Last updated: 2 Sep 2026 | 61 Views |
In cosmetics and supplement manufacturing, everything hangs on a single microbiological result. When it fails, the damage does not stop at the batch. It reaches the client, the brand, and certifications that took years to earn.
Theerawat is quality assurance manager at a mid-sized contract manufacturer of cosmetics and dietary supplements in Samut Prakan, producing for around 40 Thai brands.
The plant had held GMP certification for five years, with environmentally controlled compounding and filling rooms, air filtration, a two-stage gowning area, and thoroughly documented cleaning procedures.
The problem began in June. A 12,000-unit batch of skin cream for one client returned a total microbial count above the specification limit.
Theerawat says the team's first assumption was a laboratory error, so they retested twice, with two different laboratories. Both came back the same.
So they worked backwards. Every raw material was retested and passed. Process water was tested and passed. Equipment and mixing vessels were swabbed after cleaning and also passed.
Everything passed. The product did not.
The turning point came from a quality consultant the company brought in. He asked to place settle plates in the filling room during actual production, and to swab surfaces that did not appear on the routine cleaning schedule.
Two weeks later the results came back. The settle plates from the filling room showed counts clearly higher than they should be, and the positive swab sites were: the supply air diffuser face, behind the conveyor's electrical control cabinet, underneath the conveyor, the door seal of the gowning room, and the overhead beams in the filling room.
That, Theerawat says, was when he understood his problem.
The plant cleaned product-contact surfaces superbly. Mixing vessels, pipework, filling nozzles, containers - all with clear procedures and complete records.
But non-product-contact surfaces - ceilings, beams, upper walls, behind electrical cabinets, under conveyors and inside vents - barely existed in the system at all. Yet whatever accumulates on those surfaces has a direct path down onto product being filled below.
The cost of the incident was easy to calculate. The 12,000-unit batch had to be destroyed, over a million baht in materials and labour. The client had to postpone a launch campaign by two months and claimed partial compensation.
Worse, three other brands who heard about it immediately requested unscheduled audits, and one of them put its next production order on hold.
What kept Theerawat awake, he says, was that he had no answer for clients on how it would be prevented from happening again - other than saying they would clean more often, which he knew perfectly well was not a sufficient answer.
Microbiological control in cosmetics and supplement manufacturing has characteristics that make this problem recur easily unless the real root cause is addressed.
Most quality systems prioritise direct product-contact surfaces first, which is correct - but it tends to push everything else far down the priority list.
The difficulty is that ceilings, beams, upper walls, vent faces and conveyor undersides sit above or immediately beside the point where product is open during filling. Whatever accumulates there has a direct route down into the product.
And these surfaces are hard to reach, high up, require ladders, and require stopping the line - so the work keeps getting deferred.
Deep cleaning a production room means stopping the line, which has a direct cost. In a contract manufacturer with a full order book, finding a two-day window for a major clean is extremely difficult.
The result is that many plants deep clean only quarterly or twice a year - far too long an interval for a space people enter every day.
On top of that, wiping high surfaces from ladders inside a cleanroom risks stirring dust into the air while the work is being done.
A contract manufacturer has dozens of client brands sharing the same production space. When one batch fails, the confidence impact is not limited to that client.
Other clients immediately request unscheduled audits, which consumes team time and creates opportunities for further findings.
And in this industry, news travels very fast among brand owners who know each other.
Cosmetics with microbial counts above specification can cause irritation, rashes or skin infection, particularly around the eyes or on broken skin.
For dietary supplements the risk is illness from direct consumption, potentially leading to recall and legal action.
Theerawat is emphatic that the real reason to get this right is not fear of clients or auditors. It is that at the end of the chain is a person putting the product on their face or swallowing it.
After the incident Theerawat's team tightened everything they could, and found the conventional methods had a clear ceiling.
What the consultant recommended adding to the system was an area disinfection step covering surfaces from every direction, including places people cannot reach, achievable in a short window between shifts without ladders and without a multi-day line stop.
That is ULV - Ultra Low Volume - fogging, which fills the room volume with an enormous number of micron-scale disinfectant droplets that settle on surfaces from every direction: above, below, beside, and in shadow - which neither wiping nor UV can do.
The Airofog U260 is a German-built ULV fogger producing 15-30 micron droplets, well matched to production room work because droplets that size genuinely fill the room volume, reach beams, ceilings, diffuser faces and the gaps behind equipment, then dry quickly without leaving standing water on surfaces or equipment.
What makes it fit a busy plant is speed. A 200 square metre filling room takes roughly 12 to 15 minutes, which slots into a shift changeover or the end of the production day - turning area disinfection from a quarterly event into a daily or weekly routine.
Almost all the positive sites in this case were above reach. Wiping them requires ladders and a line stop. Micron droplets fill the room volume and settle on those surfaces on their own, with nobody climbing - far safer and far faster.
UV systems have a fundamental limitation: they act only on surfaces in direct line of sight. Behind electrical cabinets, under conveyors, inside vents and in the gaps between machinery and walls are all in shadow. ULV droplets travel with the air and reach them.
This is the biggest constraint for a contract manufacturer with a full book. A 200 square metre filling room takes 12 to 15 minutes, achievable at changeover - so frequency rises from quarterly to daily or weekly in practice.
