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Inspection Decision Scenarios Regulatory Impact Decisions

FDA Inspection Decision Scenario

Who Authorized This Risk Assessment?

ICH Q921 CFR 820.30

What FDA investigators are actually asking

FDA Investigator Question

"Who made the determination that the risk level assigned was appropriate, and what evidence was used?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the risk methodology before the risk level was formally authorized?
  • What severity and probability criteria were applied to the risk scoring?
  • What mitigations were evaluated before residual risk was accepted?
  • What risk score would have prevented authorization?
  • When was the risk acceptance formally authorized, and who is named as the decision owner?

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The authorization gap this scenario reveals

The investigator is reviewing a risk assessment for a product or process change. Risk scores are documented. The assessment is closed. The investigator asks who authorized the risk determination.

Authorization Gap

The risk assessment documents scores and mitigations. It does not document who evaluated the risk methodology, reviewed the evidence, and made the formal authorization that the residual risk was acceptable. 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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