V5 Ultimate
Radiopharmaceuticals · How V5 Runs

How V5 Ultimate runs a radiopharmaceutical production site, end to end.

Eleven decay-aware touchpoints — precursor receipt to conditional / final release and a clinical-site dispense — sharing one immutable ledger. Mapped to 21 CFR 212, 21 CFR 211 residuals, 10 CFR 35, USP <797> / <825>, EU GMP Annex 1 / Annex 3 and 21 CFR Part 11.

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21 CFR 212212.70(d)10 CFR 35USP <825>USP <797>EU GMP Annex 1ICH Q1021 CFR Part 11
ONE IMMUTABLE LEDGER21 CFR 212 · 212.70(d) · 10 CFR 35 · USP <825> · USP <797> · EU GMP Annex 1 · ICH Q10 · Part 1101Precursorapproved source02Cyclotronbeam log03Synthesismodule PLC04QCRCP + endotoxin05Conditionalrelease06Unit doseat calibration07Final releasesterility post-hocThe evidence chainEvery action signs the ledger — nothing is re-keyed at the end.
Executive summary

One ledger, every touchpoint — synthesis to clinical-site dispense, T0-aware.

V5 Ultimate runs a radiopharmaceutical site as one connected system. Cyclotron + synthesis module integration, kiosk-led dispense with decay-corrected activity at T0, conditional release pending sterility, RSO-owned radiation-safety program, and the full PQS all write to the same immutable, identity-verified ledger.

The pay-off is operational: batch records reviewed by exception in 15–25 min instead of hours, FDA pre-approval and NRC inspections supported as queries, and a recall trace that resolves as a query — forward and backward from any node, bounded only by physics.

This playbook walks you through 11 radiopharmaceutical touchpoints and the 17 PQS and radiation-safety modules that wrap them, grouped into 8 readable parts.

11
Touchpoints
8
Thematic parts
30+
Regulatory anchors
Part I

Foundations

Why decay-aware traceability is the spine, and the ten-node map.

01

Why decay-aware traceability is the product

A radiopharmaceutical isn't shelf-stable. Activity decays from the second synthesis ends. Every record — release, dispense, transport, administration — is bound to a calibration time T0.

Floor actionscan · weigh · e-sigactor + tsSTEP 01Append-only rowDB trigger writes oncesha256STEP 02Batch production record snapshotfrozen at releaseWO boundSTEP 03PDF renderfrom snapshot onlydeterministicSTEP 04Inspector packexported on demand21 CFR 11STEP 05ALCOA+ lineageAttributable · Legible · Contemporaneous · Original · Accurate · + Complete · Consistent · Enduring · AvailableOne origin event. No re-keying. No reconciliation.
ALCOA+ in one picture: one origin event, replayable downstream.

PET drugs live under 21 CFR Part 212 — a tailored cGMP that recognises radiopharmaceutical realities: short half-lives, conditional release pending sterility, decay-corrected accountability. Non-PET radiopharmaceuticals (Tc-99m generators, therapy isotopes such as Lu-177, Y-90, I-131, Ac-225) overlay 21 CFR 211, USP <825>, and state-of-the-art radiation-safety programs under 10 CFR 35.

The hazards that drive enforcement are unambiguous: dispensed activity outside the patient-dose tolerance at calibration, missed conditional-release sign-off, sterility failure on a batch already administered, unsealed-source contamination, exposure to a worker above NRC limits.

V5 Ultimate treats every synthesis run, every QC release, every dispense, every retroactive sterility sign-off, and every radiation-safety event as part of the same immutable ledger. Decay-correction is a property of the lot, not a spreadsheet.

Regulatory anchors
  • 21 CFR 212Current good manufacturing practice for positron emission tomography drugs
  • 21 CFR 212.70(d)Acceptance criteria — conditional final release pending sterility
  • 10 CFR 35NRC — medical use of byproduct material
  • USP <825>Radiopharmaceuticals — preparation, compounding, dispensing, repackaging
02

The end-to-end traceability chain at a glance

Ten touchpoints, one record. Read left-to-right. Every node writes to the same immutable ledger, with T0 stamped on every activity quantity.

