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发表于 2016-6-13 19:40:40
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本帖最后由 beiwei5du 于 2016-6-13 19:42 编辑
国外应该是很多将偏差和CAPA分开的吧,我个人觉得这样更便于管理,更便于理清思路,偏差的目的就是找出直接或根本原因,CAPA就是怎么解决这个直接和根本原因,以root case为分界点,思路清晰。同时偏差的关闭也不会影响产品的放行。下文是选自pharma Tech的一篇文章也是值得借鉴的。
http://www.pharmtech.com/preventing-and-troubleshooting-manufacturing-deviations
Understand and integrate systems
For starters, it is important that companies understand the difference between a CAPA system and a deviation system and how they work together. The CAPA system is intended to manage the correction or prevention identified to resolve the deviation, whereas the deviation system is to be used for the identification of a variation and the subsequent investigation, explains Judy O'Hara, senior consultant at Parexel Consulting, a business unit of Parexel International and a global consultancy serving the biopharmaceutical and medical-device industries .
"Resolving an issue identified through the deviation system begins with the discovery of an issue and ends with the identification of the root cause(s)," she says. "The CAPA system picks up from there. Too many times, there is a disconnect between the deviation, the root cause, and CAPA. It is important that the department responsible for the investigation, along with the Quality department, make certain that the root cause addresses the deviation and that the CAPA addresses the root cause.
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