Crisis Center

Dealing with a GMP problem now?

Something has happened, and the timeline may no longer be yours. These pathways set out what to consider first, what evidence must not be lost, and the mistakes sites most often make under pressure.

Read this first

Do not reconstruct records retrospectively. Whatever the pressure, recreating a record after the fact converts a quality problem into a data integrity problem — a different and far more serious order of finding.

The sequenceSteps 9 and 10 are the ones sites skip, and they are what decide whether the event returns.

Ten steps, in this order

  1. 01

    Contain

    Stop the situation getting worse. Quarantine affected material, halt the process step if continuing would compound the problem, and secure the area or system involved.

  2. 02

    Assess

    Establish what is known versus assumed. What happened, when, to what, and who observed it. Resist the pull to conclude a cause in the first hour.

  3. 03

    Escalate

    Notify according to your own procedure. Getting the right people informed early costs little; discovering later that QA or the QP was not told is itself a finding.

  4. 04

    Investigate

    Establish the cause with evidence rather than plausibility. Depth should be proportionate to risk, but the standard for a confirmed cause does not move.

  5. 05

    Document

    Record contemporaneously as you go. Reconstructing a record afterwards converts a quality problem into a data integrity problem, which is a different order of seriousness.

  6. 06

    Determine impact

    Assess product impact beyond the batch in front of you — other batches sharing equipment, materials, personnel or time window, and material already released.

  7. 07

    Correct

    Fix the immediate instance, and separately address the cause. Conflating correction with corrective action is the most common weakness in a response.

  8. 08

    Prevent recurrence

    Address why the process permitted the event. Where the design invites the error, training a person not to make it is a delay rather than a correction.

  9. 09

    Verify effectiveness

    Check against a criterion defined before implementation. This is the step most often skipped, and the one that decides whether the event returns as a repeat finding.

  10. 10

    Close and monitor

    Close with evidence attached, and keep the indicator under review long enough to know the fix held rather than merely completed.

Limits

This is quality guidance, not legal advice

This is practical quality guidance, not legal or regulatory advice. Whether a specific event triggers a particular regulatory obligation depends on the product, the market, the marketing authorisation and the facts. Assess against your own procedures, and take qualified advice where the situation may involve notification, recall or a deliberate act.

Need help now?

Bring the specific problem you have

If there is a response deadline, an open investigation or a batch decision waiting, fifteen minutes is usually enough to establish what to do first.