Standard Operating Procedure for QA Review of In-Process Control Records in API Manufacturing
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/176/2025 |
| Supersedes | SOP/API/176/2022 |
| 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 procedure for Quality Assurance (QA) review of In-Process Control (IPC) records generated during API manufacturing to ensure documentation accuracy, adherence to GMP, and verification of process compliance.
2. Scope
This SOP is applicable to all IPC records generated during the manufacturing of APIs including those related to raw material
verification, reaction monitoring, intermediate testing, filtration checks, drying confirmation, and milling or blending operations at the API manufacturing site.
3. Responsibilities
- Production/Process Chemists: Record all IPC data in approved formats and submit records for QA review.
- QA Officer/Executive: Reviews IPC records for completeness, accuracy, GMP compliance, and any discrepancies.
- QC Department: Provides analytical results for IPC sampling performed in the lab, if applicable.
- QA Documentation Cell: Maintains reviewed IPC records and tracks observations or trending data.
See also API Manufacturing: SOP for Documentation and Yield Calculation for Solvent Recovery - V 2.0
4. Accountability
The Head of QA is accountable for ensuring the integrity, traceability, and compliance of IPC records through timely and effective QA review processes.
5. Procedure
5.1 Types of IPC Records Reviewed
- IPC records include:
- pH checks during reaction stages
- Moisture content during drying (LOD)
- Filtration clarity and filter integrity
- Intermediate identification and assay (TLC/HPLC)
- Temperature or pressure logs
- Sampling logs and retention samples
5.2 Record Collection and Submission
- Production personnel must submit completed IPC records to QA daily or at stage completion.
- All entries must be:
- Legible, with black or blue ink
- Initialed and dated by the performer
- Crossed out with a single line in case of correction (no overwriting)
- QA shall reject any record not complying with ALCOA+ principles.
5.3 QA Review Checklist
- QA shall verify:
- Correct batch number and stage name
- Authorized signatory and date/time of activity
- Limits/specifications as per BMR/BPR
- Any deviation or OOT noted and escalated
- Use IPC Record Review Checklist (Annexure-1).
- If discrepancies are observed, a QA Observation Form shall be raised (Annexure-2).
5.4 Approval and Documentation
- If records are found compliant, QA shall sign and date each page with a “Reviewed by QA” stamp.
- Records shall be filed in the respective batch file maintained in QA archives.
- Any analytical values received from QC shall be reconciled with production records before QA approval.
5.5 Trending and Monitoring
- QA shall maintain a Monthly IPC Record Tracker (Annexure-3) to trend:
- Number of IPCs reviewed
- Non-compliance observed
- Repeat observations across batches
- This trending shall be used in the APQR and for planning training needs.
5.6 Deviations and Investigation
- In case of critical or recurring documentation errors, QA shall initiate a deviation and conduct root cause analysis.
- Based on impact, retraining or CAPA may be initiated.
6. Abbreviations
- IPC: In-Process Control
- QA: Quality Assurance
- BMR: Batch Manufacturing Record
- OOT: Out of Trend
- CAPA: Corrective and Preventive Action
- ALCOA+: Attributable, Legible, Contemporaneous, Original, Accurate + Complete, Consistent, Enduring, Available
7. Documents
- IPC Record Review Checklist (Annexure-1)
- QA Observation Form (Annexure-2)
- Monthly IPC Record Tracker (Annexure-3)
8. References
- ICH Q7: Good Manufacturing Practice Guide for Active Pharmaceutical Ingredients
- 21 CFR Part 211 – Subpart F: Production and Process Controls
- EU GMP Guidelines – Part II
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: IPC Record Review Checklist
| Checkpoint | Compliant (Y/N) | Comments |
|---|---|---|
| Batch Number matches BMR | Y | – |
| Signatures & Date present | Y | – |
| Limits followed | Y | – |
Annexure-2: QA Observation Form
| Observation No. | Date | Observed By | Description | Action Taken |
|---|---|---|---|---|
| QA/OBS/2025/04 | 12/04/2025 | Sunita Reddy | Missing IPC limits on pH record | Clarified and retrained |
Annexure-3: Monthly IPC Record Tracker
| Month | Total IPCs Reviewed | Observations Raised | Repeat Issues |
|---|---|---|---|
| March 2025 | 48 | 3 | 1 |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 01/01/2022 | 1.0 | Initial SOP | New document | QA Head |
| 14/04/2025 | 2.0 | Added IPC tracker, observation form | Improved traceability | QA Head |