Professional Documents
Culture Documents
1.0 Objective
To lay down a procedure for handling of nonconformances.
2.0 Scope
This Standard Operating Procedure is applicable for handling of nonconformances
associated with product (s) manufactured at pharmaceutical formulation plants.
Nonconformances observed in inprocess products and Finished Products shall be
handled through this SOP.
3.0 Responsibility
All HODs/ designee of the concerned departments shall be responsible for informing
the nonconformances, if observed, in products.
Head, Quality Assurance or designee to investigate, and to decide about the
disposition of nonconforming in process products or finished products.
4.0 Accountability
HOD’s of concerned departments & QA Head shall be accountable for implementation
of this SOP.
5.0 Abbreviations and Definitions
SOP : Standard Operating Procedure
QA : Quality Assurance
NCR : Nonconformance Report
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specifications and/ or not acceptable by virtue of its appearance/ physical state and/ or
by virtue of other reasons which actually are not the part of set or established
standards for that material.
Technical Committee : HODs or designee from the technical departments like
QC, QA, R&D, and Production designated for investigating or giving opinion on the non
conformances.
6.0 Procedure
6.1 If inprocess product or Finished Product is nonconforming, then it shall be
quarantined with distinct ‘HOLD’ label and shifted to the designated area under the
supervision QA personnel.
6.1.1 Officer/ Executive of the concerned department shall raise NCR (AnnexureI ),
mentioning description of nonconforming in process product or finished product.
6.2 NCR shall be sent to QA for further action.
6.3 In case of inprocess product or finished product, HeadQA may constitute a
technical committee who shall investigate the cause(s) of in process or finished
product nonconformance. Refer Non Conformance Investigation checklist (Annexure
2), before further movement of the NCR to different departments.
6.3.Based on the findings of the investigations and/ or comparison with the
specifications and / or validation data and / or product development report and / or
sound scientific assessment and / or stability data with the product and / or the API
molecule or the working experience with the similar kind of products or molecules, etc.,
by HeadQA and / or technical committee shall then give opinion on the non
conforming in process or finished product that whether the product can be :
Re graded: Nonconforming product is reassigned for an alternate market or
pharmacopeial compliance.
Use as is: A nonconformance may be minor (no significant impact on product’s
form or function) and it can be used as is.
Rejected: Nonconforming products are rejected, when failing in critical or major
test parameters that have significant affect on the product quality.
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6.4 Concerned department shall give CAPA report, if applicable.
6.5 Following completion of investigation, each NCR shall be assigned a number by
officer/ executive Quality Assurance, duly signed and dated. Each Nonconformance
report shall have a ninedigit number the form NCRXXX/YY, where:
NCR – Denotes NonConformance Report
XXX – Serial number of the NCR
/ – “Slash”
YY – Last two digits of the year. i.e. 16 for 2016, 17 for 2017 etc. A new
series of note shall be initiated every new year. The first NCR of the year 2015 shall be
numbered as NCR001/15.
6.6 If nonconforming inprocess product or finished product is rejected then the same
shall be labeled with status ‘Rejected’ and handled as per SOP titled: Disposal of Non
Recoverable Inprocess materials and SOP titled: “Destruction of finished goods”
respectively.
6.7 Based upon the investigation report head quality assurance or designee shall give
his disposition on authorization of destruction of nonconforming in process or finished
product.
6.8 After head quality assurance or designee’s disposition, quality assurance
personnel shall send a copy of NCR to the concerned departments.
6.9 After disposition on NCRs, the same shall be reviewed on monthly basis by QA
personnel and same shall be closed after verification.
