FDA Inspection Decision Scenario

Who Authorized the Process Validation Conclusion?

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

21 CFR 211.68 · FDA Process Validation Guidance 2011

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

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.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the validation conclusion authorization
  • Evidence reviewed before the conclusion was authorized
  • Regulatory standard applied to the validation determination
  • Authorization timestamp for the validation conclusion
  • Reasoning for why the data demonstrated process control within the validated state

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.