This is a ready-to-use form. Replace every <<FILL: ...>> placeholder with your own specifics, set your document numbers and dates, and route it through your normal document control, review, and approval. A worked filled specimen follows the template so you can see how a completed version reads. Verify each cited regulation against the current published source before you rely on it, and treat this as an educational reference to adapt rather than as legal or regulatory advice.
One form covers one incident. Complete it before defining the corrective action and before authorizing any re-execution, because scope determines what the correction has to reach and what the re-test has to cover. The governing process sits in SOP: Validation Test Incident Management, and the authorization that consumes this output is Validation Retest / Re-execution Authorization.
Why this form exists
A test failure arrives looking local. One step, one screen, one value. The instinct is to fix that one thing and move on, and under schedule pressure that instinct usually wins.
The scope question is what separates a fixed defect from a fixed symptom. A rounding rule is rarely confined to one field. A misconfigured parameter is rarely confined to one object, because the person who set it wrong that day probably set several the same way. A shared function called by one screen is usually called by others.
This form makes the scope question a completed record rather than an informal conversation. It also creates the two conclusions reviewers most often find missing: which already-passed tests are now in question, and what happened to data already generated.
Field table
| # | Field | Format | Required | Who completes | When |
|---|---|---|---|---|---|
| 1 | Assessment number | Text | Yes | Validation lead | On raising |
| 2 | Test incident number | Text | Yes | Validation lead | On raising |
| 3 | QMS deviation number | Text or N/A with reason | Conditional | Validation lead | On raising |
| 4 | Defect description | Free text, factual | Yes | Validation lead or SME | On raising |
| 5 | Underlying technical mechanism | Free text | Yes | SME | Before scope expansion |
| 6 | Scope expansion table (section 3) | Table, every dimension answered | Yes | SME with validation lead | Before conclusion |
| 7 | Previously passed tests in question (section 4) | Table | Yes | Validation lead | Before conclusion |
| 8 | GxP data assessment (section 5) | Table | Yes | SME with data or process owner | Before conclusion |
| 9 | Required re-test list (section 6) | Table | Yes | Validation lead | On conclusion |
| 10 | Conclusion statement | Free text | Yes | Validation lead | On conclusion |
| 11 | Approvals | Names, signatures, dates | Yes | Per section 8 | Before the retest authorization is approved |
1. Header
| Field | Entry |
|---|---|
| Assessment number | <<FILL: SIA-ID, e.g. SIA-OQ-EBR-021>> |
| Test incident number | <<FILL: TI number>> |
| QMS deviation number | <<FILL: deviation number, or N/A with reason>> |
| Incident classification (QA confirmed) | <<FILL: e.g. C5 defect, high GxP impact>> |
| Protocol number, title, version | <<FILL>> |
| System, equipment, method, or process | <<FILL>> |
| Environment and build | <<FILL>> |
| Date raised | <<FILL>> |
| Assessment owner (name, role) | <<FILL>> |
| SME contributing (name, role) | <<FILL>> |
2. The defect and its mechanism
Scope cannot be assessed from the symptom. It is assessed from the mechanism, because the mechanism is what tells you where else the same thing can happen.
| Field | Entry |
|---|---|
| What failed (observed) | <<FILL: the factual observation from the incident record>> |
| Where it failed (test case, function, screen, step) | <<FILL>> |
| Underlying technical mechanism | <<FILL: the specific parameter, expression, comparison, code path, template, deadband, mapping, or permission that produced the behaviour>> |
| When the defective condition began | <<FILL: date, deployment, configuration session, or build. State the evidence>> |
| Evidence establishing the start point | <<FILL: deployment record, audit trail extract, configuration export, change record>> |
| Is the mechanism unique to this object, or shared? | Unique / Shared. Basis: <<FILL>> |
The “when it began” field matters more than teams expect. Everything executed between that date and the correction ran against a defective condition, and that boundary is what makes section 4 answerable.
