Quality Control

Vendor Audit Questionnaire for Laminated Tube (Lamitube) Manufacturer

Vendor Audit Questionnaire for Laminated Tube: Below is a structured, regulator-aligned Vendor Audit Questionnaire tailored for a laminated tube (Lamitube) manufacturer supplying to pharmaceutical companies. The framework integrates expectations from World Health Organization, U.S. Food and Drug Administration, Pharmaceutical Inspection Co-operation Scheme, and European Medicines Agency guidelines (especially GMP for packaging materials, e.g., EU GMP Annex 1, WHO TRS 986/1019, FDA 21 CFR 210/211).

 

 

The questions are short, audit-friendly, and layered (Main → Sub-questions) so you can probe deeply during inspection.


🔷 1. Quality Management System (QMS)

Main Question:

How is the Quality Management System established, implemented, and maintained?

Breakdown:

  • Is there a documented Quality Manual aligned with GMP?
  • Are SOPs controlled, approved, and version-managed?
  • How is document lifecycle (issuance → archival) controlled?
  • Are quality objectives defined and periodically reviewed?
  • Is there a system for Quality Risk Management (ICH Q9 aligned)?
  • Are deviations, CAPA, and change control systems integrated?
  • Is management review conducted periodically?

🔷 2. Regulatory Compliance & Certifications

Main Question:

Does the company comply with applicable regulatory and GMP requirements?

Breakdown:

  • Which certifications are held (ISO 9001, ISO 15378, GMP)?
  • Are audits conducted by regulatory agencies or customers?
  • Are previous audit findings available with CAPA status?
  • Is there compliance with pharma packaging guidelines?
  • Are regulatory inspections documented and closed?

🔷 3. Personnel & Training

Main Question:

Are personnel qualified, trained, and compliant with GMP?

Breakdown:

  • Is there an organizational chart with defined responsibilities?
  • Are job descriptions documented?
  • How is initial and ongoing GMP training conducted?
  • Are training effectiveness evaluations performed?
  • Are personnel hygiene and gowning procedures defined?
  • Are operators trained in contamination control?

🔷 4. Premises & Facility Design

Main Question:

Is the facility designed to prevent contamination and mix-ups?

Breakdown:

  • Is material and personnel flow logically segregated?
  • Are clean/controlled areas defined (if applicable)?
  • Is there HVAC system qualification and monitoring?
  • Are pest control systems in place?
  • Are lighting, temperature, humidity controlled?
  • Are utilities (compressed air, water) monitored?

🔷 5. Equipment & Maintenance

Main Question:

Are equipment qualified, calibrated, and maintained?

Breakdown:

  • Is there a list of critical equipment?
  • Are IQ/OQ/PQ performed where applicable?
  • Is preventive maintenance planned and documented?
  • Are calibration records maintained?
  • Are breakdowns recorded and investigated?
  • Is cleaning of equipment validated or verified?

🔷 6. Raw Materials Control

Main Question:

How are raw materials (e.g., laminate, resins, inks) controlled?

Breakdown:

  • Are suppliers qualified and approved?
  • Are incoming materials tested against specifications?
  • Is there a quarantine → release system?
  • Are COAs verified?
  • Are storage conditions controlled?
  • Is FEFO/FIFO followed?

🔷 7. Production & Process Control

Main Question:

Are manufacturing processes controlled and validated?

Breakdown:

  • Are batch manufacturing records (BMR) available?
  • Are critical process parameters defined and monitored?
  • Is process validation performed?
  • Are line clearance procedures implemented?
  • Are in-process checks documented?
  • Is rejection/rework controlled?

🔷 8. Printing & Artwork Control (Critical for Lamitube)

Main Question:

How is printed artwork controlled to prevent errors?

Breakdown:

  • Is artwork approved by customers before printing?
  • Are master artworks securely controlled?
  • Are printing plates/cylinders controlled and verified?
  • Is line clearance done between different artworks?
  • Are barcode and text verification systems used?
  • Are reconciliation procedures in place?

🔷 9. Cleaning & Contamination Control

Main Question:

Are cleaning procedures effective to prevent contamination?

Breakdown:

  • Are cleaning SOPs defined for all areas?
  • Are cleaning records maintained?
  • Is cleaning validation required and performed?
  • Are residues (ink, adhesive) controlled?
  • Are cross-contamination risks assessed?

🔷 10. Laboratory Controls & Testing

Main Question:

Are QC laboratory operations reliable and compliant?

Breakdown:

  • Are specifications defined for tubes (dimension, leakage, print quality)?
  • Are test methods validated?
  • Is there an approved sampling plan?
  • Are instruments calibrated?
  • Are OOS (Out of Specification) handled properly?
  • Are retain samples stored?

🔷 11. Packaging & Finished Product Control

Main Question:

How are finished laminated tubes controlled and released?

Breakdown:

  • Are finished goods inspected before release?
  • Is batch traceability ensured?
  • Are packing materials controlled?
  • Are labeling and identification clear?
  • Is transport validation considered?

🔷 12. Storage & Distribution

Main Question:

Are storage and distribution conditions controlled?

Breakdown:

  • Are warehouses clean and organized?
  • Are environmental conditions monitored?
  • Are dispatch procedures documented?
  • Is traceability maintained during shipment?
  • Are damaged goods handled properly?

🔷 13. Deviations, CAPA & Change Control

Main Question:

Are quality issues effectively managed?

Breakdown:

  • Are deviations recorded and investigated?
  • Is root cause analysis performed?
  • Are CAPAs tracked for effectiveness?
  • Are changes evaluated for impact before implementation?
  • Is change control linked to validation?

🔷 14. Complaint Handling & Recall

Main Question:

Is there an effective system for complaints and recalls?

Breakdown:

  • Are customer complaints logged and investigated?
  • Is trending analysis performed?
  • Is there a mock recall system?
  • How quickly can products be traced and recalled?
  • Are regulatory authorities notified if required?

🔷 15. Data Integrity & Documentation

Main Question:

Is data integrity ensured across all systems?

Breakdown:

  • Are records attributable, legible, contemporaneous (ALCOA)?
  • Are electronic systems validated?
  • Are audit trails enabled?
  • Is access control implemented?
  • Are backups performed regularly?

🔷 16. Vendor & Supply Chain Control

Main Question:

How are upstream vendors controlled?

Breakdown:

  • Is there an approved vendor list (AVL)?
  • Are vendor audits conducted?
  • Are critical suppliers periodically re-evaluated?
  • Are agreements (Quality Agreements) in place?

🔷 17. EHS (Environment, Health & Safety)

Main Question:

Are safety and environmental controls implemented?

Breakdown:

  • Are MSDS available for chemicals (inks, solvents)?
  • Are hazardous materials stored properly?
  • Is waste disposal compliant?
  • Are fire safety systems installed?
  • Are emergency procedures defined?

🔷 18. Continuous Improvement

Main Question:

Does the company focus on continuous improvement?

Breakdown:

  • Are KPIs defined (rejection rate, complaints)?
  • Are internal audits conducted?
  • Are improvement projects documented?
  • Is trend analysis performed?

✅ Pro Tips for Strong Vendor Audit (Practical Execution)

  • Focus heavily on:
    • Artwork control (highest risk in tubes)
    • Traceability (batch → raw material → dispatch)
    • Line clearance & mix-up prevention
  • Ask for live records, not just SOPs.
  • Perform shop-floor verification (not just QA office review).
  • Cross-check:
    • BMR vs actual production
    • COA vs test raw data
  • Look for data integrity red flags (backdating, overwriting, missing logs)

 

🔴 SERIES–2: ADVANCED / FORENSIC VENDOR AUDIT QUESTIONS


🔷 1. QMS Effectiveness (Beyond Documentation)

Main Question:

How do you demonstrate that your QMS is effective, not just compliant?

Breakdown:

  • Show last 12 months trend of deviations vs CAPA closure time
  • What % of CAPAs are delayed? Justify
  • Provide example where CAPA failed → what was done next?
  • How do you ensure recurrence does NOT happen?
  • Are KPIs linked to management incentives?
  • Show evidence of risk-based decision making, not SOP-driven only

🔷 2. Data Integrity (Critical – High Risk Area)

Main Question:

How do you ensure ALCOA+ compliance in real operations?

Breakdown:

  • Show raw data vs reported COA → any mismatch?
  • Are there any blank spaces, overwriting, backdating in records?
  • Who reviews audit trails and how frequently?
  • Can operators delete or modify data?
  • Show one real audit trail for a batch
  • What controls prevent “testing into compliance”?
  • How do you detect unofficial records (shadow documentation)?

🔷 3. Deviation Investigation Depth

Main Question:

How robust is your root cause investigation?

Breakdown:

  • Show a major deviation report (last 6 months)
  • Was root cause scientifically justified or assumed?
  • Was 5 Why / Fishbone / FMEA used?
  • Were multiple root causes considered?
  • Was QA independent in conclusion approval?
  • How do you verify root cause correctness?

🔷 4. Change Control – Hidden Risks

Main Question:

How do you ensure changes do not introduce unseen risks?

Breakdown:

  • Show a recent change control affecting production
  • Was risk assessment formal (ICH Q9)?
  • Were validation/revalidation requirements evaluated?
  • Was customer notified (for critical changes)?
  • Were changes implemented before approval (backdoor change)?
  • How do you track temporary changes?

🔷 5. Process Validation – Real Assurance

Main Question:

How do you prove your process is consistently capable?

Breakdown:

  • Show Process Validation Report
  • Are worst-case conditions included?
  • What is the process capability (Cp/Cpk)?
  • How are critical parameters justified?
  • Is continued process verification (CPV) performed?
  • Show trend of in-process rejection over time

🔷 6. Artwork & Printing – Zero Error Expectation Area

Main Question:

How do you ensure zero artwork error, considering high regulatory risk?

Breakdown:

  • Show real case of artwork error → what happened?
  • Is there 100% vision inspection or manual?
  • How is mix-up between similar artworks prevented?
  • Are cylinders uniquely coded and verified?
  • Is there dual verification before printing?
  • What is reconciliation tolerance for printed tubes?

🔷 7. Line Clearance – Practical Effectiveness

Main Question:

How do you guarantee zero mix-up between batches/products?

Breakdown:

  • Demonstrate a live line clearance
  • Who verifies clearance (production vs QA)?
  • Are previous batch remnants physically checked?
  • Are labels/artwork fragments controlled?
  • Is photographic evidence used?

🔷 8. Supplier Risk Management

Main Question:

How do you control risks from your raw material suppliers?

Breakdown:

  • Show supplier risk categorization
  • How often are critical suppliers audited?
  • Any supplier disqualified recently? Why?
  • How do you verify supplier COA reliability?
  • Do you perform skip testing or full testing?

🔷 9. Laboratory Control – Reliability Check

Main Question:

How do you ensure QC results are scientifically reliable?

Breakdown:

  • Show OOS investigation (real case)
  • Was Phase I / Phase II investigation followed?
  • Are analysts trained on data integrity?
  • Any retesting without justification?
  • How are reference standards controlled?

🔷 10. Rejection, Rework & Scrap Control

Main Question:

How do you prevent rejected materials from re-entering the system?

Breakdown:

  • Show rejected batch records
  • Is rework scientifically justified and approved?
  • How is scrap physically destroyed?
  • Any case of unauthorized reprocessing?
  • Are rejection trends analyzed?

🔷 11. Traceability (Backward & Forward)

Main Question:

Can you trace any product within minutes?

Breakdown:

  • Perform mock traceability test:
    • Finished tube → raw material batch
    • Raw material → all affected customers
  • Time required to retrieve data?
  • Is system manual or ERP-based?
  • Any gaps in traceability observed?

🔷 12. Complaint Handling – True Root Cause

Main Question:

How do you ensure complaints lead to real improvement?

Breakdown:

  • Show last 5 complaints
  • Are trends analyzed (e.g., print defect, leakage)?
  • Were CAPAs effective?
  • Any repeated complaints for same issue?
  • Was customer feedback incorporated?

🔷 13. Recall System – Practical Readiness

Main Question:

How prepared are you for a real recall?

Breakdown:

  • Show last mock recall report
  • Time taken to complete recall simulation?
  • % traceability achieved?
  • Are customers informed in simulation?
  • Are regulatory requirements considered?

🔷 14. Cleaning Validation (Critical for Cross-Contamination)

Main Question:

How do you ensure no carryover of ink/chemical residues?

Breakdown:

  • Are worst-case products selected?
  • What is acceptance criteria (scientific or arbitrary)?
  • Are swab/recovery studies performed?
  • Is visual cleanliness justified scientifically?
  • Any failure observed in cleaning validation?

🔷 15. Environmental Control (Especially Printing Area)

Main Question:

How do environmental factors impact product quality?

Breakdown:

  • Are temp/humidity linked to print quality?
  • Any environmental excursions recorded?
  • Impact assessment done?
  • Are sensors calibrated?

🔷 16. Warehouse – Hidden GMP Gaps

Main Question:

How do you prevent mix-up and deterioration in storage?

Breakdown:

  • Are status labels (Quarantine/Released/Rejected) clear?
  • Any case of wrong material issuance?
  • Are returns segregated?
  • Is pest control effective (show logs)?

🔷 17. Internal Audit Effectiveness

Main Question:

Are internal audits truly identifying gaps?

Breakdown:

  • Show last internal audit report
  • Were critical findings raised?
  • Any repeat observations?
  • Is QA independent from production?

🔷 18. Management Commitment (Reality Check)

Main Question:

How does top management ensure GMP compliance?

Breakdown:

  • Are resources sufficient (manpower, budget)?
  • Any production vs quality conflict?
  • Example where batch was rejected despite pressure
  • Are quality metrics reviewed at top level?

🔥 HIGH-IMPACT AUDIT TECHNIQUES (Use During Audit)

  • Ask: “Show me now” instead of “Do you have”
  • Cross-question same topic with:
    • Operator
    • Supervisor
    • QA
  • Pick random batch → trace everything
  • Compare:
    • SOP vs actual practice
  • Watch for:
    • Delayed entries
    • Too-perfect records
    • Identical handwriting

 

🔴 SERIES–3: TRAP QUESTIONS (HIGH-IMPACT AUDIT TOOL)

⚠️ How to use:

  • Ask indirectly
  • Cross-check answers between departments
  • Always demand live evidence

🔷 1. “Show Me Now” Trap (Reality vs Documentation)

Main Trap Question:

“Can you show me a batch currently under processing and all associated live records?”

Trap Breakdown:

  • Does the operator hesitate or call QA first?
  • Are entries made in real-time or backfilled?
  • Do timestamps align with actual process time?
  • Is handwriting consistent or pre-filled?

👉 Red Flag: Records updated just before showing


🔷 2. Data Integrity Trap (Backdating Detection)

Main Trap Question:

“Pick any record from last week—can you explain when exactly this entry was made?”

Trap Breakdown:

  • Compare:
    • Ink color / pen variation
    • Time gaps between entries
  • Ask operator:
    • “Did you write this immediately or later?”

👉 Red Flag: Same pen, same handwriting for full shift data


🔷 3. Shadow Documentation Trap

Main Trap Question:

“Do operators ever use rough sheets before final entry?”

Trap Breakdown:

  • Check drawers, behind machines
  • Ask casually: “How do you remember readings before writing?”

👉 Red Flag: Unofficial notebooks / loose papers


🔷 4. Deviation Suppression Trap

Main Trap Question:

“In the last 3 months, did any process fail but was not recorded as deviation?”

Trap Breakdown:

  • Cross-check:
    • Maintenance logs
    • QC OOS
    • Production downtime
  • Compare with deviation register

👉 Red Flag: Events exist but no deviation raised


🔷 5. CAPA Effectiveness Trap

Main Trap Question:

“Show a deviation that happened twice—why did CAPA fail first time?”

Trap Breakdown:

  • Check recurrence
  • Evaluate depth of root cause

👉 Red Flag: Same issue repeating with different wording


🔷 6. Artwork Mix-up Trap (Critical for Tubes)

Main Trap Question:

“What prevents two similar artworks from being mixed during printing?”

Trap Breakdown:

  • Physically verify:
    • Cylinders
    • Printed tubes
  • Ask operator to explain difference

👉 Red Flag: Reliance only on visual check without system control


🔷 7. Line Clearance Trap (False Compliance)

Main Trap Question:

“Can we check the previous product run on this line?”

Trap Breakdown:

  • Look for:
    • Leftover labels
    • Tubes under machine
  • Ask: “Who verified clearance?”

👉 Red Flag: Clearance signed but physical evidence remains


🔷 8. Training Effectiveness Trap

Main Trap Question:

Ask operator directly:
“Explain what you will do if you find a defective tube?”

Trap Breakdown:

  • Compare with SOP
  • Check confidence level

👉 Red Flag: SOP exists but operator unaware


🔷 9. QC Testing Manipulation Trap

Main Trap Question:

“Have you ever repeated a test because the first result was not acceptable?”

