DRAP GMP Audit Check List
DRAP GMP Audit Check List
DRAP GMP Audit Check List
Part 1:
1.1 General Information
Name of Firm‟s Representative Who accompanied and assisted during the course of inspection
(s) accompanying during
inspection
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Continue…as
required
PART-I
GRADING
S. No. CONDITION Remarks
(A,B,C or D)
SECTION-I
1 GENERAL CONDITIONS
SECTION – 3
3 Quality control
Quality control department exists which is independent of other
departments and under the authority of a person with the
3.1 required qualifications and experience and with adequate
facilities.
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3.2 Basic requirements.--
(a) During the period of validity of license, adequate facilities,
trained personnel and approved procedures are available for
sampling, inspecting, testing starting materials, packaging materials,
intermediate, bulk, and finished products, and where appropriate for
monitoring environmental conditions for good manufacturing
practices purposes;
(b) Samples of starting materials, packaging materials,
intermediate products, bulk products and finished products are taken by
methods, and personnel approved of by the quality control department.
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(ii) Identity from each container.-- An identity test shall be
conducted on a sample from each container of starting material.
(iii) Examination of each batch.-- Each batch (lot) of printed
packaging materials shall be examined following receipt.
3.3.4 Test requirement for in-process control:
Records of testing.- In process control records shall be
maintained and form a part of the batch records.
3.3.5 Test requirements for finished products:
(i) Testing each batch.- For each batch of drug product, there shall
be an appropriate laboratory determination of satisfactory
conformity to its finished product specifications prior to release.
(ii) Rejection of failed products.-- Product failing to meet the
established specifications or any other relevant quality criteria may
be revalidated and shall be rejected if they do not qualify revalidation
protocols.
(iii) Reprocessing.- Reprocessing may be performed, if feasible,
but the reprocessed product shall meet all specifications and other
quality criteria prior to its acceptance and release.
3.3.6 Production record and batch review;
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which consists of an examination and assessment of all or part of
a quality system.
3.2.2 Supplier’s audits.- The quality control department shall have
responsibility together with other relevant departments for
approving suppliers.
3.6 Complaints:
3.6.1 Review of complaints.-- All complaints must be carefully
reviewed according to written procedures.
3.6.2 Person authorized.-- A person responsible for handling the
complaints.
3.6.3 Written procedures.-- There shall be written procedures
describing the action to be taken including the need to consider a
recall, in the case of a complaint concerning a possible product defect.
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(b) organization chart.
4.2 Written duties.-- All responsible staff shall have their specific
duties recorded in written descriptions.
4.3 Good manufacturing practices awareness.-- All personnel shall be
aware of the principles of good manufacturing practices that affect
them and receive initial and continuing training, including hygiene
instructions, relevant to their needs.
4.4 Prohibition of unauthorized persons.-- Steps shall be taken to
prevent unauthorized people from entering production,
storage, and quality control areas and personnel who do not work in
these areas shall not use them as a passageway.
4.5 Duties of head of departments.-- The head of the production
and quality control department may have shared, or jointly
exercised the following responsibilities relating to quality,
namely:
(a) the authorization of written procedures and other
documents, including amendments;
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(e) to ensure that the appropriate process validations and
calibrations of control equipment are performed and recorded and
the reports made available; and
SECTION--5
Good practices in manufacturing processing
(Separate format may be used for each manufacturing section)
5.1 5.1 General responsibility of licensee.-- The licensee shall
follow Good Manufacturing Practices in production of drugs
under which it shall be ensured that:--
(a) all manufacturing processes which shall be defined are
systematically reviewed in the light of experience, and shown to be
capable of consistently manufacturing pharmaceutical products of
the required quality that comply with their specifications;
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(d) instructions and procedures are written in clear and
unambiguous language, specifically applicable to the facilities
provided and followed in letter and spirit;
(i) the written system to recall any batch of product from sale or
supply is followed whenever a recall is necessitated.
