SOP Guide for Pharma

Sterile Injectable Manufacturing: SOP for Investigations of Complaints Related to Injectable Products – V 2.0

Sterile Injectable Manufacturing: SOP for Investigations of Complaints Related to Injectable Products – V 2.0

Standard Operating Procedure for Investigations of Complaints Related to Injectable Products


Department Sterile Injectable Manufacturing
SOP No. SOP/SIM/088/2025
Supersedes SOP/SIM/088/2022
Page No. Page 1 of 14
Issue Date 18/06/2025
Effective Date 20/06/2025
Review Date 18/06/2026

1. Purpose

To define a standard procedure for managing, investigating, and closing complaints related to sterile injectable products, ensuring product quality, patient safety, and regulatory compliance.

2. Scope

This SOP applies to all complaints received internally or externally that concern sterile

injectable products manufactured at the facility, including product defects, adverse reactions, and quality-related issues.

3. Responsibilities

  • QA Head: Overall responsibility for complaint handling and closure.
  • Complaint Handling Officer: Receives, records, investigates, and coordinates all activities related to complaint investigations.
  • Production Head: Provides relevant manufacturing information for investigation.
  • QC Manager: Conducts sample analysis if required during investigation.

4. Accountability

The Quality Assurance Department is accountable for ensuring that all product complaints are handled, investigated, documented, and closed in a timely and compliant manner.

5. Procedure

5.1 Complaint Receipt and Recording

  1. Complaints may be received via telephone, email, written letters, regulatory bodies, or field representatives.
  2. Immediately log the complaint in the Product Complaint Register (Annexure-1).
  3. Assign a unique complaint ID in the format: COMP/YY/NNN.
  4. Acknowledge receipt to the complainant within 2 working days.

5.2 Preliminary Assessment

  1. Review complaint description, product details, and batch number.
  2. Check if similar complaints have been reported earlier.
  3. Evaluate if the complaint is critical (e.g., sterility failure, adverse event, contamination).
  4. Inform QA Head immediately if criticality is high.

5.3 Investigation and Root Cause Analysis

  1. Form a cross-functional investigation team (QA, QC, Production, Regulatory as needed).
  2. Review:
    • Batch Manufacturing Record (BMR)
    • Packaging records
    • In-process control results
    • Environmental monitoring data
  3. If sample is returned, send to QC for analysis and retain records in Annexure-2: Sample Analysis Log.
  4. Document findings in Annexure-3: Complaint Investigation Report.

5.4 Corrective and Preventive Actions (CAPA)

  1. Based on investigation outcome, initiate appropriate CAPA.
  2. Assign CAPA responsibilities with target dates.
  3. Track CAPA completion and effectiveness verification.

5.5 Closure and Documentation

  1. QA Head reviews investigation and CAPA completion.
  2. Approve final closure with documented conclusion and corrective measures implemented.
  3. Update Complaint Register with closure status and date.
  4. Maintain complaint records for a minimum of 5 years.

6. Abbreviations

  • SOP: Standard Operating Procedure
  • QA: Quality Assurance
  • QC: Quality Control
  • CAPA: Corrective and Preventive Action
  • BMR: Batch Manufacturing Record

7. Documents

  1. Product Complaint Register – Annexure-1
  2. Sample Analysis Log – Annexure-2
  3. Complaint Investigation Report – Annexure-3

8. References

  • ICH Q10 – Pharmaceutical Quality System
  • 21 CFR 211.198 – Complaint Files
  • WHO TRS 986 Annex 2 – Quality Risk Management

9. SOP Version

Version: 2.0

10. Approval Section

Prepared By Checked By Approved By
Signature
Date
Name
Designation Manufacturing Executive QA Executive Head QA
Department Production Quality Assurance Quality Assurance

11. Annexures

Annexure-1: Product Complaint Register

Complaint ID Date Product Batch No. Nature of Complaint Status
COMP/25/001 10/06/2025 Inj. Ceftriaxone 1g CTJ25001 Particulate matter Closed

Annexure-2: Sample Analysis Log

Complaint ID Sample Received Test Performed Result Analyst
COMP/25/001 Yes Visual Inspection Particulate Confirmed Priya Nair

Annexure-3: Complaint Investigation Report

Complaint ID Investigation Summary Root Cause CAPA Taken Closure Date
COMP/25/001 Packaging fiber found inside vial Operator error during capping Retrained staff, added inspection step 15/06/2025

Revision History

Revision Date Revision No. Details Reason Approved By
01/07/2022 1.0 Initial Release New SOP QA Head
18/06/2025 2.0 Added CAPA traceability and sample log Review Update QA Head
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