7.0 Forms and Records (Annexures)
NonConformance Report – AnnexureI
Non Conformance Investigation Checklist – AnnexureII
Non Conformance register – AnnexureIII
Flow Chart – AnnexureIV
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8.0 Distribution
Master copy – Documentation Cell (QA)
Controlled copies – Quality Assurance, Production, Quality Control,
Finished Goods Warehouse, Raw Material Store, Packing Material Store
9.0 Reference:
If any
10.0 History
Revision
Date Reason for Revision
Number
– – New SOP
AnnexureI
NCR Number:
Write ‘NA’ if not applicable; attach extra sheet if space provided below for recording is
insufficient
Nonconforming Product:
AR No.:
Stage:
Specification No.: STP No.:
Batch No.:
Mfg. Date: Exp. Date:
Description of Nonconformance:
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Recorded by
HOD/ Designee
(Sign/date)
(Sign/date)
Investigation and finding Statements (Attach extra sheets if required):
CAPA required/ not required :……….
CAPA number (If applicable) :……………..
Signatures with date of Technical Committee Members:
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Quality Regulatory
Production R&D Stores
Control affairs
Disposition by Quality Assurance:
Head Quality Assurance/ Designee
(Sign./date)
Reevaluation of Non conformance required/ not required
NCR No.: Sign: Date:
Authorization for destruction of NonConforming Inprocess product or
Finished Product
Remarks
HeadQuality Assurance/ Designee
(Sign./ Date)
Reevaluation of Non conformance required/ not required
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Reevaluation of Non conformance:
Dated ………………….. by ………………………………………Department:
……………………….
Remarks:
Sign./ Date
Closure of Non Conformance:
Dated ………………….. by ………………………………………Department:
……………………….
Remarks:
Sign./ Date
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Product Name : Batch No. :
Manufacturing Date : Expiry Date:
Batch Size:
Investigators :
Name
_____________________________________________________________
Department
_______________________________________________________________
Designation
________________________________________________________________
Investigation Started on : Investigation
completed on :
Suspected cause of product failure, if any:
Note: Investigation shall not restrict to this checklist, it can go beyond it.
AnnexureII
S.
Statement Observation Remarks
No.
Checking of raw material(s) used for Batch Manufacturing and records
Check the receipt documents of the
1. materials used for manufacture of the
product under investigation:
i. Check the GoodsIn
Inspection report for physical status of
consignment received.
ii. Verify if the materials,
especially the active ingredient(s) have
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been received from approved vendors
a. Does Store has a current list of
Approved Vendors
Has the API(S) been received from more
than one approved vendor
(especially supplier) ? If yes, compare the
consignments received w.r.t.:
Transportation chosen (measures taken by
the transporters to prevent exposure of
material to heat, humidity, light, etc.)
iii. Check the
environmental conditions in the quarantine
area during storage of
material(s)
S.
Statement Observation Remarks
No.
Does the Raw Materials Specification of
the raw materials, especially the API
2.
include parameters like particle size,
density, etc. in its specification?
Check the raw material reserve / control
samples in Quality Control for :
i. Proper labelling
ii. Proper Storage
3.
Adherence to the Standard Operating
Procedures for storage and withdrawal of
control samples
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Verify Standard Operating Procedures for
accuracy of procedure, records
maintained and operational status of the
SOPs e.g. Material receipt, Dispensing
and storage of materials, handling of etc.
4.
i. As on date of investigation
ii. During period of manufacture of
product under investigation
Are the materials available in Stores
(both Raw Material and Packaging
Material Store)
i. Stored properly (isolated from floor
and detached from the walls)
ii. Properly Labelled
5.
iii. Stored as per recommended Storage
conditions
iv. Stored in the relevant areas
v. Retested, where applicable, as per
requirement and labelled accordingly
Check the raw material currently stored
and sampled by QC for
i. Proper labelling of the sampled
containers
ii. Proper Resealing of the sampled
container
6. iii. Inquire the QC Chemist for procedure
followed for sampling
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– Cleaning procedure of
sampling aids
– Handling of material
during sampling
S.
Statement Observation Remarks
No.
iv. Check the records maintained in QC for :
– Date of receipt of sample in QC
– Conditions during storage of material in QC
– Date of release of:
Check the calculation used for dispensing of
active ingredient.
a. Has the calculation been checked by
7.
production personnel and verified by QC
personnel?
