Quality reviewers examining chromatograms during an OOS investigation.

OOS Investigation

The initial result failed.The retest passed.What justifies the batch disposition?

A passing retest shows that a result inside the specification exists. The Case File shows what the disposition needs to preserve: what was found about the original failure, the plan the retest followed, the risk left open, and who had the authority to decide.

When the inspector asks why the retest counted and the first result did not, this is the record that answers.

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A page from the finished record

Read one finished decision record before you buy.

Illustrative case. This is an excerpt of the worked record inside the Case File: OOS-2026-0057, assay by HPLC, specification 90.0% to 110.0% of label claim.

DecisionRelease; original result retained, not invalidated
Decision ownerDana Whitfield, Director, Quality Assurance
Authorized17 July 2026, 15:20 EST

The conflicting evidence

  • Original result 88.6%. Reproduced on re-injection of the same preparation (88.5% and 88.7%). Phase I laboratory assessment LA-2026-0057 found no assignable cause.
  • Retests 99.0%, 98.8% and 99.2%. Three independent preparations by a second analyst, under protocol RT-2026-0057, approved by QA before testing.
  • The original was reported with the retests. None was averaged with it.

The conclusion, and what was rejected

  • Reject the lot. Rejected: the investigation did not establish that 88.6% reflected the quality of the lot, and the independent evidence pointed the other way.
  • Release on the retests alone. Rejected: with no laboratory error identified there was no basis to replace the original, and averaging would hide the gap between 88.6% and 99%.
  • Extend the hold and retest further. Rejected: the retest count was fixed in advance (SOP QA-044 §7.3) and not adjusted for results.

The risk left unresolved

  • The cause of the 88.6% was never found. Root cause stays open with the QC Laboratory Manager, due 14 August 2026, CAPA-2026-0112.
  • Subpotency risk. Lot on stability, assay at 3 and 6 months, owned by the Stability Coordinator, STB-2026-0057.
  • Reopen trigger. A stability assay below 95.0%, or a second unexplained OOS on this method in twelve months.

Who authorized the next action

  • Dana Whitfield, Director, Quality Assurance, under named authority, on a stated date and time.
  • The record shows who held the authority, what they relied on, and what risk they accepted. No one reconstructs it from memory.

What the full Case File adds

The whole record, not one page of it.

  • The complete worked record: context, evidence, judgment, risk and authorization in one document.
  • What was established, and what was only inferred.
  • The rules behind the question, including 21 CFR 211.192 and 211.165(f).
  • A private web edition and a PDF, delivered after payment.
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The disposition distinction

A passing retest is not the same decision as the investigation behind it.

An OOS result can be investigated, retested, reported, and released with every signature in place without preserving what was found about the original failure, whether the retest followed a plan fixed in advance, or who accepted the risk that remained. The harder question is whether the record shows why the passing result was entitled to decide the batch, without anyone having to reconstruct it from memory.

The disposition record

What makes the OOS disposition explainable?

Evidence

The laboratory data, the Phase I assessment, the retest plan and results, other results on the lot, and the production review, each tied to the decision.

Judgment

Why the original result was kept, why the retests were or were not relied on, and why the disposition was justified.

Risk

The unexplained cause, subpotency over shelf life, the alternatives of reject, hold or release, and the residual exposure accepted.

Authorization

Who held authority for the disposition, whether it was delegated, and the basis on which they accepted the risk.

Signals that should slow a disposition

Before dispositioning a batch after an OOS result, leadership should be able to answer more than “did the retest pass?”

Check your own OOS dispositions against these signals.

0 of 4 signals present

See the Case File →

No cause established for the first result

The original result is set aside or discounted, but the record does not show what laboratory error was confirmed, or what was checked and found.

88.6First resultLaboratory error found: ?What was checked: not recorded

Inside the $149 Case File

The retest passed. Now explain the disposition.

See how one worked example connects the evidence, the reasoning, and accountable Quality approval.

The setup · illustrative case

An inspector reviews an OOS investigation closed on a retest. The first assay was 88.6% against a 90.0% to 110.0% specification; two retests passed; the batch was released. The inspector asks what was wrong with the first result, why the retests decided the batch, and who accepted the decision. “No record responsive to any of these questions was produced.” Here is what the record would have said.

In the inspector’s chair

The inspector asks

“What was wrong with the first result, and what shows it?”

1 of 3

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Start with the finished disposition record.

The Case File is a worked example for leaders and review teams. It does not document your own OOS investigations. When an actual consequential decision needs its own record, the Inspection Response Record is built for that.

Have an actual decision to document? The Inspection Response Record — $497 → Your $149 applies.

Preview of the OOS Investigation Case File

Also: Batch release authorization · CAPA effectiveness · All Case Files