This manuscript reviews the history of terminal sterilization regulation and process expectations. Practices for this culminated in the EMA / PIC/S Decision Trees (EMA/CHMP/CVMP/QWP/850374/2015, March 2019) which outlines recommended process choices for steam and other sterilization methods. That guidance document is contrary to the recommendations included in USP Sterilization of Compendial Materials. This manuscript supports a preference for the more flexible approach to sterilization cycle development and validation provided in the USP general chapter.
James Agalloco (Wed,) studied this question.