SECTION-- 6
MATERIALS
6.1 Material, general
6.1.1 Quarantine.-- All incoming materials and finished products shall
be quarantined immediately after receipt or processing,
until they are released for use or distribution
6.1.2 Appropriate storage.-- All materials and products shall be
stored under the appropriate conditions established by the
manufacturer and in an orderly manner to permit batch segregation
and stock rotation by a first-in, first-out rule.
6.2 Starting materials
6.2.1 Purchase.-- The purchase of starting materials is an important
operation that must involve staff who have a particular and
thorough knowledge of the products and suppliers and a
pharmacist with some experience of production may be
preferred.
6.2.2 Purchase from producer or established supplies.-- Staring
materials shall be purchased directly from the producer or only form
established suppliers.
6.2.3 Checking of containers.-- For each consignment, the
containers shall be checked for integrity of package and seal and
for correspondence between the order, the delivery note, and the
supplier’s labels, and, containers shall be cleaned where necessary
and labelled, if required, with the prescribed data.
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in quarantine until their final release, and thereafter they shall
be stored as usable stock under conditions established by the
manufacturer.
6.5.2 Release.-- The evaluation of finished products and the
documentation necessary for release of a product for sale, as per
requirement of these rules, shall be followed.
6.6 Rejected and recovered materials
6.6.1 Storage and disposal.-- Rejected materials and products shall
be clearly marked as such and stored separately in restricted areas,
and they shall either be returned to the suppliers, or, where
appropriate, reprocessed or destroyed and then action shall be
approved by authorized personnel and recorded.
6.6.2 Reprocessing.-- The reprocessing of rejected products shall
be exceptional, it is permitted only if the quality of the final product
is not affect, if the specifications are met, and if it is done in
accordance with a defined and authorized procedure after evaluation
of the risks involved and record shall be kept of the reprocessing
and a reprocessed batch shall be given a new batch number.
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applicable this indication shall also mention the stage of
production.
7.1.7 Un-authorized entry prohibited.-- Access to the production
premises shall be restricted to authorized personnel.
7.1.8 In-process controls.-- In process controls are mostly performed
within the production are and they shall not carry any risk for
the quality of the product.
7.2 Prevention of cross-contamination and bacterial contamination
in production.
7.2.1 Precautions against dust.-- When dry materials and products
are used in production, special precautions shall be taken to prevent
the generation and dissemination of dust. This applies particularly to
the handling of highly active or sensitizing materials.
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(f) details of the packaging operations carried out, including
reference to equipment and the packaging lines used, and, when
necessary, the instructions for keeping the product un- packed or a
record or returning product that has not been packaged to the
storage area.
(g) whenever possible, samples of the printed packaging
materials used, including specimens bearing the batch
number, expiry date, and any additional overprinting;
(h) notes on any special problems, including details of any
deviation from the packaging instructions, with written
authorization by an appropriate person; and
(i) the quantities and reference number or identification of all
printed packaging materials and bulk product issued, used,
destroyed, or returned to stock and the quantities of product
obtained to permit and adequate reconciliation.
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10.4.9 Equipment logbooks.-- Logbooks shall be kept with major and
critical equipment as identified by the licensee and shall record,
as appropriate, any validations, calibrations, maintenance, cleaning,
or repair operations including dates and the identity of the people
who carried out these operations.
10.4.10 Equipment utilization record.-- The use of major and critical
equipment and the areas where products have been
processed shall be appropriately recorded in chronological order.
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PART-II
ADDITIONAL CONDITIONS FOR MANUFACTURE OF STERILE
PRODUCTS
In addition to the general conditions for manufacture of drugs by
way of formulation as described in Part-II of this Schedule, the
following additional conditions shall be followed for the manufacture
of sterile products.
SECTION—I
1 General
1.1 The production of sterile preparations shall be carried out in
clean areas, entry to which shall be through airlocks for personnel
and/or for goods. Clean areas shall be maintained to an appropriate
standard of cleanliness and supplied with air that has passed through
filters of an appropriate efficiency.