3. Scope expansion
Work every dimension. Record a finding for each even where the answer is “not applicable”, and record the evidence that supports the finding. A blank row is an unasked question, and an unasked question is the pattern reviewers look for.
| # | Expansion dimension | Question to answer | Finding | Evidence | In scope? |
|---|---|---|---|---|---|
| 1 | Same code path or expression | Which other functions, screens, reports, or calculations call the same code, formula, expression, script, or library routine? | <<FILL>> | <<FILL>> | Yes / No |
| 2 | Same configuration session or deployment | What else was configured, built, deployed, or migrated in the same session, by the same person, on the same day, or in the same change? | <<FILL>> | <<FILL>> | Yes / No |
| 3 | Same shared logic or shared object | Which shared templates, master data records, specification rules, recipes, phases, unit operations, or reusable components carry the same setting? | <<FILL>> | <<FILL>> | Yes / No |
| 4 | Same interface | Which inbound or outbound interfaces carry the affected field, calculation, or mapping? Are downstream systems holding a value produced by the defect? | <<FILL>> | <<FILL>> | Yes / No |
| 5 | Same user role or permission set | Which other roles inherit the affected permission, workflow routing, or view? Does the defect behave differently by role? | <<FILL>> | <<FILL>> | Yes / No |
| 6 | Same configuration parameter class | Where else does this class of parameter exist with a vendor default that the specification never overrode? | <<FILL>> | <<FILL>> | Yes / No |
| 7 | Other instances, tenants, sites, or lines | Does the same system, build, recipe, or method exist elsewhere with the same defect? | <<FILL>> | <<FILL>> | Yes / No |
| 8 | Other products, methods, or processes | Which other products, analytical methods, recipes, or processes use the affected object? | <<FILL>> | <<FILL>> | Yes / No |
| 9 | Boundary and negative conditions | Does the defect only appear at a boundary, a specific value, an error path, or an exception route that most tests never exercise? | <<FILL>> | <<FILL>> | Yes / No |
| 10 | Audit trail, signature, and record behaviour | Does the defect affect what is recorded, who it is attributed to, when it is timestamped, or whether it can be altered without trace? | <<FILL>> | <<FILL>> | Yes / No |
| 11 | Vendor scope | Does the supplier’s defect record, release note, or known-issue list identify further affected components or versions? | <<FILL>> | <<FILL>> | Yes / No |
| 12 | Prior occurrence | Has this or a similar defect been raised before, on this or another system? Check the deviation register and CAPA history. | <<FILL>> | <<FILL>> | Yes / No |
3.1 Scope expansion conclusion
| Field | Entry |
|---|---|
| Total objects, functions, or instances found affected | <<FILL: number and list>> |
| Dimensions where the answer was No, and why | <<FILL: state the basis, not just the answer>> |
| Did scope expand beyond the original failing step? | Yes / No |
| If No, the basis for concluding the defect is local | <<FILL: this needs a positive reason, not the absence of evidence to the contrary>> |
4. Previously passed tests now in question
A test that passed while a defective condition was present did not necessarily pass on its merits. Some passed because they never exercised the defect. Some passed because the defect happened not to bite on the values used. Both need to be told apart, and only one of them stays PASS.
Take every test case executed between the defective condition start date (section 2) and now, and disposition it.
| Test case | Executed date | Did it exercise the affected function or object? | Did it exercise the defective condition (boundary, path, role, value)? | Is the recorded PASS still valid? | Disposition | Basis |
|---|---|---|---|---|---|---|
<<FILL>> | <<FILL>> | Yes / No | Yes / No / Not determinable | Yes / No / Not determinable | Retain PASS / Re-execute / Re-execute with added condition | <<FILL>> |
<<FILL>> | <<FILL>> | |||||
<<FILL>> | <<FILL>> |
Decision rule. Where the third column is Yes and the fourth column is No or Not determinable, the test did not challenge the defect and its PASS is not evidence about the defective behaviour. Re-execute it with the defective condition added to the test, rather than simply repeating the original steps, otherwise the second PASS carries the same blind spot as the first.
Not determinable. If the executed record does not capture which values, roles, or paths were used, the test cannot be dispositioned from the record and is re-executed by default. Record this outcome, because it also identifies an evidence-capture gap worth correcting in the protocol template.
| Field | Entry |
|---|---|
| Test cases reviewed | <<FILL: count>> |
| Retained as PASS | <<FILL: count and list>> |
| Re-execution required | <<FILL: count and list>> |
| Re-execution with added conditions required | <<FILL: count and list>> |
| Not determinable from the record | <<FILL: count and list>> |
5. GxP data already created
Assess every dataset that could carry a value produced by, or a decision influenced by, the defect. Cover the validation environment, any environment where real data was entered, and production if the defect predates release or exists in a released system.
