SOP Guide for Pharma

API Manufacturing: SOP for Rework and Reprocessing Guidelines – V 2.0

API Manufacturing: SOP for Rework and Reprocessing Guidelines – V 2.0

Standard Operating Procedure for Rework and Reprocessing Guidelines in API Manufacturing

Department API Manufacturing
SOP No. SOP/API/039/2025
Supersedes SOP/API/039/2022
Page No. Page 1 of 10
Issue Date 13/04/2025
Effective Date 15/04/2025
Review Date 13/04/2026

1. Purpose

To establish a GMP-compliant procedure for managing rework and reprocessing of non-conforming API batches, ensuring product quality, process traceability, and regulatory oversight.

2. Scope

This SOP applies to all Active Pharmaceutical Ingredients (APIs) manufactured in-house that require rework or reprocessing due to non-compliance with predefined specifications during or after production.

3. Responsibilities

  • Production Personnel: Identify non-conformance and propose rework/reprocessing
plans.
  • QA Department: Review and approve rework/reprocessing proposals and oversee execution.
  • QC Department: Perform analytical testing before and after rework/reprocessing.
  • 4. Accountability

    The QA Head is accountable for approving rework/reprocessing procedures and ensuring regulatory compliance. The Production Head is responsible for execution as per approved protocol.

    5. Procedure

    5.1 Definitions

    • Rework: Subjecting non-conforming product to one or more processing steps different from original manufacturing process.
    • Reprocessing: Repeating one or more steps of the original manufacturing process.

    5.2 Identification of Non-Conformance

    1. Identify deviations in physical, chemical, or microbiological specifications during IPC or final QC testing.
    2. Record findings in the Batch Manufacturing Record (BMR) and notify QA.

    5.3 Proposal and Approval

    1. Production team shall prepare a “Rework/Reprocessing Proposal Form” (Annexure-1).
    2. Include:
      • Batch details
      • Root cause
      • Proposed method
      • Justification
      • Risk assessment
    3. QA reviews the proposal with QC and approves if compliant with regulatory guidelines and internal quality risk management practices.

    5.4 Execution of Rework/Reprocessing

    1. Execute only after QA approval.
    2. Follow instructions outlined in the approved plan.
    3. Document all activities separately in “Rework/Reprocessing Execution Log” (Annexure-2).
    4. Label material appropriately during each stage of reprocessing (e.g., “Under Rework”).

    5.5 Testing and Disposition

    1. Submit samples to QC for complete analysis after rework/reprocessing.
    2. Compare test results with original specifications and document in the COA.
    3. Only QA shall approve release or rejection of the batch after reprocessing.
    4. Retain full documentation in batch file and deviation records.

    5.6 Regulatory and Stability Considerations

    1. If reprocessing/rework is included in approved regulatory filing, no further approval is needed.
    2. If not included, regulatory affairs shall be consulted before execution.
    3. Perform stability studies if reprocessing has potential to impact product shelf life.

    6. Abbreviations

    • SOP: Standard Operating Procedure
    • QA: Quality Assurance
    • QC: Quality Control
    • IPC: In-Process Control
    • BMR: Batch Manufacturing Record
    • COA: Certificate of Analysis

    7. Documents

    1. Rework/Reprocessing Proposal Form (Annexure-1)
    2. Rework/Reprocessing Execution Log (Annexure-2)
    3. QC Report Post-Reprocessing (Annexure-3)

    8. References

    • ICH Q7 – Good Manufacturing Practice for Active Pharmaceutical Ingredients
    • 21 CFR Part 211 – Subpart F & J
    • WHO GMP Guidelines – Rework and Reprocessing Section

    9. SOP Version

    Version: 2.0

    10. Approval Section

    Prepared By Checked By Approved By
    Signature
    Date
    Name
    Designation
    Department

    11. Annexures

    Annexure-1: Rework/Reprocessing Proposal Form

    Batch No. Product Issue Observed Proposed Method Justification Approved By
    API-202504 API-X Low Assay Recrystallization Restores potency

    Annexure-2: Rework/Reprocessing Execution Log

    Date Batch No. Executed Step Performed By Observed Results
    13/04/2025 API-202504 Repeat Crystallization Clear crystals formed

    Annexure-3: QC Report Post-Reprocessing

    Batch No. Parameter Result Limit Status
    API-202504 Assay 99.2% 98.0–102.0% Pass

    Revision History:

    Revision Date Revision No. Details Reason Approved By
    01/01/2022 1.0 Initial SOP Release New GMP Process QA Head
    13/04/2025 2.0 Added regulatory filing considerations Audit Requirement QA Head
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