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pharmaguidances.com/handling-of-deviations-2
Objective :To describe a procedure for handling of deviations which may occur
during the execution of various activities in written procedures in facility.
Responsibility
Personnel of concerned department shall be responsible to notify immediately
their respective superiors when any deviation occurs or is noticed.
Head-Regulatory Affairs or his/her designee shall be responsible for facilitating
prior notification or intimation to the regulatory authority, if the deviation has
impact on the concerned regulatory submissions.
Head of the concerned department or his/her designee, and Head-Quality
Assurance or his/her designee of respective location shall be responsible for
implementation and compliance of this SOP.
Accountability
Written Procedures :Written procedures are the approved and controlled documents which
are followed for the execution of various activities performed in the organization viz.,Batch
Manufacturing Records detailing manufacturing and packaging procedures, Standard
Operating Procedures (SOPs), Standard Testing Procedures (STPs). General Test
Procedures and various protocols followed for the execution of validation studies, stability
studies, etc.
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Or
We have any written procedure like standard operating procedure, standard test procedure,
BMR etc. and works against this, then it is called deviation. It means deviation from any
written procedure that we have implemented.
Critical Deviation: The deviation is likely to or will have a significant impact on critical
attributes of the product.
For example: Manufacturing instructions are not followed, wrong batch details are
printed, SOPs or methods of testing not followed during analysis etc.
Major Deviation : The deviation could or may have a significant impact on critical
attributes of the product.
For example: Line Clearance is not taken from QA, physician sample wrongly printed with
price, etc.
Critical Attribute :A critical attribute is one that defines the product and contributes to
safety, identity, purity, strength or quality. Critical attributes are usually detectable
during product testing.
For example: deviation in failure of procedure, utility, material, equipment or any system is
occurred. We can consider it as any change from the previous or our written procedure.
For example: Calibration or validation is not carried out as per schedule due to delay for
various reasons.
Procedure
Deviations may be classified into following two categories:
Planned Deviation
Un-planned Deviation
Unplanned & Planned deviations shall be sub classified on the basis of their impact of
product quality in critical, major or minor.
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The reference number for an unplanned deviation report shall consist of ten (10)
alphanumeric characters.
For example, UDR/16/001 shall be assigned to the first unplanned deviation of year
2016.
In the above unplanned deviation report number, the 1st, 2nd & 3rd characters ‘UDR’
stands for ‘Unplanned Deviation Report’.
The 4th character “/” is a forward slash.
The 5th & 6th characters ‘16’ represent the last two digits of the year 2016.
The 7th character “/” is again a forward slash.
The 8th, 9th & 10th characters ‘001’ are a sequential number.
QA shall maintain a logbook for the unplanned deviations as per Annexure III.
The filled form shall be forwarded to QA head after review by QA.
Head – QA & Head – concerned department shall assess unplanned deviation
for its impact on product quality. Details shall be documented as per Annexure
II.
Head QA may recommend for performing any additional studies, if required.
If the deviation does not affect product quality, Head – QA shall allow further
processing of the batch in question.
If there is probability of product quality getting affected, Head – QA shall assess
the impact on product quality before allowing further processing of the batch.
Product may be “Quarantined” in sealed containers, if required. Containers
shall be labeled, indicating product name, Batch No., Manufacturing Date,
Expiry Date & Batch size. The labeled containers shall be kept in secured
quarantine area.
Head – QA along with the Head of concerned department shall investigate &
find out the root cause of the problem that resulted in the deviation as per SOP
on CAPA.
Based on the investigation, the proposed corrective and preventive action shall
be taken to avoid any such reoccurrence and the same shall be implemented.
If required Formulation Research & Development (FR&D) shall be consulted by
QA to review impact on product quality and decide upon the future course of
action(s).
Closure of Deviation
In conclusion, Head – QA shall close the deviation by reviewing and assessing the
impact of deviation on the quality of the product.
Any supporting data and comments required to close the deviation (e.g.stability data)
shall be recorded or attached to the deviation report.
The time line for closure of deviation (planned or un-planned) shall be not more than
30 working days. If required, extension should be taken.
Both planned and unplanned approved deviations shall be controlled by QA and the
same shall be documented in the respective BMR also.
(Note: The planned deviation shall be implemented after the approval of QA).
Distribution
Master Copy- Quality Assurance
Controlled Copies -Engineering, Human Resource, Production, Quality
Assurance, Quality Control, Regulatory Affairs, Warehouse
History
– 00 New SOP
Annexure – I
QA Review / Approval
Comments received from QP attached: Yes /No / NA
Any additional studies required: Yes / No
Stability Studies, Additional Quality Testing,Others
___________________________________________________________________________
QA Comments:
___________________________________________________________________________
Implementation of Deviation
Deviation implemented by (department)
:_______________________________
Observations (If any):______________________________________________
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Quality Profile of batches affected (If applicable):
_____________________________
Department Head
If No, Justification:
______________________________________________________
Annexure – II
Date
_______
Deviation Initiation
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1.5 Deviation related to: Procedure Process Equipment Standard
Batch Size
Others( If any) specify:
1.11 Proposed
Preventive Action
Annexure -III
Sr. Date PDR/UDR Deviation Initiated Expected date Approved Closed Remarks
No. No. Related By for / out on
to & Deptt. Implementation Rejected (sign/date)
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