| Data population | Where held | Volume or date range | Could the defect have affected it? | How assessed | Outcome and disposition |
|---|---|---|---|---|---|
| Validation test data generated in this environment | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Data entered in a training or user-acceptance environment | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Migrated or converted data | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Production GxP records (if the system is released) | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Data transmitted to downstream systems | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Reports, certificates, or submissions already issued | <<FILL>> | <<FILL>> | Yes / No | <<FILL>> | <<FILL>> |
| Field | Entry |
|---|---|
| Any released product affected? | Yes / No. If Yes, escalate immediately per <<FILL: SOP-ID for product impact or recall assessment>> |
| Any batch disposition decision affected? | Yes / No, detail <<FILL>> |
| Any regulatory submission or commitment affected? | Yes / No, detail <<FILL>> |
| Any clinical or patient-facing record affected? | Yes / No, detail <<FILL>> |
| Data integrity concern identified? | Yes / No. If Yes, route to <<FILL: SOP-ID for data integrity investigation>> in parallel |
| Data correction, re-processing, or annotation required? | Yes / No, plan reference <<FILL>> |
Where production data is affected, the assessment is not complete until each affected record has a stated disposition: verified unaffected, corrected under a controlled correction, annotated with the defect reference, or reprocessed. Note that 21 CFR 211.192 expects an unexplained discrepancy investigation to be extended to other batches that may have been associated with the failure, which is the same logic this section applies to test and system data.
6. Required re-test list
The output of this form. Everything below feeds the re-execution authorization and, where applicable, the regression scope on that form.
| # | Test case and step | Reason it is in scope | Condition to add (boundary, role, path, value) | New or re-execution | Priority |
|---|---|---|---|---|---|
| 1 | <<FILL>> | Original failure | <<FILL>> | Re-execution | Must, before release |
| 2 | <<FILL>> | <<FILL: scope dimension number from section 3>> | <<FILL>> | <<FILL>> | <<FILL>> |
| 3 | <<FILL>> | <<FILL>> | <<FILL>> | <<FILL>> | <<FILL>> |
| Field | Entry |
|---|---|
| Total re-tests required | <<FILL: count>> |
| New test cases to be written and approved | <<FILL: count and reference>> |
| Protocol addendum required? | Yes, reference <<FILL>> / No |
| Estimated impact on validation timeline | <<FILL>> |
| Any scoped item deferred? | No / Yes, item <<FILL>>, justification <<FILL>>, carried as an open item to the summary report |
7. Conclusion
<<FILL: three to six sentences. State the mechanism, how far it reached, what that did to already-passed tests, what it did to data, and what must now be re-tested. Write it so that someone reading the validation package two years from now, with no memory of the project, can follow the reasoning without asking anyone.>>
| Field | Entry |
|---|---|
| Scope conclusion | Local to the failing step / Extends to other objects within the system / Extends to other instances or sites / Extends to data already created |
| Effect on the validation conclusion | None once re-tests pass / Conditional / Blocks release until resolved |
| Escalation required beyond validation? | No / Yes, to <<FILL: e.g. product quality review, recall assessment, data integrity investigation>> |
8. Approvals
| Role | Name | Signature | Date |
|---|---|---|---|
| Prepared by (validation lead) | <<FILL>> | ||
| Technical assessment (SME) | <<FILL>> | ||
| Data or process owner (section 5) | <<FILL>> | ||
| System / process owner | <<FILL>> | ||
| Quality Assurance | <<FILL>> | ||
| Higher authority (where released product or production data is affected) | <<FILL>> |
9. References
21 CFR 211.192, which requires thorough investigation of unexplained discrepancies and extension of the investigation to other batches that may have been associated with the failure. That extension requirement is the regulatory shape of the scope question this form asks. 21 CFR 211.100(a), for the design of production and control procedures to assure product quality. 21 CFR Part 11, where the defect touches electronic record or signature behaviour. EU GMP Annex 15, Qualification and Validation (2015), which requires deviations from validation protocols to be documented with appropriate justification under quality risk management. EU GMP Annex 11, Computerised Systems (2011, currently in force), for assessment of deviations arising during validation. The draft revision published 7 July 2025, consultation closed 7 October 2025, is not final. ICH Q9(R1), Quality Risk Management, for the proportionality of the assessment effort. FDA guidance “Computer Software Assurance for Production and Quality Management System Software”, issued 3 February 2026, for the risk-based assurance context. FDA 2018 data integrity guidance, MHRA GxP Data Integrity Guidance and Definitions, and PIC/S PI 041-1, for the treatment of affected records. ISPE GAMP 5 Second Edition (2022), for the lifecycle context. Reference only.
Confirm the current version and clause numbers of each reference before issue.
