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INSPECTION CASE FILES

You signed it.
Now show the reasoning
that justified it.

Ten decisions you or your team have already made. Each one was signed, closed, or dispositioned. Each one will be challenged under inspection.

The question is whether the authorization record exists — or whether you'll be reconstructing it in real time while the investigator waits.

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RECONSTRUCTED SCENARIO

A QA reviewer signed the batch record. When asked what was checked, the room went quiet. Scope expanded to 24 months.

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CF-01 21 CFR §211.188 · §211.192

You reviewed the batch record. You signed it as complete.

The investigator opens the file and asks:

"What specific checks were performed before this record was deemed complete?"

You look at the file. The signature is there. The review logic is not.

AUTHORIZATION RECORD — BATCH RECORD REVIEW
Review Checks Performed ██████████████████████
Reviewer Determination ██████████████████████
RECORD NOT ON FILE

Scope expanded to 24 additional batch records. Sampled re-review required under QA leadership.

Review Reconstruction →
CF-02 21 CFR §211.22(a) · §211.192

You released the batch. The deviation had been closed. The excursion exceeded the validated range.

Eight days later, the investigator stops on it.

"Who concluded the excursion did not impact product quality — and what evidence supported that determination?"

The batch record is on the table. The release rationale is not.

INVESTIGATOR REQUEST

"Provide the documented rationale supporting the release decision for Lot 2024-0114, including any deviation impact assessment reviewed prior to disposition."

RATIONALE NOT ON FILE

Historical review of all prior deviation-linked releases requested. 24 additional lots flagged.

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CF-03 21 CFR §211.192 · FDA OOS Guidance

Your team dispositioned the OOS result. Laboratory error. Investigation closed.

The investigator pulls the file.

"Who authorized this closure — and on what basis was the result attributed to laboratory error?"

The investigation exists. The closure authorization does not.

DISPOSITION RECORD — OOS-2024-0139
Disposition Result attributed to laboratory error
Closure Authorization ██████████████████████
CLOSURE AUTHORIZATION NOT ON FILE

All OOS closures from the previous 12 months flagged for re-review.

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CF-04 21 CFR §211.192 · §211.113 · ICH Q9

Your team concluded the root cause. CAPA was opened. The risk assessment that justified the conclusion was never formally authorized.

"Who authorized the risk assessment that supported this root cause determination?"

The CAPA is open. The risk authorization behind it is not documented.

RISK ASSESSMENT — DEV-2024-0158
Root Cause Operator training gap identified
Risk Authorization ██████████████████████
RISK AUTHORIZATION NOT ON FILE

Investigator questioned the basis of three downstream CAPAs. All three reopened for review.

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CF-05 21 CFR §314.70 · ICH Q12

Regulatory approved the filing category. The change was implemented. No one recorded why CBE-0 was selected over a Prior Approval Supplement.

"How was the filing category for this change determined — and who had authority to approve it?"

The change is in production. The filing rationale is nowhere in the record.

CHANGE CONTROL — CC-2024-0172
Filing Category Minor (CBE-0)
Category Rationale ██████████████████████
FILING RATIONALE NOT ON FILE

Filing category for two prior changes called into question. Regulatory resubmission considered.

Review Reconstruction →
CF-06 21 CFR §820.100 · ICH Q10

You signed the CAPA effectiveness review fourteen months ago. Effectiveness check: complete. Corrective actions: documented.

The investigator pulls it.

"How did you determine this CAPA was effective — and what evidence did you review before authorizing the closure?"

The CAPA closed. The effectiveness authorization — the one with your name on it — does not exist as a record.

CAPA EFFECTIVENESS — CAPA-2023-0193
Effectiveness Check Complete ✓
Effectiveness Criteria ██████████████████████
Determination Authorization ██████████████████████
EFFECTIVENESS AUTHORIZATION NOT ON FILE

Effectiveness determinations for all open CAPAs requested. Your methodology is now under review.

Review Reconstruction →
CF-07 21 CFR Part 11 · EU Annex 11 · ALCOA+

Your team investigated the audit trail anomaly. The determination: data integrity not compromised. Investigation closed.

"Who reviewed this data anomaly — and what was the documented basis for concluding integrity was not compromised?"

The investigation is closed. The integrity determination is not in the file.

INVESTIGATOR REQUEST

"Provide the documented integrity assessment for audit trail anomaly AT-2024-0207, including the basis for the determination that data integrity was not compromised."

INTEGRITY DETERMINATION NOT ON FILE

Assessment expanded to all systems sharing the same audit trail. Three additional anomalies surfaced.

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CF-08 21 CFR §211.84 · ICH Q10

Your supplier was audited. Two findings remained open. Material continued to be received. Your team approved the exception.

But the exception authorization was never documented.

"How was this supplier determined qualified when an exception condition existed?"

The audit report exists. The exception logic does not.

SUPPLIER QUALIFICATION — SQ-2024-0224
Audit Status 2 findings open
Exception Authorization ██████████████████████
EXCEPTION AUTHORIZATION NOT ON FILE

Incoming material quarantined. Re-qualification review initiated across three additional suppliers.

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CF-09 21 CFR §211.166 · ICH Q1A(R2)

The OOT result was flagged during a routine stability pull. Your team evaluated it. Conclusion: within statistical expectation. No further action.

"Who authorized that conclusion — and where is the documented evaluation?"

The conclusion was recorded. The authorization was not.

STABILITY EVALUATION — STB-2024-0248
Trend Conclusion Within statistical expectation
Conclusion Authorization ██████████████████████
CONCLUSION AUTHORIZATION NOT ON FILE

Trend evaluation methodology for all active stability programs requested for investigator review.

Review Reconstruction →
CF-10 21 CFR §211.198 · §820.198

You closed the complaint. No field action required. The patient was not harmed.

The investigator reads the file and looks up.

"Who authorized this disposition — and what evidence supported the determination that no field action was required?"

The complaint file is complete. The disposition authorization is not in it.

INVESTIGATOR REQUEST

"Provide the documented disposition rationale for complaint CMP-2024-0271, including the basis for the determination that no field action was required."

DISPOSITION AUTHORIZATION NOT ON FILE

Complaint trending analysis requested. All related MDR filings pulled for cross-reference.

Review Reconstruction →

Which of these decisions could your team reconstruct under inspection today?

The investigator already knows the answer.
The question is whether you do.

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