FDA Inspection Decision Scenario

Who Authorized the Stability Data Acceptance?

“Who made the determination that this stability data supported the claimed shelf life, and what was the basis?”

21 CFR 211.166 · ICH Q1A(R2)

Why this becomes difficult to defend

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

The investigator is reviewing stability records for a product approaching shelf-life limits. Data is present. The investigator asks who made the formal acceptance decision.

The stability file contains test results and trend analyses. It does not contain a record of who evaluated the data and made the formal authorization that the results supported the claimed shelf life.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the stability data authorization
  • Regulatory standard applied to the acceptance determination
  • Evidence reviewed before the acceptance decision was made
  • Authorization timestamp for the shelf-life determination
  • Reasoning for why the stability data met the acceptance criteria

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.