has fulfilled their responsibility regarding the review and approval of procedures and assured their suitability for use. The second phase is to assess the data collected by the firm to identify potential quality problems. For sterile manufacturing operations, this latter objective involves large amounts of data that link to the other inspectional systems. The comprehensive review of such data by the firm is an essential element in assuring that products are produced with a high degree of sterility assurance. It is therefore important to review the firm’s system for using the data to assess the state of control of their manufacturing operations and facility. The data summaries and trend reports maintained by the Quality Unit should be reviewed during every inspection. During a routine CGMP inspection, this review can help determine which option (Full or Abbreviated) to select.

The inspection of the Quality System should include the areas listed in CP7356.002. For this program, the inspection should include a review of all data and reports that may indicate product contamination and sterility assurance issues.

Records pertaining to quality consist of the following:

1. Periodic product evaluations, complaints, adverse events, investigations, Field Alert Reports,

product retain evaluations, complaints, rejected lots, stability, and returned goods that indicate

possible product contamination or risks to patients (for example, hazy or cloudy product,

foreign matter/particulates in injectable products, cracked, and leaky containers).

2. Discrepancy and failure investigations, such as:

o All initial positive sterility tests and endotoxin and media fill failures regardless of final disposition.

o Unexpected results or trends.

o All failures that occurred during validation or revalidation of sterilization / depyrogenation processes.

o All investigations involving media fills / process simulations.

o Environmental (microbial/viable and particle/non-viable counts) and personnel monitoring results that exceed alert or action levels.

o Process deviations or equipment malfunctions that involve critical equipment, such as sterilizers and lyophilizers.

o Out of Specification (OOS) results for assay, impurities, particulate matter, or reconstitution time, if applicable.

o Product rejects (rejects determined during manufacturing and Quality Control test)

3. Trends reports/ summaries of quality indicators:

o For aseptic processing, summary of all media fills performed since last inspection.

o Environmental monitoring trend data (microbial and particle counts).

o Personnel monitoring trend data.

o Summary of water system test results.

4. Summary of change controls for critical utilities and equipment implemented since the last

inspection, for example:

o Sterilizers, lyophilizers, depyrogenation equipment

o Aseptic processing line

o Clean steam generator, process gas system

o WFI and / or Purified Water system

o Air handling systems

o Automated building management system

Every inspection of a sterile drug manufacturer should include a review of the type of information listed above and observation of the manufacturing operations occurring in the critical areas. The information can be used to select other system(s) to be covered during the inspection.

In addition, the review of summary data and observation of operations can focus the inspection on potential problem areas and provides an overview of the effectiveness of the Quality System. The inspection of the Quality System may necessitate follow-up within another system. However, this coverage does not constitute or require complete coverage of these systems.

3.6 FACILITIES AND EQUIPMENT SYSTEM

Compliance Program 7356.002 lists the general areas to cover when inspecting the Facilities and Equipment System. The areas are applicable to sterile drug products and should be covered if this system is selected. The principle objective of an effective sterile drug manufacturing operation from a facility and equipment standpoint is to provide suitable protection of product. The inspectional evaluation of this objective is again two-part:

?Review and evaluate the firm’s rationale for, and adequacy of, the facility and equipment design (Reference: Section IV of FDA’s 2004 Aseptic Processing Guidance).

?Evaluate the data that provide information relevant to the state of control of the facility and equipment.

In addition to the review of design elements and data, investigators should look for visible deficiencies in the facility and equipment, such as cleanliness, equipment deterioration (e.g., warping, corrosion), inaccessible and/or difficult to clean surfaces, and changes to critical equipment or systems that have not been qualified which may impact product quality. Investigator should look for aberrant events due to facility deterioration, a pattern of recurring and uncorrected maintenance issues, and increase or changes in production output that exceed the capacity of the facility and equipment.

A. FACILITIES

Evaluate the design and layout of the facility (e.g., personnel/material flow, cleanroom design). Specifications for clean room areas (layout, air filtration, appropriate air classification, pressure differentials between rooms and areas, temperature, and humidity) should be appropriate, and based on the risk of product contamination with particulate matter and microorganisms. Review the certification and qualification of the clean room areas to verify the areas meet design criteria and specifications. Certification and qualification typically includes data in support of the following: air flow pattern studies, HEPA (High Efficiency Particulate Air) filter integrity testing, air velocity measurement, non- viable particle, and verification of appropriate pressure differentials, temperature and humidity setpoints. Evaluate the airflow pattern (smoke studies) conducted under dynamic conditions to verify the unidirectional airflow and air turbulence within the critical area where sterilized drug product, containers, and closures are exposed to environmental conditions.

