Standard Operating Procedure for Reanalysis Protocol for Failed Samples in API Manufacturing
| Department | API Manufacturing |
|---|---|
| SOP No. | SOP/API/146/2025 |
| Supersedes | SOP/API/146/2022 |
| Page No. | Page 1 of 9 |
| Issue Date | 13/04/2025 |
| Effective Date | 15/04/2025 |
| Review Date | 13/04/2026 |
1. Purpose
To establish a scientifically sound and regulatory-compliant procedure for initiating reanalysis of samples that have yielded out-of-specification (OOS), out-of-trend (OOT), or anomalous results in the QC laboratory of API manufacturing.
2. Scope
This SOP is applicable to all raw materials, intermediates, and finished API samples tested in the Quality Control Laboratory where results are found to deviate from approved specifications
or expectations.
3. Responsibilities
- QC Analyst: Notify supervisor of failed result and complete documentation accurately.
- QC Supervisor: Evaluate initial data and determine if reanalysis is scientifically justified.
- QA Officer: Approve reanalysis plan and review the final outcome and conclusions.
4. Accountability
The Quality Head is accountable for ensuring that reanalysis is not misused to discard legitimate OOS results and is only conducted when scientifically justified and properly documented.
5. Procedure
5.1 Identification of Failed Result
- Any test result not meeting specification shall be reported immediately to the QC Supervisor.
- Do not discard any test data, raw printouts, or sample preparations.
- Label the sample “UNDER INVESTIGATION.”
- Document the result in the QC worksheet and OOS Logbook (Annexure-1).
5.2 Preliminary Review
- QC Supervisor shall:
- Review calculations, instrument logs, chromatograms, and observations
- Check system suitability and reference standard integrity
- Confirm sample handling and preparation steps
- If no apparent error is found, escalate to QA to initiate a formal OOS investigation.
5.3 Reanalysis Criteria
- Reanalysis may be justified under these conditions:
- Instrumental error (power failure, malfunction, calibration drift)
- Obvious analyst error or contamination during preparation
- Degradation or precipitation during sample storage
- Use of incorrect STP or expired reagent
- QA must approve the justification for reanalysis and assign a reanalysis plan using Annexure-2.
5.4 Conducting the Reanalysis
- Use a fresh aliquot of the same sample where possible. If not, use a new sample from retained stock.
- Prepare reagents, standards, and sample solution freshly as per the applicable STP.
- Perform complete analysis, not just the failed parameter, if required by QA.
- Ensure all new data is traceable and stored separately from the initial test.
5.5 Evaluation and Decision
- If the reanalysis result conforms:
- Investigate root cause of the original failure.
- Determine if a laboratory error is confirmed.
- If both initial and reanalysis results are out of specification:
- Batch must be considered OOS.
- Refer to QA for further action including deviation, CAPA, or rejection.
- Summarize findings and rationale in the Reanalysis Report (Annexure-3).
5.6 Documentation
- Record the following:
- Original result and analyst’s observation
- Root cause investigation outcome
- QA approval for reanalysis
- Reanalysis method and results
- Final disposition recommendation
- Retain all original and repeat results with time/date stamp and analyst initials.
6. Abbreviations
- OOS: Out of Specification
- OOT: Out of Trend
- QC: Quality Control
- QA: Quality Assurance
- SOP: Standard Operating Procedure
- STP: Standard Test Procedure
7. Documents
- OOS Logbook (Annexure-1)
- Reanalysis Authorization Form (Annexure-2)
- Reanalysis Report (Annexure-3)
- QC Worksheets and Raw Data
8. References
- US FDA Guidance on Investigating OOS Test Results (2006)
- ICH Q7 – GMP for APIs
- 21 CFR Part 211.192
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | |||
| Department |
11. Annexures
Annexure-1: OOS Logbook
| Date | Sample ID | Test | Result | Status | Remarks |
|---|---|---|---|---|---|
| 13/04/2025 | SMP-146 | Assay | 94.2% | OOS | Reanalysis Approved |
Annexure-2: Reanalysis Authorization Form
| Sample ID | Justification | Authorized By | Date |
|---|---|---|---|
| SMP-146 | Suspected glassware contamination | QA Officer | 13/04/2025 |
Annexure-3: Reanalysis Report
| Test | Initial Result | Reanalysis Result | Disposition | Conclusion |
|---|---|---|---|---|
| Assay | 94.2% | 99.1% | Acceptable | Lab Error Confirmed |
Revision History:
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 01/01/2022 | 1.0 | Initial version | Regulatory Compliance | QA Head |
| 13/04/2025 | 2.0 | Included Annexure Templates | Audit Feedback | QA Head |