Trap Breakdown:

  • Ask follow-up:
    • “Was it documented?”
  • Check raw data vs final COA

👉 Red Flag: Retesting without investigation


🔷 10. OOS Handling Trap

Main Trap Question:

“Show me an OOS result and explain full investigation”

Trap Breakdown:

  • Check:
    • Hypothesis-driven investigation
    • Lab error justification

👉 Red Flag: Blaming analyst without proof


🔷 11. Change Control Bypass Trap

Main Trap Question:

“Have you ever implemented a change urgently before approval?”

Trap Breakdown:

  • Cross-check with production/engineering
  • Verify temporary changes

👉 Red Flag: Verbal approvals / undocumented changes


🔷 12. Supplier COA Trust Trap

Main Trap Question:

“Do you always test raw materials or rely on supplier COA?”

Trap Breakdown:

  • Ask:
    • “When was last full testing done?”

👉 Red Flag: Blind trust in supplier without verification


🔷 13. Traceability Stress Test (Live Challenge)

Main Trap Question:

“Trace this finished tube to raw materials within 10 minutes”

Trap Breakdown:

  • Observe:
    • Time taken
    • Data gaps

👉 Red Flag: Delays, incomplete traceability


🔷 14. Scrap Control Trap

Main Trap Question:

“What happens to rejected printed tubes?”

Trap Breakdown:

  • Physically inspect scrap area
  • Check destruction records

👉 Red Flag: Scrap accessible / reusable


🔷 15. Warehouse Mix-up Trap

Main Trap Question:

“Can you show any wrongly placed material found in last audit?”

Trap Breakdown:

  • Check labeling system
  • Verify segregation

👉 Red Flag: Same-looking materials stored together


🔷 16. Environmental Excursion Trap

Main Trap Question:

“What happens if humidity exceeds limit during printing?”

Trap Breakdown:

  • Ask for real case
  • Check deviation link

👉 Red Flag: No impact assessment


🔷 17. Internal Audit Integrity Trap

Main Trap Question:

“Why were no critical observations found in last internal audit?”

Trap Breakdown:

  • Compare with your findings

👉 Red Flag: Internal audit too “clean”


🔷 18. Management Pressure Trap

Main Trap Question:

“Has production ever continued despite quality concern?”

Trap Breakdown:

  • Ask different levels separately

👉 Red Flag: Conflicting answers


🔷 19. “Too Perfect System” Trap

Main Trap Question:

“You have zero deviations last month—how is that possible?”

👉 Red Flag: Indicates underreporting


🔷 20. Contradiction Trap (Powerful Technique)

Method:

Ask same question to:

  • Operator
  • QA
  • Supervisor

👉 Compare answers

Example:

  • “Who performs line clearance?”
  • “Who approves deviation?”

👉 Red Flag: Different answers


🔥 CRITICAL OBSERVATION SKILLS (MOST IMPORTANT)

During audit, continuously watch for:

  • ⛔ Entries written in same handwriting
  • ⛔ No corrections in months (unrealistic)
  • ⛔ Fearful operators
  • ⛔ QA answering everything (production silent)
  • ⛔ Delayed data retrieval
  • ⛔ “We always follow SOP” without explanation

🧠 PRO AUDITOR STRATEGY (FIELD-LEVEL)

  • Never rely on verbal answers
  • Always:
    • See → Verify → Cross-check
  • Use silence pressure (wait after asking)
  • Randomly select:
    • Batch
    • Operator
    • Record

✅ If you want FINAL LEVEL (ELITE)

I can prepare:

🔷 “Audit Scoring System”

  • Critical / Major / Minor classification
  • Risk-based scoring (FDA-style)

🔷 “Lamitube-Specific Risk Matrix”

  • Leakage risk
  • Print toxicity risk
  • Extractables/leachables concern

🔷 “DGDA Bangladesh Audit Angle”

  • Local regulatory expectations
  • Common inspection findings in Bangladesh

Vendor Audit Questionnaire for Laminated Tube (Lamitube) Manufacturer Read More »

Comprehensive QC Department Audit Checklist

This is audit pack provides structured, risk‑based interview checklists covering Raw Material QC, Finished Product QC, Microbiology, and Packaging Materials in a pharmaceutical facility. Each section breaks requirements into practical questions with drill‑down subpoints to verify compliance, traceability, and real on‑floor practices. It emphasizes high‑risk areas such as sampling integrity, CoA reliance, method/version control, OOS/OOT investigations, chromatography data integrity, sterility/LAL controls, EM trending, and printed artwork/line clearance. The checklists are designed to uncover hidden loopholes like testing into compliance, mix‑ups, inadequate segregation (especially for potent women hormones), and weak reconciliation/release controls.

RAW MATERIAL QC (50 Points)

1) How is the ASL (Approved Supplier List) controlled for raw materials?

1.1 Show the latest ASL (document no., revision, effective date).
1.2 Is the ASL risk-based (API vs excipients vs critical materials)?
1.3 What is the approval workflow to add a supplier (QA approval + risk assessment)?
1.4 How is supplier disqualification communicated and implemented (ERP block, memo, training)?

2) How do you perform supplier qualification?

2.1 Show the last supplier audit report (scope, findings, CAPA status).
2.2 If no audit, show the justification/risk assessment.
2.3 Do you qualify suppliers using trial lots with tightened testing/sampling? Evidence?
2.4 How often is supplier qualification reviewed/re-approved?

3) Do you have a Quality Agreement with suppliers and does it work?

3.1 Is change notification included (site/process/spec/raw source changes)?
3.2 Are CoA requirements, traceability, and record retention defined?
3.3 Are investigation support timelines defined (supplier response time)?
3.4 Does it include data integrity (ALCOA+) expectations?

4) If you buy via Broker/Trader, how do you ensure manufacturer traceability?

4.1 Do you require original manufacturer identification on CoA?
4.2 Do you obtain manufacturer CoA in addition to trader CoA?
4.3 If repacking occurs, is repacker qualified and approved?
4.4 Is counterfeit risk assessed for high-risk APIs?

5) How do you monitor supplier performance trending?

5.1 Show supplier-wise rejection/complaint trend (last 6–12 months).
5.2 What triggers actions (tightened testing, re-audit, CAPA request)?
5.3 Is CAPA response time tracked and escalated if late?
5.4 Is there an annual supplier performance review with QA sign-off?


6) What checks are performed at material receipt?

6.1 Do you verify quantity, container condition, and seal integrity? Evidence (GRN).
6.2 How are damaged/dirty/leaking containers handled (deviation + assessment)?
6.3 For temperature-sensitive materials, who reviews transport logger/excursions?
6.4 How do you prevent acceptance of wrong material (label mismatch workflow)?

7) How do you control Quarantine labeling?

7.1 Who issues Quarantine labels and are they controlled (issuance log)?
7.2 Does the label include material code, lot, status, date, signature?
7.3 If relabeling is needed, is there second-person verification?
7.4 Are barcode/ERP printed labels used to reduce errors?

8) How is status controlled in ERP/LIMS?

8.1 Who can change status (role-based access)? Show user roles.
8.2 Is there an audit trail for status changes? Show an example.
8.3 How do you reconcile ERP status vs physical labels routinely?
8.4 Is production prevented from issuing material before release (system block)?

9) Is physical segregation of Quarantine/Approved/Rejected effective?

9.1 Show segregated areas/cages/locks and signage.
9.2 How do you prevent mix-up of similar containers/lots?
9.3 How are rejected materials controlled until disposal/return?
9.4 Are returned materials stored separately and controlled?

10) Do you allow conditional release/urgent use of raw materials?

10.1 Is there an SOP defining when conditional release is allowed?
10.2 Is QA approval mandatory with documented risk assessment?
10.3 How do you manage post-use test completion tracking?
10.4 Show one conditional release case (last 1 year), if any.


11) How is the sampling plan defined (n√N / risk-based)?

11.1 Is sampling plan different for API vs excipients vs critical materials?
11.2 Is tightened sampling used for new suppliers/first lots?
11.3 How do you document random container selection (container list)?
11.4 What happens if sampling deviates from plan (deviation record)?

12) How do you ensure container selection is truly random?

12.1 Show sampled container numbers vs total containers received.
12.2 What method is used for randomization (random list/number)?
12.3 Does supervisor/QA perform spot checks? Evidence?
12.4 For multi-pallet lots, do you sample across pallets? Criteria?

13) When is composite sampling allowed and controlled?

13.1 Is there a list of materials allowed/not allowed for composite samples?
13.2 Is risk documented (container variability can be masked)?
13.3 Is the composite preparation method defined (equal portions, mixing)?
13.4 Are container numbers included in traceability records?

14) How is the sampling area/room controlled?

14.1 Where sampling occurs (sampling room vs warehouse) and why?
14.2 Are cleaning and line clearance documented before/after sampling?
14.3 For hygroscopic materials, how is RH exposure minimized and controlled?
14.4 Is traffic control implemented to reduce contamination risk?

15) How are sampling tools controlled?

15.1 Are tools dedicated by material family/potent category?
15.2 Show tool cleaning SOP and last cleaning records.
15.3 Are clean tools stored covered, labeled, and protected from contamination?
15.4 How do you detect/replace damaged or rusty tools?

16) How do you prevent sampling contamination?

16.1 Are glove-change rules defined (per container/per material)?
16.2 Is opening multiple containers at once prohibited/controlled?
16.3 How are spills handled (cleaning + documentation + assessment)?
16.4 Is sampling sequence risk-based (potent last, dedicated session)?

17) Potent Women Hormone raw material sampling—what special controls exist?

17.1 Is containment available (downflow booth/isolator/negative pressure)?
17.2 Is special PPE required and followed (double gloves, mask/respirator)?
17.3 Are tools/consumables dedicated and segregated for potent materials?
17.4 Is potent waste segregated and disposed with records?


18) How is sample labeling controlled to prevent mislabeling?

18.1 Does label include sample ID, material code, lot, container no., date/time, sampler?
18.2 Are labels printed from LIMS (preferred) and controlled?
18.3 How are label errors corrected (GDP rules)?
18.4 Are tamper-evident seals used for samples?

19) How is chain of custody maintained from sampling to lab?

19.1 Is there a sample receipt log (time, receiver signature)?
19.2 Is seal integrity checked and documented upon receipt?
19.3 Is sample storage location logged (cabinet/fridge ID)?
19.4 If sample is lost/broken, is deviation mandatory?

20) How is sample holding time controlled?

20.1 Is max holding time defined (sampling → analysis start)?
20.2 Are holding conditions defined (temperature/light protection)?
20.3 Is deviation raised for exceeded holding time with impact assessment?
20.4 Are LIMS reminders or controls used to prevent delays?

21) How is the retain sample program managed?

21.1 Is retain quantity sufficient for full retest + investigation?
21.2 Are retains labeled completely (lot/date/storage/location)?
21.3 Are retain storage conditions monitored with alarms and excursions handled?
21.4 Is retain access controlled and logged (removal/reconciliation)?

22) How are warehouse storage conditions controlled?

22.1 Is temp/RH monitored (continuous or daily logs) with alarm response?
22.2 Is warehouse mapping/qualification available for critical zones?
22.3 Are excursions investigated with documented impact assessment?
22.4 Is FEFO/FIFO verified physically (show one example)?

23) How are partially used containers controlled?

23.1 Is “Opened on” date recorded and status updated?
23.2 Are resealing requirements defined (liner/desiccant/tape)?
23.3 Is retest date updated and tracked in ERP/LIMS?
23.4 How do you prevent mix-up between lots of the same material?


24) How do you review incoming CoA?

24.1 Do you compare CoA tests/methods/limits/units against your specification?
24.2 Do you require numeric results (not only “Pass”)?
24.3 Do you verify mfg/retest/expiry date logic and batch identity?
24.4 How do you verify CoA authenticity (source, signature, format control)?

25) If CoA reliance/reduced testing is used, how is it justified and verified?

25.1 Is there an approved reduced-testing list with QA approval?
25.2 Is periodic full verification testing scheduled and executed?
25.3 Are CoA vs internal results trended to detect inconsistencies?
25.4 Does verification failure trigger supplier CAPA and tightened testing?

26) How is specification version control ensured?

26.1 Where are current specs stored (controlled system) and how do analysts confirm latest?
26.2 How do you prevent use of obsolete printouts/worksheets?
26.3 Are analysts trained on revised specs before use? Evidence?
26.4 Are market/registration-specific specs mapped and controlled?

27) How do you manage USP/EP/BP updates?

27.1 Who monitors pharmacopeia changes and how often?
27.2 Is impact assessment documented with closure evidence?
27.3 Are method/spec updates controlled via Change Control?
27.4 Is training completed before the change becomes effective?

28) How do you ensure analysts follow the current STP/method?

28.1 Are critical steps highlighted (time/temp/pH/sequence)?
28.2 How are method deviations documented and assessed?
28.3 If method transferred, is verification/transfer report available?
28.4 Is analyst competency/authorization documented for each method?

29) Identity testing controls (FTIR/UV/chemical)—are they robust?

29.1 Is library/version control implemented (FTIR) with approval?
29.2 Are acceptance criteria defined (match/correlation %)?
29.3 Are reference spectra traceable and controlled?
29.4 What is the workflow for ambiguous/failing ID?

30) How do you control reference standards / working standards?

30.1 Are primary standard COAs traceable and current (expiry/retest tracked)?
30.2 Are working standards qualified against primary standards with reports?
30.3 Are potency/LOD/water corrections applied consistently (example)?
30.4 Are storage conditions monitored (2–8°C/desiccator/light protection)?

31) How is standard solution preparation controlled?

31.1 Does prep record include balance ID, weights, dilutions, glassware IDs?
31.2 Are prepared-by and checked-by signatures mandatory?
31.3 Is solution expiry/hold time scientifically justified?
31.4 Is reuse of old solutions prohibited/controlled?

32) How are reagents/volumetric solutions controlled?

32.1 Are reagent labels complete (name, conc, prep date, expiry, preparer/checker)?
32.2 Is standardization factor recorded for volumetric solutions?
32.3 Is “top-up” prohibited and monitored?
32.4 Is disposal of expired reagents documented?

33) How is glassware cleaning controlled?

33.1 Is cleaning SOP defined (detergent → rinse → final rinse → dry)?
33.2 Is final rinse water grade defined (PW/DI/HPLC water)?
33.3 Is dust-free storage ensured (covered storage)?
33.4 Is dedicated glassware used for potent/hormone materials?

34) How is balance control ensured?

34.1 Are daily check weights traceable and recorded?
34.2 Do weighing logs include balance ID/time/analyst sign?
34.3 If check fails, is impact assessment performed on affected tests?
34.4 Is balance environment controlled (draft/vibration)?

35) How is pH meter control ensured?

35.1 Is daily 2/3-point calibration performed with records?
35.2 Are buffers controlled (label/expiry/storage)?
35.3 Is electrode cleaning/storage defined and followed?
35.4 What happens if calibration fails (stop test/deviation/alternate meter)?


36) HPLC qualification and maintenance—are instruments fit for use?

36.1 Show IQ/OQ/PQ status and calibration/PM schedule.
36.2 Show last PM record and breakdown log (if any).
36.3 Is column history tracked (usage, product, cleaning, storage)?
36.4 Are alarms/limits active (pressure/leak) and reviewed?

37) HPLC System Suitability (SST) governance

37.1 Are SST criteria defined (RSD, tailing, plates, resolution)?
37.2 Is there a checklist for SST failure investigation?
37.3 Are rerun/reinject rules strict and controlled (QA visibility)?
37.4 Is SST calculation independently reviewed?

38) Integration/reprocessing controls (major data integrity risk)

38.1 Is there an integration guideline (baseline/peak split/merge rules)?
38.2 Is manual integration allowed only with documented justification?
38.3 Are reprocessing permissions role-restricted?
38.4 Are deleted injections/runs justified and reviewed?

39) Electronic data integrity (ALCOA+) controls

39.1 Are unique user logins enforced (no shared accounts)?
39.2 Is audit trail enabled and reviewed (per batch/periodic)? Evidence?
39.3 Are backups/archives controlled and retrieval tested?
39.4 Is system time controlled/synchronized to prevent manipulation?

40) Excel/manual calculation control

40.1 Are Excel templates validated and version-controlled?
40.2 Are formulas locked with restricted access?
40.3 Are manual calculations independently checked and signed?
40.4 Are rounding/significant figure rules defined and applied?

41) OOT trending (within-spec drift)—is it implemented?

41.1 Which parameters are trended (assay, impurity, KF moisture)?
41.2 Who reviews trends and at what frequency (monthly/quarterly)?
41.3 What triggers OOT investigation and what evidence is kept?
41.4 Are CAPA and effectiveness checks linked to trend results?

42) Raw material OOS handling (Phase I/Phase II)

42.1 Is Phase-I (lab) checklist followed and documented?
42.2 Are retest/resample rules controlled with QA approval?
42.3 What evidence is required to conclude “analyst error”?
42.4 Is supplier notified and supplier CAPA requested when needed?

43) Deviation management (sampling/storage/testing)

43.1 Are deviation triggers clearly defined (hold time, label, excursions)?
43.2 Is overdue deviation tracking implemented?
43.3 Is impact assessment signed by QC+QA?
43.4 Is CAPA effectiveness verified (not only closure)?

