Course Content
Deviations and the Pharmaceutical Quality System
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4 Topics
1 Quiz
What a Deviation Is
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The Legal and Guidance Basis
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Deviation, Non-Conformance, Out of Specification and Quality Defect
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Under-Reporting and What a Deviation Rate Really Tells You
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Knowledge Check
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Detection, Reporting and the Deviation Record
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4 Topics
1 Quiz
When a Deviation Must Be Raised
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Writing the Description
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The Initial Assessment at the Point of Raising
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The Deviation Record as a GMP Document
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Knowledge Check
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Immediate Action and Containment
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4 Topics
1 Quiz
Stopping the Activity
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Securing and Preserving Evidence
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Notifying Quality Assurance and Securing the Product
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Documenting Immediate Actions in the Record
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Knowledge Check
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Classification
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5 Topics
1 Quiz
The Tier Scheme and Where It Actually Comes From
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Critical Deviations
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Major Deviations
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Minor Deviations
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Risk-Based Assignment and Reclassification
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Knowledge Check
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Product and Batch Impact Assessment
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5 Topics
1 Quiz
Scoping the Assessment by Cause, Not by Batch
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Gathering and Presenting the Evidence
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Writing the Impact Assessment
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Where Product Has Already Been Distributed
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Common Impact Assessment Failures
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Knowledge Check
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Timelines, Ownership and Escalation
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4 Topics
1 Quiz
Timelines Are Yours, and They Bind You
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Ownership and Roles
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Escalation Routes and Management Notification
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Extensions, Overdue Deviations and Backlog Control
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Knowledge Check
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Root Cause Orientation and Handover
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2 Topics
Immediate Cause, Root Cause, and How Deep to Go
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When to Escalate to a Formal Investigation, and Where to Go
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Batch Disposition and the Qualified Person
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4 Topics
1 Quiz
Who Decides What
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The Disposition Outcomes
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Quarantine, Reject and Rework Decisions
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Documenting the Disposition Rationale for Inspection
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Knowledge Check
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Annex 16 Section 3: Unexpected Deviations at Certification
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5 Topics
1 Quiz
What Section 3 Is For
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The Conditions
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Why ‘Unexpected’ Is the Hardest Word
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Assessing a Deviation Against Section 3
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Misapplications and Their Consequences
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Knowledge Check
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Annex 15: Deviations During Qualification and Validation
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4 Topics
1 Quiz
Deviations Inside a Validation Exercise
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Protocol Deviation Versus GMP Deviation
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Handling and Closing Validation Deviations
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Impact on the Validated State
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Knowledge Check
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When a Deviation Becomes a Quality Defect or Recall (Chapter 8)
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5 Topics
1 Quiz
The Escalation Decision Point
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Quality Defect Investigation
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Recall Classification and Execution
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Reporting to Competent Authorities
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Mock Recalls and Testing the System
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Knowledge Check
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Trending and Product Quality Review
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4 Topics
What to Trend and How
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Recurrence and Signal Detection
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Closing a Deviation
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Deviations in the Product Quality Review
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Workshop: A Deviation End to End
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2 Topics
Case Brief: A Filling Line Deviation
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Working the Case Through to Closure
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Templates and Tools
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Reference: Regulations and Glossary
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Final Quiz
Final Assessment: Deviation Management in GMP Environments
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