A well-functioning Corrective and Preventive Action (CAPA) program can make the difference between a deviation being corrected and prevented the first time. The consequence is reoccurring deviations that require reopened investigations — wasting limited resources and potentially causing product quality issues.
CAPA
It’s important to remember that a well-functioning CAPA program starts with a well-functioning investigations program. After you recognize you have a problem, the first step is investigating the deviation and determining the root cause. The root cause(s) will direct how, what and where the company will take corrective and preventive action.
Preventive Action
As regulators note in ICH Q10, “CAPA methodology should result in product and process improvement and enhanced product development.”
In his book, quality consultant Phillip Crosby states, “Quality is free. It’s not a gift, but it’s free. What costs money are the ‘unquality’ things — all the actions that involve not doing jobs right the first time.”
QMS CAPA
To that end, setting up a CAPA quality system (QMS) must be surrounded by adequate standard operating procedure (SOP). Each SOP should monitor and include metrics to ensure nonconformances do not occur in the future. Especially when considering CAPA in pharma; this is the least costly way to deal with regulatory issues or product defect problems.
While the two terms in the CAPA acronym may sound similar, there are crucial differences between ‘corrective action’ and ‘preventive action’. If an FDA investigation and corresponding CAPAs are initiated, then both the corrective and preventive actions would be addressed to determine the root cause.
CAPA Quality Assurance
Further, impact on material or product and the direct correction to the issue (i.e., immediate correction) should be well documented. Corrective actions are taken to prevent the reoccurrence for a specific product or operation, while preventive actions prevent any occurrence for all products or operations.
One of the most useful strategies during a CAPA audit is to ask questions and avoid assumptions. A fishbone diagram, fault tree analysis or the ‘5 Whys Method’ are robust tools that often help determine adequate root cause.
CAPA Records
When conducting the investigation, companies must review multiple systems including manufacturing processes, machinery, equipment, environment, specifications, raw materials and people.
Deviations are not limited to these systems. Other systems should also be evaluated as necessary, but many deviations do reside within one of the listed systems.
CAPA Effectiveness
Another way to look at CAPA effectiveness is the metaphorical horse with blinders. Imagine the blinders are used to keep the horse focused and moving forward. This same metaphor can be used to think about the investigation and CAPA process.
If you go in with blinders on, just looking at the issue without reviewing other interconnected systems, important details can be missed and more costly problems may result.
CAPA Systems
Once all the elements of the deviation have been investigated, the narrative and its linked CAPAs should explain when and what happened. Documentation should also be included in your CAPA system for who was involved.
The narrative should also document the solution that was implemented to correct and prevent the reoccurrence of the issue. This includes a rationale for the root cause identified during the investigation. All these items should be well-documented within your quality system.
CAPA for Quality
A robust CAPA program designed to improve quality should include a well-documented system that identifies the root causes of a deviation. This includes the nonconformance, system failures, or process problems.
In addition, the CAPAs must address each of the root causes and identify the corrective action for remediation. Only after careful consideration about the deviation can the appropriate correction prevent the deviation from happening again.
CAPA Manufacturing
Qualified staff (with proper training, education, and experience) should run the CAPA program. Incorporating meaningful metrics to track the performance of overall systems can help provide early warning signals for deviations/nonconformances.
An appropriate Subject Matter Expert (SME) should be included in the process. Management should review potentially adverse information, oversee the overall adequacy of the CAPA program, and remediate identified deficient areas, including those that may need capital investment.
CAPA Quality
Once the appropriate solution for improving quality has been implemented, evaluating the solution’s effectiveness should be ongoing. There should be a process for monitoring the recurrence of the deviation and the closing out of the CAPA once the solution has been confirmed effective. All these items must be documented within the quality system.
The same level of depth and rigor of a CAPA for one issue may not be required for every deviation. For example, a small documentation error will likely only require a simple correction. More serious deviations, like a confirmed Out of Specification (OOS), will demand a much more robust investigation and CAPA.
Deviation Meaning
The complexity of the deviation and its concomitant CAPAs not only determine the approach taken for the investigation but also inform the timeline. For example, while some standard operating procedures may call for a 30-day timeline for investigations and CAPAs, that timeline may need to be extended. Identifying the priority of the deviation helps the entire team to recognize meaning.
In this case, you’d need to document the rationale for the extension and get the quality department’s approval. A critical caveat here is everything in the investigation leading to a CAPA does not need a time extension. If your company is extending a lot of investigations, then it may indicate another entirely different problem.
Pharmaceutical Manufacturing
The key to establishing a successful CAPA is a complete and thorough investigation focused on finding the reason the deviation occurred. This is essential in pharmaceutical manufacturing as well as many other regulated industries.
Failure to identify the correct root cause will result in possible failed effectiveness checks and the dreaded reopening of the CAPA. Everything plays a part in the investigation: people, machines, materials, processes, etc.
