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Ointments: SOP for Recording Deviations and CAPA Reports – V 2.0

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SOP for Recording Deviations and CAPA Reports – V 2.0

Procedure for Recording Deviations and CAPA Reports

Department Quality Assurance (QA)/Quality Control (QC)/Production
SOP No. SOP/Ointment/155
Supersedes V 1.0
Page No. Page X of Y
Issue Date [Insert Issue Date]
Effective Date [Insert Effective Date]
Review Date [Insert Review Date]

1. Purpose

The purpose of this Standard Operating Procedure (SOP) is to define the systematic approach for identifying, documenting, investigating, and addressing deviations in pharmaceutical manufacturing. It also outlines the Corrective and Preventive Action (CAPA) process to ensure continual improvement and compliance with Good Manufacturing Practices (GMP).

2. Scope

This SOP applies to all personnel in the Quality Assurance (QA), Quality Control (QC), and Production departments responsible for identifying deviations, recording them in deviation reports, and implementing CAPA procedures.

3. Responsibilities

  • Production Supervisor: Identifies deviations and initiates deviation reports.
  • QA Officer: Reviews deviations, conducts investigations, and proposes corrective actions.
  • QC Analyst: Evaluates quality-related deviations and assesses potential product impact.
  • CAPA Coordinator: Implements corrective and preventive actions.
  • QA Manager: Approves deviation reports and CAPA plans.

4. Accountability

The QA and Production Managers are accountable for ensuring that all deviations are documented and addressed in compliance with GMP, FDA, ICH, and WHO regulations.

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5. Procedure

5.1 Types of Deviations

Deviations are classified into three categories based on their impact on product quality and regulatory compliance:

  • Critical Deviation: Any deviation that significantly impacts product
quality, patient safety, or regulatory compliance (e.g., microbial contamination, incorrect formulation, equipment failure).
  • Major Deviation: A deviation that does not directly impact product quality but may affect process efficiency (e.g., exceeding temperature limits, incomplete documentation).
  • Minor Deviation: A minor procedural deviation with no significant effect on product quality (e.g., slight delay in record entry, minor errors in labeling).
  • 5.2 Identifying and Documenting Deviations

    • Any personnel identifying a deviation must report it to the **Production Supervisor or QA Officer** immediately.
    • A **Deviation Report** must be initiated, capturing the following details:
      • Date and time of deviation occurrence.
      • Location and process step affected.
      • Detailed description of the deviation.
      • Immediate corrective actions taken.
      • Name of the person reporting the deviation.
    • The deviation report must be submitted to QA within **24 hours** of detection.

    5.3 Investigation of Deviations

    • QA must initiate a **Root Cause Analysis (RCA)** within **48 hours** of receiving a deviation report.
    • Investigation methods include:
      • Review of batch records and process logs.
      • Interviews with personnel involved.
      • Analysis of equipment calibration and environmental monitoring records.
    • The investigation findings must be recorded in the **Deviation Investigation Report**.
    • Critical deviations must be escalated to senior management.

    5.4 Corrective and Preventive Action (CAPA) Process

    • Based on the deviation investigation, a **CAPA Plan** must be developed.
    • Corrective Actions:
      • Immediate steps to rectify the identified deviation.
      • Product recall or batch rejection if necessary.
      • Training of personnel if human error is identified.
    • Preventive Actions:
      • Revising SOPs and work instructions.
      • Enhancing equipment calibration and maintenance schedules.
      • Implementing additional quality control checks.
    • The CAPA plan must be reviewed and approved by the QA Manager.

    5.5 Implementation and Monitoring of CAPA

    • The CAPA Coordinator must track the implementation of corrective and preventive actions.
    • A **CAPA Effectiveness Check** must be conducted **one month after implementation**.
    • QA must verify that no recurrence of the deviation has been observed.

    5.6 Review and Approval of Deviation Reports and CAPA

    • QA must review all deviation reports monthly.
    • CAPA reports must be reviewed quarterly for effectiveness.
    • Deviation records and CAPA reports must be archived for a **minimum of 5 years**.

    6. Abbreviations

    • GMP – Good Manufacturing Practices
    • QA – Quality Assurance
    • QC – Quality Control
    • CAPA – Corrective and Preventive Action
    • RCA – Root Cause Analysis
    • FDA – Food and Drug Administration
    • ICH – International Council for Harmonisation

    7. Documents

    • Deviation Report Template (Annexure-1)
    • CAPA Implementation Log (Annexure-2)

    8. References

    • ICH Q10 – Pharmaceutical Quality System
    • WHO Guidelines on Deviation and CAPA Management
    • US FDA Guidance on CAPA Implementation

    9. SOP Version

    Version 2.0

    10. Approval Section

    Prepared By Checked By Approved By
    Signature
    Date
    Name
    Designation
    Department

    11. Annexures

    Annexure-1: Deviation Report Template

    Date Process Step Deviation Description Reported By QA Review
    02/02/2025 Mixing Process Temperature exceeded by 2°C John Doe Reviewed

    Annexure-2: CAPA Implementation Log

    Date CAPA Action Responsible Person Completion Date Effectiveness Check
    02/02/2025 Temperature alarm system installed Jane Smith 05/02/2025 Verified

    12. Revision History

    Revision Date Revision No. Details Reason Approved By
    02/02/2025 2.0 Expanded Procedure Improved CAPA Documentation QA Head
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    Standard Operating Procedures V 1.0

    • Aerosols
    • Analytical Method Development
    • Bioequivalence Bioavailability Study
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    • Clinical Studies
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    • Tablet Manufacturing
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    NEW! Revised SOPs – V 2.0

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