Filled specimen
The following shows the form completed for a defect found during the OQ of an electronic batch record module supporting a viral vector manufacturing process. The company, system, names, and numbers are illustrative.
Header and mechanism
| Field | Entry |
|---|---|
| Assessment number | SIA-OQ-EBR-021 |
| Test incident number | TI-OQ-EBR-033 |
| QMS deviation number | VAL-DEV-2026-051 |
| Classification | C5, defect, high GxP impact |
| Protocol | OQ-EBR-012, Operational Qualification of the EBR module, v1.0 |
| System | Manufacturing execution system, EBR module, instance MES-QUAL |
| Environment and build | MES-QUAL, build 6.0.2 |
| Date raised | 14 July 2026 |
| Assessment owner | L. Fontaine, Validation Lead |
| SME contributing | A. Devi, MES Configuration Engineer |
| Field | Entry |
|---|---|
| What failed (observed) | TC-044 step 6 required the EBR to calculate harvest volume in litres from an operator entry in millilitres. Operator entered 4,250 mL. Expected calculated value 4.25 L. Actual calculated value 425.0 L. |
| Where it failed | EBR phase “HARVEST”, calculated field HARVEST_VOL_L |
| Underlying technical mechanism | The calculated field calls shared expression library function CONV_ML_TO_L, which was configured with a divisor of 10 rather than 1000. The expression library is a single shared object referenced by calculated fields across all recipes on this instance. |
| When the defective condition began | 22 June 2026, the date the expression library version 3 was deployed to MES-QUAL |
| Evidence establishing the start point | Deployment record DEP-MES-2026-018; MES configuration audit trail extract ATT-2 showing the divisor value set on 22 June 2026 at 15:07 by the configuration engineer |
| Unique or shared? | Shared. The expression library is instance-wide. |
Scope expansion
| # | Dimension | Finding | Evidence | In scope? |
|---|---|---|---|---|
| 1 | Same code path or expression | CONV_ML_TO_L is referenced by 11 calculated fields across 4 recipes: harvest volume, buffer prep volume, sample aliquot volume, and final fill volume | Expression cross-reference report ATT-3 | Yes |
| 2 | Same configuration session or deployment | Expression library v3 deployment on 22 June also changed CONV_G_TO_KG and CONV_MIN_TO_HR. Both checked: CONV_G_TO_KG divisor correct at 1000, CONV_MIN_TO_HR divisor correct at 60 | Configuration export ATT-4, line by line comparison | Yes, checked, no further defect |
| 3 | Same shared logic or shared object | The expression library is the shared object. No other shared object carries a unit conversion | ATT-3 | Yes |
| 4 | Same interface | Harvest volume is transmitted to the process historian and to the ERP yield reconciliation interface. Both received the incorrect value during OQ execution on MES-QUAL. Neither ERP nor the historian applies its own conversion, so both hold the value as sent | Interface mapping specification IMS-MES-04; historian tag query ATT-5 | Yes |
| 5 | Same user role or permission set | Conversion is applied server side and does not vary by role. Verified by executing the same entry under operator and supervisor roles | ATT-6 | No |
| 6 | Same configuration parameter class | Reviewed all 9 numeric constants in the expression library against the configuration specification. The specification listed function names but not the constant values, so no constant had a specified value to verify against. This is the systemic gap | CS-MES-2026-02 sections 4.2 to 4.4 | Yes, systemic |
| 7 | Other instances, tenants, sites, or lines | Expression library v3 has not been deployed to MES-PROD or to the <<second site>> instance. Deployment to MES-PROD was scheduled for 28 July and is now held | Deployment schedule ATT-7 | Yes, prevented |
| 8 | Other products, methods, or processes | The 4 affected recipes cover 2 vector products and 1 buffer preparation process, all on MES-QUAL only | Recipe register ATT-8 | Yes |
| 9 | Boundary and negative conditions | The defect is value-independent; every conversion is wrong by a factor of 100. It would be caught by any test of the conversion but missed by any test that only checks that a value appears | N/A | Noted |
| 10 | Audit trail, signature, and record behaviour | No effect. The audit trail correctly records the entered value and the calculated value. The calculation is wrong; the recording of it is not | Audit trail extract ATT-9 | No |
| 11 | Vendor scope | Expression library is customer-configured, not vendor supplied. No vendor defect record applies | N/A | No |
| 12 | Prior occurrence | Deviation register search on “unit conversion” and “expression library” for 24 months returned no prior occurrence on this or the sister system | Register search ATT-10 | No |
| Field | Entry |
|---|---|
| Total objects affected | 11 calculated fields across 4 recipes, plus 2 downstream interfaces |
| Dimensions answered No, and why | 5 (server side calculation, verified across roles), 10 (recording behaviour verified correct), 11 (no vendor component), 12 (register searched, no prior occurrence) |
