FDA Inspection Decision Scenario

Who Authorized the Periodic Review Conclusion?

“Who made the determination that this system remained in a state of control, and what evidence supported that conclusion?”

21 CFR 211.180(e) · ICH Q10

Why this becomes difficult to defend

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

The investigator is reviewing an annual product review. Trend data is present. The review is marked complete. The investigator asks who authorized the state-of-control conclusion.

The periodic review documents data trends and observations. It does not document who evaluated the totality of evidence and made the formal authorization that the system remained in a validated state of control.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the state-of-control authorization
  • Evidence reviewed before the conclusion was authorized
  • Regulatory standard applied to the control determination
  • Authorization timestamp for the review conclusion
  • Reasoning linking trend data to the state-of-control determination

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.