  1. 01
    Supplier
  2. 02
    Receive
  3. 03
    Hot store
  4. 04
    Batch formula
  5. 05
    WO release
  6. 06
    Cyclotron + synth
  7. 07
    QC release
  8. 08
    OOS / CAPA
  9. 09
    Dispense + label
  10. 10
    Conditional / final
One immutable ledger underneath. Every node writes; nothing is re-keyed.

Every node carries forward precursor lot, target ID, isotope, T0, decay-corrected activity, operator, hot cell and synthesis module from the node before it. Nothing is re-keyed.

Part II

Materials in

Supplier qualification, target / precursor receipt, hot-cell storage.

03

Touchpoint 1 — Supplier and precursor qualification

Precursors, targets, cassettes, sterile filters and reference standards are the regulated heart of the batch. Wrong source = invalid batch.

Each precursor and target supplier is qualified per the approved batch formula. Substituting a supplier is a CMC change controlled through the batch formula change process. V5 holds the approved-source list per product and blocks goods-in from any other source.

Synthesis-cassette suppliers are qualified per module (e.g. GE FASTlab, Sofie ELIXYS, IBA Synthera, Trasis AllInOne) and per chemistry. Sterile-filter suppliers carry bacterial-retention certification (USP <797>). Re-qualification is calendar-driven and portal-led.

  • Precursor / target source locked to approved batch formula
  • Cassette + filter certification held per supplier × chemistry
  • REACH / DSCSA where applicable to precursor handling
  • Approved-supplier list filterable by chemistry × site × certification
Regulatory anchors
  • 21 CFR 212.40Receipt and verification of components
  • USP <797>Sterile compounding — supplier qualification for sterile components
04

Touchpoint 2 — Receiving, identity, hot-cell quarantine

Every precursor vial, every cassette, every target: weighed, scanned, identity-checked, contamination-surveyed, and locked to Quarantine until released.

The receiver scans the BOL, weighs against PO, captures the supplier lot and expiry, performs a contamination survey (where shipping is from another hot-cell facility), and stores the cassette in a controlled environment. V5 mints a goods-receipt lot ID at that moment. Until QC releases against the registered specification, the lot is Quarantine.

Identity verification is component-specific: GC / HPLC assay for precursors that allow it, certificate-of-analysis review for cassettes and filters, source-strength survey for sealed sources. Results link to the receipt lot, instrument, analyst e-signature and supplier CoA.

  • Goods-receipt lot ID minted at the dock
  • Contamination survey results bound to receipt lot
  • Cassette expiry surfaced at receipt and at synthesis-step pick
Regulatory anchors
  • 21 CFR 212.40(b)Components — verification of conformity to specifications
  • 10 CFR 20.1906NRC — procedures for receiving and opening packages
05

Touchpoint 3 — Hot-cell, refrigerator and shielded-store status

Locations are not just shelves. They are zones with shielding, temperature, contamination class, and release status.

V5 maintains location attributes: shielding class, contamination zone (controlled / restricted), temperature band, and release status. The pick list shown to the synthesis operator only includes components with current release status and unexpired stability. FEFO is enforced; overrides require reason + dual e-sig.

  • Hot-cell, refrigerator, shielded store as first-class location types
  • FEFO enforced for short-stability components
  • Parent/child lot genealogy from precursor to unit dose
Regulatory anchors
  • 21 CFR 212.40Components — handling and storage
  • 10 CFR 20 Subpart FNRC — surveys and monitoring of restricted areas
Part III

Synthesis & execution

Approved batch formula, work-order snapshot, kiosk-led cyclotron run + synthesis module.

