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发表于 2012-3-11 15:56:25
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转几个FDA officer关于退让解释:
Q:
Deviation:
A Deviation is a departure from standard procedures resulting in non-conforming processes or where there have been unusual or unexplained events which have the potential to impact on customer product quality, system or process integrity or personal safety. For compliance to GMP and the sake of continuous improvement, these deviations are recorded in the form of Deviation Report (DR). Deviations may be planned or unplanned.
An Unplanned deviation is a deviation that is discovered after the procedure has been carried out.
A Planned deviation occurs when an unexpected event prevents a procedure from being followed exactly as written. Such deviations must be authorised before they are implemented and are expected to be short-term solutions to a problem with immediate impact." A:
820.70(a) Where deviations from device specifications could occur as a result of the manufacturing process, the manufacturer shall establish and maintain process control procedures that describe any process controls necessary to ensure conformance to specifications.
820.75(c) When changes or process deviations occur, the manufacturer shall review and evaluate the process and perform revalidation where appropriate. These activities shall be documented.
Generally, the FDA expects medical device manufacturers to establish appropriate process controls to avoid process deviation, as well as document deviations when they occur.
There is no QSR requirement that you even have a procedure for handling deviations, though. Deviation needs to be addressed, though. It can be included in Design and Development procedures, Document Control, CAPA, Nonconforming Product, or as a stand-alone procedure.
Just be sure that you document a review of the deviation (I'd recommend including some reference back to Risk Management), and the need for verification / validation. FDA doesn't care if it's planned or unplanned... they just want to see you deal with it. A planned deviation system (aka temporary change, production waiver) is definitely very nice to have. It allows for flexibility in the quality system.
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