44) Training/competency control (RM analysts)

44.1 Is there a training matrix per instrument/method?
44.2 Are analysts qualified before independent work (OJT records)?
44.3 Is periodic requalification performed?
44.4 Is training effectiveness reviewed using error/OOS trends?

45) Potent/hormone cleaning verification in QC

45.1 Is cleaning procedure defined and records maintained after potent work?
45.2 Are acceptance criteria defined (visual/swab limits) with rationale?
45.3 Is worst-case selection documented?
45.4 What happens if cleaning fails (re-clean + deviation + impact)?

46) Cross-contamination prevention in RM lab

46.1 Are potent and non-potent work areas segregated?
46.2 Are consumables dedicated (spatulas/boats/vials)?
46.3 Are dust/airborne controls and housekeeping effective?
46.4 Is potent waste segregated and disposed with records?

47) Raw material release workflow (QC → QA)

47.1 Is QC review checklist completed before QA disposition?
47.2 Is ERP status updated with traceable audit trail?
47.3 Is RM CoA template/version controlled?
47.4 Are deviations/OOS checked before final release?

48) Prevention of informal release (verbal/email)

48.1 Is verbal release prohibited by SOP and trained?
48.2 Is warehouse issue blocked in ERP before release? Evidence?
48.3 Are exceptions handled via deviation and QA approval?
48.4 Are warehouse staff trained on status controls?

49) Out-of-calibration (OOC) impact assessment

49.1 How is the affected time window determined?
49.2 How are affected lots/tests identified and controlled (hold/retest)?
49.3 Who approves final decisions (QA) and how is it documented?
49.4 Is preventive action taken (PM change, training)?

50) Reviewer discipline—does data review really work?

50.1 Is there a raw data package checklist (SST, calcs, audit trail)?
50.2 Does reviewer actually check chromatograms/audit trail before sign-off?
50.3 How do you prevent backdated reviews (system controls)?
50.4 Are review findings tracked to CAPA with closure evidence?

Packaging Materials (English Version)

Scope: Primary packaging (blister PVC/PVDC, Alu foil, bottles/caps/droppers, glass vials/ampoules, rubber stoppers, seals) + Secondary packaging (cartons, labels, leaflets, shippers) + Printed material / Artwork / Version control


1) How do you control the ASL (Approved Supplier List) for packaging materials?

1.1 Show the latest ASL (document no., revision, effective date).
1.2 Is ASL risk-based (Primary vs Secondary vs Sterile components)?
1.3 What is the approval workflow to add a new supplier (QA approval + risk assessment)?
1.4 How do you communicate supplier disqualification (ERP block, training, email notice)?

2) How is supplier qualification/audit done for packaging suppliers?

2.1 Show last supplier audit report (scope, findings, CAPA status).
2.2 How do you verify supplier certifications (e.g., ISO 15378/ISO 9001/GMP compliance)?
2.3 Do you perform trial lots / line trials before full approval? Evidence?
2.4 How often do you re-evaluate or re-qualify suppliers?

3) Do you have Quality Agreements with packaging suppliers, and are they implemented?

3.1 Does it include change notification (film thickness, ink, adhesive, resin grade, tooling)?
3.2 Does it define CoA/CoC requirements and traceability expectations?
3.3 Does it define complaint/OOS response timelines and investigation support?
3.4 Does it include data integrity / record retention / confidentiality for Artwork?

4) If materials come via Broker/Trader, how do you ensure manufacturer traceability?

4.1 Do you require original manufacturer identification on CoA/CoC?
4.2 Do you obtain manufacturer CoA in addition to trader CoA?
4.3 If repacking/relabeling occurs, is the repacker qualified and approved?
4.4 Do you perform counterfeit risk assessment for high-risk items?

5) How do you review and trend supplier performance?

5.1 Show supplier-wise rejection/complaint trend for last 6–12 months.
5.2 What triggers actions (audit frequency increase, tightened inspection, supplier CAPA)?
5.3 Do you track supplier CAPA response time and effectiveness?
5.4 Is there an annual supplier review with QA sign-off?


6) What checks are performed at receipt of packaging materials?

6.1 Do you check pallet/roll/carton condition (damage, moisture, tamper evidence)?
6.2 Do you verify quantity/count vs PO/GRN? Any mismatch deviation?
6.3 For moisture/temperature sensitive items (labels/leaflets/adhesives), do you review transport conditions?
6.4 If wrong material/print suspected, what is the quarantine + deviation process?

7) How do you manage Quarantine labeling for packaging materials?

7.1 Who issues Quarantine labels and how are labels controlled (issuance log)?
7.2 What must be on the label (item code, lot, status, date, sign)?
7.3 If a label is damaged or replaced, how is relabel verification done (second check)?
7.4 Do you use barcode/ERP-printed labels to reduce human error?

8) How is material status controlled in ERP/LIMS?

8.1 Who can change status (role-based access)? Show access list.
8.2 Is there an audit trail for status changes? Show one example.
8.3 Who reconciles ERP status vs physical labels, and how often?
8.4 Is there a system block preventing issue to production before release?

9) Is physical segregation of Quarantine/Approved/Rejected effective?

9.1 Show separate areas/cages/locks and signage.
9.2 How do you prevent mix-up between similar-looking printed items?
9.3 How are rejected/returned materials controlled until disposal/return?
9.4 Are returned materials stored separately from rejected materials?


10) How is the sampling plan defined for packaging materials?

10.1 Where is sampling plan defined (SOP/AQL/risk-based)?
10.2 For roll goods, how do you select sample locations (start/middle/end)?
10.3 For printed cartons/leaflets/labels, how do you ensure representative sampling?
10.4 If sampling is missed or deviated, do you raise a deviation?

11) How do you prevent mix-up/contamination during sampling?

11.1 Is sampling area line-cleared before sampling?
11.2 Do you prevent opening two different printed items simultaneously?
11.3 Are tools/gloves controlled and changed as required?
11.4 How do you control sample ID/labeling to prevent mislabeling?

12) How do you manage sample labeling and chain-of-custody?

12.1 Sample label includes item name/code, lot, roll no., date, sampler?
12.2 Is transfer store → QC documented (receipt log with time/signature)?
12.3 Are storage conditions for samples controlled (RH/light)?
12.4 Is sample holding time defined and deviations raised if exceeded?


Primary Packaging Controls (Material Quality)

13) How do you test/control Blister PVC/PVDC film?

13.1 Thickness/width/GSM checks with acceptance criteria?
13.2 Visual defects checks (gels, pinholes, fish-eyes) with defined criteria?
13.3 Sealability/formability tests (where applicable) documented?
13.4 CoA vs internal verification results trended?

14) How do you test/control Alu lidding foil?

14.1 Thickness/temper/print adhesion/heat-seal lacquer verification?
14.2 Pinholes/creases/scratches acceptance criteria defined?
14.3 Seal strength/peel tests (if applicable) performed?
14.4 Roll number traceability captured in batch records?

15) How do you control Alu-Alu cold form foil (if used)?

15.1 Formability/cracking risk checks defined?
15.2 Thickness/visual defects inspection performed and recorded?
15.3 Storage protection from moisture/damage controlled?
15.4 CoA verification program and trending?

16) How do you control plastic bottles (HDPE/LDPE/PET)?

16.1 Dimensional checks (neck finish/thread fit) performed?
16.2 Visual defects criteria (black specks, warpage, flash) applied?
16.3 Leak/drop/fit tests (if applicable) performed?
16.4 Compliance documents (resin grade/pharma suitability) maintained?

17) How do you control caps/closures?

17.1 Torque/fit compatibility checks defined and executed?
17.2 Liner type/compatibility verified?
17.3 Tamper-evident/child-resistant functional checks (if applicable)?
17.4 Mix-up prevention for similar colors/sizes (visual control)?

18) For Eye Drops: how do you control droppers/nozzles?

18.1 Orifice size/drop rate requirement defined and tested?
18.2 Assembly/fit trial with bottle/closure documented?
18.3 Visual cleanliness/particulate checks defined?
18.4 Material compatibility documentation maintained?

19) For sterile products: how do you control glass vials/ampoules?

19.1 Dimensional checks (neck, height, brimful capacity) performed?
19.2 Cosmetic defect criteria (cracks, bubbles, stones) used?
19.3 Glass type/hydrolytic resistance documentation verified (Type I where required)?
19.4 Traceability and storage protection to prevent breakage/contamination?

20) For sterile injections: how do you control rubber stoppers?

20.1 CoA/lot traceability includes formulation/compound lot?
20.2 Visual defects/particulate/blemish criteria defined and used?
20.3 Washed/siliconized/sterilized status verified (RTU vs non-RTU)?
20.4 Storage conditions (temp/RH) controlled and documented?

21) How do you control aluminium seals / flip-off caps?

21.1 Dimensional/fit verification on vial finish?
21.2 Risk of lacquer/paint flaking assessed?
21.3 Functional crimp trial (if applicable) performed?
21.4 Color/print mix-up prevention controls?


Printed Materials (Highest Mix-up Risk)

22) How do you control Artwork (master data)?

22.1 Where is the master Artwork stored (controlled system/access control)?
22.2 How do you ensure correct version/revision (current vs obsolete)?
22.3 Who verifies regulatory text/strength/warnings (QA/RA approval)?
22.4 Show Artwork approval workflow and final approved master.

23) Incoming control for printed labels?

23.1 Verify correct text, strength, batch/expiry fields, layout—checklist used?
23.2 Barcode/2D code readability verification performed?
23.3 Adhesive performance checks (peel) done where required?
23.4 Label roll direction/winding/orientation verified?

24) Incoming control for cartons?

24.1 Print quality, color, legibility, cut/crease alignment verified?
24.2 Carton dimensions and folding trial performed?
24.3 Security features (hologram/tamper seal) verified if applicable?
24.4 Coding area (batch/expiry) correct and readable?

25) Incoming control for leaflets/inserts?

25.1 Confirm correct text version (latest PI/SmPC) against approved Artwork?
25.2 Pagination/order verified (page sequence correct)?
25.3 Paper GSM/size/fold orientation verified?
25.4 Smudging/ink transfer criteria checked?

26) How do you perform text reconciliation against approved Artwork?

26.1 Is it line-by-line proofing or sample-based? SOP requirement?
26.2 Do you use a “golden sample”/approved reference for comparison?
26.3 What is the workflow if mismatch found (quarantine + deviation + supplier notification)?
26.4 Do you check for unintended changes vs previous lot?

27) How do you control obsolete printed materials?

27.1 Obsolete labels/cartons/leaflets stored in locked segregated area?
27.2 Obsolete destruction record with witness?
27.3 ERP block to prevent issue of obsolete item codes?
27.4 Line clearance checklist includes “obsolete search” step?


Storage, Handling, Issuance & Reconciliation

28) Packaging material storage conditions (Temp/RH) control?

28.1 Continuous or daily monitoring with alarms?
28.2 Humidity-sensitive items (leaflets/labels) in controlled conditions?
28.3 Excursion handling with impact assessment?
28.4 FEFO/FIFO practiced—show a physical example.

29) Handling control for roll goods (foil/film/labels)?

29.1 Protection against edge damage (stands/pallets/wrapping)?
29.2 Roll ID label intact and readable throughout storage/use?
29.3 Partial roll return—status relabeling and quarantine controls?
29.4 Dust protection (covered storage) and housekeeping?

30) Packaging material status labels (Approved/Rejected) governance?

30.1 Who issues labels and where recorded?
30.2 If label missing, is material automatically put on hold?
30.3 Approved label applied only after QA release—verified?
30.4 Rejected label triggers physical lock and segregation?

31) Material issuance to packaging line control?

31.1 Issue only after QA/QC release confirmation?
31.2 Dual check/barcode scanning to prevent wrong issue?
31.3 Issued quantity checked vs BOM/requirement?
31.4 Wrong-issue near-miss reporting exists?

32) On-line print verification (in-process checks) control?

32.1 Start-up “first-off approval” performed and signed?
32.2 Batch coding (batch no., mfg/exp) accuracy verified and recorded?
32.3 Vision system/barcode verifier challenge test performed?
32.4 In-process check frequency defined and followed?

33) Line clearance between batches—effectiveness?

33.1 Line clearance checklist covers all printed items and components?
33.2 QA verification and sign-off before start?
33.3 Checks include under machines/bins/surrounding areas?
33.4 Clearance failure triggers deviation?

34) Packaging reconciliation (issued vs used vs returned vs destroyed)?

34.1 Reconciliation performed for each batch with defined method?
34.2 Printed materials counted piece-by-piece vs estimate—SOP requirement?
34.3 Discrepancy triggers deviation investigation and CAPA?
34.4 QA reviews and approves reconciliation records?

35) Control of returned packaging materials (open/part-used)?

35.1 Returned materials labeled “Opened/Part-used” with date and status?
35.2 Returned quantities verified and recorded?
35.3 Segregated storage for returned items?
35.4 Reuse criteria (time/condition) clearly defined?

36) Control of scrap/waste destruction (printed items security risk)

36.1 Printed scrap is shredded/defaced before disposal?
36.2 Destruction record includes item, qty, date, witness?
36.3 Security controls prevent scrap leaving uncontrolled?
36.4 If outsourced destruction, is vendor qualified?


Sterile Packaging Component Special Controls

37) Sterile components cleanliness/pack integrity control?

37.1 Incoming cleanliness/visible particles criteria defined?
37.2 RTU vs non-RTU status clearly verified?
37.3 Sterile wrap integrity checks (tear/wet/puncture) performed?
37.4 Storage in controlled segregated area?

38) Supplier sterilization/irradiation documentation control (if applicable)

38.1 Gamma/ETO certificate reviewed and accepted?
38.2 Certificate lot matches your received lot (traceability)?
38.3 Requirements like SAL addressed (where applicable)?
38.4 Certificate authenticity verification practice?

39) CCIT awareness—packaging component changes impact?

39.1 Stopper/vial/seal change triggers CCIT impact assessment?
39.2 Supplier/lot change risk assessment exists?
39.3 Complaint trending (leakers) by component lot?
39.4 Sterile failure investigations consider packaging component linkage?


Change Control / Deviations / Complaints / People

40) Packaging specification control (dimensions/print requirements)

40.1 Spec master list + version control exists?
40.2 Spec changes via Change Control with QA approval?
40.3 “Golden sample”/reference retains maintained?
40.4 Obsolete spec usage prevention?

41) Supplier change control for packaging materials

41.1 Supplier change notifications are captured in Change Control?
41.2 Impact assessment includes seal/stability/leachables risks (as applicable)?
41.3 Line trial evidence recorded before implementation?
41.4 QA approval gate before use?

42) Deviation management for packaging issues

42.1 Deviations opened for print mismatch, damage, shortage, reconciliation mismatch?
42.2 Root cause analysis covers supplier vs handling vs line causes?
42.3 CAPA tracking to closure?
42.4 Effectiveness check to ensure recurrence reduced?

43) Complaint/market feedback linkage to packaging lots

43.1 Complaint trends for label peeling/smudging/wrong leaflet tracked?
43.2 Packaging lot traceability to batch ensured?
43.3 Retain packaging samples kept for investigation?
43.4 Supplier notification and CAPA integration?

44) GDP compliance of packaging QC records

44.1 Controlled forms with issuance/reconciliation?
44.2 Corrections follow GDP (single-line strike, sign/date/reason)?
44.3 Blank spaces controlled (NA/strike-through)?
44.4 No uncontrolled loose papers?

45) Printed materials issuance/return/destruction registers

45.1 Issuance/return/destruction entries are contemporaneous?
45.2 Dual witness where required is followed?
45.3 Periodic review by supervisor/QA?
45.4 Records are retrievable and complete?

46) ERP/BOM control for packaging components

46.1 BOM links correct component codes (no alternates without control)?
46.2 System controls prevent wrong pick (scan/validation)?
46.3 Substitution requires QA approval and documentation?
46.4 ERP audit trail is reviewed for changes?

47) Training & competency (packaging QC/warehouse/line)

47.1 Training matrix covers Artwork, line clearance, reconciliation?
47.2 New personnel qualification before independent work?
47.3 Refresher training schedule exists?
47.4 Near-miss lessons lead to training updates?

48) Women Hormone (potent) packaging segregation & controls

48.1 Hormone packaging materials segregated in storage and issuance?
48.2 Visual controls/color coding to prevent mix-up?
48.3 Enhanced line clearance for hormone products evidence?
48.4 Rules on reuse/return of hormone printed materials defined?

49) Potent/hormone packaging waste handling

49.1 Hormone packaging scrap destroyed with segregation controls?
49.2 Disposal records with witness and traceability?
49.3 Security controls prevent scrap leaving uncontrolled?
49.4 EHS requirements followed and documented?

50) Final packaging material release decision control

50.1 QC release checklist covers spec + CoA/CoC + inspection results?
50.2 QA disposition gate exists (no release without QA approval)?
50.3 Informal release (verbal/email) prevented by procedure/system?
50.4 Traceability: packaging lot → finished batch mapping is available and retrievable?

FINISHED PRODUCT QC (50 Points)

1) Is the finished product sampling plan defined and followed?

