Saxsons Group

Radiopharmacist's Notes · FLEX™ Dispensing Hot Cell

A cyclotron radiopharmacy runs under four overlapping rule-sets. The dispensing isolator sits where all four meet.

Annex 3 covers the radiopharmaceutical manufacture; Annex 1 covers the sterile dispensing step; Annex 11 covers the LIMS and audit trail; the AERB cyclotron-facility document covers Indian site licensing. The FLEX dispensing isolator is the node where they all converge — configured to the 100 mm Pb Indian cyclotron norm, Grade A inside the box, closed-system dispensing, audit-trail-friendly controls. This page maps the requirement set against the FLEX feature set with every row cited.

The four rule-sets the dispensing isolator has to clear

Each card is a published standard or regulator document; each defines a separate compliance surface the dispensing isolator has to face.

Annex 3

Radiopharmaceutical manufacture

The cyclotron + synthesis + QC + dispensing chain. Grade C is allowed inside a closed, automated synthesis hot-cell — dispensing for injection still hands off to Annex 1.

EU Commission, EudraLex Vol. 4 Annex 3 (PIC/S PE 009 mirror).

Annex 1

Sterile dispensing inside the isolator

Revised 2022, in force 2023-08-25. Grade A inside the dispensing isolator is the expected minimum. Site-wide Contamination Control Strategy (CCS) is mandatory.

EU Commission, EudraLex Vol. 4 Annex 1 (rev. 2022).

Annex 11

LIMS, audit trail, data integrity

In-force text governs validation, audit trails and ALCOA+ data integrity of the cyclotron-site computerised systems — the dispenser's touch-screen control PC is one node. Annex 11 revision is in EMA consultation (2025).

EU Commission, EudraLex Vol. 4 Annex 11; EMA concept paper, 2025.

AERB 2017

Indian cyclotron facility licensing

AERB Regulatory Requirements & Guidelines for Medical Cyclotron Facility (2017) — Atomic Energy (Radiation Protection) Rules 2004 licensing path. Self-contained controlled radioactive area + automatic dose-dispensing unit required.

AERB (India), 2017.

Requirement → FLEX feature

Each row maps a specific requirement from the GMP / AERB stack onto a documented FLEX feature. Source for each map cited inline.

01

100 mm Pb shielding (Indian cyclotron-site norm)

FLEX is configured at 100 mm Pb all sides for Indian cyclotron sites — supplied by Saxsons. The manufacturer baseline on the Manufacturer product page is 75 mm; the India-configured build is the 100 mm variant.

Source: Saxsons Group configuration for the Indian market. FLEX product page (75 mm baseline).

02

Grade A working area inside the dispensing isolator (Annex 1)

Vertical laminar flow across the working area — marketed as a "GMP Grade A shielded isolator" on the Manufacturer product page.

Source: FLEX product page.

03

Closed-system aseptic dispensing of sterile injectables (Annex 1 + Annex 3)

Optional µ DDS-A automatic dose-drawing — closed-vial dispensing via septum piercing, open-vial dispensing via integrated crimping station, and shielded syringe dispensing. CRP vial dispenser option for automated PET unit-dose workflow.

Source: FLEX product page — µ DDS-A and CRP descriptions.

04

Audit-trail-friendly control system (Annex 11 / ALCOA+)

Touch-screen operational panel for dispensing parameters and batch logging. Remote teleassistance for aftersales support without a console-side install. The LIMS integration itself is the cyclotron site's responsibility — the manufacturer does not publish a turnkey LIMS module.

Source: FLEX product page; EU GMP Annex 11 §9 (audit-trail requirement).

05

Terminal sterilisation where the product tolerates steam

Optional AUT 1500 autoclave — available as an integrated accessory for a dispensed-then-sterilised workflow.

Source: FLEX product page — AUT 1500 description.

06

Container retrieval without breaking the Grade A barrier

Automatic shielded-container retrieval from front, back or sides — vial extraction integrated with the isolator body.

Source: FLEX product page — vial extraction system.

What the isolator does not do for you

The GMP and AERB stack is a programme, not a piece of equipment. The FLEX gives you a compliant dispensing node; the cyclotron operator still owns the rest.

  • Site-wide Contamination Control Strategy (CCS) document — Annex 1 §2
  • Validated LIMS / batch-record / e-release workflow per Annex 11 + GAMP 5
  • Environmental monitoring programme (viable + non-viable particle counts)
  • Operator gowning, aseptic-technique qualification + retraining records
  • Shielding-integrity tests, HEPA-filter validation, leak-rate testing on a defined cadence
  • AERB site licence under the Atomic Energy (Radiation Protection) Rules 2004

Sources: EU GMP Annex 1 (2022 revision); EU GMP Annex 11; AERB 2017 Regulatory Requirements; WHO TRS 1025 Annex 2.

What's on the regulatory horizon

Two live workstreams a cyclotron radiopharmacy should track when buying capital today:

  • Annex 11 revision (EMA concept paper, in consultation 2025) — the next revision will tighten audit-trail, data-integrity and risk-based-validation language. A dispenser with a documented touch-screen + remote-teleassistance trail is easier to validate than a non-recording one.
  • Theranostic expansion (Lu-177 PRRT / PSMA) — cyclotron sites that today only run F-18 are increasingly adding Lu-177 dispensing. An isolator sized for both today avoids a second capital purchase when the programme expands.

Sources: EMA concept paper on Annex 11 revision (2025); joint EANM/SNMMI/IAEA theranostics-centre enabling guide.

Scope of this page

We do not claim "FLEX is GMP-certified" — Annex 3 / Annex 1 / Annex 11 / AERB are programme-and-facility frameworks, not equipment certifications. The manufacturer designs the FLEX against these requirements; the GMP licence and AERB consent sit with the cyclotron operator. The 100 mm Pb Indian-site shielding figure is a market-practice norm — the AERB 2017 document defines the licensing path and self-contained-area requirement, but does not publish a single isolator-thickness number that we could quote verbatim.

Sources cited on this page

  • European Commission. EudraLex Vol. 4 Annex 3 — Manufacture of Radiopharmaceuticals. PIC/S Annex 3 PDF ↗
  • European Commission. EudraLex Vol. 4 Annex 1 — Manufacture of Sterile Medicinal Products. Revised text, fully effective 2023-08-25. EC text ↗
  • European Commission. EudraLex Vol. 4 Annex 11 — Computerised Systems. In-force text; revision in EMA consultation (2025 concept paper). Annex 11 PDF ↗
  • Atomic Energy Regulatory Board (India). Regulatory Requirements and Guidelines for Medical Cyclotron Facility. AERB, 2017. AERB PDF ↗
  • World Health Organization. WHO TRS 1025 Annex 2 — joint IAEA/WHO GMP for radiopharmaceutical products. 2020. WHO ↗
  • the manufacturer. FLEX — GMP Grade A shielded dispensing isolator. Manufacturer product page. temasinergie.com ↗