?Reference: Section IV of FDA’s 2004 Aseptic Processing Guidance.

?Routine monitoring and maintenance to assure air handling systems continue to operate within established parameters (microbiological monitoring is discussed under the Laboratory Control System).

o Afford special attention to facilities that are performing construction in the clean areas, or at the vicinity of cleanroom. Because microbes (e.g., fungal spores) can be liberated from the

movement of walls and other construction activities, determine if the facility is returned to

acceptable environmental control through proper measures (environmental monitoring,

media fills) before production can resume.

o Verify that environmental monitoring of non-viable particle is occurring during operations including sites where there is the most risk to exposed product, container and closures.

o Check if pressure differentials, temperature, and humidity are continuously monitored during routine production.

o Determine if continuous monitoring systems are alarmed to alert operators of excursions.

o Check if excursions from acceptable ranges are investigated to determine impact on product and that needed corrective actions are taken.

o Evaluate the program for periodic testing / recertification of the HEPA filters in critical areas to maintain appropriate air flow. The tests typically include integrity testing of the

HEPA filters and air velocity checks.

?Sanitization / disinfection of clean room areas, processing lines, and non autoclavable equipment, materials, and components should be reviewed. Focus on the areas where the

sterile product is exposed up to and including sealing operations. These critical areas represent

the highest risk to the product. The suitability, efficacy, and limitations of disinfecting agents

and adequacy of procedures should be reviewed, including the data that establishes the expiry

of the disinfection solution. (Reference: Section X.A.3 of FDA’s 2004 Aseptic Processing

Guidance)

?For multi-use facilities and non-dedicated equipment, evaluate the adequacy of the changeover procedures and cleaning to prevent cross-contamination between products.

B. EQUIPMENT

Equipment used in the manufacture of sterile drug products may include the following:

?Production Equipment

?Container/closure processing equipment (e.g. stopper washer, glassware depyrogenation equipment)

?Support system/material system related equipment (e.g. WFI system and related equipment, process gas related equipment)

Specific considerations include:

(1) Production Equipment

(a) Aseptic Processing Equipment. Determine that all equipment that comes in direct contact

with product (e.g., filters, transfer lines, holding tanks, stopper bowls, filling line equipment) and sterile components (e.g., stoppers) are sterilized and protected from contamination prior to and during use. Equipment logs or other related information may provide insight into significant maintenance or other problems that may increase exposure of batches to contamination risk.

(b) Stopper washer. Inspectional considerations include the qualification of the equipment,

cycle validation and supporting data, equipment preventative maintenance (maintenance requirements and frequency), quality of water used for washing, and associated water sampling/qualification data. The appropriateness of the air supply used in any drying operations should also be verified.

(c) Capping Equipment (vials). The vial cap provides the final closure element of a sealed vial.

The capping machine folds and crimps the cap (aluminum) over the neck of the stoppered vial.

The cap on the vial protects the stopper from external damage, while firmly holding the stopper

in the fully seated, sealed position. Evaluate the established processing settings (crimp angles, pressures), and preventative maintenance schedules of the capping machine. Air supply quality to the capping units should also be evaluated.

(d) Post fill Visual Inspection/Automated Inspection Equipment. The 100% inspection of the final filled and sealed product may occur via a manual, automated, or semi-automated inspection process. Manual and semi-automated inspection processes involve specified viewing fields and calibrated light sources. Semi-automated processes may use conveyor belts and rotational units that present the filled product to an operator for visual inspection. All conveyor and rotational speed set points should be verified against established parameters. Automated inspection systems may inspect for one or all types of defects in a given filled product. Defect categories with relevant action levels should be defined. The qualification of the equipment and the challenges performed to verify equipment functionality prior to routine use should be evaluated as well as the training program for operators performing manual visual inspections.

(e) Sterilizers. The inspection should cover the Installation and Operation Qualification of equipment and the Performance Qualification of the process (IQ, OQ and PQ), and operation, calibration and preventative maintenance of representative types of equipment used to sterilize finished dosage forms, filling equipment, containers, closures, etc. Such equipment includes autoclaves, dry heat ovens, dry heat tunnels, steam-in-place (SIP) equipment and chemical sterilization systems (i.e., hydrogen peroxide, peracetic acid). Inspection of sterilizers should include physical examination of the equipment. Review the engineering specifications which may be described in the equipment’s DQ (Design Qualification). DQ is performed prior to the IQ (Installation Qualification) and OQ (Operational Qualification), and verify that the sterilizer is maintained, calibrated and drained properly and that it has appropriate measuring devices (temperature sensors, pressure gauges, etc.).