1.1 Show SOP for tablet/capsule sampling (start/middle/end at compression/packing).
1.2 For sterile batches, show filling start/middle/end sampling + intervention sampling.
1.3 Who samples (QC/production) and what oversight exists?
1.4 If sampling is missed/late, is deviation raised?

2) Is sampling representative in practice?

2.1 Do you sample across shippers/cartons/positions (evidence in record)?
2.2 Do you sample across bins/drums for bulk?
2.3 Are shift changes/line speed changes considered?
2.4 Do records show convenience sampling patterns?

3) Are samples labeled correctly to prevent mix-ups?

3.1 Label includes product, strength, batch, stage, time, sampler ID?
3.2 Printed labels from LIMS used? If handwritten, verification step?
3.3 GDP corrections applied correctly on label/record?
3.4 Tamper-evident seals used where required?

4) Is chain of custody maintained?

4.1 Sample receipt log includes time/receiver signature?
4.2 Seal integrity checked on receipt and documented?
4.3 Sample storage location recorded (rack/fridge)?
4.4 Lost/broken sample triggers deviation?

5) Are samples segregated in the lab (multiple batches)?

5.1 Separate trays/racks/areas used for different batches/products?
5.2 “Unattended samples” prevented by SOP?
5.3 Retest samples uniquely identified and controlled?
5.4 LIMS login is timely (no back-entry)?

6) Is the correct specification (current version) always used?

6.1 LIMS auto-selects specs by product code/strength? Show mapping.
6.2 Obsolete spec/worksheet use prevented?
6.3 Market/registration specs controlled and mapped?
6.4 Analysts trained on spec revisions with evidence?

7) Are all required release tests performed?

7.1 Release vs periodic test matrix exists and is followed?
7.2 Missing tests block release/CoA in system?
7.3 Skip testing rules require QA approval + justification?
7.4 Out-of-schedule testing tracked and investigated?

8) Is method validation/verification linked to current formulation/process?

8.1 Validation report matches current strength/matrix?
8.2 Change control triggers revalidation where needed?
8.3 Compendial method verification exists?
8.4 Robustness and critical parameters are defined?

9) Is method revision control effective at the bench?

9.1 Controlled STP access; analysts confirm latest revision?
9.2 Critical steps are clearly highlighted (time/temp/pH)?
9.3 Method deviations handled via deviation system?
9.4 Training completed before method effective date?


HPLC/GC (High risk)

10) Are HPLC systems qualified and maintained?

10.1 IQ/OQ/PQ, calibration, PM current?
10.2 Breakdown deviation + impact assessment exists?
10.3 Column history maintained?
10.4 Alarm/limits functional (pressure/leak)?

11) Is HPLC sequence setup controlled?

11.1 Sequence includes blank, SST, standards, bracketing, samples?
11.2 Carryover checks included (blank after high standard)?
11.3 Sequence templates locked/controlled?
11.4 Peer review of sequence setup documented?

12) Are SST criteria defined and failures handled correctly?

12.1 SST criteria documented (RSD, tailing, plates, resolution)?
12.2 SST failure checklist used before rerun?
12.3 Rerun/reinject rules strict and controlled?
12.4 SST calculations independently reviewed?

13) Is standard preparation controlled (HPLC/GC)?

13.1 Potency correction applied with documented calculations?
13.2 Prepared-by and checked-by signatures present?
13.3 Standard solution expiry/hold time defined and followed?
13.4 Storage conditions maintained and recorded?

14) Is sample preparation controlled (HPLC/impurities)?

14.1 Weighing traceability (balance ID/log) maintained?
14.2 Extraction/sonication time and conditions controlled?
14.3 Filter compatibility/adsorption evidence exists?
14.4 Sample solution stability/reinject window defined?

15) Is integration/reprocessing controlled? (common loophole)

15.1 Integration guideline exists (baseline/peak split/merge)?
15.2 Manual integration requires documented justification?
15.3 Audit trail captures changes and reviewer signs?
15.4 Selective integration only to “make pass” is monitored and prevented?

16) Chromatography data integrity controls

16.1 Unique user logins (no shared accounts)?
16.2 Audit trail enabled and reviewed per batch/periodic?
16.3 Deleted injections/runs justified and reviewed?
16.4 Backup/archival and retrieval testing exists?

17) Calculation/transcription controls

17.1 Instrument→LIMS interface validated (if used)?
17.2 Manual entry double-checked and documented?
17.3 Rounding/unit conversion rules defined and followed?
17.4 CoA vs LIMS reconciliation step exists?


Dissolution (Tablet/Capsule)

18) Is dissolution apparatus qualified and verified?

18.1 Mechanical checks (RPM/temp/centering/wobble) current?
18.2 Vessel verification/PVT performed if required?
18.3 Cleaning logs and carryover prevention present?
18.4 Timer accuracy verified periodically?

19) Is dissolution media preparation controlled?

19.1 Media pH adjustment/verification recorded?
19.2 Degassing method standardized and followed?
19.3 Media temperature at start controlled and recorded?
19.4 Media hold time defined and followed?

20) Is dissolution sampling/timing controlled?

20.1 Sampling time accuracy maintained; delays recorded?
20.2 Volume replacement/correction rules followed?
20.3 Filter compatibility evidence exists?
20.4 S1/S2/S3 stage rules correctly applied?

21) Dissolution failures—investigation discipline

21.1 Single vessel failure handled per SOP (not immediate rerun)?
21.2 Mechanical checks reviewed during investigation?
21.3 Retest rules controlled with approvals?
21.4 OOT trending used to detect gradual drift?


KF / GC / Physical tests

22) KF controls (instrument + reagents)

22.1 Drift/blank limits defined and monitored?
22.2 Reagent factorization schedule followed?
22.3 Moisture pickup prevented during sample handling?
22.4 High drift triggers investigation/actions?

23) KF calculation and verification

23.1 Template validated (LIMS/controlled Excel)?
23.2 Duplicate determination rules defined?
23.3 Reviewer sign-off on results?
23.4 Moisture OOT trending performed?

24) GC residual solvents controls (if applicable)

24.1 SST/curve criteria defined and met?
24.2 Headspace vial crimp/leak controls in place?
24.3 Reinjection policy controlled with justification/approval?
24.4 Parameter changes controlled via change control?

25) Tablet/Capsule physical tests control

25.1 Equipment calibration/verification current?
25.2 Sample selection and sample size representative?
25.3 Retest rules controlled and documented?
25.4 GDP recording and independent review performed?

26) Content Uniformity (CU) governance

26.1 CU sampling rules and method are current?
26.2 Calculation template validated and formulas locked?
26.3 Rounding rules defined and followed?
26.4 Acceptance stage rules correctly applied with second review?


Sterile product related QC interfaces

27) Eye drops appearance/clarity/visible particles control

27.1 Light box qualification and maintenance records current?
27.2 Acceptance criteria clearly defined (objective guidance)?
27.3 Operator training/qualification documented?
27.4 Retest/recheck rules controlled?

28) Eye drops pH/osmolality/viscosity controls

28.1 Instrument calibration/verification current?
28.2 Standards/buffers expiry controlled?
28.3 Sample temperature equilibration rules defined?
28.4 Cleaning between samples prevents carryover?

29) Injections particulate/clarity testing (if applicable)

29.1 Instrument qualification and method control?
29.2 Sample handling SOP followed?
29.3 Failure triggers investigation (not only retest)?
29.4 Trending by line/shift performed?

30) Sterile batch release gating (Sterility/LAL completion)

30.1 QA disposition requires sterility and LAL completion?
30.2 ERP/LIMS gate blocks release if micro pending?
30.3 Conditional release criteria controlled by SOP?
30.4 Missing/late micro results handled via deviation/hold?

31) Sterile filtration integrity test linkage (if applicable)

31.1 Pre/post integrity test records attached to batch?
31.2 Equipment calibration and operator training current?
31.3 Failure triggers deviation + impact assessment?
31.4 Traceability between integrity test and batch ensured?

32) CCIT status and change impact

32.1 CCIT validation/verification exists and is current?
32.2 Routine monitoring plan defined?
32.3 Packaging change triggers CCIT impact assessment?
32.4 Complaint trend (leakers) linked to component lots?


Women Hormone (Potent) controls in QC

33) Women Hormone sample handling segregation

33.1 Dedicated hood/area for hormone sample preparation?
33.2 Dedicated tools/consumables (spatulas, vials, filters)?
33.3 PPE requirements defined and followed?
33.4 Potent waste segregated and disposed with records?

34) Hormone cross-contamination prevention

34.1 Line clearance/area clearance checklist before/after hormone work?
34.2 Shared equipment cleaning verification (balance/sonicator) documented?
34.3 Scheduling controls (end-of-day/segregated sessions) defined?
34.4 Spill response and decontamination records maintained?

35) Hormone cleaning verification effectiveness

35.1 Acceptance criteria defined (visual/swab limits) with rationale?
35.2 Cleaning records specify what was cleaned and by whom?
35.3 Cleaning failures trigger deviation + impact assessment?
35.4 Periodic effectiveness review/trending performed?


Documentation / Data integrity / QMS

36) Controlled worksheets and forms (GDP)

36.1 Controlled form issuance and reconciliation (serial numbers)?
36.2 Missing worksheets trigger investigation?
36.3 Corrections follow GDP (single-line, sign/date/reason)?
36.4 Blank spaces controlled (NA/strike-through)?

37) Logbooks discipline (equipment/instruments)

37.1 Logbook entries contemporaneous and complete?
37.2 No blank spaces; corrections controlled?
37.3 Periodic supervisor review documented?
37.4 Backdating prevention controls exist?

38) Excel templates control (if used)

38.1 Validation report exists for the template?
38.2 Formulas locked and access controlled?
38.3 Version control prevents use of local/old copies?
38.4 Changes require QA approval via change control?

39) LIMS/e-signature controls

39.1 Unique users and role permissions defined?
39.2 Result edits require reason and approval?
39.3 Audit trail review performed with evidence?
39.4 User disable/transfer access removal controlled?

40) Finished product OOS handling

40.1 Phase-I lab investigation checklist used?
40.2 Retest occurs only after investigation and with approvals?
40.3 Resampling only with proven sampling error?
40.4 CAPA effectiveness verified?

41) OOT trending program

41.1 Trending parameters defined (assay, impurities, dissolution, moisture)?
41.2 Review frequency and trigger limits defined?
41.3 Documented actions taken based on trends?
41.4 QA/QC approval of trend reports?

42) Deviation management (lab deviations)

42.1 Clear triggers (late tests, wrong reagent, excursions)?
42.2 Overdue tracking and escalation?
42.3 Impact assessment signed by QC+QA?
42.4 CAPA effectiveness checks performed?

43) Stability program control

43.1 Stability protocol and pull schedule adhered to?
43.2 Chamber qualification/mapping current?
43.3 Excursions investigated with QA impact assessment?
43.4 Missed pulls handled via deviation?

44) Stability data integrity and accountability

44.1 Sample accountability (stored/pulled/tested) reconciled?
44.2 Raw data package review same as release testing?
44.3 Stability OOT trending performed?
44.4 Stability summary/report approval workflow exists?

45) Retain sample controls (finished)

45.1 Retains kept in market pack with correct components?
45.2 Storage conditions monitored and excursions handled?
45.3 Access/removal log maintained?
45.4 Quantity sufficient for investigation?

46) Batch release workflow QC → QA → Dispatch

46.1 QA checklist includes deviations/OOS/OOT/stability/micro status?
46.2 ERP dispatch blocked before QA release?
46.3 CoA template/version control enforced?
46.4 Informal release prevented by policy/system?

47) Informal release prevention (verbal/email)

47.1 Policy exists and training completed?
47.2 Exception handling via deviation + QA approval only?
47.3 Evidence of periodic checks for informal release?
47.4 Warehouse awareness verified?

48) Analyst training/authorization

48.1 Authorization list for HPLC/GC/Dissolution/KF exists?
48.2 New analyst qualification and supervised runs documented?
48.3 Refresher training schedule exists?
48.4 Analyst error trends used for retraining?

49) Instrument breakdown handling

49.1 Breakdown triggers deviation/incident record?
49.2 Impact assessment on tested batches performed?
49.3 Requalification after repair completed?
49.4 Service reports archived and QA closed?

50) Near-miss and continuous improvement

50.1 Near-miss log exists (wrong label, late test, sample mix-up)?
50.2 Root cause and lesson learned documented?
50.3 SOP/training updates implemented?
50.4 Recurrence monitoring performed?


MICROBIOLOGY (50 Points)

1) Is microbiology lab zoning/segregation adequate?

1.1 Sterility testing area separated from culture handling/media prep?
1.2 Rules prevent non-sterile work entering sterility zone?
1.3 Access control and entry logs implemented?
1.4 Separate waste exit route to prevent cross contamination?

2) How is personnel flow controlled?

2.1 Entry logs maintained (who/when/why)?
2.2 Maintenance/visitors controlled with permission and records?
2.3 Door opening events managed/recorded if relevant?
2.4 Rules to minimize unnecessary movement displayed/trained?

3) Is gowning SOP clear and followed?

3.1 Gowning steps clearly documented (visual/steps)?
3.2 Gowning compliance checks performed (mirror/supervisor)?
3.3 Sterile gown/glove inventory and expiry controlled?
3.4 Gowning area cleanliness/segregation maintained?

4) Aseptic technique qualification for sterility testing analysts

4.1 Analyst qualification required before independent sterility testing?
4.2 Requalification frequency defined and executed?
4.3 Failure handling (retraining/restriction) defined?
4.4 Qualification records complete (date, assessor, result)?

5) Cleaning program—frequency and accountability

5.1 Cleaning schedule by room/grade documented?
5.2 Responsibilities defined (micro vs housekeeping)?
5.3 Verification/review signatures present?
5.4 Missed cleaning triggers deviation?

6) Disinfectant rotation program

6.1 Rotation includes alcohol + QAC + sporicidal?
6.2 Rotation plan/calendar available?
6.3 Rotation changes controlled via change control?
6.4 Justification exists if rotation not used?

7) Disinfectant preparation/dilution control

7.1 Calculation sheet available and followed?
7.2 Labels include name, concentration, prep date/time, expiry, prepared/checked by?
7.3 “Top-up” prohibited and monitored?
7.4 Expired disinfectant disposal logged?

8) Disinfectant contact time compliance (observe)

8.1 Contact time defined in SOP?
8.2 Wet contact time maintained (not immediate wipe)?
8.3 Timers/visual reminders used?
8.4 High-touch surfaces receive proper contact time?

9) Cleaning tools segregation (mops/wipes)

9.1 Dedicated tools by area with color coding?
9.2 Decontamination/laundering procedure defined?
9.3 Prevent dirty-to-clean tool transfer?
9.4 Clean dry storage of tools ensured?


Environmental Monitoring (EM)

10) Is EM plan risk-based and documented?

10.1 EM map includes critical points (doors, return air, interventions)?
10.2 Frequency defined per grade/operation?
10.3 Methods defined (active air/settle/contact/swab/personnel)?
10.4 Annual review of EM plan performed?

11) EM sampling technique training

11.1 Training records for active air/settle/contact/swab sampling?
11.2 Standardized pressure/area for contact plates?
11.3 Swab area templates used and trained?
11.4 New sampler supervised until qualified?

12) Active air sampler calibration/controls

12.1 Calibration certificates current?
12.2 Flow verification before use documented?
12.3 Cleaning/decontamination SOP exists?
12.4 Missed sampling due to breakdown handled via deviation?

13) Settle plate controls

13.1 Exposure time standardized in SOP?
13.2 Placement rules defined and followed?
13.3 Labeling complete (location, date/time, operator)?
13.4 Handling of knocked/overexposed plates defined?

14) Surface monitoring (contact plates)

14.1 Pressure/time technique standardized?
14.2 Site list and frequency defined?
14.3 Media lot release confirmed before use?
14.4 Failures trigger cleaning/investigation and controlled resampling?

15) Swab monitoring controls

15.1 Swab area size standardized (template)?
15.2 Neutralizer use defined where needed?
15.3 Transport/holding time controlled?
15.4 Swab labeling/traceability ensured?

16) Personnel monitoring program

16.1 Monitoring points defined (gloves/sleeves/forearm/chest)?
16.2 Timing defined (exit/after interventions)?
16.3 Failure response defined (retrain/restrict/increased monitoring)?
16.4 Trending by person/shift to detect recurrence?

17) EM incubation parameters and control

17.1 Incubation temperatures/durations defined?
17.2 Incubator monitoring logs maintained?
17.3 Plate inversion/stack height controlled?
17.4 Incubation excursions investigated?

18) EM data review discipline

18.1 Daily/weekly review and sign-off performed?
18.2 Monthly/quarterly trending reports generated?
18.3 Conclusions and actions documented?
18.4 QA review/approval where required?

19) Alert/Action limits governance

19.1 Limits based on historical data/capability or justified reference?
19.2 Limits differ by grade/area as appropriate?
19.3 Alert vs action responses defined and followed?
19.4 Limits reviewed periodically with QA approval?