06

Touchpoint 4 — Approved batch formula = the registered synthesis

The batch formula is the approved synthesis. In V5 it's a versioned, signed, machine-readable record bound to the FDA submission (ANDA / NDA / IND) and to the cassette and module.

Each formula holds: drug substance, drug product, route (PET / SPECT / therapy), cyclotron target conditions, synthesis module + cassette ID, precursor BOM, in-process control plan (radiochemical identity, radiochemical purity, chemical purity, residual solvent, pH, appearance, bacterial endotoxin), final-product specification, filter integrity test, container-closure spec, and the registered label artwork.

Effectivity is two-signature: the formulator signs the change, the QA/Authorised Person signs that the change is within the registered batch formula (or that a CBE / amendment has been filed). New work orders pick up the new revision; in-flight work orders keep the snapshot they were released against.

  • Cassette + module + chemistry locked at the formula level
  • Bubble-point / filter-integrity spec inside the formula
  • Endotoxin limit per administered-dose volume calculated and recorded
  • Label artwork locked to formula revision
Regulatory anchors
  • 21 CFR 212.50Production and process controls
  • 21 CFR 211.100Written procedures; deviations — applicable as residual cGMP
07

Touchpoint 5 — Work-order release as a snapshot

Releasing a synthesis takes a snapshot of the batch formula. From that moment the batch carries its own copy — frozen forever.

Approved batch formula v3.2BOM · Routing · IPCSpec · LabelEFFECTIVE · 2-SIGSNAPon releaseWO-2026-0418Bound to Approved batch formula v3.2Frozen at releaseRELEASED · sha256:a4f9…runs even ifApproved batch formula revisesBatch production record (this batch)Filled by kiosk+ IPC + dev + sigsIMMUTABLEApproved batch formula v3.3 (later revision)does NOT affect WO-2026-0418
The WO carries a frozen copy of Approved batch formula v3.2. Later revisions don't disturb this batch.

If the batch formula is revised mid-shift, the work order keeps the snapshot it was released against. The auditor sees exactly the synthesis this batch was built to, with the sha256 of the snapshot recorded against release.

Regulatory anchors
  • 21 CFR 212.110Records — production, process control, laboratory
  • 21 CFR Part 11Electronic records and signatures
08

Touchpoint 6 — Kiosk-led cyclotron + synthesis + dispense

The kiosk is the floor's single pane of glass. Every cyclotron parameter, every synthesis-module event, every dispense is signed and timestamped with T0.

Cyclotron parameters (beam current, irradiation time, target pressure / temperature) stream into the work order. The synthesis module's PLC sequence is recorded step-by-step. End-of-synthesis activity is captured by the dose calibrator, decay-corrected to T0, and bound to the lot.

Dispense to unit doses is at calibration time: each vial / syringe is labelled with patient ID (where applicable), activity at calibration, calibration time, volume, expiry, and lot. Mis-pick at dispense (wrong patient, wrong activity, expired lot) hard-stops the step.

  • Cyclotron parameter stream captured per run
  • Synthesis-module PLC events captured step-by-step
  • Dose calibrator data bound to lot, decay-corrected to T0
  • Unit-dose dispense hard-gated by activity and expiry
Regulatory anchors
  • 21 CFR 212.60Laboratory controls — equipment, methods
  • USP <825>Radiopharmaceuticals — dispensing and labelling
09

Touchpoint 7 — In-process and finished-product QC under decay pressure

QC tests run in real time alongside synthesis. The compendial radiochemical-purity test, the residual-solvent GC and the bacterial endotoxin test all stream back to the work order.

Radio-TLC / radio-HPLC for radiochemical purity, GC for residual solvent (acetonitrile, ethanol, DMSO depending on chemistry), pH, appearance, filter bubble-point, half-life confirmation, bacterial endotoxin (LAL or rapid-method) — all scheduled by the work order. Sterility (USP <71>) is post-release: the lot is released conditionally and the sterility sign-off is retroactive.

