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Inspection Decision Scenarios Investigation Closure Decisions

FDA Inspection Decision Scenario

Who Authorized the Root Cause Determination?

21 CFR 211.19221 CFR 820.100

What FDA investigators are actually asking

FDA Investigator Question

"Who made the decision that this was the root cause, and what evidence was used to reach that conclusion?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the investigation data before the root cause was formally accepted?
  • What methodology was applied to identify and confirm the root cause?
  • What alternative causes were evaluated and ruled out?
  • What evidence would have required the investigation to continue?
  • When was the root cause determination authorized, and who is named as the decision owner?

Can your team answer this question in under five minutes? The Authorization Assessment identifies where your decision trail breaks before an investigator does.

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The authorization gap this scenario reveals

The investigator is reviewing a closed investigation. A root cause is documented. The investigator asks who authorized the root cause determination — not who documented it.

Authorization Gap

The investigation record shows a root cause was identified. It does not show who made the formal authorization that the identified cause was sufficient — or that the evidence justified closing further investigation. This is the authorization gap: the decision was made, but it was never documented as an authorization event — with a named decision owner, the evidence reviewed, the regulatory standard applied, and a timestamped record of when the authorization occurred.

What evidence the investigator expects

Organizations operating with authorization infrastructure produce this record at the moment the decision is made.

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These gaps are not documentation failures. They are authorization failures. The Authorization Assessment maps exactly where your decision trail is missing these elements.

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Authorization Assessment

Which of your decisions
have an authorization gap?

The Authorization Assessment identifies where your compliance decisions are undocumented as authorization events — the exact gap inspectors expose in scenarios like this one.

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Inspection Case Files document the authorization gap in detail — showing exactly what a Decision Defense Record resolves and what inspectors expect to see.

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