1.3 Clean areas for the production of sterile products are classified
according to the required characteristics of the air, in grades A, B, C
and D
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clean areas, and cosmetics that can shed particles shall not be
used, clothing shall be appropriate to the air grade of the area where
the personnel will be working, and the description of clothing
required for each grade is given below:
Grade D:-- The hair and, where appropriate, beard shall be covered,
protective clothing and appropriate shoes or long shoes shall be worn,
and appropriate measures shall be taken to avoid any contamination
coming from outside the clean area.
Grade C:-- The hair and, where appropriate, beard shall be covered,
a single or two-piece trouser suit, gathered at the wrists and with a
high neck and appropriate shoes or overshoes, shall be worn, and
the clothing shall shed virtually no fibers or particulate matter.
Grade B:-- Headgear shall totally enclose the hair and where
appropriate, beard; it shall be tucked into the neck of the suit, a face
mask shall be worn to prevent the shedding of droplets’ sterilized
non-powdered rubber or plastic gloves and sterilized or disinfected
footwear shall be worn; trouser-bottoms shall be
tucked inside the footwear and garment sleeves into the gloves, and
the protective clothing shall shed virtually no fibers or particulate
matter and shall retain particles shed by the body.
SECTION—2
4. Maintenance of clean area
4.1 General.-- Each manufacturing operation requires an
appropriate air cleanliness level in order to minimize the risks of
particulate or microbial contamination of the product or
materials being handled.
4.2 Airlock system.-- The entry to the sterile production areas shall be
through airlocks for personal and/or for materials. Airlocks
doors shall not be opened simultaneously, and an interlocking
system and a visual and/or audible warning system where
appropriate shall be operated to prevent the opening of more
than one door at a time.
4.3 Air supply system.-- A filtered air supply system of appropriate
efficiency, shall maintain a positive pressure relative to
surrounding area under all operational conditions and flush the area
effectively. Moreover particular attention shall be paid to the
protection of the zone of greatest risk that is, the immediate
environment to which the product and the cleaned components in
contact with it are exposed, and the various
recommendations regarding air supplies and pressure
differentials may need to be modified if it becomes necessary to
contain materials such as pathogenic, highly toxic, radioactive, or live
viral or bacterial materials. Decontamination facilities and the
treatment of air leaving a clean area may be necessary for some
operations.
4.4 Maintenance of equipment.-- When equipment maintenance is
carried out within the clean area, clean instruments and tools
shall be used, and the area shall be cleaned and dis-infected, where
appropriate, before processing recommences if the required standards
of cleanliness and/or asepsis have not been maintained during the
maintenance work.
4.5 Water supply.-- Water treatment plants shall not be operated beyond
their designed capacity and water shall be produced,
stored and distributed in a manner that prevents microbial growth
for example by constant circulation at 90C or at temperature validated
to keep microbial count of water within the limit.
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SECTION—3
5. Equipment maintenance
5.1 Documentation.-- All equipment, including sterilizers, air-
filtration systems, and water-treatment systems including still, shall
be subject to planned maintenance, validation and monitoring, and its
approved use, following maintenance work, shall be documented.
SECTION—4
6.1 Procedure.-- The sanitation of clean areas is particularly
important, they shall be cleaned frequently and thoroughly in
accordance with a written progress approved by the quality
control department, where disinfectants are used, more than one
type shall be employed with periodic alterations, the monitoring shall
be regularly undertaken in order to detect the emergence of resistant
strains of microorganisms, and in view of its limited effectiveness,
ultraviolet light shall not be used as a substitute for chemical
disinfection.
6.2 Use of disinfectants and detergents.-- Disinfectants and
detergents shall be monitored for microbial contamination. Dilutions
shall be kept in previously cleaned containers and shall not be
stored for long periods unless sterilized, and partly emptied containers
shall not be topped up.
6.3 Fumigation.-- Fumigation of clean areas may be useful reducing
microbiological contamination in inaccessible places, if required.