Regulatory anchors
  • 21 CFR 212.70(d)Acceptance criteria — conditional final release
  • USP <71>Sterility tests — applied to radiopharmaceuticals retroactively
  • USP <85>Bacterial endotoxins test
Part IV

Quality events

OOS, conditional-release exceptions, recalls — one queue.

10

Touchpoint 8 — Deviations, OOS, and CAPA in one queue

Every event lands in the same queue — OOS radiochemical purity, failed bubble-point, dose-calibrator excursion, contamination-survey hit, sterility failure on a conditionally released lot.

A single register categorises by event type. Sterility failure on a released lot triggers a defined patient-notification workflow and is a reportable event. Root-cause uses the structured fields the auditor expects.

Regulatory anchors
  • 21 CFR 212.71Investigation of failures
  • 21 CFR 803Medical device reporting — adjacent for diagnostic context
Part V

Dispense to patient

Unit-dose at calibration, retroactive sterility sign-off, transport.

11

Touchpoint 9 — Unit-dose labelling, transport, retroactive sterility sign-off

The label is the regulated record. V5 prints from the formula and the dose-calibrator reading at calibration — never from a Word document.

Per-unit-dose labels carry: patient ID (or 'patient-pending'), drug substance, activity at calibration, calibration time, volume, expiry, lot, syringe shield ID, NRC permit conditions, and DOT shielding category for transport. The retroactive sterility sign-off, when it arrives, is appended to the same batch record and visible to the clinical site through the portal.

  • Per-dose activity printed at calibration time — decay math is automatic
  • Patient-specific labelling where pre-dispensed; otherwise patient-pending
  • Retroactive sterility sign-off appended to the same batch record
Regulatory anchors
  • USP <825>Radiopharmaceutical labelling and dispensing
  • 49 CFR 173.421–173.427DOT — radioactive material shipping
12

Touchpoint 10 — Conditional release and final release

QA's first release is conditional pending sterility. QA's second release closes the loop once USP <71> completes. Both signatures live in the same record.

Conditional release authorises dispense and administration on the basis of every cGMP test except sterility. Final release on completion of sterility either closes the loop or triggers the failure workflow. Both signatures are identity-verified, both bound to the snapshot.

Regulatory anchors
  • 21 CFR 212.70(d)Conditional final release
  • 21 CFR 212.70(e)Final release — completion of sterility testing
13

Touchpoint 11 — Distribution and recall in seconds

Recall is a query, not a project. Forward from a precursor lot, backward from a dispensed dose at a clinical site.

Recall / withdrawal lookback timelineFrom trigger to drafted regulator report — measured in minutes, not weeksT+0sSterility failQA flips lotSTEP 01T+12sBackward tracePrecursor · cassette · synthSTEP 02T+38s100% doses foundSite · syringe · timeSTEP 03T+90sClinical sites pushPortal + phone treeSTEP 04T+8mFDA / NRC draftAuto from ledgerSTEP 05Bidirectional from any node — unit ⇄ case ⇄ pallet ⇄ batch ⇄ lot ⇄ supplier
One ledger, one query. Forward and backward from any node.

Every unit dose is shipped against a manifest that carries the lot code and the clinical site. When a recall trigger fires — sterility failure, dose-calibrator out-of-tolerance back-look, precursor recall — V5 walks the ledger in both directions in seconds: every dose made from this synthesis, every clinical site, every patient (where pre-assigned).

For short-half-life PET drugs the practical recall window is bounded by physics; V5 still records the trace and the notifications.

Regulatory anchors
  • 21 CFR 7.40–7.59FDA recall guidelines
  • 10 CFR 35.27NRC — reports of medical events
Part VI

Quality system

PQS, documents, training, management review, NRC + FDA inspections.

14

Pharmaceutical Quality System — ICH Q10 as a live object

Q10 is the operating shell around the Part 212 work. V5 holds it as a structured, signed, live record.

