According to the revised Annex 1, published in 2022 and mandatory as of August 25, 2023, companies must adopt a risk-based approach to prevent all forms of contamination in the final product. To demonstrate that companies have control over their production facilities and processes to prevent contamination, Annex 1 now requires that a Contamination Control Strategy be in place.

What is a Contamination Control Strategy?
A Contamination Control Strategy (CCS) is a compilation of all existing controls designed to prevent contamination in facilities, processes, and finished products. In other words, a CCS is an umbrella document summarizing all activities aimed at preventing all forms of contamination. It must be clear at a glance that all critical process parameters have been defined, and where necessary, risk assessments and scientific evidence must be used to demonstrate that the risk of contamination is low.
Creating a CCS requires not only process knowledge but also technical expertise. That is why it is important to work with a multidisciplinary team.
How to Implement
To begin with, it is important that everyone on the team is aware of the Annex 1 changes and what they mean for the various departments. Conduct a gap analysis to assess the current status and identify priorities.
Brainstorm solutions together and start building your CCS.
“Keep the CCS alive!”—so review and update your CCS regularly. Demonstrate that there is a culture of continuous improvement within the company.

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