Standard Operating Procedure for Change Control Request Evaluation and Implementation in API Manufacturing
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/164/2025 |
| Supersedes | SOP/API/164/2022 |
| Page No. | Page 1 of 13 |
| Issue Date | 14/04/2025 |
| Effective Date | 16/04/2025 |
| Review Date | 14/04/2026 |
1. Purpose
To define a systematic and controlled procedure for initiating, reviewing, evaluating, approving, implementing, and closing change control requests (CCRs) in API manufacturing, ensuring GMP compliance, traceability, and product quality assurance.
2. Scope
This SOP is applicable to all proposed changes that may directly or indirectly affect manufacturing processes, facilities, utilities, documentation, equipment, raw materials, packaging materials, testing
methods, and computerized systems within the API manufacturing plant.
3. Responsibilities
- Change Initiator: Raise the Change Control Request Form with appropriate justification.
- Department Head: Review technical feasibility and operational impact.
- QA Head: Evaluate regulatory and quality impact; coordinate change control system.
- Change Control Committee: Approve or reject changes and oversee implementation.
4. Accountability
The Head of Quality Assurance is accountable for the administration of the change control system, final approval of change controls, and verification of implementation effectiveness.
5. Procedure
5.1 Types of Change
- Major Change: Likely to affect product quality or regulatory filings (e.g., formulation changes, new equipment).
- Minor Change: Limited impact, requires internal documentation (e.g., label text correction).
- Temporary Change: Time-bound or one-time deviation from a standard process (requires justification and timeline).
5.2 Initiation of Change
- The concerned department shall fill out a Change Control Request Form (Annexure-1).
- The form shall include:
- Details of proposed change
- Justification and rationale
- Classification (Major/Minor/Temporary)
- Expected implementation date
- Submit the form to QA for registration and evaluation.
5.3 Change Control Register
- QA assigns a unique CCR number (e.g., CCR/2025/017).
- Enter all details in the Change Control Register (Annexure-2).
5.4 Evaluation and Impact Assessment
- The QA team shall assess:
- Impact on validated systems
- Impact on regulatory filings
- Need for requalification or revalidation
- Training and documentation updates
- Departmental review shall include:
- Engineering – Facility or utility modifications
- QC – Analytical method or equipment impact
- Production – Impact on process flow or batch yield
- Complete the Impact Assessment Sheet (Annexure-3).
5.5 Review by Change Control Committee
- The QA Head shall convene a Change Control Committee (CCC) meeting for review.
- CCC shall include representatives from QA, QC, Production, Engineering, Regulatory Affairs, and Warehouse.
- The committee decides:
- Approval
- Rejection with reasons
- Modification before re-submission
5.6 Implementation
- Upon approval, implementation shall be done as per approved action plan.
- QA shall oversee:
- Equipment requalification
- Document revision and issuance
- Process revalidation (if needed)
- Training to concerned staff
- Document implementation evidence in the Change Control Implementation Log (Annexure-4).
5.7 Effectiveness Verification and Closure
- After implementation, QA performs effectiveness verification to confirm:
- No adverse impact on product/process
- Change is working as intended
- QA Head signs the Change Control Closure Form (Annexure-5).
- Mark CCR as “Closed” in the Change Control Register.
5.8 Deviation or CAPA Linkage
- If a change arises from a deviation, link the CCR number with the deviation or CAPA number for traceability.
- Ensure CAPA closure before final CCR closure.
5.9 Archiving and Review
- All CCR documentation shall be archived for a minimum of 5 years.
- QA shall trend all changes and present analysis in quarterly Quality Review Meetings.
6. Abbreviations
- CCR: Change Control Request
- QA: Quality Assurance
- QC: Quality Control
- CCC: Change Control Committee
- CAPA: Corrective and Preventive Action
7. Documents
- Change Control Request Form (Annexure-1)
- Change Control Register (Annexure-2)
- Impact Assessment Sheet (Annexure-3)
- Implementation Log (Annexure-4)
- Change Control Closure Form (Annexure-5)
8. References
- ICH Q10 – Pharmaceutical Quality System
- 21 CFR Part 211 – Subpart B: Organization and Personnel
- EU GMP Guidelines – Chapter 1: Pharmaceutical Quality System
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: Change Control Request Form
| CCR No. | Date | Proposed Change | Initiator | Type |
|---|---|---|---|---|
| CCR/2025/017 | 12/04/2025 | Replace SS pipeline with PTFE | Rajesh Kumar | Major |
Annexure-2: Change Control Register
| CCR No. | Date | Department | Status | Closed On |
|---|---|---|---|---|
| CCR/2025/017 | 12/04/2025 | Production | Open | — |
Annexure-3: Impact Assessment Sheet
| CCR No. | Area Assessed | Impact | Assessed By |
|---|---|---|---|
| CCR/2025/017 | Equipment Qualification | Requalification required | Sunita Reddy |
Annexure-4: Implementation Log
| CCR No. | Activity | Date | Performed By | Status |
|---|---|---|---|---|
| CCR/2025/017 | Pipeline Replacement | 15/04/2025 | Maintenance Team | Completed |
Annexure-5: Change Control Closure Form
| CCR No. | Closure Date | Effectiveness Verified | QA Approval |
|---|---|---|---|
| CCR/2025/017 | 20/04/2025 | Yes | QA Head |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 01/01/2022 | 1.0 | Initial Issue | New SOP System | QA Head |
| 14/04/2025 | 2.0 | Updated annexures and impact evaluation workflow | Process Improvement | QA Head |