Change Control Management
Change Control Management
IN
STANDARD OPERATING PROCEDURE
Restricted Circulation
Department: Quality Assurance
TITLE: CHANGE CONTROL MANAGEMENT
SOP No. Revision No.
Effective Date Supersedes No.
Review Date Page No. 1 of 26
1.0 OBJECTIVE:
To lay down a Procedure to define the Standard Operating Procedure for Change Control Management.
2.0 SCOPE:
2.1 The scope of the SOP is applicable for change control management at ……………. related to
following areas but shall not be limited to following:
2.1.1 Change in the manufacturing or analytical equipment/instrument.
2.1.2 Addition/discontinuation/modification/transfer of any equipment.
2.1.3 Change in qualification, validation or revalidation approach, formats/protocol/reports.
2.1.4 Change in formulation/manufacturing process/process parameters/key steps.
2.1.5 Changes in the facility/utilities/design and the layout (including man material movement,
equipment, duct, loop routing, filter supply lines etc.)
2.1.6 Pharmacopoeias Change
2.1.7 Change in specifications (raw material/packing material/in process intermediates/
finished product /stability)
2.1.8 Analytical methods/Analytical Method approach.
2.1.9 Product shelf life /storage conditions/label claim.
2.1.10 Changes in the documents (SOPs, Site Master File, Validation Master Plan, Cleaning
Validation Master Plan and other documents)
2.1.11 Change in source of raw material (API, Key starting material, excipient)/primary
packing material.
2.2 Change in Batch Size
2.2.1 Change in Container closure system.
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
3.0 RESPONSIBILITY:
3.1 Officer/Executive-QA
3.1.1 Officer/Executive QA shall be responsible for issuance of change control form to the
concerned department on receiving Request Form for Issuance of Documents.
3.1.2 To log the change control form and assign tracking number to it.
3.1.3 To verify the documents related to change control has been completed after
implementation of the proposed change.
3.2 Initiator : A responsible person in the department or the function may suggest the Change(s)
and shall
3.2.1 Initiate the change proposal in the prescribed format.
3.2.2 Follow up for evaluation and decision on the proposed change.
3.2.3 Complete the necessary activity /document(s) as identified before and after approval of
change for implementation.
3.2.4 To implement the change, if approved and monitor its progress.
3.2.5 Furnish the required information /data after implementation of change to functional Head
and QA for impact assessment and evaluation post implementation.
3.3 Head of the Department
3.3.1 To review the Change proposal submitted in the prescribed format and evaluate if the
reason/ justification given in support of the change(s) proposed are appropriate and
Signature
Date
justified.
3.3.2 To guide initiator for evaluation and impact assessment of the proposed change.
3.3.3 To discuss the proposal with concerned stakeholder (if applicable). Attach feasibility
report if necessary with the change proposal.
3.3.4 To recommend the proposed change after review and forward the same to QA.
3.3.5 To ensure the implementation of the change after approval from QA.
3.3.6 To review the post implementation data and forward to QA for closure of the change
proposed.
3.3.7 In case the proposed change(s) does not serve the purpose, ensure return to the original
practice/position.
3.4 Manager QA or his/her Designee
3.4.1 To review the change proposal.
3.4.2 To verify if all the necessary attachments are attached to support the proposal.
3.4.3 To evaluate the proposed change and its impact on safety, purity, efficacy, quality of the
product, cGMP, documentation and training requirements.
3.4.4 Identify the actions required as part of impact assessment as consequence to the proposal
made.
3.4.5 Identify the departments from where evaluation of change is required and arrange to
forward the proposal to the concerned department for their evaluation/comments and
acceptance.
3.4.6 To decide if the change proposed requires the review /comments, approval from the RA,
or any other corporate functions as applicable.
3.4.7 To communicate the decision on the approval /rejection of the proposed change to the
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
Signature
Date
Signature
Date
purity, strength, stability, safety and efficacy or physical characteristic of the product.
5.3 Major Change: A change that may have an impact upon the identity, quality, purity, strength,
stability, safety and efficacy or physical characteristic of the product.
5.4 Critical Change: A change that has a significant impact on quality and/or safety of the final
product.
6.0 PROCEDURE:
6.1 Request for Change Control Form
6.1.1 The change initiator from Concerned Department shall first raise request for change
control form from QA through ‘Request Form for Issuance of Documents’.
