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Inspection Decision Scenarios Regulatory Impact Decisions

FDA Inspection Decision Scenario

Who Authorized the Process Validation Conclusion?

21 CFR 211.68FDA Process Validation Guidance 2011

What FDA investigators are actually asking

FDA Investigator Question

"Who made the determination that this process was validated, and what evidence supported that conclusion?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the process performance data before the validation conclusion was authorized?
  • What statistical criteria were applied to the validation determination?
  • What process variability was evaluated before the conclusion was made?
  • What results would have required additional validation runs?
  • When was the validation conclusion authorized, and who is named as the decision owner?

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The authorization gap this scenario reveals

The investigator is reviewing a process validation report. Statistical data is present. The validation is marked approved. The investigator asks who authorized the validation conclusion.

Authorization Gap

The validation report documents test results and statistical analysis. It does not document who evaluated the totality of evidence and made the formal authorization that the process was validated. 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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Inspection Case File

See exactly what this authorization gap looks like — and what closes it.

The case file reconstructs this scenario in full: the investigator's question, the record that existed, the authorization evidence that was missing, and the Decision Defense Record that resolves it.

Inspection Case File

Close this authorization gap
before inspection.

The case file documents this exact scenario — the investigator's question, the missing authorization trail, and the Decision Defense Record that produces the evidence inspectors expect.

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