CAPA GMP REVIEW


This graphic used in the CAPA GMP Review page is the city of Montreal Skyline.

Introduction to CAPA

Are CAPA Reviews being regularly used?  If so; why is it that Corrective and Prevention action procedures continue to be a major source of 483 observations. The majority of companies claim to have fully functioning systems in use and yet FDA audits regularly find these systems are either partially or incorrectly used.  How can companies proactively address these regulatory deficiencies?



CAPA Review Rationale.

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The FDA and regulators world-wide require manufacturers of pharmaceutical, biological and medical devices not only to have a procedure (CAPA) in use; but to regularly execute reviews that will identify,  instigate investigation, and report on deficient or failure within the system. These compliance reviews and all relevant records of compliance verification should be retain for regulatory review.  

Having such a system recording and instigating investigation into all reported defects not only helps companies fulfill their regulatory obligations, but also helps prevent new problems from arising, and known problems from re-occurring.  Poor CAPA systems remain one of the top problem areas for both the drug and device industries when it comes to FDA inspections. And citations account for more than 50 percent of FDA warning letters.

This CAPA review document has been prepared to enable your system to be easily assessed for compliance with the requirements.  As part of the CAPA functionality, individual users complete action tasks by providing input and/or results, and managers approve the overall CAPA process. Similarly, the CAPA review process enables quality managers to schedule audits and track their progress and results. Individual contributors can provide responses, enabling the entire team to multi-task and facilitate an in-progress review. Quality Improvement Central is intended to provide a powerful, yet simple solution for managing quality while maintaining tight process inter-operability with other aspects of the product life-cycle.


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Management Involvement.

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Management must ensure and be involved in a review and confirmation that actions taken were effective and did not introduce new issues or concerns. The following questions should be considered at appropriate times throughout the process and be revisited in the final review:

  • Has the problem been comprehensively identified?
  • Have the root cause/contributing factors of the problem been identified and  addressed?
  • Has the improvement action(s) been defined, planned, documented, verified and implemented?


    CAPA Defined (ICH Q9 & 10)

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    A structured approach to the investigation process should be used with the objective of determining the root cause.

    The level of effort, formality, and documentation of the investigation should be commensurate with the level of risk, in line with ICH Q9.

    CAPA methodology should result in product and process improvements and enhanced product and process understanding.

    Please note.

    ICH Q9 & Q10; are not intended to create any new expectations beyond current regulatory requirements. Consequently, the content of ICH Q9 & 10 that are additional to current regional Good Manufacturing Practice (cGMP) requirements are optional.



    CAPA REVIEW.



    Combined IQ-OQ-PQ Computer (Issue-4) $159.00

    This Pharmaceutical Validation combination protocol has been produced in response to several hundred reader suggestions we received in our ‘Suggestions Section’. It has been carefully designed to make it the preferred choice for Process and Laboratory stand alone equipment and associated standard operating procedure TEMPLATE. The associated medical device validation  Master Plan template is interactive, easy to use and suitable for all mixes of equipment with and without software. Where temperature mapping is required it will included in this section. This of course may well be a validation A Plan template. As per 21 CFR Part 11.

    The Installation Qualification Template section establishes documented verification that all medical device validation template online executables are catered for and that key aspects of the equipment Qualification adhere to approved design Qualification template and the recommendations of the manufacturer have been suitably considered. The Operational Qualification Template section establishes that there is documented verification that the installed system functions as specified and that there is sufficient documented process validation A executables to demonstrate this. The PQ section develops documented evidence that all the requirements specified in your corporate validation 4U manual have been verified as operating consistently and exactly as specified in the medical device validation template; i.e, The User Requirement Specification template. 



    User Requirements Specification (Issue 8) $115.00

    This document was designed to be used as a live document up until the DQ is completed and approved. It uses three levels of URS, URS Level 1, 2 and 3, and is the only URS to guarantee traceability from the User requirements specification template through to the final PQ and OQ functionality testing. A mandatory requirement for Full Life Cycle Validation of computer systems and compliance with Current Good Manufacturing Practice legislation. It can be used on mechanical, electrical and software controlled, monitored or driven systems and of course medical device validatioN Template along with the Software Qualification template.



    Installation Qualification. SOP & Protocol (Issue 9.) $115.00 10000020

    The Standard Operating Procedure template (SOP) used to generate this pharmaceutical validation IQ, takes you through the process line by line, chapter by chapter. It really is unique to find a SOP document so easy to use, all the work is done for you. All the documents are detailed, all the drawings listed and all the checks and tests detailed. The final product is a professional and comprehensive Installation Qualification Protocol. One that you can produce in less than 60 minutes. Yes, think about it, we all know how long producing IQ documents has taken in the past, whether for medical device validatioN  TEMPLATE or for being able to produce 4 to 8, IQ protocols per 8 hour day.



    Operational Qualification, SOP & Protocol (Issue 10.) $115.00 

    You will find the Operational Qualification template (OQ) delightfully simple and straightforward to use, as it takes you through the process of customization of your Operational Qualification Protocol template. Following the attached SOP will quickly and smoothly convert your template into an equipment specific 21 CFR Part 11 compliant Installation  Qualification Template. The OQ template comes complete with all the standard test scripts, more specialist test scripts can be found listed below. These can easily be pasted into the standard OQ, allowing you to quickly build your own fully detailed and referenced company bespoke Operational Qualification Protocol.



    Equipment Validation Pack 2. $520.00

    You want to validate a process line or new process equipment or individual process assembly stage equipment or just similar equipment that requires  equipment qualification after  having been subjected to major modification.
    In this case you require the following validation protocols 
    VP, URS, VRA, DQ, IQ, OQ, PQ.
    Level 2 Package consists of one of each of these.



    User Requirements Specification (Issue 8) -- $115.00

    This document was designed to be used as a live document up until the DQ is completed and approved.  It uses three levels of URS, URS Level 1, 2 and 3, and is the only URS to guarantee traceability from the URS through to the final PQ and OQ functionality testing.  A mandatory requirement for Full Life Cycle Validation of computer systems that are the subject of predicate rules.  It can be used on  mechanical, electrical Equipment qualification and software controlled, monitored or driven systems.



    Validation Risk Assessment (Issue 11) -- $125.00

    This is a robust and simple to execute document, one that will lead you through the process and deliver a result that can be used as the foundation for your validation activities. The VRA now includes the assessment table for categorizing and documenting the new 21 CFR Part 11 guidance ruling on what predicate data must be stored in a Part compliant system, along with the new broadsheet to establish your new database of part 11 records & equipment qualification.



    Installation Qualification.  (Issue 9.) -- $115.00