6.2 Logging of the Change Control Proposal:
6.2.1 Officer/Executive-QA shall assign a tracking number to the Change Control Form after
Issuance. The tracking numbers to be assigned sequentially based on the order in which
the change control is issued to concerned department, as mentioned below.
CC No. - CC/YY/NNN
Where,
CC – stands for Change Control
/ – separator
YY – stands for last digit of the year (i.e. 17 stands for 2017, 18 stands for 2018.
/ – separator
NNN – stands for the continuous serial number of the Change Control raised in the
respective year (i.e. 001, 002, 003,………….)
Signature
Date
Signature
Date
Signature
Date
Signature
Date
6.9.1.6 Change in environmental conditions that affect the product quality and
stability
6.9.1.7 Change in product usage directions
6.9.1.8 Change related to basic ERP / other computer software system in use.
Note: Risk Assessment shall be performed for Change Proposal which is categorized
as Critical as per SOP.
6.9.2 Major: If the proposed change may have impact on the product quality.
6.9.2.1 Modification in the facility, utility systems, addition or replacement of
Equipment with same principle of operation.
6.9.2.2 Changes related to the non-critical process parameters/operating steps/
instructions.
6.9.2.3 Changes in the stability program.
6.9.2.4 Changes in secondary packing material.
6.9.2.5 Major modifications for enhancement of GMP/GLP at the site for
improvement in product Quality.
6.9.2.6 Source of major excipient and updation in its specifications.
6.9.2.7 Change in cleaning procedure(s).
6.9.2.8 Increase in batch size without any change in the ingredients and with
Proportional change in quality of ingredients as per proposed batch size.
6.9.2.9 Change in artworks of primary/ secondary packing materials /color
combination/label claim/label design.
6.9.2.10 Change in registration profile for products already registered with agency.
6.9.2.11 Major changes related to master data in ERP.
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
Signature
Date
6.10.3 In case of disagreements on decision for recommending the change among identified
evaluators, the final decision shall be taken by Head QA/Designee with justification.
6.11 Implementation of the Approved Change:
6.11.1 On receipt of the information regarding approval of the proposed change, initiator or
other department as identified shall carry out the activity /actions /document revision
/new document preparation as recommended for the implementation of the proposed
change.
6.11.2 On completion of the activity the implementer shall inform to the QA Department and
shall submit the necessary data/information as required.
6.12 Post Implementation review by QA Department:
6.12.1 Head QA shall verify the data/ information as submitted and if found satisfactory shall
authorize for regularization of the change. In case, the data /information is not
satisfactory Head QA shall advise to return to the original procedure/practice and
discontinuation of the approved change.
6.13 Closure of the Change Control:
6.13.1 After the post implementation evaluation of change implemented, Manager QA
/Designee at site shall close the change control form after verifying:
6.13.1.1 The result and supporting data are satisfactory.
6.13.1.2 Completion of the required activities/documents as identified during the
evaluation and approval of change.
6.13.1.3 The proposed change meets its objective based on impact assessment.
6.13.1.4 All the documents related Change Control shall be closed within 30 days from
the date of approval of Change Proposal.
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
6.13.1.5 Change Control related to stability study shall be closed within 6 months from
the date of approval.
6.13.1.6 Facility related Change Control shall be closed within 6 months from the date
of Change Control Approval.
6.14 Interim Closure:
6.14.1 A change control may be closed by QA in the interim, if all activities are completed
but the final implementation /regularization is pending for approval from agency (e.g.
pre-approval from FDA, variation application or country specific MOH) or generation
of the stability data.
6.14.2 Interim closure may be done by QA, justifying the reason by using Interim Closure of
the Change Control (Format No.: F04).
6.14.3 The disposition of any product placed on “QA HOLD” as a result a Change Control
will be evaluated by the Quality Assurance upon completion of the Change Control
and any applicable testing.
6.15 Extension of the Change Control:
6.15.1 All the actions / activity pertaining to the implementation of the approved Change
Control shall be completed within 30 days of the approval of Change Proposal and
facility & stability related Change Control shall be closed within 6 months from date
of Approval. However if the implementation of the activities is not completed within
defined time frame, extension form (Format No.: F03) may be requested, which may
be approved by Head QA if justified.
6.16 Review of the Change Control shall be carried out quarterly & trend shall be prepared by QA
Department according to SOP.
