Objective: To lay down a procedure for investigation of any discrepancy incidents, complaints, etc) using Root Cause Analysis (RCA).
Scope: This procedure is applicable for investigation and
RCA of (but not limited to):
·
Incidents
·
Market
Complaints
·
Out
of Trend (OOT)
Which
are related to the quality of product and or system observed at ---------------------------
Responsibility: Officer / above of QA:
Co-ordination with the investigation team.
Investigation
Team: Investigation and Root Cause Analysis of the observed discrepancy. Head QA /
Designee: Team Formation, Approval of Investigation Report.
Accountability: Head QA / Designee shall be
accountable for the implementation of this SOP.
Procedure:
Whenever
a discrepancy occurs, that shall be routed through the respective SOP For example if any incident occurs, then it shall be routed through SOP
"Handling of Incident (QA-GN-005)".
After
initiation of respective form as per the discrepancy, if the need for thorough the investigation is identified, then the investigation shall be initiated as per
the procedure is given below:
Head QA
/ Designee will formulate a cross-functional investigation team (SMEs of the
departments)
The investigation team shall start the investigation using the root cause analysis process.
The Root Cause Analysis Process
has the following identifiable steps:
Define the Problem:
Ø
What
wrong happened?
Ø
What
are the specific symptoms?
Collect
Data:
Ø
What
proof we have that the problem exists?
Ø
How
long has the problem existed?
Ø
What
is the impact of the problem?
Ø
We
need to analyze a situation fully before we can move on to look at factors that
contributed to the problem. To maximize the effectiveness of RCA, get together
everyone - experts and front line staff - who understands the situation. People
who are most familiar with the problem can help lead us to a better
understanding of the issues.
Identify Possible Causal Factors:
Ø
What sequence of events leads to the problem?
Ø
What
conditions allow the problem to occur?
Ø
What
other problems surround the occurrence of the central problem?
Ø
During
this stage, identify as many causal factors as possible. Following tools can be
used to help identify causal factors (but not limited to):
A.
Events and Causal Factor Charting
B.
Change Analysis
C.
Barrier Analysis
D.
Ishikawa diagrams
E. 5 Why
Method
F.
Pareto Analysis
G.
Storytelling
H. Fault
Tree Analysis
I.
Failure Modes and Effect Analysis
Note:
Refer Annexure No. QAGNO32/A02 for investigation tools details,
Identify the Root Cause(s):
Why does
the causal factor exist?
What is
/ are the probable reason(s) of the occurred problem?
Impact Assessment of the
discrepancy:
What is
the impact of the discrepancy?
Is there
any impact on the product's safety, efficacy, identity, purity & strength?
Recommend and Implement
Solutions:
What can
you do prevent the problem from happening again?
How will
the solution be implemented?
Who will
be responsible for it?
What are
the risks of implementing the solution?
Finally
based on the recommendations, came out of the investigation, CAPA shall be
proposed
The
investigation report shall be prepared as per the template (as per Format No. QAGNO32/F01).
The
proposed CAPA in the investigation shall be implemented and tracked through the
current version of SOP on "Corrective and Preventive Action",
numbered "QAGN-024".
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Pharmaceutical guideline only