Records of unplanned maintenance, as well as preventative maintenance, should be reviewed to assure all significant changes have been evaluated and qualified as appropriate. Equipment logs should also be reviewed. For example, repeat sterilization of loads because of cycle failures can indicate a serious problem with a sterilizer. Impact of re-sterilization to product quality should be evaluated. (Performance qualification is covered under the Production System).

The equipment can be computer controlled or operated in a manual mode. For computer controlled system, programmable logic controller (PLC) or a more complex Supervisory Controlled and Data Acquisition Management System (SCADA), may require an assessment to determine if the computer control and/or monitoring system are Part 11 compliant. Reference:

o PDA Technical Report No. 1 Revised 2007 Validation of Moist Heat Sterilization Processes: Cycle Design, Development, Qualification and Ongoing Control;

o ISO 17665 Moist Heat Sterilization.

(f) Lyophilizer. Because partially sealed vials are used in the lyophilization process, sterile product is exposed to the environment from the time of filling until the vials are fully stoppered in the lyophilization chamber at the end of the cycle. The inspection should verify that partially

sealed vials are transported and loaded into the lyophilizers under Class 100 (ISO 5) protection.

Investigators should observe the transport of vials and loading of lyophilizers.

Other key equipment areas to cover include: validation of the sterilization of the lyophilization chamber between uses, current sterilization controls, leak testing of the chamber, integrity testing of air/gas filters, and calibration of temperature and pressure controllers.

Reference: FDA’s Guide to Inspections of Lyophilization of Parenterals.

(g) Isolators. Evaluate the design and control elements that maintain the separation or isolation

of the product. Pressure differential, glove integrity, and protection of the transfer (i.e., entry,

exit) ports are key elements for the isolators. The transfer of containers, closures and supplies

(including environmental monitoring supplies) into an isolator should be carefully controlled.

Another critical element for these systems is the effectiveness of the chamber decontamination program. Current methods (e.g., vaporized hydrogen peroxide, steam hydrogen peroxide,

peracetic acid) used to decontaminate isolator barriers are capable of surface sterilization but

lack the penetrating capabilities of steam sterilization. Investigators should be mindful of the

limitations of these surface sterilants, including their inefficiency in penetrating obstructed or

protected surfaces. Validation of the decontamination of the interior (surfaces) of an isolator

should demonstrate a 6-log reduction of the biological indicator (BI). Quantitative measuring

devices (e.g., near infrared) or chemical indicators (qualitative test) can be used to determine the worst case location for decontamination validation using BI. Factors to be considered in

decontamination validation include the location of the BI and the type of surfaces where the BIs are inoculated.

Utensils and equipment surfaces inside the isolator that have direct contact with sterile product and components should be sterilized to render them free of microorganisms. The sterilization

validation should achieve a minimum of a 6-log reduction of the BI

Reference:

o Appendix 1 of FDA’s 2004 Aseptic Processing Guidance;

o PDA Technica l Report 51 (2010) Biological Indicators for Gas and Vapor Phase Decontamination Processes: Specifications, Manufacture, Control and Use provides

general principles to be considered in decontamination by BI.

(h) Restricted Access Barrier System (RABS). In general, a RABS is a fill-finish line in a rigid

wall enclosure that provides full physical separation of the filling line from operators. It is

important to note that the inside surfaces of the RABS are disinfected with a sporicidal agent2, but this is not accomplished using the automated decontamination cycles employed for isolators.

This requires firms to carefully supervise disinfection procedures and assure ongoing

effectiveness of the disinfection program. Operators use glove ports, half suits or automation to access areas within the enclosure during filling. There are 2 types of RABS, “open” and “closed”

RABS. The doors to a “closed” RABS are never opened during an operation. While an “open”

RABS is designed to operate with doors closed at all times, on rare pre-defined circumstances

2 Robust disinfection of all non-product contact surfaces within the RABS should be performed with a suitable sporicidal

the doors of the enclosure can be opened to perform certain interventions. If doors are routinely opened during a filling operation, the system is not considered a RABS because it no longer restricts access to the critical areas. Typically, the cleanroom surrounding the RABS is controlled as a Class 10,000 (ISO 7) area and operators are fully gowned.

