The result obtained out of defined test limit is called
out of specification.
USFDA guideline "Investigating Out of Specification
(00S) Test Results for Pharmaceutical Industry" Published by CDER in Oct 2006. Quality unit should have wel define SOP for 00s The scope of SOP should be well define History of O0S guideline Event Year
USFDA audited Barr Laboratory, identified attempt of "Test 1989/1991/
untilpass " and other abnormality, 1992
FDA prosecuted Barr Laboratory, Court directed to FDA to Feb 1993
draft the 00S guidelines
FDAgenerated draft O0S guideline Sept 1998
FDA published final O0S guideline Oct 2006
O0s Investigation Laboratory Investigation Must be Thorough Timely Unbiased Well documented Scientifically sound O0SInvestigation -(Phase I) Laboratory Investigation Check list to identify obvio,us Laboratory error
1. Analyst qualification and training on intended work
2. Correctness Test specification and Method 3. Instrument calibration or performance 4. Preparation test solutions and dilutions 5. Validity of Reagents and standards 6. Performance of system suitability 7. Correctness of calculation and etc... O0S Investigation -(Phase I) Laboratory Investigation If Analyst Error identified, it should be logical and appropriate " not on hypothetical basis
Identify appropriate assignable cause for Laboratory error
Correct the error, and repeat the analysis to invalidate the O0S.
Suggest the Corrective and Preventive actions e.g. training
to the Analyst, Requalification of Analyst etc. whatever the scientifically appropriate. o0sInvestigation -(Phase II) Extended Investigation If No assignable cause fou.nd in phase I investigation, Phase II investigation should be initiated Retesting of Material with other analyst (n 3) Resampling and testing Investigation at Plant " Further Extend investigation (upon rejection) Toolfor O0S Investigation & Related Corrective and Preventive action
Identify the Suspect
5M -Tool to Identify the Route cause Man Machine Material Method
Movement Scan the Suspect Target the suspect
Use 5 why technique to reach at root cause
Ask Why, Why, Why, Why and Why five times and try to reach at more probable reason
OTo check the reason scientifically sound - Process each
reason with six sigma technique -DMAIC Process the Root cause
Six sigma technique (DMAIC)
Define Measure Analyze Improve Control Corrective And Preventive Action " Draw appropriate root cause. Root cause should be logical and scientific. Collect the historical evidence if any with same process or any other process in the plant. Identify the need for extend the investigation to past or future batches... Provide corrective action with evidence Suggest preventive action