Standard Operating Procedure for Handling of Unplanned Events in GMP Areas
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/199/2025 |
| Supersedes | SOP/API/199/2022 |
| Page No. | Page 1 of 15 |
| Issue Date | 14/04/2025 |
| Effective Date | 16/04/2025 |
| Review Date | 14/04/2026 |
1. Purpose
To provide a systematic approach for identifying, documenting, evaluating, and managing unplanned events that occur in Good Manufacturing Practice (GMP) areas of API manufacturing, in order to mitigate risks to product quality and ensure timely resolution and regulatory compliance.
2. Scope
This SOP applies to all unplanned events observed in GMP manufacturing, packing, quality control, and
storage areas during operations. These may include environmental excursions, power interruptions, equipment breakdowns, procedural deviations, and utility failures.
3. Responsibilities
- Initiator (Operator/Supervisor): Immediately identifies and documents the unplanned event.
- Department Head: Evaluates preliminary impact and notifies QA.
- QA Officer: Performs assessment, categorization, and initiates documentation and investigation.
- QA Manager: Approves final disposition, ensures corrective/preventive actions are implemented.
4. Accountability
The Head of Quality Assurance is accountable for ensuring that all unplanned events are properly managed, investigated, and closed as per defined timelines and in accordance with GMP guidelines.
5. Procedure
5.1 Identification and Initial Action
- Any GMP personnel observing an unplanned event must immediately:
- Stop the process (if necessary)
- Secure product and environment
- Inform the area supervisor
- The supervisor shall record initial details in the Unplanned Event Notification Form (Annexure-1) and notify QA.
5.2 Classification of Unplanned Event
- QA shall classify the unplanned event based on impact:
- Minor: No impact on product quality or GMP compliance
- Major: Potential or confirmed impact on quality/process
- Critical: Definite impact on product, requires immediate action or regulatory notification
- Classification shall be recorded in the Unplanned Event Register (Annexure-2).
5.3 Documentation and Evaluation
- The QA Officer shall:
- Log the event in the tracking system
- Assign a unique reference number (e.g., UE-API-2025-007)
- Initiate the Unplanned Event Investigation Form (Annexure-3)
- Department Head and QA shall jointly perform impact assessment and risk evaluation using the Risk Assessment Template (Annexure-4).
5.4 Root Cause Analysis
- Use tools such as:
- 5 Whys
- Ishikawa (Fishbone) Diagram
- Document RCA in Section C of the Investigation Form and attach supporting evidence.
5.5 Corrective and Preventive Actions (CAPA)
- Define:
- Corrective Actions: To address the current issue
- Preventive Actions: To prevent recurrence
- QA shall approve CAPA plan and assign target dates and responsible persons.
- Track progress in the Unplanned Event CAPA Log (Annexure-5).
5.6 QA Review and Closure
- QA Manager shall:
- Verify CAPA implementation
- Ensure effectiveness checks
- Review supporting documentation
- Closure shall be documented in the final section of the Investigation Form and approved by QA.
5.7 Trending and Reporting
- QA shall trend unplanned events monthly using the Event Trending Sheet (Annexure-6).
- Trends must be reviewed during:
- Quarterly Quality Review Meetings
- Annual Product Quality Review (PQR)
6. Abbreviations
- GMP: Good Manufacturing Practices
- QA: Quality Assurance
- CAPA: Corrective and Preventive Action
- RCA: Root Cause Analysis
- PQR: Product Quality Review
7. Documents
- Unplanned Event Notification Form – Annexure-1
- Unplanned Event Register – Annexure-2
- Unplanned Event Investigation Form – Annexure-3
- Risk Assessment Template – Annexure-4
- Unplanned Event CAPA Log – Annexure-5
- Event Trending Sheet – Annexure-6
8. References
- ICH Q10 – Pharmaceutical Quality System
- EU GMP Chapter 1 – Quality System
- 21 CFR 211.100 – Written Procedures
- WHO Technical Report Series No. 981 – GMP for APIs
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: Unplanned Event Notification Form
| Date | Time | Area | Description | Initiator |
|---|---|---|---|---|
| 12/04/2025 | 10:15 AM | Granulation Room | Power interruption during drying | Rajesh Kumar |
Annexure-2: Unplanned Event Register
| Event ID | Date | Classification | Status | Closed On |
|---|---|---|---|---|
| UE-API-2025-007 | 12/04/2025 | Major | Closed | 14/04/2025 |
Annexure-3: Unplanned Event Investigation Form
| Event ID | Description | Initial Assessment | RCA Summary | QA Review |
|---|---|---|---|---|
| UE-API-2025-007 | Equipment stopped during granulation | Batch on hold | Loose wire in panel | Impact nullified |
Annexure-4: Risk Assessment Template
| Parameter | Severity | Probability | Detectability | Risk Score |
|---|---|---|---|---|
| Batch impact | Medium | Low | High | 6 |
Annexure-5: Unplanned Event CAPA Log
| CAPA ID | Action | Owner | Due Date | Status |
|---|---|---|---|---|
| CAPA/2025/018 | Replace panel wire | Engineering | 13/04/2025 | Completed |
Annexure-6: Event Trending Sheet
| Month | Minor | Major | Critical | Total |
|---|---|---|---|---|
| March 2025 | 4 | 2 | 0 | 6 |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 01/01/2022 | 1.0 | Initial Release | New SOP | QA Head |
| 14/04/2025 | 2.0 | Added annexures and classification tiers | Internal Audit Recommendation | QA Head |