Sunday, 6 October 2019

CAPA (based on Risk based approach).

In Pharmaceutical Industries, in most of the cases investigator has fixed many CAPAs without identifying the actual root cause.
Our investigation and CAPA should be like that to avoid the re-occurance of event with the same reason.
Here the case study...

“Fixing problem “is the main activity at pharmaceutical industry now a days, Rather than manufacturing medicine, we are focusing on the failure investigations, root cause identification, CA-PA implementation & effectiveness verification. When a facility or a product is designed, the risk based approach not followed. Maximum problems happed during tech transfer from R&D to commercial manufacturing. Failure is happened due to higher variability in utility, machinery & area maintenance, operation and control. This is the time when we start taking support with short cut (quick-fix solutions).

Suppose the problem stated as “Mr. Y. have fallen down in the bathroom due to slippery floor”,
Then what will be the thought process of CAPA as a pharmaceutical professional. 

·  We will fix the first cause is Human error / person does not know how to move in bathroom –Blame on Training adequacy

·  After that, we will propose extensive Cleaning of bathroom – Inadequate Process

·   Then, change the detergent of bathroom cleaning will be additional control – Blame on the external supplier and material use.

·  Increase frequency of cleaning to avoid the slippery floor – Inadequate maintenance program

·   Training how to move in slow motion in bathroom – Inadequate process control

·  Visible board mentioned “Wet floor, move slowly” and mention Ambulance number in case of emergency  – Additional control to make process more complex and to satisfy auditors

·  Increase the lighting for better visibility – Additional budget investment and increase annual maintenance cost

·  Installed telephone to take help from neighbor – Involves of external consultant to fixed internal problem

· One person will stand outside of bathroom to support in case of emergency -  Proposal of increase of manpower to management

But we did not think for permanent solution. 
In current scenario change in bathroom floor tiles with Rough Surface new tiles can be an appropriate CAPA. 

In fact design and installation of bathroom should to be with rough surface tiles only as part of risk based approach. But here the attitude which comes that is it's ok. Because to fix the actual problem productivity can be temporary decrease but in future same problem will not be happened.

2 comments:

  1. Please interpret about OOT with guide line reference
    like
    1. Which result is to be considered as OOT
    2. For drug product having different limit for non destructive as well as destructive test.
    Ex. Assay limit 95 to 110% of LA, NLT 95% LA, NLT 80% of LA. etc.
    3. For drug substances having different limit. like 98 to 105 %,
    NLT 97% , NLT 50% etc.

    ReplyDelete