FDA Inspection Decision Scenario

Who Authorized the Deviation Disposition?

“Who made the disposition decision for this deviation, and what evidence did they review?”

21 CFR 211.192

Why this becomes difficult to defend

The decision exists. The basis for it may not be retrievable as one record.

The investigator is reviewing a closed deviation. The deviation was documented. The product was released. The investigator asks who authorized the disposition.

The deviation record shows the event was captured and closed. It does not show who evaluated the regulatory significance of the deviation and made the formal disposition authorization.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the disposition authorization
  • Regulatory impact analysis supporting the disposition
  • Evidence reviewed at the moment of the disposition decision
  • Timestamp of the authorization event
  • Reasoning for why the deviation did not affect product quality or compliance

Relevant proof

See how the record connects evidence, judgment, risk, and authorization.

A completed ComplianceWorxs record shows the reasoning layer that is usually hardest to reconstruct after the decision has been made.

EvidenceWhat was known JudgmentHow it was evaluated RiskWhat was weighed AuthorizationWho decided and why

When this is your active decision

Preserve the reasoning before the context disappears.

Use the completed proof first. When the decision is consequential enough to preserve, create an Inspection Response Record for the actual decision.