Reference: Restricted Access Barrier Systems (RABS) for Aseptic Processing; ISPE; August 16 2005.

When inspecting a RABS:

o Determine that the gloves and gauntlets attached to the glove ports are sterile when installed. After installation, the gloves should be disinfected or changed at appropriate

intervals to minimize the risk of contamination.

o Verify there is a well defined written procedure that describes what is done when an open- door intervention is performed. All open-door interventions should be documented and

described in batch records, and followed by disinfection.

o RABS entry is often accompanied by an appropriate line clearance, which should be clearly documented in batch records.

o Determine that all fluid pathways and product contact parts such as stopper bowl, feed and placement systems are sterilized prior to the filling of each batch.

o Observe how sterile components and supplies are transferred to the RABS. Verify that the transfer system prevents exposure of sterile surfaces to less clean environments.

o Verify that non-product contact surfaces within the RABS undergo thorough disinfection with a sporicidal agent before each batch. The effectiveness of the overall disinfection

program should be validated and routinely evaluated by the environmental monitoring

program.

(i) Blow-fill-seal (BFS) Technology. BFS is an automated aseptic filling process in which containers are formed, filled and sealed in a continuous operation. BFS systems can reduce the risk of product contamination by reducing operator interventions. The systems are typically used for filling sterile ophthalmic and respiratory care products. See Appendix 2 of FDA’s 2004 Aseptic Processing Guidance for information about BFS systems. It should be noted that the inner surfaces of the containers can be exposed to the surrounding environment during the formation and molding steps prior to filling. The sterile product can also be exposed to the environment during the filling and sealing steps of the BFS process. Therefore, the air quality should meet the microbiological level established for Class 100 (ISO 5) should be supplied to where the sterile product or its containers are exposed during the BFS process. Some of the more advanced BFS equipments that provide enhanced protection for the sterile product operation can be located in a Class 100,000 (ISO 8) area. Otherwise, a Class 10,000 (ISO 7) area is appropriate. Research has demonstrated a direct relationship between the number of contaminated units and the level of microbial contamination in the air surrounding the machine (see Reference #20). Typically, the product supply line and sterilizing product filters are steam sterilized-in-place (SIP).

When inspecting BFS:

o Verify that HEPA-filtered or sterile air is used during steps where sterile product or materials are exposed (e.g., parison formation, container molding, and filling steps).

o Evaluate the monitoring and preventative maintenance programs to determine the integrity of the utilities (cooling water, heating, etc.) associated with the BFS machine is routinely checked. Leaks in the molds or utility connections at the molds can contaminate the sterile product or containers.

o Review the SIP system used to sterilize the product line. Determine the sterilization cycle has been validated and the condensate properly drains from the line. The line should also be protected between sterilization and use.

o Verify that personnel who enter the classified environment surrounding the BFS machine are properly gowned and trained.

o If possible, observe equipment setup and any difficulties that can lead to contamination risks.

Other control procedures (media fills, environmental monitoring, disinfection of surfaces, etc.) are the same as discussed for conventional aseptic processing line.

(j) Reactor, Centrifuge, Dryer, Mill. This type of equipment can be used to aseptically manufacture sterile bulk Active Pharmaceutical Ingredients (APIs). The equipment and all transfer piping must be sterilized prior to processing. This is typically done with sterilize-in- place (SIP) systems which use clean steam or a chemical sterilant. Review the validation, cycle controls and the routine monitoring of the SIP system. The equipment and all transfer piping must remain integral (no fluid or air leaks) and sterile throughout the entire manufacturing process. Determine how the firm verifies the integrity of the equipment train throughout the process. If a piece of equipment is opened in the process (e.g. adding seed crystals), verify the area surrounding the open operation is robustly protected from contamination risks with a Class 100 (ISO 5) air system as well as implementing a carefully designed aseptic operation. Reference: FDA’s Guide to Inspections of Sterile Drug Substance Manufacturers.

(2) Container/Closure Processing Equipment

Depyrogenation equipment may include a dry heat oven and/or depyrogenation tunnel. Depyrogenation of stoppers can also be accomplished by dilution via a washing process. The final rinse of the washing process uses Water for Injection (WFI). For more information, see FDA’s Aseptic Processing Guidance, Section VI.B, Containers/Closures.

(3) Support Utilities

(a) Water System. Specifically, review WFI generation equipment and distribution loop(s), including tanks, water lines, isometric diagrams, vent filters, and preventive maintenance schedules (See also Materials System). Monitoring equipment associated with the Water System should also be evaluated.