20) EM excursion investigation quality

20.1 Immediate containment actions defined (reclean/restrict/resample rules)?
20.2 Resampling controlled (not “resample until pass”)?
20.3 Root cause analysis documented (5-why)?
20.4 CAPA effectiveness verified via follow-up EM results?

21) Organism identification (ID) for excursions

21.1 ID required for action-level excursions/sterility positives?
21.2 ID method verified (MALDI/API/biochemical) with controls?
21.3 Recurrence database maintained and reviewed?
21.4 Objectionable organisms escalation procedure exists?


Media / Autoclaves / GPT

22) Media receipt and storage control

22.1 Vendor CoA reviewed and signed?
22.2 Expiry and damage checks performed?
22.3 Storage conditions (temp/RH) monitored?
22.4 Open-date control for dehydrated media?

23) Media preparation records

23.1 Weighing records include balance ID, quantities, operator?
23.2 pH adjustment recorded (target vs actual)?
23.3 Autoclave cycle printouts attached?
23.4 Labels complete (media name/lot, prep date, expiry)?

24) Autoclave routine monitoring

24.1 Each cycle reviewed/signed (time/temp/pressure)?
24.2 Load pattern controlled per SOP?
24.3 Chemical indicator use and acceptance criteria?
24.4 Failed cycle handling (quarantine/investigation/discard)?

25) Autoclave validation/mapping

25.1 Mapping report includes worst-case load?
25.2 Cold spot identified and BI placement justified?
25.3 Requalification after repair/relocation performed?
25.4 Validation approved by QA?

26) Media sterility check program

26.1 Sterility check sampling plan defined?
26.2 Incubation conditions/time defined?
26.3 Sterility failure triggers quarantine/discard of media lot?
26.4 Investigation includes autoclave/pouring/handling review?

27) GPT (Growth Promotion Test) compliance

27.1 GPT frequency defined and followed per media lot?
27.2 ATCC strains controlled and correct strains used?
27.3 Inoculum CFU target controlled/verified?
27.4 GPT failure investigation and media hold documented?

28) Culture/strain management

28.1 Master vs working stock separation?
28.2 Passage limits defined and controlled?
28.3 Freezer (-80°C) monitoring and alarm response logs?
28.4 Purity/contamination checks performed?


Sterility Testing

29) Sterility test method control (Membrane filtration/Direct inoculation)

29.1 SOP current and method clearly defined?
29.2 Method suitability (inhibition/neutralization) current per product?
29.3 Units/volumes per pharmacopeia followed?
29.4 Sample holding time controlled (sampling → test start)?

30) Sterility test environment (BSC/Isolator) controls

30.1 BSC certification current (HEPA/airflow/smoke)?
30.2 Cleaning/decontamination validated and recorded?
30.3 Work practices (arrangement, slow movements) defined in SOP?
30.4 UV reliance (if any) supported by effectiveness validation?

31) Sterility test execution discipline

31.1 Analyst aseptic qualification current?
31.2 Media lot released (GPT + sterility check pass) before use?
31.3 Incubation dual temperature controlled (if required)?
31.4 Results reading second-person verification performed?

32) Sterility positive investigation

32.1 Organism ID mandatory for positives?
32.2 “Lab contamination” conclusion requires defined evidence?
32.3 Batch impact assessment and QA disposition documented?
32.4 Retesting rules controlled to prevent testing into compliance?


Endotoxin / LAL

33) LAL method control

33.1 LAL validation/verification exists (product-specific where required)?
33.2 PPC criteria defined; failure handling defined?
33.3 Standard curve acceptance criteria defined?
33.4 Calculation template controlled/validated?

34) LAL reagents/consumables control

34.1 LRW storage/expiry controlled?
34.2 CSE/RSE traceability and sensitivity verification?
34.3 Pipette calibration (µL) current?
34.4 Endotoxin-free consumables controlled and verified?

35) Depyrogenation controls (if applicable)

35.1 Depyrogenation oven cycle validated?
35.2 Load configuration controlled?
35.3 Cycle record review and sign-off?
35.4 Post-cycle protection (covered storage) to avoid recontamination?


Non-sterile Micro (MLT / Bioburden) + Data Integrity + Utilities

36) Non-sterile MLT method suitability

36.1 Product inhibition/neutralization studies available?
36.2 Neutralizer selection justified and documented?
36.3 Formula change triggers re-suitability testing?
36.4 Suitability results reviewed/approved?

37) Non-sterile sample holding time controls

37.1 Sampling/receipt/test start timestamps recorded?
37.2 Holding conditions (temp) defined and followed?
37.3 Delays trigger deviation + impact assessment?
37.4 Transport/handling SOP exists?

38) Plate counting rules and consistency

38.1 Countable range and TNTC rules defined?
38.2 TNTC handling (next dilution/repeat) defined?
38.3 No overwriting; GDP corrections used?
38.4 Second-person verification for critical results?

39) PW/WFI sampling technique control

39.1 Tap sanitization method and time defined?
39.2 Flush time/volume standardized?
39.3 Sterile bottles used; neutralizer used where needed?
39.4 Sampler training documented?

40) Water microbiology testing and trending

40.1 Test method/incubation conditions defined and followed?
40.2 Alert/action limits defined and justified?
40.3 Trend reports generated to detect upward drift?
40.4 Upward trends trigger biofilm action plan and sanitization review?

41) Water OOS handling and batch impact assessment

41.1 QA/production notified promptly?
41.2 Affected batches/cleaning/production assessed and documented?
41.3 Corrective action (sanitization/maintenance) recorded?
41.4 Effectiveness check verified (post-action results)?

42) Water sanitization program governance

42.1 Sanitization schedule adherence evidence?
42.2 Post-sanitization monitoring defined and followed?
42.3 Deviations handled and documented?
42.4 Engineering interface and approvals documented?

43) Compressed air/gas micro monitoring (if applicable)

43.1 Sampling points list is risk-based and approved?
43.2 Frequency/limits defined?
43.3 Failures investigated with CAPA?
43.4 Trends reviewed periodically?

44) Micro GDP for plates/worksheets

44.1 Plate labels complete and traceable (date, location, operator)?
44.2 Counts recorded contemporaneously (not later from memory)?
44.3 Corrections follow GDP (single-line, sign/date/reason)?
44.4 Uncontrolled loose papers prohibited and monitored?

45) Plate retention and disposal controls

45.1 Retention time defined in SOP?
45.2 Plates retained during investigations as required?
45.3 Disposal logs maintained (date, method, witness if required)?
45.4 Early disposal triggers deviation?

46) Preventing “recount until pass”

46.1 Recount rules defined (when allowed, who can recount)?
46.2 Discrepant counts handled by SOP (tie-break rules)?
46.3 Second-person verification applied to critical counts?
46.4 Recount history documented?

47) Micro computerized systems data integrity (if used)

47.1 Unique logins and role permissions?
47.2 Result changes require reason capture?
47.3 Audit trail review performed with evidence?
47.4 User access removal controlled when personnel change?

48) Micro OOS/deviation investigations

48.1 Investigation checklist covers media/incubator/technique/environment?
48.2 Evidence attached (photos, plates, ID reports)?
48.3 Root cause documented (5-why) with CAPA?
48.4 Effectiveness check performed and documented?

49) Change control impact on microbiology

49.1 Changes to media/disinfectants/equipment captured in Change Control?
49.2 Verification/revalidation performed where required?
49.3 Training updated before implementation?
49.4 Post-change monitoring plan defined?

50) Batch disposition interface (Micro → QA release)

50.1 QA release requires completion of sterility/LAL/critical EM?
50.2 Critical findings communicated promptly to QA/production?
50.3 Hold/release decisions traceable and documented?
50.4 Conditional release (if any) controlled by SOP and risk assessment?

Comprehensive QC Department Audit Checklist Read More »

Comparative Dissolution Study procedure

Comparative Dissolution, General Overview

[][]Comparative Dissolution, Oral dosage form like Table & Capsule are more popular than IV/IM(Intravenous/Intramuscular) Injection formulation. From the very beginning, people are most familiar with oral solid dosage form (Tablet, Capsule, Powder etc.) and becoming more popular till today as no special technique or device is not require to administer these products and associated pain is not involved here.

[][]In the period of time its are considered as the most effective and efficient method to treat the patient. This orally taken drugs are dissolved in GI (Gastro Intestinal) fluid and then bioavailable at the systemic circulation as it absorbed here. To measure the bioavailability of a certain drugs (in vivo Analysis, vivo is Latin for “within the living, test perform in living organism) is not accurately possible due to its complex nature.

[][]For this reason, in vitro (vitro is Latin for “within the glass, test perform outside the living organism) methods are followed to measure the dissolution rate of a certain drugs. This method is officially recognized by certain regulatory authority and it(in vitro study) considered most convenient way to develop new formulation of oral solid dosage form.

Comparative Dissolution Consideration

[][]Dissolution method is the best option for the lower strength drug where different strength is proportionally formulated to acquire the biowaiver of certain formulated drug. For a certain product which higher strength bioequivalence study has been carried out and found proportional to the concentration then biowaiver is conceivable to the lower strength.

Dissolution test are considering the most quality control tool for the commercial batch to batch product to monitor its consistency over a certain period of time. It also provides significant information during post approval changes of the certain product as changes made in formulation, manufacturing process and different scale up procedure.

[][]The most physiological factor is considered as the dissolution and solubility of the API and its permeability through the membrane of the GI[Gastro Intestinal] tract. As this measurement is so prone to error due to its complex nature then in vitro study consider the most convenient and reliable procedure to achieve the required target. During development of a certain solid dosage form, dissolution is considered as the best option to determine its quality parameter which have the great impact on the bioavailability of the formulated product.

Comparative Dissolution, Waiver of in vivo bioavailability

[][]BCS system applied in this case so that waiver for in vivo analysis can be assured. BCS [Biopharmaceutical Classification System] is a system which measure the permeability and solubility of drugs in a certain prescribed condition.

[][]The actual aim of BCS is to aid the post approval changes and arranging approval activities based on in vitro data studies.

This system has been optimized based on the oral solid dosage unit as most of the market products are available at oral dosage form [More than 50% total market share, US$23.4 Bn in 2021, US$24.7 Bn in 2022 as estimated, growth rate 5.9%).

[][]Waivers[ means giving permission to skip in vivo bioequivalence study] is actually reserved for those products that meet the specific requirements of solubility & permeability & most of the cases rapid dissolve in body fluid.

[][]Using the BCS, appropriate formulation study shall be developed such as Type II drugs designed as Permeable but insoluble, this class is not the actual right candidate for development of a new moiety.

[][]So, solubility shall be developed to acquire the right dissolution profile. Based on the solubility and permeability BCS has classified the four categories of the product as depicted below

Dosage form challenge

[][]Comparison has been drawn from old drug to new drug formulation, where older drugs compare to the current products are more prone to solubilities. Class II compound has been remarkably increased as 30% to 60% where class I compound has down to 40% to 20% where low solubility has the main cause to encounter the issue.

 A oral solid dosage form is the preferred option but all time this can’t possible the suspension or solution is continued to prove its existence  

[][]Generally a highly soluble active substance and rapidly dissolve dosage form provide better bioavailability and in this case biowaiver can be waived for bioequivalence studies base on its dissolution profile.

[][]If a active substance found low solubility but high permeability then the rate limiting steps of absorption may be consider as dissolution. Most of the cases dissolution profile control the more than one of excipients or special design matrix compounds. So Test condition may be consider as various time frame (10, 15, 20,30, 45 & 6 minutes).

[][]Drugs that are poor soluble in water then various time frame are considered and accepted timeframe is set for dissolution profile. Here USP Type 4 apparatus to be used to develop such type dissolution profile. Most of the time, monograph for combination product is not available at BP or USP the individual monograph shall be used to set the dissolution profile.

Selection of Dissolution Media

Selection of the dissolution media is the vital point to achieve the goal. pH of the media as the key role as all of the dosage form goes to GI[Gastro Intestinal] tract so pH shall be simulate with the GI Tract environment. pH shall be 1.2 to 6.8 which is the physiologic pH range of the body.

ZonepH
[A]Pre-prandial
Stomach
1.8(1~3)
Duodenum6.0(4~7)
Upper Jejunum 6.5(5.5~7)
Lower Jejunum 6.8(6~7.2)
Upper Ileum7.2(6.5~7.5)
Lower Ileum7.5(7~8)
Proximal Colon(5.5 ~6.5)
[B]Post-prandial
Stomach
4.0(3~6)
Duodenum5.0(4~7)
Upper Jejunum 5.5(5.5~7)
Lower Jejunum 6.5(6~7.2)
Upper Ileum7.2(6.5~7.5)
Lower Ileum7.5(7~8)
Proximal Colon(5.5 ~6.5)

Dissolution Statistics

Different cases obtaining after multipoint dissolution which is calculative as follows:
[][]If Test Product and Reference Product both shows dissolution rate more than 85% within first 15 minutes then no calculation is required, they are considered as similar. If it didn’t achieved then seek for next step.
[][]Seek for f2 value[ f2, similarity factor] if f2>50% then it consider similar then in vivo study is not required.
[][]Difference Factor [f1] is the percentage (%) difference between the two curve at the each time period and also measure the relative error between two curve.

How it works

To determine the difference and similarity factor(f2) following pont shall be noted:
[][]Use the Two different products for study, from each product collect 12 unit [12 unit from Test Product & 12 Unit from Reference Product].

[][]Three time point shall be considered[Exclude Point Zero], only one measurement after 85% shall be measured.
[][]Produced curve shall be similar, f2 values shall be close to 100. Most of the time f2 value more than 50 denote similarity of the two curves as well as equivalence of the two products.

 If Three/Four Time points come to the test then following points shall be considered. 

[][]The measurement for the Test Product and the Reference product shall be same. Dissolution Time point shall be same for the both product (10,15,20,30,45,60 minutes etc.). Products which tend to faster dissolution (85% dissolve within 30 minutes) then time frame shall be consider as 10, 15, 20, 30 minutes.
[][]Only One measurement shall be consider after completion of 85% dissolution of both sample and reference products.

System Requirements to Perform Comparative Dissolution

Dissolution Activities shall be continued on USP Type I Dissolution apparatus at 100 RPM or USP Type II Apparatus at 50 RPM using 900 ml of different dissolution media mentioned below.
[][]Media Use in Comparative Dissolution
[][]Acid Media: 0.1N HCL or Simulated Gastric Fluid USP without Enzyme
[][]Acetate Buffer pH 4.5
[][]Phosphate Buffer pH 6.8 or Simulated Intestinal Fluid without Enzyme
[][]If both the Test Product and Reference product shows more than 85% dissolution within first 15 minutes then no calculation required. If not meets the above requirements then calculate f2 Value.
[][]If found f2>50, then the profile considered as similar and in vivo study is not required. Minimum 12 unit of each shall be consider for comparative dissolution.

Comparative Dissolution Study procedure Read More »

Certification of Analyst

Certification of Analyst, Purpose :

Certification of Analyst, The purpose of this SOP is to determine the capability of the newly recruited analyst to perform analysis accurately within the specified parameters and to demonstrate the analyst’s ability to perform in quality control laboratory at XX Pharmaceuticals Ltd.

Certification of Analyst, Scope :

This SOP applies to assure that the analysts are familiar with all test parameters, analytical procedures, instruments operation and documentation in quality control laboratory of XX Pharmaceuticals Ltd.

Definitions/Abbreviation:

Standard Operating Procedure (SOP): Standard Operating Procedure.

Responsibilities:

The roles and responsibility is as follows:

Officer/Executive/ Sr. Executive, Quality Control

[][]To follow the instructions of this procedure correctly.
[][]To maintain the records properly as per SOP.

Manager, Quality Control

[][]Responsible for the certification of analyst and verification of results and comparison with acceptance criteria.
[][]To ensure that this procedure is kept up to date.
[][]To confirm that the SOP is technically sound and reflects the required working practices.
[][]To arrange training on the SOP to all concerned personnel and to ensure implementation of the SOP after training.

Head of Quality Assurance

[][]Approval of SOP
[][]To ensure the overall implementation of the SOP.

Procedure:

General Precaution(s):

[][]Training should be conducted until the analyst is competent enough to carry out the analysis independently.
[][]Make sure that new employee know about the laboratory safety procedure.
[][]Adequate knowledge on handling of spillages and management of chemicals & reagents in the laboratory.
[][]Hands on waste management in the laboratory.
[][]Understanding the operation, cleaning and calibration procedure of instruments used in the laboratory.

