2015_GMP_Validation_Forum_Deviation-Incident-Non-conformance-Systems (1).pdf

Setting up deviation,
incident, non-
conformance systems
Presented by Debbie Parker
4 July, 2016

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Introduction
This session will cover:
Regulations
Definitions
Process
Case Study
Setting up a new system
Common issues

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Deviations, incidents, non-
conformances, discrepancies…
What is a
deviation
Or a non-
conformance?
What about an
incident?
And a
discrepancy?

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Definitions
• A deficiency in a characteristic, product
specification, process parameter, record, or
procedure that renders the quality of a product
unacceptable, indeterminate, or not according to
specified requirements
Non-conformance
• The nonfulfillment of a specified requirement
(820.3)
Non-conformity

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Definitions
• Datum or result outside of the expected range;
an unfulfilled requirement; may be called non-
conformity, defect, deviation, out-of-
specification, out-of-limit, out-of-trend
Discrepancy
• Departure from an approved instruction or
established standard.
Deviation
• Operational event which is not part of standard
operation (GAMP)
Incident

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PIC/S Expectations
• Significant deviations are fully
investigated
• QC – any deviations are fully recorded
and investigated
• Assessment of deviations from
specified procedures
• Incorporate risk assessment
• Reviewed in PQR
• Signed authorisation for deviation
from manufacturing formula,
processing instructions and packaging
instructions

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PIC/S Expectations
• Written policies, procedures, and the
associated records of actions taken or
conclusions reached of any deviations
or non-conformances
• Should be avoided as far as possible;
should be approved in writing
• Any deviation from expected yield
should be recorded and investigated
• Include stability program

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FDA expectations
• Quality Systems staff are effectively integrated into
manufacturing and involved in non-conformance
investigations.
• The investigation, conclusion and follow-up must be
documented
• Any deviation from the written
procedures recorded
and justified.

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FDA expectations
Any unexplained discrepancy (including a
percentage of theoretical yield exceeding the
maximum or minimum percentages established
in master production and control records) or
the failure of a batch or any of its components
to meet any of its specifications shall be
thoroughly investigated, whether or not the
batch has already been distributed. (211.192)

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FDA expectations
The investigation shall extend to other batches
of the same drug product and other drug
products that may have been associated with
the specific failure or discrepancy. A written
record of the investigation shall be made and
shall include the conclusions and follow up.
(211.192)

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Key steps: System
• Create the tools – SOP, form, register, process flow
• Incorporate risk assessment into process
• Train staff in whole process, including risk processes
• Ensure procedure is understood and followed
• Track progress of each deviation
• Ensure timely closure
• Periodically review raised deviations
• Look for trends, repeat events

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Key steps: Process
Raise ASAP
Complete
initial details
Assess
criticality
Identify
immediate
actions /
corrections
Investigate Assess risks
Identify
corrections
Conclude
Raise CAPAs Close

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FDA guidance for industry
In a quality system, it is important to develop and document
procedures that define who is responsible for halting and resuming
operations, recording non-conformities, investigating
discrepancies, and taking remedial action. Under a quality system,
if a product or process does not meet requirements, it is essential
to identify and/or segregate the product so that it is not
distributed to the customer.
Remedial action can include any of the following:
• Correct the non-conformity
• With proper authorization, allow the product to proceed with
justification of the conclusions regarding the problem’s impact
• Use the product for another application where the deficiency does
not affect the products’ quality
• Reject the product

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When to raise a deviation
As soon as it is known that an
unexpected event, deviation
from a process or failure to meet
a limit or specification has
occurred
• QA should be involved as early
as possible
• Record the issue in the
deviation register at the time it
is raised
• Track progress

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Initial information
You cannot re-create a point in time so your initial
deviation information and entries are critical
Review:
• Sufficient detail
• All technical details
• Critical process (e.g.5 why)

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Investigating deviations
• Fishbone / cause and effect diagram
• 5 whys
• Fault tree analysis
Establish what happened
Seek understanding of events
Use investigation tools e.g.
Identify likely causes
Is there a common cause?
Might other batches, components, materials, equipment also be
affected?

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Root Cause Analysis –
Methods/Tools for identifying Causes
5 whys Cause and effect Tree diagram
Factor analysis Brain storming

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Root Cause Analysis –
Methods/Tools for identifying Causes
Fishbone diagrams Pareto chart
Failure Mode & Effect
Analysis
Change Analysis Flow charting

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Closing deviations
Write up the
investigation
Explain what
happened and
why
Identify &
document root
cause(s)
Detail corrections
and any
corrective actions
Ensure CAPAs are
raised as needed
Review by QA
Final closure by
QA
Update register

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Case Study

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Raising a deviation
DEV-14-01-003
05 Mar 2014
22 Jan 14
Lucy Liu L Liu

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Assigning deviation level
All critical deviations must be escalated

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Investigating the event

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Root cause – Fishbone diagram
Problem statement = Plastic contaminant was found in batch ABC-
1234 during milling.
• What was different to normal conditions?
Plastic
contaminant
Environment
Materials
Machines
Methods
People
New freeze drying
trays used
Manufacturing staff
performed an
additional step
without approval
No changes in plant
No maintenance
performed
Batch record does
not include all
preparation
instructions
No changes in
environment
In process checks
may not be good
enough or
completed correctly

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• Staff made a mistake – possible contributing action
• New freeze drying trays – how are these different to
normal? Inspect new stock.
Of the possible causes, what’s different?
• Plastic film on new trays not removed completely prior
to use– no instructions to do this or specifications
• Staff did not seek approval for extra preparation step
with the trays
Most probable root cause:

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Plastic
contaminant
Environment
Materials
Machines
Methods
People
New freeze
drying trays
used
Manufacturing
staff performed
an additional step
without approval
No changes in plant
No maintenance
performed
Batch record does
not include all
preparation
instructions
No changes in
environment
In process checks
may not be good
enough or
completed correctly

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Setting up a deviation system
Basic elements
• SOP
• Process flow
• Deviation form
• Deviation register
Decisions
• Manual, electronic or
hybrid?
• Approval process – who,
when?
• Timeframe
• What triggers a CAPA?

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Basics
Follow SOP
Raise ASAP
Investigate quickly
Investigate thoroughly
Find route causes
Address route causes – raise CAPAs
Close ASAP, within target timeframes

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Tips
Make sure the
SOP, form and
process flow are
aligned
Have a few staff
trained as site
experts in
investigations
Don’t over-
complicate the
process
Don’t expect
everyone to be
good at
investigating
Do
Don’t

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Common problems
Poor
investigations
Not addressing all
facts / Ignoring
evidence
Only considering
one route cause
Poor scientific
basis
Making
assumptions
Not addressing
issues / not
raising CAPAs
Repeat deviations
– failure to
address
Failure to
consider the
impact on other
batches

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References
• Guidance for Industry Quality Systems Approach to
Pharmaceutical CGMP Regulations , FDA, Sep 2006
• PIC/S guide to good practices, for the preparation of
medicinal products in healthcare establishments, PE-010-
3, Oct 2008

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In Conclusion
This session covered:
Regulations
Definitions
Process
Case study
Setting up a new system
Common issues

of © PharmOut 2014
Thank you for your time.
Questions?
Debbie Parker
Debbie.parker@pharmout.net
Senior Consultant
www.pharmout.net

2015_GMP_Validation_Forum_Deviation-Incident-Non-conformance-Systems (1).pdf

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