(b)HVAC. Refer to Section IV of FDA’s 2004 Aseptic Processing Guidance on qualification and maintenance of the HVAC system.

(c) Process Gases. Gases that are in contact with the drug product or components in drug

manufacturing operations are referred to as process gases. Gases used in aseptic operations, or downstream of sterilization, must be filtered through a sterilizing grade filter to maintain asepsis.

The integrity testing of these filters (typically hydrophobic) should be evaluated. The system

used in the generation of the process gas(es) should also be evaluated including preventive

maintenance (PM) schedules, monitoring (including temperature, pressure, and humidity), and sampling. See also under Materials System.

3.7 MATERIALS SYSTEM

Compliance Program 7356.002 lists the areas to cover when inspecting the Materials System. The areas are applicable to sterile drug products and should be covered if this system is selected. In sterile operations, the quality attributes of each of the materials (ingredients, WFI, containers, closures) have a bearing on the critical attributes of the finished product. Review the firm’s procedures for receipt, handling, sampling, testing, approval and storage of manufacturing materials to verify their fitness for use. Emphasis should be placed on incoming materials that are represented to be sterile and / or pyrogen free.

Areas of special concern for sterile drug products include:

(1) Water Systems. Water for Injection (WFI) is an ingredient in many sterile drugs, including injectable products and sterile ophthalmic products. It is also used in depyrogenation (or endotoxin removal) of equipment and stoppers and in cleaning operations. The quality of the water, and its endotoxin levels and controls, used in the upstream process should also be evaluated in order to ensure the removal of bacterial endotoxin to the appropriate level downstream. Purified water can be used for some sterile non-injectable solutions.

?Observe and understand elements of the generation and distribution systems.

?Evaluate the water system “As Built” diagrams” and inspect for leaks, pipe slopes (via the isometric diagrams and verification of the degree of the slopes), so called “dead legs”, and

non-sanitary fittings in the distribution system.

?Evaluate how microbial alert and action levels are established.

?Evaluate sampling sites, procedures, frequencies and tests performed.

?Review procedures for preventative maintenance and calibration of critical instruments, including scheduling and equipment update procedures.

?Review raw data to verify that all of the above is completed per established procedure.

?Review and observe routine monitoring (in-line TOC and conductivity) of water system.

?Review trend data for chemistry, microbiological and endotoxin tests.

?Review investigation of results that are at or over alert and action levels.

Reference: FDA’s Guide to Inspections of High Purity Water Systems.

(2) Process Gas. Process gas and related equipment controls may be covered in conjunction with the Facilities and Equipment System. Specific considerations include controls over final filtration of the

processed gas and filter integrity testing. Gas used as a component in a finished product may include the Nitrogen gas overlay for Oxygen sensitive products.

(3) Pre-washed / Ready to Sterilize Closures. The CGMP regulation (21 CFR 211.94(c)) states that, where indicated, containers and closures must be processed to remove pyrogenic substances. Many manufacturers of small volume parenterals purchase stoppers that are ready-to-sterilize, (i.e., they are pyrogen-free). No washing or depyrogenation is done by the dosage form manufacturers but these firms are still responsible for assuring the stoppers are of acceptable quality for use in manufacturing. The pyrogen requirements should be included in specifications for the stoppers and, if the manufacturer does not conduct testing of each incoming lots for pyrogen/endotoxin, they should establish the reliability of the supplier’s test results by qualification of the vendor, followed by periodic testing.

(4) Microbiological and Endotoxin Testing of Component, Container and Closure. 21 CFR

211.84(d) specifies that each lot of component, container or closure that is liable to microbial contamination which is objectionable in view of its intended use shall be subjected to microbiological tests before use. Evaluate the firm’s system for determining if microbiological or endotoxin testing is required and the rationale for setting acceptance criteria. Review test data to verify that the materials meet test criteria and, if not, verify that investigations were conducted to determine the cause and corrective actions were implemented.

(5) Verification of Container and Closures. The physical and chemical characteristics of containers and closures can be critical to the sterility and stability of the finished product. Many containers and closures look alike (color and dimensions), but are made of different materials or have a different surface treatment such as silicone on stoppers and ammonium sulfate on Type I glass. Evaluate the firm’s procedures for assuring containers and closure consistently meet appropriate specifications. Determine what tests and examinations are done to verify the containers and closures are made of the correct materials with the correct dimensions (critical to ensuring continuing container-closure integrity) and are free of critical defects.

