By Sofia Steiner
Sofia Steiner is a critical-utilities consultant who helps GMP facilities in Europe and West Africa specify, qualify and operate water and steam systems with fewer deviations and faster releases. She specialises in lifecycle qualification (URS–DQ–IQ/OQ/PQ) aligned to WHO TRS 1033 and USP <1231>, embeds contamination-control principles from EU GMP Annex 1, and applies ISPE’s Baseline Guide Vol. 4 and GAMP 5 practices to deliver audit-ready utilities.
Pharmaceutical water underpins everything from buffer prep to final cleaning. Get it right and batches flow; get it wrong and you invite deviations, downtime and recalls. This practical primer distils the essentials of what to make, how to make it, and how to keep it compliant - without drowning in jargon.
Know your grades (and what they’re for)
Most facilities revolve around three pillars. Purified Water (PW) serves non-parenteral steps and many cleaning applications; pharmacopeial control relies on conductivity and total organic carbon (TOC) as primary chemical attributes, supported by microbiological expectations in the relevant monographs and chapters. In practice that means demonstrating ionic control per USP <645> and organic control per USP <643>, whether measured on-line or off-line.
Water for Injections (WFI) is reserved for parenteral and other high-risk uses. Since 2017, the European Pharmacopoeia has permitted WFI produced by non-distillation routes such as reverse osmosis with appropriate complementary techniques, provided an equivalent risk-controlled outcome is proven; the EMA’s water guideline and EDQM notices capture the scope and expectations and remain the touchstones for inspectors.
Pure (clean) steam must be generated from suitably qualified feed so the condensate meets expectations aligned to PW or WFI at the point of use. ISPE’s Baseline Guide, Volume 4 is the recognised engineering reference for water and steam utilities across design and operation.
A practical rule follows: match the grade to the risk of the use point - not to habit. If the process risk is parenteral-adjacent, design and defend accordingly in your contamination control strategy.
Production trains that regulators recognise
A robust train starts with pretreatment to stabilise the feed, then applies purification stages to reach the target grade, and finishes with a clear sanitisation concept and final treatment where needed. WHO’s GMP text sets the lifecycle expectation without ambiguity: systems must be designed, installed, commissioned, qualified, validated, operated and maintained to deliver consistent quality, with routine monitoring and documented control from source to distribution.
For PW, common architectures use RO → EDI (or RO → RO) with final microfiltration, backed by either hot-water or chemical/ozone sanitisation—choices that should be justified in risk and qualification records. For WFI, Europe now accepts two families: traditional distillation from suitably treated feed, and membrane-based “cold WFI” built for biofilm resilience and continuous monitoring; where membranes are adopted, regulators expect enhanced control and defendable risk management.
ISPE’s Baseline Guide, Volume 4 remains the engineering playbook for both water and steam: it explains accepted solutions for separation, trapping, distribution, sampling and lifecycle management, and provides the language many inspectors expect to see reflected in designs and SOPs.
Storage and distribution: where quality is won - or lost
A high-spec skid cannot outrun a weak loop. Distribution should maintain hygienic hydraulics with steady recirculation, well-controlled velocities and minimal dead legs; pipework must drain and be maintainable. Thermally sanitised hot loops (typically 65–80 °C) deter biofilm; cold loops demand disciplined sanitisation (for example heat on RO, or ozone with controlled decay) and careful materials selection. Online conductivity and TOC at storage and critical points create actionable trending and alarm logic that mirrors the compendial tests while enabling real-time control. Together, WHO’s lifecycle guidance and ISPE’s engineering patterns provide the standard of care for these decisions.
What to test - and how to set limits
Regulators expect you to pass the pharmacopeial tests and to defend site-specific alert and action levels that make sense for your design capability. Conductivity tracks ionic contamination (per USP <645>), TOC tracks organic load (per USP <643>), and microbiology limits should reflect intended use (PW versus WFI) and historical performance. Endotoxin control is essential for WFI and any direct parenteral contact. The art is tying design ranges and routine trending to meaningful alerts, avoiding “surprise” excursions and whack-a-mole investigations.
Microbial control and biofilm thinking
Microbes exploit stagnation, nutrients and rough surfaces. Effective control blends hygienic design, validated sanitisation frequency, secure air breaks and disciplined hose and sampling practices at points of use. In hot systems the temperature does the heavy lifting; in cold systems the burden shifts to sanitants, materials and maintenance. WHO’s water GMP and ISPE’s utility guidance remain the most widely cited references for demonstrating that this control strategy is intentional, verified and repeatable.
Qualification, validation and the digital evidence trail
WHO’s annex lays out the lifecycle plainly: commissioning, IQ/OQ/PQ, routine monitoring and periodic review, with QA sign-off at each gate. Build a URS that anchors risk (for example ICH Q9 principles), trace design decisions to requirements, and maintain an audit-ready dossier - P&IDs, weld logs, FAT/SAT records, calibration, sanitisation histories and change control. ISPE’s Baseline Guide complements this with engineering-led patterns and change-friendly philosophies, which are invaluable when justifying loop temperatures, sanitisation intervals or added membrane stages to QA or regulators.
Common pitfalls - and how to avoid them
Over-specifying WFI where PW suffices wastes capital; under-specifying PW for high-risk cleaning invites deviations. Cold loops without a firm sanitisation regime drift into trouble. Testing without trending hides signal until it becomes an incident; integrating on-line conductivity and TOC with sensible alerts keeps control day-to-day rather than month-to-month. Above all, avoid documentation debt: if you cannot show the why (URS and risk) and the how (qualification and control), inspections will be harder than they need to be.
What changed with WFI in Europe - and why it matters
Allowing non-distillation WFI did not lower the bar; it shifted the burden to risk management and demonstrable control. If you pursue “cold WFI”, be ready with a robust contamination-control concept, continuous monitoring and a defendable sanitisation strategy. The EDQM’s revision notice and the EMA’s water guideline are the primary sources to cite in design reviews and regulatory correspondence; they continue to guide inspector expectations across the region.
A compliant, resilient water system is less about a shiny skid and more about joined-up design and disciplined operations. Use the pharmacopoeias to define what quality looks like, WHO/ISPE to define how you achieve and sustain it, and your data to prove you actually do. Keep those three aligned and audits get easier—and so does manufacturing.