Posts tagged "CAPA"

CAPA Chapter II – Driving Source

September 21st, 2019 Posted by e-GMP, ISO 13485, Recall 0 thoughts on “CAPA Chapter II – Driving Source”

Often times, we suspect products and process as the main sources for CAPA. However, there are several other areas that we can consider as CAPA sources. They include;

  • Customer Complaints: It represents a majorly of all product-related sources for CAPA.  In the event that the customer complaints are repetitive, then there is a chance that the root cause can keep recurring. Also, complaints about the system are an indication that there is a problem with the training or instruction.
  • Yield Rates: Yields rates are most likely the main cause of CAPA rising in the manufacturing industry. Systemic issues become unavoidable when there are frequent expulsions in the process limit.
  • External and Internal Audits: Audits are the biggest identifiers that there should be a process PA or CA in the system.
  • Employee Feedback: The feedback from employees could help prevent process issues as well as enhance product development in the future.  Employee feedback is one of the direct sources a company can use to implement CAPA.
  • Vigilance: Another great resource for CAPA is to remain abreast of competitors in the same field. You can study your competitor’s product to try and implement steps to prevent certain likely problems that may arise in your product. For example, you learned that pumps develop a free flow problem by studying your competitor’s pumps. You can hereby take steps to eliminate the problem in your own pumps. We at Orcanos conduct daily research on every recall that is reported by the FDA site and conducts a technical analysis to allow the share of such events with our customers.

Managing Risks

Subconsciously most people find themselves managing risk by prioritizing their daily tasks and giving more effort to tasks they consider more important. Similarly, CAPA requires the same approach.  The actions to be taken should be prioritized based on risks. The reasons to apply such a strategy are;

  1.  To prevent the company from wasting resources on trivial problems.
  2.  To continue to create an opportunity to respond to public safety concerns.
  3.  The risk will help determine the approach of the investigation. For instance, you could take a scientific approach like the FMEA or FTA when dealing with patients safety. Meanwhile, a five-why approach can be used to address process issues.
  4. Always document your risk-based decisions.

The Process

In taking a closer look into the CAPA process, we will be expanding on the key requirements. They include;

  • Analysis
  • Investigation
  • Determining action
  • Implementing action
  • Determining the Effectiveness

First Thing to Consider: Understand

The step in the CAPA process is understanding. Without understanding the issue, it will be impossible to find the root causes or determine appropriate action. In the event that you do implement appropriate actions, there is a chance that actions and the changes would not be as comprehensive as they ought to be.

However, there are steps to take in order to understand the problem. The steps include;

  1. Defining the problem as well as writing it down. In so doing, you can better grasp the starting point of the issue.
  2. Try to identify the cause of the problem. A simple tool to use is the Fishbone Diagram.
  3. Using the Fishbone Diagram you have to determine if people, machinery, environment, process, material, and management are contributing to the problem. While you might not be solving the problem at this stage, you will be gaining a better understanding.
  4. The scope of the problem is the next step in the process.  For instance, perhaps you are using a piece of particular equipment to manufacture several parts. Unfortunately, there seems to be a fault with just one part.

Regardless of the fact that the other parts created using the same equipment have no faults, you should consider the possibility that the equipment could be contributing. Likewise, there could be a documentation problem. The ability to analyze scope ensures that you identify all the root causes.

In the event that a problem escapes detection, then it is important that there be an investigation as to why it wasn’t detected.  Perhaps there were no early-stage checks or the current checks are ineffective. 

The importance of early-stage checks is vital in the software industry where late-stage errors can prove to be costly. For example, an error that is not fixed in design stage can be 3 times or more expensive to fix at the verification stage of the process. Therefore, best to think of the early stages where the problems could be fixed and document them.

Containment

When you discover a non-conformity in a product, then it is time to exercise damage control. The damage control is not to divert the financial burden, but to ensure that the product does not cause harm to patients. If the product is already in the market then issuing a call-back and inform the customers to prevent more damage is the best course of action. 

However, if the product is still in the inventory, then the containment action will be to quarantine the inventory until the problem is solved. Containment actions should always match the risk as the damage control for issues that will affect customer’s health will differ from actions that have to deal will function or form.

Scope Analysis

Below is the summary of the thought that should go into scope analysis.

  1.  If a product is affected by equipment, then what other products are affected by the same equipment?
  2.  How thorough is your quality control system if a process is missing a particular document?
  3.  Are there audit gaps or any other gaps?
  4.  Are all of your software system validated? Is your validation process complete?
  5.  Do components affect the quality of your system and what role does your supplier play?

In conclusion, if you do not fully comprehend the extent of a problem in the CAPA system, then there is bound to be some missteps along the way.

Closed System LOOP FDA Recommended CAPA Methodology

October 11th, 2015 Posted by 510(k), FDA, Medical Device Directive 93/42/EEC, Standards and Regulations 0 thoughts on “Closed System LOOP FDA Recommended CAPA Methodology”

In this paper we are going to examine the quality of the event management process, and in particular the CAPA, referred to as corrective and preventive action.
As we think about the quality management systems (QMS), and their different components, certainly quality event management is one of the most important.
Additionally, as we look at the quality event management system more specifically, we see that it may be broken up into primary components:
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