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Inspection Decision Scenarios Regulatory Impact Decisions

FDA Inspection Decision Scenario

Who Authorized This Supplier Qualification?

21 CFR 211.8421 CFR 820.50

What FDA investigators are actually asking

FDA Investigator Question

"Who made the qualification decision for this supplier, and what was the basis for that determination?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the audit findings and quality data before the qualification decision was made?
  • What qualification criteria were applied to the supplier evaluation?
  • What regulatory standard governed the qualification threshold?
  • What would have prevented this supplier from being qualified?
  • When was the qualification formally authorized, and who is named as the decision owner?

Can your team answer this question in under five minutes? The Authorization Assessment identifies where your decision trail breaks before an investigator does.

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The authorization gap this scenario reveals

The investigator is reviewing your approved supplier list. Audit records exist. The investigator asks who made the formal qualification decision.

Authorization Gap

The supplier file contains audit reports and quality agreements. It does not contain a record of who evaluated the totality of evidence and made the qualification authorization decision. 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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