Check the weighment sheet and issuance
record for raw materials issued for manufacture
of the product in the Store for :
i. Quantities of materials dispensed
ii. AR. No. of materials dispensed
iii. Conformance of issuance of materials to
8.
FEFO
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COA of materials dispensed and retest date
(cross check AR. No. recorded in the issuance
records, value of assay, water/ LOD, etc.)
Check the Open Fronted Containment Facility
(OFCF) Records at the time of dispensing for
the product batch:
i. Area purging records
ii. Line purging
iii. Cleaning records(of both OFCF, dispensing
aids and vessels/ containers in which the
9. materials have been dispensed
iv. Machine Log sheet
Preventive Maintenance
Check the Status of balances used for
dispensing of Raw Materials in Store for :
i. Calibration Status
10.
ii. Cleaning Status
Has any material been released on deviation?
If yes, verify:
i. Reason of deviation
11.
ii. Deviation authorised by
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If the material is still available in stores, check
the following:
i. Labelling on the containers
12.
ii. Retest date, if applicable on the label
iii. Proper storage
Check the calibration records of :
i. Balances used for dispensing
ii. Hygrometer
13.
iii. Pressure gauges of the Open Fronted
Containment Facility
iv. Master weight certificate (Issuance date:
valid up to:
Is the access to the printed packaging material
14.
store restricted?
Does Store maintain list of persons authorised
15.
to entry areas with “restricted entry”?
Checking of Manufacturing Operation and records
Verify Standard Operating Procedures relevant
to different manufacturing operations. Are
these ‘current’?
i. As on date of investigation
16.
ii. During the period of manufacture of the
product
During the period of manufacture of the
17. product
Are the equipment labelled according to their
18.
status and content?
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Is the manufacturing area clean?
i. Check area cleaning records
ii. Has the frequency of cleaning as per
SOP
19.
iii. Has rotation of disinfectants
implemented
iv. Has the checking of area undertaken by
QA as per frequency mentioned in the SOP
Check and record the following information
w.r.t. product under investigation:
i. Material dispensed on:
ii. Batch manufacturing started on :
20. (date) (time)
iii. Storage conditions of materials during
the period dispensed material was stored prior
to the start of batch manufacturing:
Observe the area environment conditions and
21.
cross check with the records.
Select any machine e.g. blender, sifter, filling
machine and check the following:
i. Line purging record (cross check with the
Batch Manufacturing Record of the previous
product mentioned)
22. ii. Preventive maintenance label and verify
iii. Calibration records of instruments, where
applicable
iv. Qualification data
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Check the Batch Manufacturing Record of the
product under investigation
i. For overwriting, cutting or any other
23.
indications suggestive of intentional change in
data.
ii. Environmental conditions at the
time of manufacturing
iii. Check the equipment used for
manufacture of the product for:
a. Description/ capacity of equipment as
per BMR
b. Line purging
c. Calibration status of critical instruments,
if applicable
d. Preventive Maintenance Status
e. Training records of the personnel who
operated the machines at the time of
manufacture of the product (Select any
three machines e.g. Compression/ Capsule
filling/ Bottle filling, blender, FBD, etc.)
Machine name and code Operator Name
Operator Name Operator Name
_________________
____________ ____________
___________ _______________
___________ ___________
__________
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_______________ ____________
___________ __________
iv. Are all the production stages entries
signed by designated personnel?
v. Has the “online” inprocess test
undertaken by production personnel as
mentioned in the BMR of the product?
vi. Has the sampling for inprocess tests
other than the above mentioned, been
conducted by IPQA /QC personnel?
vii. Check the Inprocess testing
records for:
a. Check if the parameters tested is an per
specification or as mentioned in BMR
b. Check if the inprocess request is signed
and dated both by production and QA, as
appropriate
c. Check the raw data
d. Is the analysis records signed by both
person who executes them and an authorised
person from QC
e. Verify if the testing has been done as per
Standard Testing Procedure
viii. Has the thorough put time of the
process gone beyond the normal judged time?
ix. Is the Process Capability Index, if
any available for the product?
