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Aerosol: SOP for Documenting Deviations in Manufacturing Processes – V 2.0

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Aerosol: SOP for Documenting Deviations in Manufacturing Processes – V 2.0

SOP for Documenting Deviations in Manufacturing Processes

Department Aerosol
SOP No. SOP/Aerosol/153/2025
Supersedes SOP/Aerosol/153/2022
Page No. Page 1 of Y
Issue Date 06/02/2025
Effective Date 16/02/2025
Review Date 06/02/2028

1. Purpose

The purpose of this Standard Operating Procedure (SOP) is to define the process for documenting deviations that occur during aerosol manufacturing. Documenting deviations is essential for identifying potential risks to product quality, investigating the root cause, and implementing corrective and preventive actions (CAPA). This SOP ensures that all deviations are recorded, reviewed, and appropriately addressed to maintain compliance with regulatory standards and Good Manufacturing Practices (GMP).

2. Scope

This SOP applies to all deviations that occur during the manufacturing process of aerosol products. It includes deviations related to raw materials, equipment, personnel, environmental conditions, and process parameters. The procedure covers the documentation, investigation, and resolution of deviations, as well as ensuring compliance with GMP and internal company policies.

3. Responsibilities

  • Production Team: Responsible for identifying and reporting any deviations during the manufacturing process, as well as providing relevant details and information for investigation.
  • Quality Assurance (QA) Team: Responsible for reviewing, investigating, and approving all deviation reports. The QA team ensures that deviations are addressed and that corrective actions are implemented effectively.
  • Engineering Team: Responsible for identifying equipment-related deviations, conducting investigations, and
implementing corrective actions to resolve any equipment failures that contribute to deviations.
  • Maintenance Team: Responsible for addressing maintenance-related deviations and ensuring that equipment is functioning according to specifications to prevent further issues.
  • 4. Accountability

    The Manufacturing Manager is accountable for ensuring that all deviations are documented and that appropriate corrective actions are implemented. The overall compliance with this SOP is monitored by the Quality Assurance (QA) Manager.

    5. Procedure

    5.1. Identifying Deviations

    1. During the manufacturing process, deviations from standard operating procedures (SOPs) or process parameters should be immediately identified by production personnel. Deviations may include, but are not limited to:
      • Failure to meet specified process parameters (e.g., temperature, pressure, filling volume)
      • Out-of-specification raw materials or ingredients
      • Equipment malfunctions or failures
      • Personnel errors or non-compliance with procedures
      • Environmental conditions outside the acceptable range (e.g., humidity, airflow)
    2. Once a deviation is identified, production personnel should immediately notify the supervisor or quality control staff, and the deviation must be documented in the Deviation Report (Annexure-1).

    5.2. Documenting the Deviation

    1. The Deviation Report should include the following information:
      • Deviation ID (unique identification number)
      • Description of the deviation (e.g., the nature of the issue, how it was identified, and the equipment or process affected)
      • Date and time of the deviation
      • Personnel involved in the deviation
      • Immediate actions taken to mitigate or contain the deviation (e.g., stopping production, adjusting process parameters)
      • Root cause investigation (if applicable)
    2. Ensure that the Deviation Report is signed and dated by the responsible personnel who identified and documented the deviation.

    5.3. Investigating the Deviation

    1. The Quality Assurance (QA) team is responsible for investigating all deviations. The investigation should include:
      • Reviewing the batch manufacturing record (BMR) and other relevant documentation (e.g., equipment logs, environmental monitoring records)
      • Conducting interviews with the personnel involved in the deviation to understand the cause
      • Examining the equipment used in the process to identify potential issues (e.g., malfunctioning equipment, incorrect settings)
      • Assessing the impact of the deviation on product quality and compliance with specifications
    2. Once the root cause is determined, document the findings in the Deviation Report and outline any corrective actions required to address the issue.

    5.4. Implementing Corrective and Preventive Actions (CAPA)

    1. Based on the investigation, the QA team should determine appropriate corrective and preventive actions (CAPA) to resolve the deviation and prevent recurrence. CAPA should include:
      • Immediate corrective actions to resolve the deviation (e.g., adjusting equipment settings, replacing raw materials, retraining personnel)
      • Long-term preventive actions to prevent similar deviations from occurring in the future (e.g., revising SOPs, upgrading equipment, implementing more stringent monitoring procedures)
    2. Ensure that the CAPA plan is documented in the Deviation Report and that all actions are tracked to completion. The responsible personnel should sign off on the actions taken.

