Quality System Regulation: Reflecting on CAPA Procedures

February 19, 2019
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Our training program (QSRCP) Quality System Regulation (QSR) Certified Compliance Professional™ is designed to demystify the complex regulatory policies of the FDA for Quality System Regulation, a process with some many moving parts that pharmaceutical and medical device manufacturers find themselves in a maze of stumbling blocks. Non-compliance is costly in terms of time and money, and quality system regulation touches every stage of development.


Our training program can help you jump these hurdles, but before you begin the course, here are two questions that you can ask yourself about current operations and procedures to get a better grip on how you approach quality system regulation. In particular, let’s look at CAPA or corrective and preventive action:


Why do we have CAPA procedures in place?

If your knee-jerk reaction is “to comply with the FDA regulations” you may need to rethink your answer. CAPA is not just about cutting through red tape; it’s about delivering the best product to consumers, creating efficiencies in your processes and steering clear of roadblocks. But few companies are focused on the real reasons for CAPA. In fact, reporting from 2016 indicated that between the period of 2010-2016, the FDA issued the most Form 483s for inadequate CAPA procedures than any other type of violation. If your bar for quality system regulation and CAPA is low, it’s time to raise it for the health of your business.


Can you reframe how you approach CAPA closures?

If your current quality system regulation process focuses on the timeline of a CAPA closure, you’re aiming at the wrong target. CAPA is about find the root cause of a problem, not about completing a task on a deadline. While keeping a closure investigation on target is certainly important, and deadline are a help, the goal here is to find where the problem started and prevent it from happening again, regardless of the time spent. After all, solving the problem will prevent it from cropping up in the future, and that’s the real time metric your company should focus on.


 

Source:

https://incompliancemag.com/article/a-guide-to-medical-device-corrective-action-and-preventative-action-capa/

https://www.qualitydigest.com/inside/management-article/five-common-mistakes-companies-make-capa-062018.html


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October 27, 2026
Our analysis identified quality leadership and culture as a foundational systemic gap. When senior management does not give the quality unit sufficient authority, resources, and organizational support, deficiencies rarely stay confined to one procedure or department. They can affect investigations, facility maintenance, production decisions, corrective and preventive action (CAPA) effectiveness, and timely risk escalation throughout the pharmaceutical quality system (PQS). What the Warning Letters Revealed The Warning Letters reviewed for this analysis repeatedly showed three related patterns: ineffective quality-unit oversight, inadequate management attention to known deficiencies, and corrective actions that addressed individual observations without resolving their underlying systemic causes. 1. Ineffective Quality Unit Authority Quality units (QUs) commonly exist on paper but often lack the authority, resources, or competence to enforce current good manufacturing practice (cGMP) compliance. These limitations lead to a host of issues, from failing to investigate discrepancies to allowing unsafe production practices to continue. For example, in a June 2026 Warning Letter , the FDA found that Excelvision, a Fareva facility, was disinfecting critical equipment components with sporicide rather than sterilizing them between batches. The pharmaceutical manufacturer responded by stating that some components cannot be sterilized due to machine design. The company also claimed they would use sporicide between each batch, increase microbiological sampling, and swab equipment, but the FDA deemed these actions unacceptable substitutes for sterilization. FDA concluded that Excelvision's QU either lacked the proper authority to carry out its responsibilities or had insufficiently implemented them. The company must develop a remediation plan to ensure its QU has the authority and resources to function effectively, among other requirements. 2. Inadequate Executive Oversight and Resourcing Warning Letters commonly point to senior leaders failing to resolve deficiencies and systemic flaws, rather than exercising the oversight that cGMP compliance requires. Without that oversight, employees may find workarounds or hide issues that executive leadership failed to address proactively. Some leaders do not give QU the funds to ensure maintenance programs are followed, compromising product safety and ultimately forcing large-scale remediation or heightened scrutiny. Consider the June 2026 Warning Letter issued to Huons Co., Ltd . FDA found that a microbiology team leader directed staff to discard bioburden plates that showed contamination, and changed timestamps to create backdated documentation. The team leader also admitted to cutting pages out of a logbook and replacing them with fabricated ones, instructing an analyst to backdate and omit bioburden testing results. Huons must conduct a comprehensive investigation into the scope of the falsification, perform a risk assessment of the quality of the affected drugs, and commit to two years of third-party audits to verify its corrective actions, among other requirements, to address the violations. In the Warning Letter to Excelvision, the FDA found that the company had built parts of its sterile manufacturing areas, including filling rooms and compounding rooms, with ceiling and partition materials that could not be waterproofed or decontaminated. The facility experienced repeated water intrusion, and mold was detected in cleanrooms. Now the company must implement a CAPA plan ensuring vigilant oversight of equipment and facility conditions, including making necessary repairs and upgrades. 3. Reactive CAPAs and Repeated Deficiencies Throughout our research, we concluded that leadership may view recurring problems as isolated incidents that can be fixed by superficial corrective and preventive action (CAPA). Companies commonly retrain employees rather than finding and fixing the root cause. For example, in a December 2025 Warning Letter to Apothecary Pharma, LLC, the FDA found that retraining on aseptic technique failed to address specific behaviors that had caused the original contamination risk. Putting a temporary “band-aid” over problems may keep production moving, but it won't prevent recurring deficiencies. A superficial approach to problem-solving can also go along with reactive compliance, where companies act only after regulators intervene. In both the Excelvision and Huons Warning Letters, for instance, the FDA recommended a voluntary recall before either company committed to one, rather than deciding to recall on their own as a proactive measure.  Why This Is a Systemic PQS Weakness
5 Systemic Training Gaps That FDA Warning Letters Keep Revealing
October 20, 2026
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