(6) Container / Closure Integrity. The integrity of the container / closure system is critical to assuring that all units of drug products remain sterile through shipment, storage and use. Leaking containers or closures lead to product contamination.

Reference: FDA’s 1994 Guidance for Industry for the Submission of Sterilization Process Validation in Applications for Human and Veterinary Drug Products.

Evaluate the tests and studies performed to demonstrate the integrity of container / closure systems for all sterile drugs, including:

?Verify that all incoming container-closure components meet specifications, including all appropriate dimensions.

?Determine studies adequately simulate the stress conditions of the sterilization process, handling and storage.

?Verify that the units tested in validation are appropriate (e.g., for terminally sterilized drug product, the units selected should be exposed to the maximum sterilization cycles using the

production process).

古代晋灵公不君、齐晋鞌之战原文及译文

晋灵公不君(宣公二年) 原文: 晋灵公不君。厚敛以雕墙。从台上弹人,而观其辟丸也。宰夫胹熊蹯不熟,杀之,寘诸畚,使妇人载以过朝。赵盾、士季见其手,问其故而患之。将谏,士季曰:“谏而不入,则莫之继也。会请先,不入,则子继之。”三进及溜,而后视之,曰:“吾知所过矣,将改之。”稽首而对曰:“人谁无过?过而能改,善莫大焉。诗曰:‘靡不有初,鲜克有终。’夫如是,则能补过者鲜矣。君能有终,则社稷之固也,岂惟群臣赖之。又曰:‘衮职有阙,惟仲山甫补之。’能补过也。君能补过,衮不废矣。” 犹不改。宣子骤谏,公患之,使鉏麑贼之。晨往,寝门辟矣,盛服将朝。尚早,坐而假寐。麑退,叹而言曰:“不忘恭敬,民之主也。贼民之主,不忠;弃君之命,不信。有一于此,不如死也!”触槐而死。 秋九月,晋侯饮赵盾酒,伏甲将攻之。其右提弥明知之,趋登曰:“臣侍君宴,过三爵,非礼也。”遂扶以下。公嗾夫獒焉。明搏而杀之。盾曰:“弃人用犬,虽猛何为!”斗且出。提弥明死之。 初,宣子田于首山,舍于翳桑。见灵辄饿,问其病。曰:“不食三日矣!”食之,舍其半。问之,曰:“宦三年矣,未知母之存否。今近焉,请以遗之。”使尽之,而为之箪食与肉,寘诸橐以与之。既而与为公介,倒戟以御公徒,而免之。问何故,对曰:“翳桑之饿人也。”问其名居,不告而退。——遂自亡也。 乙丑,赵穿①攻灵公于桃园。宣子未出山而复。大史书曰:“赵盾弑其君。”以示于朝。宣子曰:“不然。”对曰:“子为正卿,亡不越竟,反不讨贼,非子而谁?”宣子曰:“呜呼!‘我之怀矣,自诒伊戚。’其我之谓矣。” 孔子曰:“董狐,古之良史也,书法不隐。赵宣子,古之良大夫也,为法受恶。惜也,越竞乃免。” 译文: 晋灵公不行君王之道。他向人民收取沉重的税赋以雕饰宫墙。他从高台上用弹弓弹人,然后观赏他们躲避弹丸的样子。他的厨子做熊掌,没有炖熟,晋灵公就把他杀了,把他的尸体装在草筐中,让宫女用车载着经过朝廷。赵盾和士季看到露出来的手臂,询问原由后感到很忧虑。他们准备向晋灵公进谏,士季说:“如果您去进谏而君王不听,那就没有人能够再接着进谏了。还请让我先来吧,不行的话,您再接着来。”士季往前走了三回,行了三回礼,一直到屋檐下,晋灵公才抬头看他。晋灵公说:“我知道我的过错了,我会改过的。”士季叩头回答道:“谁能没有过错呢?有过错而能改掉,这就是最大的善事了。《诗经》说:‘没有人向善没有一个开始的,但却很少有坚持到底的。’如果是这样,那么能弥补过失的人是很少的。您如能坚持向善,那么江山就稳固了,不只是大臣们有所依靠啊。