Operation:

[][]Recently approved two specific samples of raw material or finished product or packaging material shall be given to the analyst to perform test for analyst certification.
[][]The samples are to be coded as (A) or (B).
[][]These samples packed in a manner which can prevent exposure to moisture, light and heat.
[][]In-Charge, QC should ensure that the analyst is performing the specified tests following respective method of analysis and specification.
[][]The analytical findings shall be recorded in the respective worksheet and the summary of results shall be entered in the prescribed format (Annexure-I).
[][]In-Charge, QC shall review the results in comparison with the known values for the test carried out and forward to Head of QA for approval.
[][]The analyst shall be considered qualified if the results obtained by him/her within the specification limit and within acceptable limit for certification of analyst.
[][]The details like calculations, chromatograms and spectrums along with comments of Head of QA shall be filed in training file of analyst.
[][]No repeat of the test will be allowed to the analyst.
[][]The result are provided by analyst will be crosscheck to the previous result and check the similarity.
[][]Head of QA will decide for the selection of analyst for routine analysis after review of analysis report. If the analyst is failed to qualify the test analyst will undergo further training.
[][]The certification of analyst shall be applicable to him/her only for carrying out these activities for which he/she is certified.
[][]Re-certification of the analyst shall be carried out once in every three years.
[][]The acceptance criteria for the analytical results shall depend upon the nature of tests carried out and the range provided in the specifications.
[][]Following acceptance criteria may be used for evaluation comparing with approved analyst.
[][]Assay by Spectrophotometer +/- 1% of previous value
[][]Assay by HPLC +/-0.5% of previous value
[][]IR spectra should match with standard and previous spectra
[][]Water content by KF +/-1% of previous value

Annexure:

Annexure-I: Analyst Certification Report.

Certification of Analyst Read More »

Water Sampling and Analysis in QC Laboratory

Water Sampling, Purpose :

Water Sampling, The purpose of this SOP is to describe the procedure for sampling and analysis of water in quality control laboratory.

Water Sampling, Scope :

This procedure is applicable for sampling and analysis in Quality Control Laboratory for purified water, water for injection, purified steam condensate, potable water, drinking water and effluent treatment plant water from different user points used in XX  Pharmaceuticals Ltd.

Definitions / Abbreviation:

[][]QC: Quality Control
[][]QA: Quality Assurance
[][]QCom: Quality Compliance
[][]COA: Certificate of Analysis
[][]WFI : Water for Injection
[][]PW: Purified water
[][]ETP: Effluent treatment plant

Responsibilities:

The roles and responsibility is as follows:

Lab Attendant, QC

[][]To collect water sample from different sampling points.

Officer / Executive, QC Officer / Executive, QC

[][]To prepare schedule sampling of water.
[][]To organize the sampling of water.
[][]Analysis of water and preparation of respective test report.
[][]Trend analysis of water.
[][]To ensure that this procedure is followed.
[][]To maintain the records properly as per SOP.

Sr. Executive, QC

[][]Reviewing of test report.

Manager, Quality Control

[][]Approval of test report.
[][]To ensure implementation of the SOP after training.

Head of Quality Assurance

[][]To ensure the overall implementation of the SOP.
[][]Approval of the SOP.

Procedure:

Precaution(s):

[][]Use gloves, mask & cap during sampling.
[][]Collect sample carefully to avoid contamination.
[][]Carefully collect water sample with high temperature and close the cap of container freely.

Sample Collection :

[][]Take required number of 500 ml to 1 Liter clean glass containers with cap for sampling.
[][]Open sampling points such as tap fixtures / hosepipe and allow water to run for not less than 1 minute.
[][]Rinse the container with respective water.
[][]Collect approximately 500 ml of water and immediately recap the sample containers after collecting samples. Keep the cap slightly loose when water temperature is above 30°C.
[][]Label the sample container providing information such as name of water, sample point no. / location, time, initial of sampler and date of sampling.
[][]Transfer the sample immediately to laboratory and analyze the sample within 24 hours of sampling. Preserve the sample in refrigerator (2°C to 8°C), if required.
[][]Entry information of sampling in sampling register after sampling.

Test Schedule :

Perform the test as per the following schedule :

Source of Water /Test frequency

Potable Water/ Once in a month
Purified Water/ Once in 14 days
ETP Water /Once in a week
Water for Injection/ Once in a week

Chemical Analysis :

[][]Perform analysis of water as per respective specification and method.
[][]Compile the raw data and prepare the certificate of analysis as per respective annexure with the test results & take approval of the COA.
[][]Share the water test reports with Engineering department and or Production department.
[][]Water test results are to be evaluated on a continuous basis and should be summarized in trend analysis report six monthly in order to identify significant trends.
[][]Inform respective department i.e. Engineering, Production and Quality Assurance Department whenever atypical data found beyond alert limit.
[][]Inform respective department i.e. Engineering, Production and Quality Assurance Department for taking actions whenever data found beyond action limit.

Annexure:

Annexure-I : Format for Certificate of Analysis for Potable water/Drinking water
Annexure-II : Format for Certificate of Analysis for Purified water/Water for injection/Purified Steam Condensate
Annexure-III : Format for Certificate of Analysis for Effluent Water
Annexure-IV : Format for Water Sampling Register
Annexure-V : Water sampling points

Water Sampling and Analysis in QC Laboratory Read More »

Calibration of Semi-micro Osmometer with operation & cleaning

Calibration of Semi-micro Osmometer, Purpose:

Calibration of Semi-micro Osmometer, The purpose of this SOP is to describe the operation, calibration and cleaning of Semi-micro Osmometer (Brand: KNAUER; Model: K-7400) used in the quality control laboratory of XX Pharmaceuticals Limited.

Calibration of Semi-micro Osmometer,Scope:

This procedure is applicable for Semi-micro Osmometer, installed in the quality control laboratory general block of Labaid Pharmaceuticals Limited.

Definitions / Abbreviation:

Standard Operating Procedure (SOP): Standard Operating Procedure.
QC: Quality Control.

Responsibilities:

The roles and responsibility is as follows:

Sr. Executive/Executive, QC

[][]To ensure that this procedure is followed.
[][]To maintain the records properly as per SOP.

Manager, Quality Control

[][]To ensure that this procedure is kept up to date.
[][]To confirm that the SOP is technically sound and reflects the required working practices.
[][]To arrange training on the SOP to all concerned personnel and to ensure implementation of the SOP after training.
[][]Schedule calibration of the instrument at the defined intervals.

Head of Quality Assurance

Approval of the SOP.
To ensure the overall implementation of the SOP.

Procedure:

Precaution(s):

[][]Prior to use, user must ensure that equipment is calibrated.
[][]To ensure a fixed sample volume, always introduce the solutions with a clean and dry pipette into the measuring vessel.
[][]Handle the thermistor always very carefully. All abrasive materials should be kept away from it.
[][]Solutions containing proteins, such as sera, can only be measured once. Freezing causes denaturisation of the protein so that repetition of the measurement with the same sample would result in increased values. Thus, in the case of sera, only one measurement is possible for one sample.
[][]Only real osmolalities can be measured. It is not possible to prepare other standard solutions by dilution of a calibration solution since the activity coefficient of the solution changes with dilution.
[][]In this case Store the water which is used for the zero point calibration in glass bottles.
[][]If the same salt solution is measured several times, it must be mixed after thawing (stir briefly). During the thawing process ice floats to the top of the solution. As ice does not contain salt, the top layer of the solution is diluted while thawing.
[][]Calibration solutions can become more concentrated if the bottle is opened frequently. So, use KNAUER calibration solutions in glass ampoules.
[][]Prior to the measuring, a little bit water condensed in the cooling compartment should be removed with a dry cloth.

Operation:

[][]Preparing the Osmometer K-7400
[][]Switch ON the instrument at least 5 minutes before use.
[][]Press the vibrator key to check the stirrer. It will run for a second.
[][]Optionally a thermo printer can be connected to the RS232 socket. The result of each measurement will be printed automatically.
[][]After a calibration, an outprint of Calibration will be found automatically.
[][]In case of interrupted runs (caused by any error), the screen displays the corresponding error message.

Preparing a Measurement

[][]Place 0.15 ml sample or calibration solution into a clean, dry measurement vial.
[][]Put the vial all the way into the adapter. The meniscus of the liquid must be horizontal.
[][]Place the measuring head on the instrument in such a way that the vial extends into the cooling cavity.
[][]Thus the instrument is ready for calibrating or measuring.

Calibration:

[][]Prepare the instrument for a measurement of deionised water.
[][]Set the first field in the second row of the CALIBRATE screen to „0000“.
[][]Press the start key.
[][]After finishing the run on the screen is displayed 0000 mOsmol > -0.81°C<.
[][]To accept this value, press the START key again.
[][]Wait for the warming up to the stand-by temperature.
[][]Prepare the instrument for a measurement of a 300 mOsm/kg calibration solution.
[][]Activate the second calibration field and select “0300” and repeat steps
[][]For a 4 point calibration, repeat the procedure for calibration fields

Measuring Samples:

[][]Prepare the instrument for a measurement of a sample solution.
[][]Press the START key to start the measurement run.
[][]The instrument detects the freezing point depression and if the crystallisation occurred properly displays the corresponding osmolality on the main screen.
[][]The printer output is given automatically.
[][]If no crystallisation (temperature increase) takes place after the automatically start of the vibrator the measurement will be stopped with the error message “> ERROR < NO FREEZE”.
[][]If the crystallisation (temperature increase) takes place before the start of the vibrator the measurement also will be stopped with an error message> ERROR < FREEZE.
[][]Do not remove the measurement vessel from the adapter before the sample is molten. Otherwise the danger of damaging the measuring head is given. The sample melting can be accelerated by warming up with the fingers.

Cleaning procedure:

[][]Measuring vessel and thermistor should be cleaned occasionally with KNAUER cleaning solution supplied with the instrument. (Dilution: 1: 10 solution in purified water of 40±5°C)
[][]Clean and dry the measuring vessels with alcohol or acetone because remaining solvent vapours could cause false results.

Annexure:

Annexure-I: Operation Logbook for Semi-micro Osmometer.

Calibration of Semi-micro Osmometer with operation & cleaning Read More »

Calibration of Oven Operation with Operation & Cleaning

Calibration of Oven , Purpose :

Calibration of Oven , The purpose of this SOP is to describe the operation, calibration and cleaning of Oven (256 L) (Brand: Memmert, Model: UNE 600) used for drying of glassware in the quality control laboratory at XX Pharmaceuticals Ltd.

Calibration of Oven , Scope :

This SOP applies for operation, cleaning and calibration of Oven (256 L) (Brand: Memmert, Model: UNE 600) in quality control laboratory of  XX Pharmaceuticals Ltd.

Definitions/Abbreviation:

Standard Operating Procedure (SOP): Standard Operating Procedure.

Responsibilities:

The roles and responsibility is as follows:

Sr. Executive/Executive, Quality Control

[][]To follow the instructions of this procedure correctly.
[][]To maintain the records properly as per SOP.

Manager, Quality Control

[][]To ensure that this procedure is kept up to date.
[][]To confirm that the SOP is technically sound and reflects the required working practices.
[][]To arrange training on the SOP to all concerned personnel and to ensure implementation of the SOP after training.
[][]Schedule calibration of the instrument at the defined intervals.

Manager, Quality Control

[][]Approval of SOP
[][]To ensure the overall implementation of the SOP.

Annexure:

N/A

Procedure:

General Precaution(s):

[][]Do not wipe with damped cloth at on position.
[][]Do not overload the chamber with glassware.
[][]Do not keep the items those may produce inflammation with air.
[][]Keep glassware to avoid the touch of inner surface of the chamber.
[][]Avoid opening the door for long period.
[][]Do not move the oven at on position. Severe vibrations may cause serious damage of the temperature probes.

Operation:

[][]Connect the instrument to the main power supply.
[][]Switch ‘ON’ the mains.
[][]Press push/turn control key to put on the main power switch in front of the instrument. The oven will start in normal mode with the display of timer, the chamber temperature, alarm temperature (red color indication).
[][]Hold down the SET key and turn the push/turn control key at the clockwise or anti clockwise for setting date, local time, operating temperature, alarm temperature. After setting, SET key will be released the display briefly flashes the set point.
[][]The display then changes to the actual current temperature and starts to the setting temperature. The temperature will be automatically increased at setting temperature and display the setting temperature digitally.
[][]Observe the display temperature until stable position.
[][]Hold down the SET key (appr. 3 seconds) to select the operation mode, if require. The current operating mode will be flashed on the display. There are three operating mode in the oven:

Normal Operation
Weekly Programmer
Ramp time Programme Operation

[][]Select the required programme and set as per operation manual.
[][]Select the fan speed to set the air changes.
[][]Turn the push/turn control at clockwise until the fan symbol flashing to move the air slider opens and closes the air valve to control the supply and discharge of air.
[][]Check the chamber temperature using by a calibrated digital thermometer, when the setting Temperature reaches.
[][]Keep the glassware’s inside the oven.
[][]The oven will automatically control the Temperature.
[][]The instrument will automatically adjust the temperature. When the temperature exceed the setting temperature, “off” light will illuminate and if the temperature decrease the “on” light will illuminate.

Cleaning Procedure :

[][]Switch off the oven and disconnect the power plug.
[][]Remove all glassware’s from the chamber of oven.
[][]Clean inside & outside of the chamber with dry cloth.
[][]Reload all items into the chamber when reach to dry the chamber surface.
[][]At the end of cleaning, connect the power plug and switch on the oven.
[][]Clean the chamber once in a month.
[][]Clean the outer surface of the oven every day.

Calibration Procedure:

[][]Switch ‘ON’ the mains of instrument.
[][]Set the desired temperature. Follow above operation procedure
[][]Allow sufficient time to equilibrate the set temperature.
[][]Check the temperature using a calibrated thermometer/data logger and record the temperature in the calibration certificate as per Annexure-V of Engineering SOP
[][]Carry out others two calibration temperatures in the same manner.
[][]Calibrate the oven once in a year ± 15 days.

Maintenance :

[][]If oven shows any mechanical, electrical or any others problem, inform to supplier or Engineering Department for corrective action.
[][]After corrective action, recalibrate the oven if it is necessary.

Calibration of Oven Operation with Operation & Cleaning Read More »

Atomic Absorption Spectrophotometer Calibration

Atomic Absorption Spectrophotometer Calibration, Purpose :

Atomic Absorption Spectrophotometer Calibration, The purpose of this SOP is to describe the operation and cleaning procedure of Atomic Absorption Spectrophotometer Model No. – A Analyst 400 with Graphite Furness HGA 900 used for analysis of the finished product & raw materials in the Quality Control Laboratory at XX Pharmaceuticals Ltd.

Atomic Absorption Spectrophotometer Calibration, Scope :

This procedure is applicable for the Atomic Absorption Spectrophotometer, installed in the Quality Control Laboratory of XX Pharmaceuticals Limited.

Definitions / Abbreviation:

Standard Operating Procedure (SOP): A written authorized procedure, which gives instructions for performing operations.
QC: Quality Control.

Responsibilities:

The roles and responsibility is as follows:

Sr. Executive/Executive, QC

[][]To ensure that this procedure is followed.
[][]To maintain the records properly as per SOP.

Manager, Quality Control

[][]To ensure that this procedure is kept up to date.
[][]To confirm that the SOP is technically sound and reflects the required working practices.
[][]Arrange training on the SOP to all concerned personnel.
[][]To ensure implementation of the SOP after training.
[][]Schedule calibration of the instrument at the defined intervals.

Head of Quality Assurance

[][]Approval of the SOP.
[][]To ensure overall implementation of the SOP.

Procedure:

Precaution(s):

[][]Care must be taken in handling the instrument opening, putting sample, and closing especially.
[][]Ensure optimum fluid level, otherwise flame will not ignite.
[][]All the solutions must be prepared carefully.
[][]The detection chamber must be clean and free from any dust of foreign particles.
[][]The selection of correct hollow cathode lamp of a particular atom must be present on a correct position of the lamp holder.
[][]The Air conditioning system and air exhauster must be open during operation of the Instrument.

Operation

[][]Procedure for getting concentration of a particular atom in Flame Method
[][]Ensure proper cleaning of the machine before operation.
[][]Turn on the computer and printer.
[][]Turn on the switch of the instrument.
[][]Turn on the switch of air compressor.
[][]Let open the exhaust switch for a few minutes of the compressor to expel moisture from it.
[][]Close the exhaust switch to retain huge amount of compressed air in it.
[][]Set the accessories apparatus of the flame mode.
[][]Turn on the switch of the Flame mode.
[][]Turn on the operating software on the computer.
[][]Align and optimize the instrument.
[][]Turn the screw of the acetylene gas cylinder and ensure its proper flow to the ignition chamber.
[][]Method setting: A method set by following way-
[][]At first click to file manager.
[][]Then go to new and click to method.
[][]Select the element (test element) from starting condition and click OK.
[][]Click on spectrometer at define element & write the method name in method description.
[][]Then select AA/AA-BG (as per method) from signal option.
[][]Click on setting and select the time, delay time & replicates.
[][]Click on sampler and select Air from Oxidant.
[][]Click on calibration and select Linear Through zero then select results unit (ppb, ppm etc) from equation & units.
[][]Click on standard concentration & select Blank and standard (1, 2, 3 etc).
[][]Then check sequence setting: set the number of standard and samples sequentially and save it.
[][]Then check sequence setting: set the number of standard and samples sequentially and save it.

[][]After completion the program, arrange & displayed the results window, the calibration window, the manual analysis control window and the flame control window from monitor window bar.
[][]Click “ON” button on the right side of the Flame option.
[][]Then follow the instruction of the software and input information accordingly.
[][]After completion of the calibration curve input sample according to software instructions.
[][]After completing analysis print the output or it may be saved.
[][]Turn off the software.
[][]Turn off the gas flow.
[][]Turn off the main instrument and expel air from compressor.
[][]Turn off the Switch of the computer.