    5.5. Reviewing and Approving the Deviation Report

    1. Once the deviation investigation is complete and corrective actions are implemented, the Deviation Report should be reviewed by the QA team to ensure that all relevant details are included, and that corrective actions are appropriate.
    2. If the deviation is resolved and no further issues are identified, the QA team should approve the Deviation Report and close the case.
    3. If additional actions are needed, the QA team should request further investigation and corrective actions until the deviation is fully resolved.

    5.6. Archiving the Deviation Report

    1. Once approved, the Deviation Report should be archived for future reference. All deviation reports should be retained for the required duration according to company policy and regulatory requirements.
    2. Ensure that archived deviation reports are accessible to authorized personnel and can be retrieved for audits, inspections, or further investigations.

    6. Abbreviations

    • GMP: Good Manufacturing Practice
    • QA: Quality Assurance
    • SOP: Standard Operating Procedure
    • CAPA: Corrective and Preventive Action
    • BMR: Batch Manufacturing Record
    • PCR: Product Control Record
    • QC: Quality Control

    7. Documents

    1. Deviation Report (Annexure-1)
    2. Corrective Action Log (Annexure-2)
    3. Root Cause Analysis Report (Annexure-3)

    8. References

    This SOP is based on the following regulatory guidelines and industry standards:

    • Good Manufacturing Practice (GMP) Guidelines
    • FDA Code of Federal Regulations (CFR) Title 21, Part 211
    • ISO 9001 – Quality Management Systems

    9. SOP Version

    Version: 2.0

    10. Approval Section

    Prepared By Checked By Approved By
    Signature
    Date
    Name
    Designation
    Department

    11. Annexures

    Annexure-1: Deviation Report

    Deviation ID Deviation Description Corrective Action Root Cause Investigation Date Responsible Person
    DEV-12345 Pressure deviation in filling machine Recalibrated pressure gauge Equipment malfunction 06/02/2025 Rajesh Patel

    Annexure-2: Corrective Action Log

    Action ID Action Description Responsible Person Completion Date
    CA-12345 Recalibrated pressure gauge and inspected equipment Rajesh Patel 06/02/2025

    Annexure-3: Root Cause Analysis Report

    Root Cause ID Root Cause Description Investigation Findings Corrective Action Responsible Person
    RC-12345 Incorrect calibration of pressure gauge Pressure gauge was improperly calibrated during maintenance Recalibrated and tested pressure gauge Rajesh Patel

    12. Revision History:

    Revision Date Revision No. Revision Details Reason for Revision Approved By Page No. Ref. Point No. Details of Revision
    01/01/2024 V 1.0 Initial Release First Issue Anjali Sharma Page 1 [Ref Point] First Release
    01/01/2025 V 2.0 Updated deviation documentation procedure To comply with updated GMP regulations Anjali Sharma Page 1 [Ref Point] Updated procedures
    See also  Aerosol: SOP for Post-Fill Weight Checks in Aerosol Cans - V 2.0
    Aerosols V 2.0 Tags:Aerosol Batch Production, Aerosol Can Design, Aerosol Cold Filling, Aerosol Documentation Standards, Aerosol Emissions Control, Aerosol Environmental Regulations, Aerosol equipment calibration, Aerosol Filling Process, Aerosol Fire Safety Measures, Aerosol Formulation, Aerosol Good Manufacturing Practice (GMP), Aerosol Hazardous Materials Handling, Aerosol Incident Reporting, Aerosol Leak Testing, Aerosol Maintenance Schedules, Aerosol Personal Protective Equipment (PPE), Aerosol Pressure Filling, Aerosol Product Labeling, Aerosol Product Testing, Aerosol Propellant Selection, Aerosol quality control, Aerosol Regulatory Compliance, Aerosol Risk Assessment, Aerosol Safety Protocols, Aerosol Standard Operating Procedures (SOPs), Aerosol Storage Requirements, Aerosol Training Programs, Aerosol Valve Crimping, Aerosol Ventilation Systems, Aerosol Waste Disposal

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