| Did scope expand beyond the failing step? | Yes, from 1 field to 11 fields, 4 recipes, and 2 interfaces |
Previously passed tests
| Test case | Executed date | Exercised the affected object? | Exercised the defective condition? | PASS still valid? | Disposition | Basis |
|---|---|---|---|---|---|---|
| TC-038 buffer prep volume entry | 30 June 2026 | Yes | No, verified only that the field accepted input and was mandatory | No | Re-execute with added condition | The test checked field behaviour, not the calculated value |
| TC-039 buffer prep record print | 01 July 2026 | Yes | No, checked that the field appeared on the printed record, not its value | No | Re-execute with added condition | Printed value was wrong but the criterion did not check it |
| TC-041 sample aliquot logging | 06 July 2026 | Yes | Yes, expected value 0.5 L for a 500 mL entry. Recorded PASS | Not determinable | Re-execute | Recorded evidence does not show the displayed value, only a PASS mark. Evidence gap |
| TC-042 historian tag population | 08 July 2026 | Yes | No, verified the tag received a value, not which value | No | Re-execute with added condition | Interface test checked connectivity, not correctness |
| TC-045 final fill volume reconciliation | 13 July 2026 | Yes | Yes | No | Re-execute | Depends directly on the defective conversion |
| TC-030 to TC-037 equipment interlocks | 24 to 29 June 2026 | No | No | Yes | Retain PASS | No calculated field involved, confirmed against test scripts |
| Field | Entry |
|---|---|
| Test cases reviewed | 13 (TC-038, TC-039, TC-041, TC-042, TC-045, and TC-030 to TC-037) |
| Retained as PASS | 8 (TC-030 to TC-037) |
| Re-execution required | 2 (TC-041, TC-045) |
| Re-execution with added conditions required | 3 (TC-038, TC-039, TC-042) |
| Not determinable from the record | 1 (TC-041, already counted in the re-execution row above rather than added to it, and the reason it is re-executed) |
GxP data already created
| Data population | Where held | Range | Affected? | How assessed | Outcome |
|---|---|---|---|---|---|
| Validation test data on MES-QUAL | MES-QUAL database | 22 June to 14 July 2026 | Yes | Query of all records containing a conversion-derived field | 47 test records hold incorrect volumes. All are validation test records, not GxP production data. Records annotated with TI-OQ-EBR-033 and retained as evidence, not corrected |
| Training environment | MES-TRAIN | N/A | No | Expression library v3 not deployed to MES-TRAIN | Confirmed by deployment record |
| Migrated data | N/A | N/A | No | No migration into this module | N/A |
| Production GxP records | MES-PROD | N/A | No | Expression library v3 never deployed to MES-PROD | Confirmed by deployment record ATT-7; deployment held |
| Downstream transmitted data | Process historian, ERP QUAL | 22 June to 14 July 2026 | Yes | Historian tag query and ERP QUAL extract | Values in QUAL environments only. Historian test tags flagged and excluded from any trending; ERP QUAL records annotated |
| Reports or certificates issued | N/A | N/A | No | No reports issued from QUAL | N/A |
| Field | Entry |
|---|---|
| Released product affected? | No |
| Batch disposition affected? | No |
| Regulatory submission affected? | No |
| Clinical or patient-facing record affected? | No |
| Data integrity concern? | No. The values are wrong because the calculation was wrong, and the record of them is accurate and attributable. No record was altered without trace |
| Data correction required? | No correction. Affected QUAL records annotated with the incident reference and retained |
Required re-test list
| # | Test case and step | Reason in scope | Condition to add | New or re-execution | Priority |
|---|---|---|---|---|---|
| 1 | TC-044 step 6 | Original failure | Verify 4,250 mL converts to 4.25 L | Re-execution | Must, before release |
| 2 | TC-038, TC-039 | Dimension 1, same shared expression | Verify the calculated value, not only field presence | Re-execution with added condition | Must, before release |
| 3 | TC-041 | Dimension 1, plus evidence gap | Capture the displayed calculated value as evidence | Re-execution | Must, before release |
| 4 | TC-042 | Dimension 4, interface | Verify the value received by the historian matches the value calculated | Re-execution with added condition | Must, before release |
| 5 | TC-045 | Dimension 1, direct dependency | Verify final fill reconciliation against a known input | Re-execution | Must, before release |
| 6 | TC-046a to TC-046h (new) | Dimension 6, systemic | One verification per remaining expression library constant against a stated specification value | New test cases, protocol addendum 1 | Must, before release |
| Field | Entry |
|---|---|
| Total re-tests required | 14 (6 re-executions of existing test cases, plus 8 new test cases) |
| New test cases | 8 (TC-046a to TC-046h) |
| Protocol addendum required? | Yes, OQ-EBR-012 addendum 1 |
| Timeline impact | 5 working days |
| Any item deferred? | No |