6.4 Monitoring of clean areas.-- Clean areas shall be monitored at
planned intervals during operations by means of microbial counts
of air and surfaces, where aseptic operations are performed,
monitoring shall be frequent to ensure that the environment is within
specifications, the results of monitoring shall be considered when
batches are assessed for approval, air particulate quality shall also be
evaluated on a regular basis, and additional monitoring is sometimes
desirable even when there are no production operations such as after
validation of systems, cleaning and fumigation.
SECTION—5
7. Processing
7.1 Precautions against contamination.-- Precautions to minimize
contamination shall be taken during all processing stages
including the stages before sterilization.
7.2 Preparations of live organisms.-- Preparations containing live
microbiological organisms shall not be made or containers filled in
areas used for the processing of other pharmaceutical products except
for validation purposes, however, vaccines of dead organisms or of
bacterial extracts may be dispensed into containers after validated
inactivation and validated cleaning procedures in the same premises
as other sterile pharmaceutical products.
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7.3 Simulation of aseptic operations validation.-- The use of nutrient
media that support microbial growth in trials to simulate aseptic
operations, sterile media fills and broth fills, is a valuable part of
overall validation of an aseptic process, and such trials shall have the
following characteristics, namely:--
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shall be working limit on contamination immediately before
sterilization that is related to the efficiency of the method to be used
and the risk of pyrogens, all solutions in particular large- volume
parenteral, shall be passed through a micro-organism retaining filter,
if possible immediately before the filling process, and when aqueous
solutions are held in sealed vessels, any pressure-release outlets shall
be protected such as by hydrophobic microbial air filters.
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the coolest part of the load or loaded chamber having been
determined during the validation. The temperature shall preferably, be
checked against a second independent temperature probe located at the
same position, the chart, or a photocopy of it, shall form part of the
batch record, and chemical or biological indicators may also be used
but shall not take the place of physical controls.
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specified.
12.3 Measurement of radiation.-- During the sterilization procedure
the radiation dose shall be measured and for this purpose,
dosimeters that are independent of dose rate shall be used giving a
quantitative measurement of the dose received by the product itself,
dosimeters shall be inserted in the load in sufficient number and
close enough together to ensure that there is always a dosimeter on
the chamber; where plastic dosimeters are used, they shall be used
within the time-limit of their calibration, dosimeter absorbance shall
be read within a short period after exposure to radiation. Biological
indicators may be used only as an additional control. Radiation-
sensitive
colour discs may be used to differentiate between packages that have
been subjected to irradiation and those that have not; they are not
indicators of successful sterilization. The information obtained shall
constitute part of the batch record, and the total radiation dose shall be
administered within a predetermined time span.
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controlled manner under ventilated conditions to allow residual
gas and re-action products to fall to the defined level, and this
process shall be validated.
14. Filtration of pharmaceutical products that cannot be sterilized in the final container.
14.1 General.-- Whenever possible, products shall be sterilized in the final
container preferably by heat sterilization. Certain solutions
and liquids that cannot sterilized in the final container can be filtered
through a sterile filter of nominal pore size 0.22um or less, or with a
least equivalent microorganism-retaining properties into a previously
sterilized container, such filters can remove bacteria and moulds, but
not all viruses or
mycoplasmas.
14.2 Using double filter layer.-- Owing to the potential additional risks
of the filtration method as compared with other sterilization
processes, a double filter layer or second filtration via a further
sterilized microorganism-retaining filter immediately prior to filling
may be advisable and the final sterile filtration shall be carried out
as close as possible to the filling point.
14.3 Eliminate fibres.-- Filters that shed fibres shall not be used and
the use of asbestos-containing filters shall be absolutely
excluded.
14.4 Checking integrity of filters.-- The integrity of the filter shall be
checked by an appropriate method such as a bubble point test
immediately after each use, it may also be useful to test the filter in
this way before use, the time taken to filer a known volume of bulk
solution and the pressure difference to be used across the filter shall be
determined during validation and any significant differences from this
shall be noted and investigated. Results of these checks shall be
recorded in the batch record.
14.5 Frequency of use of filter.-- The same filter shall not be used for
more than one working day unless such use has been validated.
