Standard Operating Procedure for Management of Temporary Procedure Changes in API Manufacturing
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/195/2025 |
| Supersedes | SOP/API/195/2022 |
| Page No. | Page 1 of 15 |
| Issue Date | 14/04/2025 |
| Effective Date | 16/04/2025 |
| Review Date | 14/04/2026 |
1. Purpose
To define a controlled process for initiating, evaluating, approving, implementing, and reverting temporary changes to standard operating procedures (SOPs), methods, or practices in API manufacturing when urgent or exceptional circumstances demand a deviation from approved processes.
2. Scope
This SOP applies to all temporary changes in manufacturing processes, analytical methods, equipment operation, raw material handling, packaging, cleaning, and documentation in API
3. Responsibilities
- Initiator (Process Owner): Submits the Temporary Change Request (TCR) with justification.
- QA Department: Evaluates, reviews, approves, and tracks temporary changes.
- Functional Departments: Implement approved temporary changes and ensure compliance during the defined period.
4. Accountability
The Head of Quality Assurance is accountable for ensuring all temporary changes are justified, risk-assessed, and managed within regulatory and GMP-compliant frameworks.
5. Procedure
5.1 Initiation of Temporary Change
- The department requiring a temporary change shall complete the Temporary Change Request Form (Annexure-1) detailing:
- Reason for change
- Scope and impact
- Duration of proposed change
- Risk mitigation strategy
- The initiator must submit the form to QA for evaluation.
5.2 Risk Assessment and Impact Evaluation
- QA, in consultation with cross-functional teams, shall assess:
- Impact on product quality, safety, and efficacy
- Compliance with regulatory filings
- Documentation and data integrity
- Training and monitoring requirements
- A Risk Assessment Checklist (Annexure-2) must be completed.
- If the change impacts a registered dossier, Regulatory Affairs must be consulted.
5.3 Approval of Temporary Change
- Upon satisfactory evaluation, QA shall approve or reject the TCR.
- Approval shall include:
- Start and end dates
- Conditions for execution
- Monitoring parameters
- Final approval shall be documented in the TCR Approval Sheet (Annexure-3).
5.4 Communication and Training
- All concerned departments shall be informed of the temporary change.
- If required, a training session must be conducted and recorded using the Training Record Log (Annexure-4).
5.5 Implementation and Monitoring
- Departments must implement the temporary change only during the approved timeframe.
- QA shall conduct periodic checks to ensure compliance using the Temporary Change Monitoring Log (Annexure-5).
- Any deviation during implementation must be handled per the Deviation Handling SOP.
5.6 Reversion to Original Procedure
- Upon expiration of the temporary change period:
- Operations must revert to the original SOP/process.
- QA shall verify reversion using the Closure Checklist (Annexure-6).
- A Temporary Change Closure Report (Annexure-7) must be completed and signed.
5.7 Extension or Conversion to Permanent Change
- In case the temporary change is beneficial and intended to continue, the department shall initiate a formal Change Control Request (CCR) and close the TCR accordingly.
- QA shall not permit extension beyond 90 calendar days without Head QA authorization and documented justification.
6. Abbreviations
- TCR: Temporary Change Request
- QA: Quality Assurance
- CCR: Change Control Request
- SOP: Standard Operating Procedure
- GMP: Good Manufacturing Practices
7. Documents
- Temporary Change Request Form (Annexure-1)
- Risk Assessment Checklist (Annexure-2)
- TCR Approval Sheet (Annexure-3)
- Training Record Log (Annexure-4)
- Temporary Change Monitoring Log (Annexure-5)
- Closure Checklist (Annexure-6)
- Temporary Change Closure Report (Annexure-7)
8. References
- ICH Q9 – Quality Risk Management
- ICH Q10 – Pharmaceutical Quality System
- 21 CFR Part 211 – GMP for Finished Pharmaceuticals
- EU GMP 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: Temporary Change Request Form
| Change Title | Initiator | Department | Reason | Proposed Duration |
|---|---|---|---|---|
| Alternate Equipment for Granulation | Rajesh Kumar | Production | Breakdown of primary equipment | 7 days |
Annexure-2: Risk Assessment Checklist
| Parameter | Risk Level (Low/Med/High) | Mitigation |
|---|---|---|
| Impact on Product Quality | Medium | Increased IPC frequency |
| Regulatory Impact | Low | Not registered yet |
Annexure-3: TCR Approval Sheet
| TCR No. | Approved By | Effective Date | Expiry Date |
|---|---|---|---|
| TCR/2025/014 | QA Head | 15/04/2025 | 22/04/2025 |
Annexure-4: Training Record Log
| Date | Name | Department | Trainer | Signature |
|---|---|---|---|---|
| 14/04/2025 | Sunita Reddy | QA | QA Officer |
Annexure-5: Temporary Change Monitoring Log
| Date | Parameter Checked | Observation | Inspector |
|---|---|---|---|
| 16/04/2025 | IPC Sampling | Compliant | QA Officer |
Annexure-6: Closure Checklist
| Checklist Item | Status | Remarks |
|---|---|---|
| Original SOP Re-implemented | Yes | Completed |
| Training on Reversion | Yes | Documented |
Annexure-7: Temporary Change Closure Report
| TCR No. | Date Closed | Closed By | Remarks |
|---|---|---|---|
| TCR/2025/014 | 23/04/2025 | QA Manager | Successfully reverted |
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 | Clarified timelines and added risk assessment section | Regulatory Compliance | QA Head |