药学英语第五版第三单元

Biochemistry Seeks to Explain Life in Chemical Terms The molecules of which living organisms are composed conform to all the familiar laws of chemistry, but they also interact with each other in accordance with another set of principles, which we shall refer to collectively as the molecular logic of life. These principles do not involve new or yet undiscovered physical laws or forces. Instead, they are a set of relationships characterizing the nature, function, and interactions of biomolecules. If living organisms are composed of molecules that are intrinsically inanimate, how do these molecules confer the remarkable combination of characteristics we call life? How is it that a living organism appears to be more than the sum of its inanimate parts? Philosophers once answered that living organisms are endowed with a mysterious and divine life force, but this doctrine (vitalism) has been firmly rejected by modern science. The basic goal of the science of biochemistry is to determine how the collections of inanimate molecules that constitute living organisms interact with each other to maintain and perpetuate life. Although biochemistry yields important insights and practical applications in medicine, agriculture, nutrition, and industry, it is ultimately concerned with the wonder of life itself. All Macromolecules Are Constructed from a Few Simple Compounds Most of the molecular constituents of living systems are composed of carbon atoms covalently joined with other carbon atoms and with hydrogen, oxygen, or nitrogen. The special bonding properties of carbon permit the formation of a great variety of molecules. Organic compounds of molecular weight less than about 500, such as amino acids, nucleotidase, and monosaccharide, serve as monomeric subunits of proteins, nucleic acids, and polysaccharides,

药学专业英语药学词汇

6-磷酸葡萄糖脱氢酶 glucose-6-phosphate dehydrogenase Janbon综合症 Janbon's syndrome PPB浓度 parts per billion concentration pphm浓度 parts per hundred million concentration PPH浓度 parts per hundred concentration ppm浓度 parts per million concentration 安全范围 safety range 安全试验法 innocuity test method 安全系统 safety coefficient 安慰剂 placebo 螯合剂 chelating agent 靶细胞 target cell 白蛋白微球制剂 albumin microballoons 百分浓度 percentage concentration 半合成抗生素 semisynthetic antibiotics 半抗原 haptene 半数致死剂量 half lethal dose ; median lethal dose; LD50 半衰期 half-life period; half life time 包衣片 coated tablet 薄膜衣 film-coating 饱和溶液 saturated solution 贝克勒尔 Becquerel 被动免疫 passive immunity 被动转运 passive transport

崩解度 disintegration 崩解剂 disintegrants 必需氨基酸 essential aminoacid 必需脂肪酸 essential fatty acid 变态反应 allergy; allergic reaction 表面活性 surface activity 表面张力 surface tension 丙种射线 gamma rays 补体 complement 补体系统 complement system 不良反应 adverse reaction 不完全抗原 incomplete antigen 搽剂 liniments 长期毒性实验 long term toxicity test 长效制剂 prolonged action preparation 肠肝循环 enterohepatic circulation 肠溶控释片 enteric controlled release tablets 肠溶衣 enteric coating 处方 prescription;recipe 穿透促进剂 penetration enhancers 磁性控释制剂 magnetic controlled release dosage form 磁性药物制剂 magnetic medicinal preparations 大分子 macromolecule 单克隆抗体 monoclonal antibody

如何翻译古文

如何翻译古文 学习古代汉语,需要经常把古文译成现代汉语。因为古文今译的过程是加深理解和全面运用古汉语知识解决实际问题的过程,也是综合考察古代汉语水平的过程。学习古代汉语,应该重视古文翻译的训练。 古文翻译的要求一般归纳为信、达、雅三项。“信”是指译文要准确地反映原作的含义,避免曲解原文内容。“达”是指译文应该通顺、晓畅,符合现代汉语语法规范。“信”和“达”是紧密相关的。脱离了“信”而求“达”,不能称为翻译;只求“信”而不顾“达”,也不是好的译文。因此“信”和“达”是文言文翻译的基本要求。“雅”是指译文不仅准确、通顺,而且生动、优美,能再现原作的风格神韵。这是很高的要求,在目前学习阶段,我们只要能做到“信”和“达”就可以了。 做好古文翻译,重要的问题是准确地理解古文,这是翻译的基础。但翻译方法也很重要。这里主要谈谈翻译方法方面的问题。 一、直译和意译 直译和意译是古文今译的两大类型,也是两种不同的今译方法。 1.关于直译。所谓直译,是指紧扣原文,按原文的字词和句子进行对等翻译的今译方法。它要求忠实于原文,一丝不苟,确切表达原意,保持原文的本来面貌。例如: 原文:樊迟请学稼,子曰:“吾不如老农。”请学为圃。子曰:“吾不如老圃。”(《论语?子路》) 译文:樊迟请求学种庄稼。孔子道:“我不如老农民。”又请求学种菜蔬。孔子道:“我不如老菜农。”(杨伯峻《论语译注》) 原文:齐宣王问曰:“汤放桀,武王伐纣,有诸?”(《孟子?梁惠王下》) 译文:齐宣王问道:“商汤流放夏桀,武王讨伐殷纣,真有这回事吗?(杨伯峻《孟子译注》) 上面两段译文紧扣原文,字词落实,句法结构基本上与原文对等,属于直译。 但对直译又不能作简单化理解。由于古今汉语在文字、词汇、语法等方面的差异,今译时对原文作一些适当的调整,是必要的,并不破坏直译。例如: 原文:逐之,三周华不注。(《齐晋鞌之战》) 译文:〔晋军〕追赶齐军,围着华不注山绕了三圈。