Observe the Batch Manufacturing Record for
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duration for which various intermediates have
been stored? Record few examples.
Stage Process
Completed on Next step started on
______________
_____________________
______________________
24. ______________
_____________________
______________________
Does the period suggest any detrimental effect
on the quality of intermediate e.g. deblending?
Has difference between particle size of various
25. ingredients evaluated during product
development/ validation?
Has Purified Water been used during
manufacture of product? If yes, check:
i. Sampling procedures followed
26. ii. Testing records
iii. Release reports
Does the product intermediates like blend,
compressed tablets, etc. require specific
storage conditions? If yes, then check the
following:
i. i. Storage Area environmental records
for the period when the intermediate was
stored
ii. Period for which the intermediate was
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27. stored
iii. Is the entry to the Intermediate storage
area restricted
iv. Is list of person(s) authorised for entry into
restricted areas available
Is the packaging material stored in the
designated area? Check the storage of issued
packaging materials, especially printed
packaging material, before use
28.
Check the packaging materials issued for the
product for:
i. Quantities issued
ii. Stock register of stores for compliance to
29. FIFO
iii. Verification of Quantities by production
after receipt of material in production
Is the entry to the Printed Packaging Material
30.
Restricted?
Does Packaging Material Store Maintain a list
31. of person(s) authorised for entry into restricted
areas?
Was line and area purging done before start of
printing and packaging operations?
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32. Check the line purging records of the packaging
machine.
Verify
Time of issue of Packaging Material:
33.
Time of Start of Packaging Operation:
Has reconciliation of packaging material done
34.
after completion of batch?
Has the returned packaging material
35.
adequately entered in the Store registers?
Has destruction of packaging materials,
36. especially printed packaging material, done
under the supervision of QA personnel?
v. Check the Control Samples of the
product:
i. Quantity of samples withdrawn
ii. Physical condition of Control Samples
37.
iii. Condition of Control Sample storage area.
iv. Is the access to Control Sample storage
area restricted
Verify if the yields at different stages of
manufacturing operations of the product.
i. If within the limit, compare the yield with
at least preceding two batches and succeeding
batch.
38.
ii. If out of limit, has deviation been raised
and investigated?
iii. Are any corrective and preventive actions
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taken?
Has deviation occurred during manufacturing?
If yes, has deviation been raised?
i. Deviation Report No.:
39.
ii. Has investigation been completed
iii.If investigation is pending, reason:
i. Date of transfer to Quarantine Finished
Goods Stores:
ii. Date of release of batch by Production:
iii. Date of release of
batch by QA:
iv. Does the product
40.
has any microbiological testing? If yes, date of
release of batch
after microbiological analysis:
v. Date of dispatch of first
consignment and quantity:
Check the Distribution Warehouse for:
iv. Storage condition
v. Environmental conditions
41.
vi. Labelling
vii. Segregation
Are temperature and relative humidity records
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available during the transit and transportation
of the finished products?
– If no, reasons thereof
– If yes, are the conditions appropriate
with the labelled storage conditions
42.
– Collect data of a period spreading
across different season to obtain information
regarding environmental conditions during
transportation.
Other Queries
What tests have been used to assess the
43. uniformity of the final product? Verify the
Content Uniformity/ weight variation testing?
Check for a possible interactions between the
process and its effect on the tablets
44. compression e.g. tablet machine rpm on the
dwell time and hardness or capping
Does any ingredient in the formulation affects
the density of the final blend to a greater
45. extent than any other ingredient? If yes, does
the specification ensures the density of such
ingredient is well controlled?
Has the manufacturer informed Torque
Pharmaceuticals regarding any major changes,
46.
if undertaken in process or specifications of the
material being supplied by him?
AnnexureIII
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NCR Non
Details of
No. Conformance Batch Mfg Exp. Implementation
Deptt. Stage Non
product No. date date Status
conformance
AnnexureIV
Page_0
Sachin Choudhary
http://pharmapathway.com
Data feed by Quality Assurance desk and reviewed by pharmapathway team.
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