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OBJECTIVE
This SOP defines procedures to be followed when an Out of Specification (OOS) result is detected on
any analytical laboratory test performed on samples of raw materials, in-process materials, bulk
products and finished products. It describes responsibilities of laboratory personnel, the laboratory
phases of the investigation (Initial Laboratory Review, Full Laboratory Investigation) including
additional testing/experiments that may be needed, when to expand the investigation outside the
laboratory, retesting requirements if the investigation is inconclusive and the final evaluation of all
test results by QA.
These procedures may also be used for out-of-trend investigations
Minimally, for raw materials OOS results, the laboratory investigation aspects of this SOP will be
followed. Further investigation may be performed at the supplier.
For OOS investigations of process water produced by in-plant water systems, the laboratory
investigation aspects of this SOP will be followed.
For packaging components testing, the principles of this SOP can be used as appropriate in the
investigation.
2. SCOPE
This procedure applies to all analytical testing on samples of raw materials, in-process materials, bulk
products and finished products, including the following
Release testing of raw materials, in-process materials, bulk products and finished products.
Testing of product from previously released/distributed product lots.
o Confirmatory, on-going and accelerated stability testing to support market launch.
o Testing associated with consumer complaints.
Testing performed as part of process deviation investigations.
Process validation testing.
Analytical testing on clinical /consumer trial materials intended for human/animal use.
Analytical testing for physical attributes such as viscosity, particle size and specific gravity, although
certain steps in the investigational aspects of the procedure may not be applicable in every case,
depending on the type of test, sample preparation, etc. For example, there may be no
intermediate standard/sample preparations to evaluate as part of the investigation.
It does not apply to:
Materials used in or manufactured solely for laboratory evaluation (e.g., evaluations for R&D
purposes on materials not used for human/animal exposure).
Laboratory testing performed by human evaluation (e.g., color, shape, form). While a
laboratory-related investigation is not required (i.e., limited to documenting the OOS in the
system), a manufacturing investigation will be initiated and documented.
In-line or on-line analytical testing that is used in conjunction with process controls to provide
continuous data for release purposes.
OOS microbiological results. This is covered by a separate SOP.
R&D testing where specification limits have not been established, although the principles of
this SOP can be used, as appropriate, to evaluate for possible analytical or manufacturing
issues when data is considered aberrant/unexpected.
In the case of a known stability OOS trend in R&D, and the studies are continued to collect
additional data for modeling.
3. GLOSSARY
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Reanalysis:
- Analysis of retained sample preparations
- Repeating some part of testing e.g.
- Re-measurement,
- Re-injection
- Re-dilution of sample and standard preparations
- Further extraction.
Retest:
- New preparation & analysis of a portion of original sample
- Part of full scale OOS investigation
Resample:
Collecting and testing a new sample of the same lot of material or product, provided original sample
is found to be non-representative/contaminated or confirmation of batch failure
Laboratory error:
Analytical or laboratory error can be instrument, environment or operator related e.g., injection /
instrument failure / mistake in following the method of analysis, wrong sample preparation, wrong
reference standard used, transcription or calculation mistake etc.
4. RESPONSIBILITIES
4.1 Manager Quality
- Ensuring that there are specific site procedures and systems to comply with this SOP
- Review of report and final decision as to the disposition and use of the result.
- Ensuring that all relevant persons in QC have appropriate training.
- Responsible for batch related decisions when an OOS or OOT result has not been invalidated
through laboratory investigation.
4.4 QC Analyst
- Archiving accurate laboratory testing results
- Should be aware of potential problems that could occur during the testing process
and should watch for problems that could create OOS results.
- Immediate reporting to respective Assistant Manager of an OOS / OOT result.
- Preservation of sample, solutions, standards and glassware for reanalysis, if required.
5.3 Corrective and preventive actions (CAPA) must be taken to prevent reoccurrence of
OOS or OOT test results.
5.4 All OOS results, both valid and invalid must be tracked and trended.
5.5 All analysts must be trained on the handling of OOS and OOT results process prior
to commencing their job.
5.6 Results are allowed to be invalidated only if a laboratory or sampling error can be
assigned. Invalidated results must not be used to determine the final reportable
result for the test.
5.7 An investigation must be initiated no later than 2 business days after the OOS or
OOT occurs. It must be completed within 07 business days, or a written rationale
must be provided.
5.8 Previous occurrences of the problem (historical data) and other batches or products
possibly affected must be taken into consideration. Appropriate CAPA must be
defined as part of the investigation’s conclusion and implemented.
5.9 Alert limits are important criteria that need to be established for specific analytical
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5.10 When compendial tests are performed which describe calculation, interpretation and
handling of test results, that compendial procedure must be followed.
6. PROCEDURE
6.1 Reporting OOS/OOT test results
6.1.1 The analyst when come across with an OOS/OOT result will immediately inform QC Executive
or Assistant Manager QC or Manager QC and preserve the sample and standard preparations.
6.1.2 The analyst will report this event by filling Out of Specification/Out of Trend Report Form
(Annexure – 1, PART - A).
6.2 Investigation
Investigation will be carried out in two phases:
6.2.1 Initial Laboratory Investigation
6.2.2 Full Scale OOS Investigation
6.2.1.2 Initial assessment on OOS results related to printed text / color / font style & size / packaging
/ labeling will be limited to sample storage and specification / standards used. In case no
error is detected, the report will be submitted to Manager QC who may allow for re-sampling
& testing and will take final decision based on the results so obtained.
Signature Date
The review of production must consist of timely, thorough, and well documented
investigation including, for example:
•Master Manufacturing Document (MMD) evaluation
• Equipment (Validation, Qualification, Calibration)
• Personnel training evaluation
• Risk management evaluation
• Deviations & complaints systems
If this part of the OOS investigation confirms the OOS result and is successful in identifying its root
cause, the OOS investigation may be terminated and the investigation report written.
Re-sampling will be carried out by one analyst as per normal sampling plan or as approved by
Manager QC and recorded in the respective logbook
o The retest result confirms the OOS or OOT: the original test result is reported as such
and the retest results will be documented and filed;
o The retest result does not confirm the OOS or OOT but no laboratory or sampling error
is identified: all test results, both passing and suspect, will be reported in the
investigation report
Report on Full OOS Investigation will be completed and submitted within 20 business days
from the date of initiation. Any exception will be notified, justified and authorized by
Manager Quality.
6.2.3.1 In the case of microbiological tests, averaging is a practice dependent of the application, but
where used it will be documented in the analytical procedure and justified.
6.2.3.2 In the case of physical and chemical tests, averaging is more limited:
- when one or more of the results are OOS and others are within specifications,
even if the difference between those results is within the defined specification of
a distribution range.
- between the initial OOS result and results obtained from retest or re-sampling.
For biological assays with high variability, an outlier test may be an appropriate tool
to identify extreme results. For chemical assays, such tests may be used in an
auxiliary fashion to evaluate the significance, but should not be used to invalidate
suspect results.
In case of confirmed OOS for a product already on the market or for a risk that could
affect other batches or products already on the market, a quality alert, describing the issue
will be sent to the region
7. TRAINING
Training on this SOP will be provided to all concerned as mentioned in the Annexure – 2 and
as illustrated in training material TM-QA-000/0.
8. DISTRIBUTION
Total number of copies to be prepared = 03
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10 HISTORY
Version No. Effective Date Reason for Revision Change Control No.
First Issue
Second Issue
Signature Date