CAPA Audit
Management of these players is key to identifying the deviation’s root cause. The audit process behind the investigations is crucial in addressing the issue at hand. The aim shouldn’t be to find a single root cause that management believes to be the reason for the failure but to analyze all possible root causes across all systems.
If an identified root cause isn’t the true reason for the failure, then the root cause can be eliminated. Each root cause eliminated narrows down the investigation. Any potential root cause that cannot be eliminated must be remediated, even if that root cause is not THE root cause of the failure.
Root Cause Analysis
A mistake companies make is identifying a root cause that needs remediation and stopping there. Companies should always identify all possible root causes and address them accordingly. When executed correctly, CAPAs help organizations remediate deviations/issues before they cause more technical problems and escalated costs.
A practical example of an investigation and CAPA process is as follows: Company X had an investigation related to the detection of nonconforming vials, which were discovered prior to packaging. The inspectors on the line found the nonconforming vials, informed the quality team, and an initial investigation ensued.
Quality Assurance
The quality assurance team correctly put the lot on hold while the investigation was being conducted. During the early phase of the investigation, the nonconforming vials were sent away to be analyzed by a third-party qualified laboratory. The results came back stating the discoloration was due to chemical contamination.
The chemical in question was not part of the formulation or the container closure system and was not on any product contact surfaces within the equipment. Company X eventually decided the contamination happened at the vial manufacturer and closed the investigation. One week after the initial observation of the discolored vials was opened and closed, the same issue arose with another product and the original investigation was reopened.
Forensic Investigation
The company subsequently audited the vial manufacturer, but the results were inconclusive, with no identified source of the chemical responsible for the nonconforming vials. The company continued manufacturing while the investigation was ongoing and began a 100% incoming material inspection.
A week later, a line operator noticed a vial exiting the depyrogenation tunnel that had a discolored blob in it. Manufacturing was stopped and the vial was sent to the contract lab for analysis. Once again, the chemical in question was the culprit.
Supplier Audit
The company sent a consultant to do a supplier audit of the vial manufacturer while they continued manufacturing the product. Similar to the initial for-cause audit, the external consultant could not find the source of the chemical leading to the nonconforming vials.
Finally, after opening the line for inspection, the company discovered that the contaminating chemical was associated with the HEPA filters. Manufacturing was finally halted on the line.
Corrective Action and Preventive Action
After completing a more thorough investigation, the root cause was determined to be faulty cooling valves in the depyrogenation tunnel. This was previously identified by the company as a potential root cause in the initial investigation, but was not pursued because it was classified as ‘possible but highly unlikely’ and ranked lowest on the priority list.
There was no alarm associated with the cooling valve which explains why the issue was not caught under routine maintenance checks. Once the problem was correctly identified, the proper and effective corrective action could be taken, including the potential costly endeavor of evaluating all products made on the line and looking at other lines with the same depyrogenation oven.
Cost of Poor Quality
Hypothetically, let’s say the cost of a critical deviation for Company X is a million dollars. We start by looking at the cost of poor quality (COPQ) of a defect.
The cost is eliminated only if the pharma company’s quality management system (QMS) is organized. This includes the QMS system being designed to detect, investigate, correct and prevent issues/deviations.
QMS System
If the company can prevent defects with their robust QMS, they will save money because they allocated sufficient qualified resources toward an efficient QMS — which in turn meant they didn’t have to address many defects/deviations and CAPAs. Hence the quality system pays for itself.
If the issue is detected within the company before anything is shipped out, the cost rises tenfold to ten million dollars. This is due to the company needing to address the now-detected issue and implement corrections (corrective action) to rectify the issue. Additionally, the team would put measures in place to ensure issues do not occur in the future (preventive action).
Forensic Analysis
Finally, if the company detects an issue in a drug product after it has been released by the quality department and delivered to the customer, the cost raises tenfold again. The forensic analysis must now include the cost of recalls, as well as corrective and preventive actions. The cost of quality is important to understand — for Company X, they caused themselves a $100 million mistake.
Company X initially thought the issue seemed small and negligible, which led to an unfortunate quick closure of the investigation. Ultimately the deviation affected twenty-eight lots of manufactured products. These lots, produced over a two-month period for several clients, were rejected due to the nonconforming vials.
Root Cause Strategy
Company X should have utilized a more thorough investigation and root cause strategy to follow every possible root cause. Instead, the company chose what seemed like the easiest root cause and jumped to the wrong conclusion. Then the company quickly closed this initial investigation without a complete and thorough investigation. In conclusion, this mistake created a bigger issue and a compliance and business risk.
It takes diligence, thoroughness and a healthy number of questions to ensure you investigate, correct, and prevent problems. But without this, the quality and efficacy of the drug product being manufactured could be jeopardized.
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