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QA SOP

SOP Title: Change Control Management

SOP Title: Change Control Management

  1. Objective:

To document and evaluate approval system for initiation and/or implementation of technical changes in procedures, Raw Materials, Packing Materials, manufacturing process, Analytical Testing Methods, equipments, utilities and operating environment etc.

  1. Scope:

This SOP covers the following:

  1. Change/s in Quality System and its documentation.
  2. Manufacturing Process or Testing Method and its Equipment and/or Instrument.
  3. Approved Facility/Utilities, Specifications (Raw, Packing, In-process, Finished

Product/Finished Product shelf life).

  1. Modifications in Water System / HVAC System or Compressed Air System.
  2. Storage Conditions, Formulations, Vendors of Raw and Packing Materials, Packaging Material, Packaging Configuration/ Style / Text Matter and Artworks etc.
  3. Responsibility:

Concerned Department: To identify and assess need of change required & initiate through Change Control procedure.

QA Department: To review and approve the change; to verify the implementation and ensure compliance of the procedure.

Other Departments: To analyse the impact of the change in their respective departments and review the change as applicable.

 

  1. Accountability:

Head Quality Assurance and Head Concerned Department

  1. Procedure:
  • Definition:

         Change: Change includes any Addition to, Deletion of or Modification to a System, Process, Materials, Product, Procedure and Equipment or Instrument. Changes can be categorized as follows:

  1. Minor change:

A change that may not have an impact on the identity, quality, purity, strength, stability, safety

and efficacy or physical characteristic of the product.

  1. Major change:

A change that is likely to have an impact on quality of the product, but does not make any

significant change in the final quality of the product.

  1. Critical change:

A change that has a significant impact on the quality and/or safety of the final product

  • Procedure
5.2.1 A proposal for any change i.e. addition/deletion/modification shall be initiated in change control format.  
5.2.2 The Change Control Log for all changes taking place within the facility shall be maintained in format.  (having the details like: Change Control No., Date, Initiating Department, Document No., Description of change, Type of change i.e. Minor/Major/Critical, Change Control Approved/Rejected, Closing date, Closing Remark and Sign of  QA).  
5.2.3 All supporting and reference documents shall be attached to the change control form before sending for QA approval.

e.g.: Draft SOP, Proposed layout design, Draft STP, Specification, Guideline, Regulatory document etc as applicable.

 
5.2.4 Change control form and supporting document shall be reviewed for its appropriateness before sending to QA Department.  
5.2.5 If changes are more and cannot accommodate in space provided in Change Control Form then separate annexure shall be prepared by making column for proposed change, existing procedure and justification for change with Prepared By, Checked By, Sign and Date.  
5.2.6 After review of Concerned Department Head, initiator shall submit the change control form to QA Department for approval.  
5.2.7 A Change Control number shall be allotted to each change  as mentioned below:

CCQAYYNNN

Where, CC denotes Change Control,

QA denotes Department Code for Quality Assurance Department,

YY denotes last two digits of the current year and

NNN denotes three digits serial number (e.g. 001,002,003…..).

For Example:-first change notified for year 2024 shall be numbered as CCQA24001.

 
5.2.8 Review of proposed changes and supporting documents shall be done before approval.  
5.2.9 If needed, additional supporting documents may be required with respect to proposed changes.  
5.2.10 The Change Control form shall be circulated to Concerned Department for impact assessment and comments. Impact of proposed changes on other department shall also be assessed.  
5.2.11 After receiving comments from all Concerned Department QA shall review the comments to assess any other impact of the change.  
5.2.12 After complete assessment, change shall be approved or rejected.  
5.2.13 The review of a proposed change shall involve activities such as conducting experiments, analysis, review of master documents, stability data etc if required.  
5.2.14 In case of a change pertaining to the product manufactured for specific customer on contract basis, approval of the change shall be taken from the customer prior to the implementation by sending notification of the proposed change with justification and proposed change data generated to support evaluation of the change. Upon receipt of acceptability from the customer, the change shall be implemented.  
5.2.15 The change shall be implemented with immediate effect based on the information, review and recommendation.  
5.2.16 After implementation of the proposed change necessary data shall be collected and forwarded to Head QA.  
5.2.17 The verification shall be carried out to ascertain whether the changes and the consequent changes have been implemented satisfactorily.  
5.2.18 All the documents undergoing changes due to implementation of change control shall be revised and controlled as per SOP.  
5.2.19 The change control shall be closed within 30 days from the date of initiation. However, based on the nature of the change, extent of the work involved or any experiments / validations studies to be carried out; extension to closing time can be approved for completion and it shall be written as in the Change Control forms.  
5.2.20 Trending of changes shall be done once in a year during product quality review. If frequent changes observed on a particular subject, then Corrective and Preventive Action shall be followed to reduce the number of changes.  
5.2.21 Recommended supporting studies for changes
   

Sr. No. Type of change Recommendations
01 Change in procedures Training to concerned persons, change in relevant documents and/or Validation wherever required.
02 Change in manufacturing formula Validation of 3 consecutive batches with Stability Studies or as per the requirement.
03 Change in BMR Training to the concerned.
04 Change in manufacturing process Validation of 3 consecutive batches with Stability Studies or as per the requirement.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

05 Change in specifications Stability studies on the changed specifications, test Method Validation.
06 Change in Test Methods Method validation study.
07 Change in SOP Training to the concerned, change in relevant documents.
08 Change in expiry Stability studies, change in relevant documents, intimation to Concerned Department.
09 Change/modification in manufacturing equipment Validation of 3 consecutive batches, equipment, Re-qualification.
10 Change in storage conditions Stability Studies in changed conditions change in relevant documents.
11 Change in RM source or supplier Stability studies of the lots comprising the changed RM.
12 Change in packing material other than primary PM Change in relevant documents, intimation to concerned dept., transport trials if required.
13 Change in pack style Change in relevant documents, intimation to Concerned Department.
14 Change in printed text Change in relevant documents, intimation to Concerned Department.
15 Change in Primary PM Validation of 3 consecutive batches, Accelerated /

Long Term Stability Studies.

16 Change in manufacturing lot size Validation of 3 consecutive batches accelerated / long term Stability Studies.
17 Change in control procedures i.e. computers, configuration of software etc. Complete validation of the New Software.
18 Change in Room Specification Area Re-qualification / Validation.
19 Transfer of Instrument/Equipment Instrument Re-qualification.
5.2.22 List of Major  and Critical Changes
 
Sr. No. Major Changes Critical Changes
01 Source of Excipients Manufacturing Process
02 Storage Conditions Manufacturing Formula
03 Specifications Manufacturing Batch Size
04 Secondary Packaging Materials Manufacturing Location
05 Packaging Style Source of Active Raw Materials
06 Printed Text Bill of Material
07 Modification in existing Equipment Primary Packaging Materials
08 Testing Methods Addition of New Equipment
09 Standard Operating Procedures Change in Equipment
10 Formats Structural Change in the Premises
11 Protocols ———-

The list is not exhaustive and can be extended based on practical changes occurring.

 

  1. Abbreviation:

 

Abbreviation Expansion
SOP Standard Operating Procedure
QA Quality Assurance
RM Raw Material
PM Packing Material
BMR Batch manufacturing Record
STP Standard Test Procedure

 

*Note – Ready to use SOP available in “DOWNLOAD” Section.

 

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