Cleaning

[][]Clean all parts of the machine with cotton cloth using methanol after use.
[][]Procedure for getting concentration of a particular atom in Graphite Method
[][]Ensure proper cleaning of the machine before operation.
[][]Turn on the computer and printer
[][]Turn on the switch of the instrument
[][]Turn on the switch of air compressor
[][]Let open the exhaust switch for a few minutes of the compressor to expel moisture from it
[][]Close the exhaust switch to retain huge amount of compressed air in it.

[][]Set the accessories apparatus of the Graphite mode.
[][]Check the cooling system, the water level retain between maximum and minimum level.
[][]Turn on the switch of the Graphite mode.
[][]Turn on the operating software on the computer.
[][]Align and optimize the instrument.
[][]Turn the screw of the Argon gas cylinder and ensure its proper flow to the ignition chamber.
[][]Method setting: A method set by following way-
[][]At first Click to file manager.
[][]Then go to new and click to method.
[][]Then go to new and click to method.
[][]Then select the element (test element) from starting condition and click OK.
[][]Then go to spectrometer at define element & write the method name in method description and select AA/AA-BG from signal option. (as per method)
[][]Click on setting and select the time, delay time, BOC time & replicates.
[][]Click on sampler and go to Furness program & select Temperature, Ramp time, Hold time, internal flow & gas type.
[][]Click on Autosampler and select sample volume, Diluent location, matrix modifiers volume & location.
[][]Click on calibration and select Linear Through zero from calibration equation.
[][]Then select result unit (ppm, ppb etc) from equation and unit.
[][]Click on standard concentration & select Blank and standard (1, 2, 3 etc).
[][]Click on calculate standard volume & select stock standards, location & concentrations. Select the location of blank & reagent blank. Then click to OK and save it.
[][]Then click on Displayed the sample information editor. Write sample location and sample ID then save as in sample information file.
[][]Click on Auto (Automated analysis control)
[][]Click on Open from results data set name (for Data save).

[][]Click on analyze.

[][]After completion the program, arrange & displayed the results window, the calibration window, the automated analysis control window and the Furness control window from monitor window bar.
[][]Then click on analyze all
[][]Then follow the instruction of the software and input information accordingly
[][]After completion of the calibration curve automatically input sample according to software instructions.
[][]After completing analysis print the output or it may be saved.
[][]Turn off the software.
[][]Turn off the gas flow.
[][]Turn off the main instrument and expel air from compressor.
[][]Turn off the Switch of the computer.

Cleaning

[][]Clean all parts of the machine with cotton cloth using methanol after use.
[][]Procedure for getting concentration of a particular atom in MHS Method
[][]Ensure proper cleaning of the machine before operation.
[][]Ensure proper cleaning of the machine before operation.
[][]Set the MHS part with AAS properly.
[][]Set the sample tube on the flame chamber properly.
[][]Turn on the computer and printer.
[][]Turn on the switch of the instrument.
[][]Turn on the switch of air compressor.
[][]Let open the exhaust switch for a few minutes of the compressor to expel moisture from it.
[][]Close the exhaust switch to retain huge amount of compressed air in it.
[][]Turn on the switch of apparatus of the Graphite mode.
[][]Check the cooling system, the water level retain between maximum and minimum.
[][]Turn on the switch of the Flame mode.
[][]Turn on the operating software on the computer.
[][]Align and optimize the instrument.
[][]Turn the screw of the Argon & acetylene gas cylinder and ensure its proper flow to the ignition chamber.
[][]Method setting: A method set by following way-
[][]At first Click to file manager.
[][]Then go to new and click to method.
[][]Select the element (test element) from starting condition and click OK.
[][]Then go to spectrometer at define element & write the method name in method description.
[][]Click on setting and select the time, delay time, BOC time & replicates.
[][]Then click on sampler and go to Furness program & select Temperature, Ramp time,
[][]Hold time, internal flow & gas type.
[][]Click on calibration and select Linear Through zero from calibration equation.
[][]Then select result unit (ppm, ppb etc) from equation and unit.
[][]Click on standard concentration & select Blank and standard (1, 2, 3 etc).
[][]Then check sequence setting: set the number of standard and samples sequentially and save it.
[][]After completion the program, arrange & displayed the results window, the calibration
[][]window, the manual analysis control window and the flam control window from monitor window bar
[][]Then click “ON” button on the right side of the Flam option.
[][]Then follow the instruction of the software and input information accordingly
[][]After completion of the calibration curve input sample according to software instructions.
[][]After completing analysis print the output or it may be saved.
[][]Turn off the software.
[][]Turn off the gas flow.
[][]Turn off the main instrument and expel air from compressor.
[][]Turn off the Switch of the computer.

Cleaning

Clean all parts of the machine with cotton cloth using methanol after use.

Calibration:

Calibration for Flame System:
Wavelength Accuracy Using Ni:

Test Conditions:

[][]Open the default Nickel method (File-New-Method-Ni)
[][]Open the continuous Graphics window so the system will set up for Nickel.
[][]Ensure the lamp has been on for 15 minutes before measuring g absorbance with the Nickel standard.

Test prerequisites:

[][]Burner position Optimized and Nebulizer adjusted using Copper.

Test Steps:

[][]Under the tool bar, double click on the instrument icon in the ‘Spectrometer status panel’ to open the diagnostic/spectrometer window.
[][]Select the ‘Optical Position’ button at the button of the diagnostics window.
[][]Select the ‘Optical Position’ button at the button of the diagnostics window.
[][]A graphic plot of the peaked positions for the prism and Grating will be displayed

The Prism Tolerance is ±190 motor steps
The Grating Tolerance is +380, -260 motor steps

Sensitivity and Precision Using Ni:

Apparatus:

Volumetric flask with stopper, 1000 ml
Glass pipette 3 ml
Beaker 10 to 200 ml

Reagents:

1000 ppm Ni AAS standard solution.
Nitric acid

Preparation for 3ppm Ni standard solution:

[][]Pour a small quantity of 1000 ppm Ni AAS standard solution in the beaker. Use it to rinse the 3 ml pipette and the beaker, then discard it.
[][]Pour another 5ml (minimum) 1000ppm Ni AAS standard solution into the beaker.
[][]Pipette 3 ml standard from the beaker into the 1000 ml volumetric flask.
[][]Half fill the volumetric flask with de-ionized water.
[][]Pour 10 ml (approximately) of nitric acid into the volumetric flask.
[][]Fill the volumetric flask with de-=ionized water exactly to the mark.

Note: 3ppm Ni standard should be produced before the day of test.

Test Steps:

Edit the Nickel default method and enter/verify the following parameter:
Signal type: A
Read time:10.0
Replicates: 10

[][]While in the method editor, go to the calibration/ standard concentrations page. Enter blank for calibration blank ID and Nickel standard for standard ID.
[][]In the ‘Flame Control’ window, select the ‘Flam On/off’ icon to light the flame.
[][]In the ‘Manual Analysis Control’ window, aspirate blank and select ‘Analysis Blank’. 10 Replicates will be measured and autozero will occur.
[][]Aspirate a 3ppm Ni standard and select ‘Analysis Sample’. 10 Replicates will be measured.
[][]The results will be displayed in the result window. Record the values for mean absorbance and relative standard deviation (RSD).The value should meet following requirements.

Mean Absorbance ≥ 0.200
RSD ≤ 0.3%

[][]Return to the ‘Flame Control’ window and extinguish the flame by pressing Flame On/Off.

Wavelength Accuracy Using As:

Test Conditions:

[][]Open the default Arsenic method (File-New-Method-Ni)
[][]Open the continuous Graphics window so the system will set up for Arsenic.
[][]Ensure the lamp has been on for 15 minutes before measuring absorbance.

Test prerequisites:

[][]Burner position Optimized and Nebulizer adjusted using Copper.

Test Steps:

[][]Under the tool bar, double click on the instrument icon in the ‘Spectrometer status panel’ to open the diagnostic/spectrometer window.
[][]Select the ‘Optical Position’ button at the button of the diagnostics window.
[][]A graphic plot of the peaked positions for the prism and Grating will be displayed.
The Prism Tolerance is ±200 motor steps
The Grating Tolerance is ±380 motor steps

[][]Select the ‘X’ in the upper right hand corner to exit the ‘Optical position’ window. Select the X in the Upper right corner to close the window.

AA-BG Baseline Noise at 1 Abs. Using As:

Test Steps:

Edit the Arsenic default method and enter/verify the following parameter:

Signal type:AA-BG
Read time: 2
Replicates: 99

[][]In the Manual Analysis Control window, select the ‘Analyze blank’ button. The system will take 99 readings and perform an autozero.
[][]Insert the 1.0 A neutral density filter into the filter holder.
[][]In the Manual Analysis Control window, select the ‘Analyze Sample’ button. When the reading is complete, record the SD value. It should be ≤ 0.005.

AA Baseline Noise and Drift using Cu:

Test prerequisites:

[][]Burner position Optimized and Nebulizer adjusted using Copper.
[][]Copper lamp should be warmed up at least 15 minutes.

Test Steps:

[][]Open the default Copper method (File-New-Method-Ni)
[][]Open the continuous Graphics window so the system will set up for Copper.
[][]Edit the Copper default method and enter/verify the following parameter:
Signal type: AA
Read time: 0.5
Replicates: 99

[][]In the Manual Analysis Control window, select the ‘Analyze blank’ button. The system will take 99 readings and perform an autozero.
[][]In the Manual Analysis Control window, select the ‘Analyze Sample’ button. Data collection for 99 replicates will begin.
[][]At the end of 99 replicates, record the standard deviation (SD) value in the table below. It should be ≤0.001. Record the mean absorbance value as well.
[][]Wait 15 minutes and repeat the measurement. Record the mean absorbance value for the second measurement.
[][]Calculate the difference between the absorbance measurements. It should be ≤ 0.002 Abs.

Wavelength Accuracy Using Cu:

Test Steps:

[][]Under the tool bar, double click on the instrument icon in the ‘Spectrometer status panel’ to open the diagnostic/spectrometer window.
[][]Select the ‘Optical Position’ button at the button of the diagnostics window.
[][]A graphic plot of the peaked positions for the prism and Grating will be displayed.

The Prism Tolerance is ±120 motor steps
The Grating Tolerance is ±380 motor steps

[][]Select the ‘X’ in the upper right hand corner to exit the ‘Optical position’ window. Select the X in the Upper right corner to close the window.

Copper Capacitance:

The Optical position box also displays two capacitances values. Cap: in the upper left corner. The first value is the cap: used for peaking and the last value is the Final Cap: Record the Final Cap. It should be ≥1.0 pF

Flame Sensitivity and Precision using Cu:

Apparatus:

Volumetric flask with stopper, 1000 ml
Glass pipette 2 ml
Beaker 10 to 200 ml

Reagents:

1000 ppm Cu AAS standard solution.
Nitric acid.

Preparation for 2ppm Cu standard solution:

[][]Pour a small quantity of 1000 ppm Cu AAS standard solution in the beaker. Use it to rinse the 2 ml Pipette and the beaker, then discard it.
[][][][]Pour another 5ml (minimum) 1000ppm Cu AAS standard solution into the beaker
Pipette 2 ml standard from the beaker into the 1000 ml volumetric flask.
[][]Half fill the volumetric flask with de-ionized water.
[][]Pour 10 ml (approximately) of nitric acid into the volumetric flask.
[][]Fill the volumetric flask with de-=ionized water exactly to the mark.

Note: 2ppm Ni standard should be produced before the day of test.

Test Steps:

[][]Edit the Copper default method and enter/verify the following parameter:
Signal type: AA
Read time:10.0
Replicates: 10
[][]In the ‘Flame Control’ window, select the ‘Flam On/off’ icon to light the flam.
[][]In the ‘Manual Analysis Control’ window, aspirate blank and select ‘Analysis Blank’. 10 Replicates will be measured and autozero will occur.
[][]Aspirate a 2ppm Cu standard and select ‘Analysis Sample’. 10 Replicates will be measured.
[][]The results will be displayed in the result window. Record the values for mean absorbance and relative standard deviation (RSD).The value should meet following requirements.
Mean Absorbance ≥ 0.250
RSD ≤ 0.30%
[][]Select the Spectrometer- Setting tab and enter/verify the following parameter:
[][]Signal type: AA

Read time:0.1
Replicates: 10

[][]In the ‘Flame Control’ window, select the ‘Flam On/off’ icon to light the flam.
[][]In the ‘Manual Analysis Control’ window, aspirate blank and select ‘Analysis Blank’. 10 Replicates will be measured and autozero will occur.
[][]Aspirate a 2ppm Cu standard and select ‘Analysis Sample’. 10 Replicates will be measured.
[][]The results will be displayed in the result window. Record the value for relative standard deviation (RSD).The value should meet following requirements.
RSD ≤ 3.0%
[][]Return to the ‘Flame Control’ window and extinguish the flame by pressing Flame On/Off.

Calibration for Flame System:

Chromium Baseline Noise For Furness:

Test Steps:

[][]Click on the File pull down menu, then on Open. Select Method.
[][]Click on Browse. Go up 2 levels and double-click on Service. Then double click on Method.
[][]Double click on HGA Cr Test method. Select the Method Ed icon to open the Method Editor window.
[][]In the spectrometer section, select set. Select 2.7 Slit Width and 0.8 Slit Height. Select OK. Click on the file pull down menu, then on Save. Select Method. Close the Method Editor window.
[][]Click on the Tools pull down menu and then select Continuous Graphics. This will set up the Lamp. Close the Continuous Graphics window.
[][]Open the Align lamps window. Look at the Bar Graph status window and verify that the Cr HCL Lamp current is 15 mA and the Slit is se4t to 2.7/0.8. Also verify that the Background corrector is On. Allow the lamp to warm up for 30 minutes.
[][]Close the Align Lamps window.
[][]From the Tools pull down menu open the windows Results, Peaks and Automated Analysis. Arrange and align the windows as desired.
[][]Open the Furness control window and select the Furness ON/Off button to run at least one dry firing (without any sample) to make sure that there is no residual signal (Peak area less than 0.005) from any previous injections or tube contamination.
[][]Make sure position 3 of the Autosampler is empty. Type in 3 as the sample lactation in the setup page of the Automated Analysis window, click on the Analyze tab and then on the Analyze Samples button to measure 5 Furness dry firings (without any sample).
[][]Ensure that the AA and BG signals do not diverge from the baseline. Realign the Furness into the optical beam if necessary.
[][]The standard deviation of the mean dry-firing result in integrated absorbance (Peak area) for the Cr wavelength must not exceed a maximum value of 0.002. Record the result.

Chromium Characteristic Mass and Precession:

Test Steps:

[][]Use the same method as in the previous test. Demonized water should be in position 1 and Cr standard should be in position 2 of the Autosampler.
[][]Type in 2 as the sample lactation in the setup page of the Automated Analysis window, click on the analyze tab and then on the Analyze Samples button to measure 5 furnace firings using 20 µl sample injections.
[][]Calculate the characteristic mass using the Calculate characteristic mass tool from the Analyses pull down menu.

Characteristic Mass Result:

The characteristic mass (m0) results in pg and calculated from the mean integrated absorbance (Peak area) values should lie within the following ranges:

Element: Cr

Lower Limit (pg): 2.3

Target Value (pg): 3.0

Upper Limit (pg): 3.8

Note: If the characteristic mass exceeds the lower limit, check for possible contamination of the water used for sample preparation. Prepare a new solution if required.

Precision:

[][]The relative standard deviation (%RSD) of the mean sample solution readings calculated from the integrated absorbance (peak area) values for Cr must not exceed the maximum value of 2.0%.
[][]Record the results in the OQ Test Certificate on page 40.
[][]AS-800 Autosampler Linearity
[][]Click on the File pull down menu, then on Open. Select Method.
[][]Verify that you are in the Service\Methods directory. If not, click on Browse. Go up 2 levels and double-click on Service. Then double click on Method.
[][]Double click on HGA AS-800 Lin method.
[][]Select the Method icon to open the Method Editor window.
[][]In the spectrometer section, select Set. Select 2.7 Slit Width and 0.8 Slit Hight. Select OK.
[][]On the right side of the Method window select the Settings tab.
[][]In the Lamp Current section, select Use current (mA) and then type 15 in the Lamp Current box.
[][]Click on the File pull down menu, then on Save. Select Method.
[][]Close the Method Editor window.
[][]Clock on the Tools pull down menu and then select Continuous Graphics. This will set up the Lamp. Close the Continuous Graphics windows.
[][]Open the Align lamps windows. Look at the Bar Graph status window and verify that the Cr HCL Lamp current is 15mA and Slit is set to 2.7/0.8. Also verify that the Background Correction is ON. Allow the lamp to warm up for 30 minutes (if not already warmed up).
[][]Close the Align Lamps window.
[][]From the Tools pull down menu open the windows Results, Peaks, Examine Calibration and Automated Analysis. Arrange and align the windows as desired.
[][]Click on the Analyze tab of the Automated Analysis window and then on the Calibration button top start the calibration.
[][]When the calibration is finished check the Correlation Coefficient Result in the Examine Calibration window.
[][]The Correlation Coefficient Result Cr must exceed the minimum value of 0.999.