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
7.0 ABBREVIATIONS:
BMR : Batch Manufacturing Record
BPR : Batch Packing Record
cGMP : Current Good Manufacturing Practices
CC : Change Control
GLP : Good Laboratory Practices
HVAC : Heating Ventilation and Air Conditioning
WHO : World Health Organization
TRS : Technical Report Series
SOP : Standard Operating Procedure
QA : Quality Assurance
QC : Quality Control
API : Active Pharmaceutical Ingredient
BOM : Bill of Material
RA : Regulatory Affairs
MFR : Master Formula Record
GTP : General Test Procedure
STP : Standard Test Procedure
ERP : Enterprise Resource Planning
SMF : Site Master File
VMP : Validation Master Plan
Signature
Date
8.0 ANNEXURES:
ANNEXURE No. TITLE OF ANNEXURE FORMAT No.
Annexure-I Change Control Form SOP/QA/008/F01-02
9.0 DISTRIBUTION:
• Master Copy Quality Assurance Department
• Controlled Copy No. 01 Quality Assurance Department
• Controlled Copy No. 02 Quality Control Department
• Controlled Copy No. 03 Production Department
• Controlled Copy No. 04 Human Resource Department (HR)
• Controlled Copy No. 05 Engineering Department
• Controlled Copy No. 06 Warehouse Department (Store)
• Controlled Copy No. 07 Information Technology Department.
10.0 REFERENCES:
IN HOUSE
Signature
Date
Signature
Date
ANNEXURE-I
WWW.PHARMASCHOLARS.IN
QUALITY ASSURANCE
CHANGE CONTROL FORM
Initiator
Sign & Date:
Signature
Date
Assessment by Quality Assurance Department for Impact of the Proposed Change (tick mark ( ) for
Applicable and (X) for Not Applicable)
Document Details/Activity Name of Document/Activity Existing Document
recommended for review Number (If Applicable)
SOP(s)
BMR
BPR
MFR
Specification(s)
STP(s)
GTP(s)
Process Validation
Cleaning Validation
AMV(s)
Artwork(s)
Stability
Signature
Date
Equipment Qualification
Calibration
Vendor
License
SMF
VMP
Layouts/Drawings
ERP based system
Facility
Area Qualification
Technology Transfer
Other(s)
Comments from Impacted Department tick mark ( ) by QA and (X) for Not Applicable
Department Name Name of Comments Sign and Date
Reviewer
Quality Assurance
Quality Control
Production
Engineering
Human Resource
Warehouse
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
PPIC
Regulatory Affairs
Concerned Customer/
Regulatory Agency
Any Other
Reviewed by Manager QA
(Sign and Date):
Risk Assessment: Required Not Required
If Required perform Risk Assessment as per SOP No. SOP/QA/024
Doc. No.:
Change Action Plan (To be completed by impacted Departments)
S. No. Activity to be performed Responsible Sign and Date Target
Department Completion
Date
Head QA
(Sign and Date):
Prepared By Checked By Approved By
---
Officer/Executive Department Head Head Quality Assurance
Name
Signature
Date
Head QA
(Sign and Date):
C. POST IMPLEMENTATION EVALUATION OF THE CHANGE
Details of documents/activity to be reviewed Revised Document No. Date of Responsible
post implementation Implementation Department
Head QA
(Sign and Date)
Recommended for the Regularization of the Proposed Change: Yes/No
Date of Closure:
Quality Assurance
(Sign and Date):
FORMAT No. …………… Page X of Y
Signature
Date
ANNEXURE –II
WWW.PHARMASCHOLARS.IN
QUALITY ASSURANCE
Signature
Date
ANNEXURE-III
WWW.PHARMASCHOLARS.IN
QUALITY ASSURANCE
EXTENSION OF CHANGE CONTROL FORM
CHANGE CONTROL LOG BOOK
To Quality Assurance Department
From Department
Change Control No
Details of the Pending Activity :
Signature
Date
ANNEXURE-IV
WWW.PHARMASCHOLARS.IN
QUALITY ASSURANCE
INTERIM CLOSURE OF THE CHANGE CONTROL
Approved By:
Head QA
Sign & Date:
Signature
Date
ANNEXURE-V
WWW.PHARMASCHOLARS.IN
QUALITY ASSURANCE
CHANGE CONTROL FLOWCHART
Signature
Date
Categorization of Change
(Major, Minor, Critical) by Head QA
Verification by QA
Signature
Date