药学英语第五版原文翻译 (2)(2020年7月整理).pdf

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《鞌之战》阅读答案附翻译

《鞌之战》阅读答案(附翻译) 《鞌之战》阅读答案(附翻译) 鞌之战[1] 选自《左传·成公二年(即公元前589年)》 【原文】 癸酉,师陈于鞌[2]。邴夏御齐侯[3],逢丑父为右[4]。晋解张御郤克,郑丘缓为右[5]。齐侯曰:“余姑 翦灭此而朝食[6]。”不介马而驰之[7]。郤克伤于矢, 流血及屦,未绝鼓音[8],曰:“余病[9]矣!”张侯[10]曰:“自始合,而矢贯余手及肘[11],余折以御,左轮 朱殷[12],岂敢言病。吾子[13]忍之!”缓曰:“自始合,苟有险[14],余必下推车,子岂识之[15]?——然 子病矣!”张侯曰:“师之耳目,在吾旗鼓,进退从之[16]。此车一人殿之[17],可以集事[18],若之何其以 病败君之大事也[19]?擐甲执兵,固即死也[20]。病未 及死,吾子勉之[21]!”左并辔[22],右援枹而鼓[23],马逸不能止[24],师从之。齐师败绩[25]。逐之,三周 华不注[26]。 【注释】 [1]鞌之战:春秋时期的著名战役之一。战争的实质是齐、晋争霸。由于齐侯骄傲轻敌,而晋军同仇敌忾、 士气旺盛,战役以齐败晋胜而告终。鞌:通“鞍”,齐

国地名,在今山东济南西北。 [2]癸酉:成公二年的六月十七日。师,指齐晋两国军队。陈,列阵,摆开阵势。 [3]邴夏:齐国大夫。御,动词,驾车。御齐侯,给齐侯驾车。齐侯,齐国国君,指齐顷公。 [4]逢丑父:齐国大夫。右:车右。 [5]解张、郑丘缓:都是晋臣,“郑丘”是复姓。郤(xì)克,晋国大夫,是这次战争中晋军的主帅。又称郤献子、郤子等。 [6]姑:副词,姑且。翦灭:消灭,灭掉。朝食:早饭。这里是“吃早饭”的意思。这句话是成语“灭此朝食”的出处。 [7]不介马:不给马披甲。介:甲。这里用作动词,披甲。驰之:驱马追击敌人。之:代词,指晋军。 [8]未绝鼓音:鼓声不断。古代车战,主帅居中,亲掌旗鼓,指挥军队。“兵以鼓进”,击鼓是进军的号令。 [9]病:负伤。 [10]张侯,即解张。“张”是字,“侯”是名,人名、字连用,先字后名。 [11]合:交战。贯:穿。肘:胳膊。 [12]朱:大红色。殷:深红色、黑红色。 [13]吾子:您,尊敬。比说“子”更亲切。

药学英语专业词汇

药学名词(中-英) 6-磷酸葡萄糖脱氢酶glucose-6-phosphate dehydrogenase Janbon综合症Janbon's syndrome PPB浓度parts per billion concentration pphm浓度parts per hundred million concentration PPH浓度parts per hundred concentration ppm浓度parts per million concentration 安全范围safety range 安全试验法innocuity test method 安全系统safety coefficient 安慰剂placebo 螯合剂chelating agent 靶细胞target cell 白蛋白微球制剂albumin microballoons 百分浓度percentage concentration 半合成抗生素semisynthetic antibiotics 半抗原haptene 半数致死剂量half lethal dose ; median lethal dose; LD50 半衰期half-life period; half life time 包衣片coated tablet 薄膜衣film-coating 饱和溶液saturated solution 贝克勒尔Becquerel 被动免疫passive immunity 被动转运passive transport 崩解度disintegration 崩解剂disintegrants 必需氨基酸essential aminoacid

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