Quality manual, process performance, product quality monitoring, CAPA, change management, management review — all structured workspaces, not Word documents.

Regulatory anchors
  • ICH Q10Pharmaceutical Quality System
  • 21 CFR 212.20Personnel and resources
15

Document control — controlled, versioned, two-signature

Every SOP, work instruction, batch formula, validation report, NRC license condition and policy is a controlled record.

Draft → Review → Approved → Effective → Periodic Review → Superseded / Retired. Two qualified signatures effect every release. Operators see only the effective revision; superseded revisions are retained per 21 CFR 212.110 retention rules.

Regulatory anchors
  • 21 CFR 212.110Records — retention
  • ICH Q10 §3.2Documentation
16

Training and competency — Authorised User / Authorised Nuclear Pharmacist gated

If your NRC qualification or your competency for the synthesis step is not current, the kiosk won't let you advance it.

V5 maintains a training matrix per role × isotope × module. NRC Authorised User / Authorised Nuclear Pharmacist status is a bounded credential; an expired or out-of-scope status locks the operator out of the relevant kiosk action.

Regulatory anchors
  • 10 CFR 35.50 / 35.55NRC — training for authorised users and authorised nuclear pharmacists
  • 21 CFR 212.10Personnel qualifications and training
17

Management review — assembled continuously, signed quarterly

Management review is not a 4-week scramble. V5 assembles it continuously from the ledger.

Management Review — continuous compilationEvery batch, IPC, OOS, deviation and complaint feeds the review as it happensJanbatch · IPCFebbatch · IPCMarbatch · IPCAprbatch · IPCMaybatch · IPCJunbatch · IPCJulbatch · IPCAugbatch · IPCSepbatch · IPCOctbatch · IPCNovbatch · IPCDecbatch · IPCManagement ReviewTrends · CpK · OOS · CAPAStability · Complaints · PVICH Q10 §3.2.5CpK trend chartOOS / CAPA registerStability projectionSigned review PDF
Management Review assembles continuously — not a 4-week scramble at year end.

Every batch's quality signals, every CAPA, every conditional / final release statistic, every NRC event, every customer complaint — all stream into the management-review workspace as they happen.

Regulatory anchors
  • ICH Q10 §3.2.5Management review
18

Internal audits, FDA inspections, NRC inspections

Audits land in the same queue as deviations. Findings drive CAPAs; CAPAs drive effectiveness checks.

V5's audit module schedules internal audits, FDA pre-approval and surveillance inspections, NRC inspections, and Agreement-State inspections. When the inspector arrives, the request list is a query.

Regulatory anchors
  • 21 CFR 212.110(b)Records to be inspected
  • 10 CFR 35.2024NRC — records of authority and responsibilities
Part VII

Radiation safety & ops

Radiation safety program, ALARA, equipment, hot cell, sanitation, complaints.

19

Radiation Safety Program — RSO-owned, V5-anchored

The Radiation Safety Officer's program is held in V5: permits, license conditions, area surveys, leak tests, exposure records.

Sealed-source inventory, leak tests, area-survey schedule, personal dosimetry data import, ALARA reviews — all structured workspaces. Reportable events (10 CFR 20 / 35) auto-open the relevant notification timer.

Regulatory anchors
  • 10 CFR 20Standards for protection against radiation
  • 10 CFR 35.24 / 35.26RSO duties; written directives
20

ALARA and personal dosimetry

Per-worker dose is monitored, trended and reviewed.

Dosimetry results import into V5, get associated to the worker, the task, the hot cell. ALARA targets and investigation levels are configurable; an excursion opens a CAPA and routes to the RSO.

Regulatory anchors
  • 10 CFR 20.1201Occupational dose limits for adults
  • 10 CFR 20.2102Records — occupational doses
21

Sanitation, environmental classification, sterile area control

Aseptic processing areas are classified, monitored and signed.