Conclusion
A single shared expression library function converting millilitres to litres was configured with a divisor of 10 instead of 1000, so every conversion on the instance returned a value 100 times too high from 22 June 2026 onward. The mechanism is instance-wide rather than local, reaching 11 calculated fields across 4 recipes and two downstream interfaces, and the same configuration specification gap that allowed it, function names listed without their constant values, applies to all 9 constants in the library. Five previously passed test cases were passed without ever checking a calculated value and are re-executed with the value check added, and one is re-executed because its evidence does not show what was displayed. No production data and no released product is affected, because the library version was never deployed outside the qualification instance and the scheduled production deployment is held. Fourteen re-tests are required in total, six of them re-executions of existing test cases and eight of them new test cases written to close the systemic gap, all under protocol addendum 1.
| Field | Entry |
|---|---|
| Scope conclusion | Extends to other objects within the system |
| Effect on the validation conclusion | Blocks release until the re-tests pass |
| Escalation beyond validation? | Yes, production deployment held pending correction; notified to the MES system owner and change board |
Notice what the form forced. Dimension 2 made the team check the two other constants changed in the same deployment, which turned out fine, and that “checked, no further defect” record is itself worth having. Dimension 6 turned a single wrong constant into a specification gap covering nine constants, which is what the eight new test cases exist to close. Section 4 found that five tests had passed without ever looking at a calculated value, which is a test design weakness the original protocol review should have caught. Section 5 established, with a deployment record rather than an assumption, that production was untouched.
Common inspection findings this form prevents
- A defect corrected only where it was found, with no record that anyone asked whether the same defect existed elsewhere.
- Scope stated as “this test case only” with no basis given, so the conclusion rests on an assumption rather than a check.
- Test cases left marked PASS although they were executed while a known defective condition was present.
- A test re-executed with the same steps that missed the defect the first time, producing a second PASS with the same blind spot.
- No assessment of whether data already generated in validation, training, or production carries values produced by the defect.
- Downstream systems left holding incorrect values because the interface was never included in the scope question.
- A production deployment proceeding on a build carrying a defect already found in the qualification environment.
- The systemic cause left unaddressed: one wrong parameter corrected while the specification gap that allowed it stays open for the next build.
- An investigation that never checked whether the same or a similar defect had been raised before, so a recurring problem is treated as a first occurrence each time.
- The 21 CFR 211.192 expectation to extend an investigation to other potentially associated batches applied to batch records but not to the systems and data that produce them.
How to adapt this form
- Set your assessment numbering scheme and link it to your incident and deviation numbering so the three records reconcile.
- Add expansion dimensions specific to your technology in section 3. Recipe inheritance hierarchies, multi-tenant configuration, report template libraries, master data governance, and analytical method parameter sets each deserve their own row. Removing a dimension is a decision; leaving one blank is an omission.
- Where you run a system with a strong dependency map or a where-used report, name that report in section 3 so the SME reaches for evidence rather than memory.
- Decide your default for the “not determinable” outcome in section 4. Re-execute is the safer default, and it also surfaces evidence-capture weaknesses in your protocol templates.
- Tune section 5 to the data populations you actually hold. If you hold clinical data, add rows for the trial master file, the clinical database, and any transfer to a sponsor or partner. If you hold distribution data, add rows for serialization and traceability records.
- Set the escalation trigger in section 5 to point at your real product impact, recall assessment, and data integrity investigation procedures.
- Where the assessment concludes that production data or released product is affected, require the higher-authority signature in section 8 and treat the timeline as an escalation, not a validation task.
- Confirm every regulation in section 9 against the current published version before issue, in particular the status of the EU GMP Annex 11 revision, which was still in draft at the time of writing.