Droplet size decides whether you get whole-room coverage or only local coverage. Droplets that are too large fall immediately and treat only where you point. The 15-30 micron range stays airborne long enough to distribute through the room volume before settling.
The positive sites in this case included behind the electrical control cabinet and under the conveyor - narrow gaps a cloth cannot reach and equipment that cannot be dismantled for cleaning. The hose lets an operator fog directly into them.
Filling rooms with electronics and conveyors need a light, fast-drying application. Raw material stores, gowning rooms and corridors tolerate more. Six settings mean one machine serves the whole plant.
Cosmetics and supplement work has strict requirements on chemical type and residue. The U260 accepts many chemistries, so QA can select a documented formulation consistent with the plant's quality system.
At audit, inspectors want equipment documentation, chemical documentation and completed records. The Airofog U260 carries certification from Thailand's Department of Medical Sciences, Department of Health and the Faculty of Medicine at Mahidol University, plus WHO, TUV Rheinland and IPARC.
A plant has several rooms to treat in a round - compounding, filling, gowning, packaging store. A light machine lets one operator complete them without stopping, and is easy to handle in cleanroom garments.
The single destroyed batch in this case exceeded a million baht, before compensation and the delayed production order. Against the price of one high-quality fogger, the decision takes no time at all.
Theerawat says the most valuable outcome is not the table. It is being able to present a concrete, documented measure at a client audit, instead of saying only that the team will be more careful.
Plants that successfully bring this into the quality system make it a documented, measured procedure rather than an optional extra done when there is time.
Step 1: Establish a baseline with settle plates and swabs first
Place settle plates in production rooms during actual production, and swab surfaces that are not in the system - beams, diffuser faces, behind cabinets, under conveyors - so you know where the problem is before you fix it.
Step 2: Write the procedure into your quality documentation
Produce a work instruction specifying areas, walking order, nozzle setting, chemical and dilution, contact time, and re-entry time, so auditors can see it is part of the system rather than an ad hoc activity.
Step 3: Set frequency by room criticality
Filling rooms where product is open should be treated daily after production; compounding and packaging stores weekly; corridors and gowning areas weekly.
Step 4: Always fog after routine cleaning, never instead of it
The ULV pass is a final layer following your existing mechanical cleaning, not a replacement. Visible soil and residues must be removed first for disinfection to be fully effective.
Step 5: Cover or remove all open product and materials
Make it a rule that no open product or raw material is in the room during a pass, and that conveyors and filling nozzles are covered as specified in the work instruction.
Step 6: Record it in the same format as your existing GMP documents
Log date, room, chemical and dilution, contact time, operator and verifier, in the same table format as your existing cleaning records, which auditors already know how to read.
Step 7: Verify monthly with settle plates and review at quality meetings
Place settle plates at the same points each month to prove the system still works, and take the results to the quality review meeting - trend data is what auditors and clients weigh most heavily.
For cleanroom work the decisive specifications are the 15-30 micron droplet size, which fills the room volume and reaches high surfaces without ladders, and the 50 cm gooseneck hose that reaches behind cabinets and under conveyors.
“For five years we tested everything that touches product, in detail. Then it turned out that not one of the positive sites touched product at all. They were on beams, in vents and behind cabinets.”
“The consultant said to me: if the contamination is where people cannot reach, you need something that does not require people to reach it. I understood immediately. We ran a first pass in the filling room with settle plates before and after, and the difference was unmistakable.”
“We now fog the filling room every day after production - twelve to fifteen minutes - and the whole plant weekly. We have had no failed batches in the past year, and when a client audits us I have the work instruction, the historical records and monthly settle plate results to show them.”
— QA manager, contract cosmetics and supplement manufacturer, Samut Prakan (name withheld)
If the contamination is where people cannot reach, you need a tool that does not depend on people reaching it.
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The World Health Disinfection team is happy to advise you before you decide, at no cost, and can prepare a quotation and the documents your procurement process needs.
Can ULV fogging replace our existing cleaning procedure?
No, and it should not. ULV fogging is a disinfection layer applied after your existing mechanical cleaning, because visible soil and residues must be removed first for disinfection to be fully effective.
How long does a 200 square metre filling room take?
About 12 to 15 minutes in practice, including walking every zone and concentrating on risk points such as diffusers and conveyor undersides - which fits a shift changeover.
How long before the room can be re-entered?
It depends on the chemistry and the room's ventilation, typically 20 to 30 minutes. Specify this clearly in the work instruction and enforce it strictly.
Will the fog damage filling equipment or electrical systems?
Use the lowest nozzle setting near control cabinets and electronics, or cover them as specified in the work instruction. At an appropriate setting, 15-30 micron droplets dry quickly and leave no standing water.
How does it differ from a fixed UV installation?
UV acts only on surfaces in direct line of sight, so shadowed areas - behind cabinets, under conveyors, inside vents - receive no effect at all. ULV droplets travel with the air and reach shadowed areas. The two complement each other well.
Is the documentation usable in GMP or client audits?
Yes. The Airofog U260 carries certification from Thailand's Department of Medical Sciences, Department of Health and the Faculty of Medicine at Mahidol University, plus WHO, TUV Rheinland and IPARC, supporting your quality system file. The team can assemble the pack.
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