V5 holds sanitation procedures per zone × equipment, with frequency, agent, contact time and verification. Aseptic-area particle counts, viable air, surface plates and personnel monitoring are scheduled and trended per EU GMP Annex 1 / USP <797>.

Regulatory anchors
  • EU GMP Annex 1Manufacture of sterile medicinal products
  • USP <797>Pharmaceutical compounding — sterile preparations
22

Equipment and calibration — cyclotron, dose calibrators, well counters

Every instrument that touches activity has a calibration schedule, a reference source, and an out-of-tolerance procedure.

Dose calibrators (constancy, linearity, accuracy, geometry per NRC), well counters, survey meters, HPLC, GC, particle counters — each is a tracked asset with calibration interval, certificate, tolerance, and an out-of-tolerance impact-assessment that triggers a back-look.

Regulatory anchors
  • 10 CFR 35.60Possession, use, and calibration of instruments to measure dosages
  • 21 CFR 212.60Laboratory controls — equipment
23

Environmental and contamination monitoring

Hot-cell surface contamination, hood and pass-box surveys, removable-contamination wipes — all scheduled and trended.

Sample sites, frequency, action and alert limits, and corrective actions on a positive (decontamination, hold, re-survey) are all scheduled and tracked.

Regulatory anchors
  • 10 CFR 20 Subpart FSurveys and monitoring
24

Complaints — every report links to a lot

A clinical site reporting a flushed-syringe reading inconsistent with calibration, a contamination event at delivery, a packaging defect — each is a complaint tied to a lot on intake.

Intake captures lot, calibration time, site, observed issue, severity, patient outcome. V5 binds the complaint to the batch and surfaces adjacent batches.

Regulatory anchors
  • 21 CFR 212.100Complaint handling
Part VIII

Compliance & onboarding

Part 11 evidence, customer surface, onboarding, regulatory matrix.

25

21 CFR Part 11 — a property of the ledger

Part 11 isn't a module. It's a property of how V5 writes every record.

Every signed event carries the actor's verified identity, signature meaning, time, and a sha256 of the record. The signature row is append-only. PDF renders are deterministic from the snapshot.

Regulatory anchors
  • 21 CFR Part 11Electronic records and signatures
  • ALCOA+Data-integrity principles
26

Customer experience — clinical-site portal, CoA, final-release notice

Clinical sites query the ledger through a scoped portal.

CoAs per lot, conditional and final release sign-offs, dose-calibrator constancy data, transport documentation — all on the portal. Audit-trail of who accessed what is automatic.

27

Onboarding and support — weeks, not quarters

V5 ships pre-configured for a typical PET production site: 21 CFR 212 templates, NRC-permit model, EU GMP Annex 1 overlay.

A typical site onboards in 6–10 weeks: master data import, batch-formula migration, cyclotron + module integration, kiosk training, parallel-run validation, cutover. The validation pack (URS → IQ → OQ → PQ) is built in.

28

Regulatory matrix — every clause, every touchpoint

Where every clause lands in the V5 product surface.

Abbreviated mapping. Each link opens the full readiness guide.

RegulationScopeTouchpointsGuide
21 CFR 212cGMP for PET drugs — full SubpartsAll
21 CFR 212.70(d)Conditional final release pending sterility09, 12
21 CFR 211Residual cGMP elements for non-PET radiopharmaceuticalsAll
10 CFR 35NRC — medical use of byproduct material03, 16, 19, 20, 22
10 CFR 20NRC — radiation protection19, 20, 23
USP <825>Radiopharmaceuticals — preparation, compounding, dispensing08, 11
USP <797>Pharmaceutical compounding — sterile preparations03, 21
USP <71>Sterility tests09
EU GMP Annex 1Manufacture of sterile medicinal products21Read →
ICH Q10Pharmaceutical Quality System14Read →
21 CFR Part 11Electronic records and signatures07, 08, 12, 25Read →

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