Annexure: Atomic Absorption Spectrophotometer Calibration

Annexure-I: Calibration Information Sheet for Wavelength Accuracy, Sensitivity and Precision using Ni
Annexure-II: Calibration Information Sheet for Wavelength Accuracy and AA-BG Baseline Noise at 1 Abs. using As
Annexure-III: Calibration Information Sheet for Baseline Noise, Wavelength Accuracy, Copper Capacitance, Flame Sensitivity and Precision using Cu
Annexure-IV: Calibration Information Sheet for Baseline Noise, Characteristic Mass and Precession, Autosampler Linearity using Cr
Annexure-V: Operation logbook for Atomic Absorption Spectrophotometer

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Wash Water from production equipment sampling & analytical procedure

Wash Water, Purpose:

Wash Water, The purpose of this SOP (Standard Operating Procedure) is to define the Sampling and analytical procedure for wash water.

Wash Water, Scope:

This procedure is applicable for sampling of wash water from production equipments and analysis of wash water in the Quality Control laboratory  of XX Pharmaceuticals Ltd.

Definition:

None

Responsibilities:

The roles and responsibility is as follows:

Executive, Production

[][]To co-ordinate to collect the sample as per defined procedure
[][]To send duly filled Wash Water Sampling Advice Form to QC/QA Department.
[][]To maintain the proper documentation.

Sr. Executive/Executive, Quality Assurance

[][]To withdraw the sample as per the defined procedure.

Sr. Executive/Executive, QC

[][]To analyze the sample as per defined procedure
[][]To ensure that this procedure is kept up to date.

Manager, Quality Control

[][]To ensure appropriate personnel from the section are trained on this procedure.
[][]To confirm that SOP is technically sound and reflects the required working practices.

Head of Quality Assurance

[][]To ensure the overall implementation of the SOP.
[][]Approval of the SOP.

Procedure:

[][]Production personnel clean the equipment as per standard cleaning procedure, intimates QC/QA for wash water sampling with the “Wash Water Sampling Advice Form” in duplicate.
[][]Quality Compliance representative inspects the equipment and its parts for cleanliness and then collects the sample as follows:

Vibratory Shifter:

[][]Attach the sieve on the body of the sifter and wash with 3.0 L of Purified water and collect the sample at the receiver into a clean bowl. Rinse the dismantled parts (Lid, clamp, hopper and silicon gasket) with 2 liters of purified water and collect into the same bowl. Collect approx. 30 ml of the sample into an amber colored bottle for analysis.

Container Blender:

[][]Rinse the colloid mill with 3.0 L of Purified water and collect it into a clean bowl. Collect 30ml of the sample into an amber colored bottle from the bowl for analysis.

Rapid Mixer Granulator:

[][]Rinse the equipment bowl and top lid with 30.0L of Purified water and collect the water into a clean bowl through the discharge taking care that the whole surface of the bowl and top lid is rinsed properly and rinse the dismantled parts (clamp for binder addition, charging port, spray nozzle, vent filter, chopper blade, impeller blade discharge valve and all gaskets) with 5 liters of purified water and collect into the same bowl. Collect approximately 30 ml of sample into an amber colored bottle for analysis.

FBD (Fluid Bed Drier):

[][]Rinse the retarding chamber internally with 10.0 L of Purified water and collect it into a clean bowl. Collect approximately 30 ml of the sample into an amber colored bottle for analysis. Similarly rinse the FBD trolleys with 10.0 L of Purified water each and collect 30ml of the sample separately from the two bowls. Rinse the cartridge filters/FBD bag with 5-liters of purified water and collect the water into the clean bowl. Collect approximately 30 ml of the sample into an amber colored bottle for analysis.

Tablet Coating Machine:

[][]Rinse the pan with 10.0L of Purified water and collect the sample into a clean bowl through the discharge taking care that the whole surface and the Baffles are rinsed properly. Rinse the dismantled parts (Silicon tube, Gun assembly, inlet duct and outlet duct) with 5 liters of purified water and collect into the same bowl. Collect approximately 30 ml of the sample into an amber colored bottle for analysis.

Compression machine:

[][]Rinse the hoppers, butterfly valve, triclover clamp, force feeder, inlet connector, Turret guards, Powder scrapper, Acrylic guards, feeder shaft, Exhaust pipes with 5 liters of purified water and collect in a clean bowl. Collect approximately 30 ml of this sample into an amber colored bottle for analysis. Similarly rinse the y – chute, Gravity pipe with 5 liters of purified water and collect in the clean bowl. Collect approximately 30 ml of this sample into an amber colored bottle for analysis.

Capsule Filling Machine:

[][]Rinse the capsule loading channel, hopper, Loading ring, Auger, Locking pin assembly with 5 liters of purified water and collect in to clean bowl. Collect approximately 30 ml of this sample into an amber colored bottle for analysis.

Capsule polishing Machine:

[][]Rinse S.S cover of polishing Machine and polishing brush with 2 liters of purified water and collect in to clean bowl. Collect approximately 30 ml of this sample into an amber colored bottle for analysis.
[][]While collecting wash water sample, collect Purified water about 30 ml into an amber colored bottle.
[][]Use this as blank.

Note: For the equipments, which are not specified above, use 2.0 L, 5.0 L, & 10.0 L as the rinsing water quantity depending on the size i.e. small, medium & big.

Analysis:

[][]After getting sampling advice form from production department, QC personnel will entry in the wash water register and assign a lab control number as WW-000X/MM/XX(where WW for Wash Water, 000X- Sequential number of four digits, MM-Month and YY-Last two digits of year. For example: WW-0001/08/XX). Then the compliance personnel will collect the sample and send to Quality Control department for analysis.
[][]QC analyses the sample by scanning through 190-400 nm on UV-VIS Spectrophotometer, using Purified water (collected as explained earlier) as blank.
[][]Observe for any abnormal peaks and/or peaks having same wavelength maximum of active material of previous product.
[][]Reject the sample in case of any abnormal peak or if a peak of previous product having more absorbance that of a 10 ppm standard solution of active of previous product and send the information to the concerned department.
[][]Take the spectrum print out on the back side of the wash water report copy (QC copy) and inform production for rewash.
[][]If absorbance is less than that observed in standard graph, intimate the concerned department by sending the original copy of the report after making necessary entries and approving the clean card. Retain the duplicate copy of the report and file it after making necessary entries in the register.

Annexure:

Annexure-I: Wash Water Sampling Advice Form.
Annexure-II: Wash Water Register.

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Out Of Specification (OOS) Handling and Investigation

Out Of Specification (OOS), Purpose :

Out Of Specification (OOS), The purpose of this SOP is to define the procedure for handling of OOS results in the Quality Control Laboratory of XX Pharmaceuticals Ltd.

Out Of Specification (OOS),Scope :

[][]This SOP is applicable for all Out of Specification (OOS) results detected during testing of any product or materials in Quality Control Laboratory of general block of XX Pharmaceuticals Limited.
[][]If an out of specification results is generated for dissolution/ Drug release, uniformity of dosage units, weight variation, disintegration test, In process sample and any other test which is used to measure variability in a lot this SOP does not apply. In such cases respective Pharmacopoeial guidelines or criteria shall be apply.
[][]This SOP does not apply to samples of various stages like In process samples, Intermediate samples, scale up batches, method validation, method development, solvents, packaging material, wash water, decontamination samples, evaluation samples, raw material received from new vendor, description and solubility test, tests where tentative limits given.
[][]This SOP does not apply for OOS to tests like Bulk density, Sieve analysis, Particle size and other physical parameters.
[][]This SOP does not apply when system suitability failure, bracketing standard, transcriptional errors or processing method errors (In case of failure due to the integration parameters for the HPLC).
[][]This SOP does not apply to incomplete analysis where result is not derived.
[][]Out of Specification is not applicable for out laboratory testing.

Definitions / Abbreviation:

[][]Standard Operating Procedure (SOP): Standard Operating Procedure. A written authorized procedure, which gives instructions for performing operations.
[][]QC: Quality Control.
[][]CAPA: Corrective action and preventive action.
[][]OOS result: An OOS result is a result from a defined test procedure that fails to meet established specifications or criteria. An OOS result does not constitute a failure unless further investigation confirms this result.
[][]Atypical result: Results that are still within specification but are unexpected, questionable, irregular, deviant or abnormal.
[][]Obvious error : Obvious error can be occurred due to:
Calculation Error
Laboratory error
[][]Laboratory Error: A mistake that occurs within the test laboratory caused by an analyst or piece of equipment. Examples include use of incorrect standards, improper sample or standard preparation, improperly calibrated balances, equipment failure and miscalculations.
[][]Laboratory Investigation: The investigation that is conducted within the laboratory to determine the cause of the OOS results.
[][]Assignable Cause: An identified reason for obtaining an OOS or aberrant/anomalous result.
[][]No Assignable Cause: When no result could be identified.
[][]Review: To check all critical parameters involved in the test which may cause of the OOS results.
[][]Reanalysis: Further analysis with the same dilution of sample or of same aliquots which produced OOS results.
[][]Retest: Re-examining the material from the original sample that was used as the source of the aliquot that produced OOS result.
[][]Resample: A new sample from the original container where possible, required in the event of insufficient material remaining from original sample composite or proven issue with original sample integrity.

Responsibilities:

The roles and responsibility is as follows:

Executive, QC

[][]Analysis of any product or materials and to notify the OOS results to supervisor.

Sr. Executive, QC

[][]To ensure the initial investigation of the test parameters and to organize the testing.

Manager, Quality Control

[][]To ensure that this procedure is kept up to date.
[][]To confirm that the SOP reflects the required working practices.
[][]To make decision for re-sampling.
[][]To arrange training on the SOP to all concerned personnel and to ensure implementation of the SOP after training.

Head of Quality Assurance

[][]Approval of the SOP.
[][]To take the final decision to release the batch.
[][]To ensure the overall implementation of the SOP.

Procedure:

[][]The procedure mentioned below shall be followed if a Laboratory result for raw materials sample, In-process Sample or Finished Product sample fails to meet the Specification.
[][]Analyst shall not destroy the sample preparation / solution and shall retain the prepared solutions, Standards and Sample solutions until the investigations have been concluded.
[][]Retain all Glassware, Blend & Finished Product Sample.
[][]Check the whole analysis for compliance (Self-check).
[][]Inform immediately to the Supervisor about the OOS result.
[][]Supervisor will discuss with the analyst about the test method and confirm analyst knowledge of and performance of the correct procedure.
[][]Check if a laboratory error could be the cause of OOS results and inform Manager, QC.
[][]Check and record the present conditions in Notification of out of specification (OOS) result as per Annexure-I.
[][]Follow the Flow Chart (Annexure-II) for OOS Investigation
[][]The QC Manager should assess the data promptly to ascertain if the results may be attributed to laboratory error, or whether the results could indicate problems in the manufacturing process.

[][]It is to be clarified together with the QC Manager whether there is an apparent analytical error. A formal check is to be carried out (Investigation stage 1) using Out of Specification (OOS) Results Investigation Checklist (Annexure – IV) which shall be issued by QC Manager making entry in the Out of specification investigation register (Annexure – III) and assigning sequential number as below:
e.g. OOS-001/xx
Where, OOS is the abbreviation of Out of Specification
001 is the sequential number of Out of Specification investigation
/ is separator
xx is last two digits of year 20xx

[][]At the first step, the QC Manager along with Analyst shall immediately try to find out any obvious Error (Example: Calculation error, Power outage, Equipment failure, Testing Error, Incorrect Instrument Parameters etc.)
[][]If any calculation error is found out, make correction the calculation and release the material/product; analyst shall be re-trained for the error parts.
[][]If the calculation / documentation are correct, proceed with the investigation of the stepwise analysis which may include re-examination of the actual solutions, test units, glassware used in the original measurements and preparations.
[][]The following steps should be taken as part of the investigation:
[][]Discuss the test method with the analyst; confirm analyst knowledge of and performance of the correct procedure.
[][]Examine the raw data obtained in the analysis, including chromatograms and spectra, and identify anomalous or suspect.
[][]Confirm the performance of the instruments.
[][]Determine that appropriate reference standards, solvents, reagents, and other solutions were used and that they meet quality control specifications.
[][]Evaluate the performance of the testing method to ensure that it is performing according to the standard expected based on method validation data.
[][]Document and preserve evidence of this investigation.
[][]Where a transient equipment malfunction or other problem in the dosage form (e.g. incomplete extraction) is suspected, re-inject the retained sample preparations to assign a cause for OOS results.
[][]When laboratory error is identified, determine the source of that error (root cause) generating CAPA as per the SOP for ‘Corrective and Preventive Action’  and take corrective action to ensure that it does not occur again. Recommend on Out of Specification (OOS) Results Investigation Checklist (Annexure – IV) for performing a repeat analysis on the same sample with the same analyst. If the repeat analysis result is passing, void the initial result and approve the batch based on the re-test result.
[][]If no apparent analytical error can be found, i.e. evidence of laboratory error remains unclear, investigation stage 2 should be conducted to determine what caused the unexpected results, which may include re-testing and/or re-sampling and further investigation.
[][]Before further investigations are carried out during the next step, the subsequent procedure has to be written down in the testing protocol (Annexure – IV).
Tasks in testing protocol:
“What” is to be done (retesting, re-sampling, etc.)?
“Who” will be carrying out the investigations (1st analyst, 2nd analyst, etc.)?
“How” will the investigations be carried out, which equipment, which reagents, additional analysis of reference samples (state batch and number of analysis)?
“How often” will the analysis be repeated (final criterion to prevent “analysis” into
“compliance”)?
[][]A justification for the procedure must be given by the QC manager prior to implementation of the testing protocol and the test plan must be approved.
The number of retests should be 3 times or more
[][]The investigation may involve re-testing a portion of the original sample. The sample used for the retesting should be taken from the same homogeneous material / product that was originally collected for the lot/batch, tested and yielded the OOS result. For a liquid, it may be from the original unit liquid product or composite of the liquid product; for a solid it may be an additional weighing from the same sample composite that had been prepared by the analyst.
[][]Decisions to retest should be based on the objectives of the testing and sound scientific judgment. Retesting should be performed by an analyst other than the one who performed the original test.
[][]If the result is within specification (passes), the material/product shall be re-analyzed by first analyst with the same sample and to investigate the first analyst.
[][]If investigation of first analyst found satisfactory then release the material/product
[][]If the material/product fails by the second analyst also, simultaneously analyze after re-sample with the previously approved material/product.
[][]Re-sampling should involve analyzing a specimen from the collection of a new sample from the batch. A re-sampling of the batch should be conducted if insufficient quantity of the original sample remains to perform all further testing or if the investigation shows that the original sample was not representative of the batch. This would be indicated, for example, by widely varied results obtained from several aliquots of the original composite (after determining there was no error in the performance of the analysis). Re-sampling should be performed by the same qualified, validated methods that were used for the initial sample. However, if the investigation reveals that the initial sampling method was in error, a new accurate sampling method must be developed, qualified and documented.
[][]If previously approved material/product passes within the specification and material/product under investigation meets the specification, release the material/product.
[][]In case of material if previously approved material passes within the specification and material under investigation fails to meet the specification, material shall be rejected.
[][]In case of product if previously approved product passes within the specification and product under investigation fails to meet the specification, the laboratory investigation may be extended to review the quality of the materials (raw & primary packaging) used in manufacturing of the finished product. If any problem in quality of the materials is identified which may have potential effect on the OOS scenario, the root cause will be attributed to that problem.
[][]The procedure is then to be implemented and the results be evaluated. The results are to be summarized in Annexure – VI (report level 2).
[][]Conclusion must be drawn and it must be stated which individual values will be entered in the result (on Certificate of Analysis).
[][]The error category of the initial OOS result must also be recorded.
[][]At measures, a statement must be made explaining how similar OOS results are to be avoided in future.
[][]During investigation of an OOS result, review the previous investigation reports to determine whether a similar occurrence has taken place.
[][]When the laboratory investigation does not determine that laboratory error caused the OOS result and testing result appears to be accurate, the laboratory investigation/report to be handed over to QA manager for a full-scale failure investigation as per the SOP for ‘Deviation Procedure’.
[][]In case the process error is identified during failure investigation, suitable corrective action shall be taken. Sample shall then be analyzed as per routine procedure and accordingly release, if the results are okay.
[][]Quality Assurance Manager will initiate the CAPA based on root cause found in the failure investigation. CAPA must be implemented within agreed time lime. All CAPAs must be implemented based on criticality.

Annexure:

Annexure-I: Notification of Out of Specification Result
Annexure-II: Flow Chart for OOS Investigation
Annexure-III: Out of Specification (OOS) Register
Annexure-IV: Out of Specification (OOS) Investigation Checklist
Annexure-V: Out of Specification (OOS) Testing Protocol
Annexure-VI: Out of Specification (OOS) Investigation Report

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