The reasoning lived in a meeting. The answer depends on who still remembers it.
In this record
Closure rested on four findings agreeing, not on 90 quiet days alone: no repeat excursion, retraining, the revised procedure, and an independent audit at day 65.
Illustrative structure only. Not regulatory guidance or a real company decision.
COMPLIANCEWORXSThe Record Behind the Decision
Inspection Response RecordCAPA-2025-0118
§01
Authorization
CAPA Effectiveness Closure
Authorized by
P. Trubl
Role
Director, Quality Systems & CAPA
Decision date
12-AUG-2025
Originating record
DEV-2025-0042
Authorization summary
P. Trubl authorized closure of CAPA-2025-0118 after the defined effectiveness window. The submitted record showed zero recurrence during the 90-day environmental-monitoring period, completion of analyst retraining, implementation of SOP-EM-318 R04, and a day-65 internal audit observation confirming execution of the revised procedure.
Inspection question this section answersWho authorized closure, what was authorized, and when?
§02
Evidence Reviewed
What was available to support the authorization
Evidence
Reference
What it supports
Environmental-monitoring trend
EM-DAILY · 14-MAY–12-AUG
No recurrence across the verification window
Analyst retraining records
TRAIN-EM · 02-MAY
Corrective action implemented
Revised procedure
SOP-EM-318 R04
Procedural control in force
Internal audit observation
AUDIT-2025-031 · 18-JUL
Observed compliant execution at day 65
Inspection question this section answersWhat evidence did the authorizing person rely on?
§03
Risk & Limitations
The record shows what is known — and what is not.
A credible record does not hide uncertainty. Where a fact, review, or justification was not documented, the record identifies that limitation clearly. It does not convert a later explanation into contemporaneous evidence.
Material gap identified during intake
Residual risk was not documented in the source record.
The original CAPA record concluded that the corrective action was effective but did not state what uncertainty remained after closure or what residual risk was being accepted.
Treatment selectedMark as not documented
Accepted byP. Trubl · 12-AUG-2025 14:32
ComplianceWorxs preserves this limitation rather than generating a convenient risk statement that the source record does not support.
Inspection question this section answersWhat remained uncertain, and was that uncertainty honestly preserved?
§04
Decision Reasoning
Why the available record supported closure
The authorization relied on convergence rather than absence of recurrence alone. The monitoring trend showed no repeat excursion during the effectiveness window; the analyst population had completed retraining; the revised procedure was in force; and the internal audit provided an independent observation that the revised process was being followed.
The record therefore supports the conclusion that the corrective action was operating as intended during the documented period. It does not establish conditions outside that period, and the missing residual-risk statement remains a known limitation of the source record.
Inspection question this section answersWhy did the evidence justify this authorization at that time?
§05
Audit Trail
How the record was completed
Source record evaluated
CAPA closure record and four supporting references entered into the IRR workflow.
Material gap surfaced
Residual risk statement not found in the supplied record.
Treatment options presented
Add documented information · Link evidence · Mark not documented · Route for human review.
User selected treatment
“Mark not documented.” No unsupported language was added.
Human acceptance recorded
P. Trubl accepted the treatment and the limitation was preserved in the completed record.
Inspection question this section answersWhat changed during completion, who accepted it, and what was preserved?
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