14.6 Filter safety.-- The filter shall not affect the product by removal of
ingredients from it or by release of substances into it.
15. Finishing of sterile products
15.1 General.-- Containers shall be closed by appropriately validated
methods, and samples shall be checked for integrity according to
appropriate procedures.
15.2 Use of vacuum.-- Containers sealed under vacuum shall be
sampled and the samples tested for maintenance of that vacuum after
an appropriate pre-determined period.
15.3 Inspection of containers.-- Filled containers of parenteral products
shall be inspected individually, when inspection is done
visually it shall be done under suitable and controlled conditions of
illumination and background, operators doing the inspection shall pass
regular eyesight checks, with spectacles if worm, and be allowed
frequent breaks from inspection, and where other methods of
inspection are used, the process shall be validated
and the performance of the equipment checked at intervals.
SECTION—7
16. Quality control
16.1 Sterility testing.-- Samples taken for sterility testing shall be
representative of the whole of the batch but shall, in particular,
include samples taken from parts of the batch considered to be most
at risk of contamination, such as:-- (a) for products
that have been filled aseptically, samples shall include containers
filled at the beginning and end of the batch and after any
significant interruption of work; and
(b) for products that have been heat sterilized in their final containers,
and samples can be taken from any part of the load.
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16.2 Sterility test as the last measures.-- The sterility test applied to
the finished product shall be regarded only as the last in a series of
control measures by which sterility is assured and can be interpreted
only in conjunction with the environmental and batch processing
records.
16.3 Monitoring endotoxins.-- For injectable products, consideration
shall be given to monitoring the water and the intermediate and
finished product for endotoxins, using an established pharmacopoeial
method that has been validated for each type of product, for large-
volume infusion solutions, such monitoring of water or intermediates
shall always be done, in addition to any tests required by the marketing
authorization on the finished product, and when a sample fails a test,
the cause of failure shall be investigated and remedial action taken
where necessary.
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SCHEDULE B-III
[See rule 20 (b)]
PARTICULARS TO BE SHOWN IN MANUFACTURING
RECORDS
A. Substances Parenteral preparation in general: Remarks
1. Serial Number.
2. Name of the drug.
3, Batch Size,
4. Batch number.
5. Date of commencement of manufacture and date when
manufacture was completed,
6. Name of all ingredients, quantities required for the batch size,
quantities actually used. (All weighing and measurements shall be
checked initiated b¥ the competent person in the section).
7. Control reference numbers in respect of raw materials used in
formulation.
8. Date of mixing in case of dry products, e.g., powder, powder
mixture for capsule products, etc.
9. Date of granulation wherever applicable.
10. Weight of granules.
11. Date of compression in case of tablets/date of filling in case of
capsules.
12. Dates of coating wherever applicable.
13. Records of test to be carried out in case of tablets as under
(a) Average weight every thirty minutes.
(b) Disintegration time as often as practicable.
14. Records of readings taken to check weight variation in case of
capsules,
15. Reference to Analytical Report number stating whether of
standard quality or otherwise.
16, Records on the disposal of rejected batches and batches with-
drawn from the market.
17, Actual production and packing particulars indicating the size and
quantity of finished packings,
18. Date of release of finished packings for distribution or sale,
19. in case of Hypodermic tablets and ophthalmic preparations which
are required to be manufactured under aseptic conditions, records shall
be maintained indicating the precautions taken during the process of
manufacture to ensure that aseptic conditions are maintained,
20. Signature of the expert staff responsible for the manufacture,
B. Parenteral preparation:
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1. Serial Number,
2. Name of the drug,
3. Batch Size,
4. Batch number (if bulk lot is divided into various batches and processed
separately, a batch number distinctly different from that of the bulk lot
should be assigned to each of the processed batch),
5. Date of commencement of manufacture and date of completion.
6. Name of all ingredients, quantities required for the lot size, quantities
actually used. (All weighings and measurements shall be checked and
initialled by the competent person in the section).
7. Control reference numbers in respect of raw materials used.
8. PH of the solution wherever applicable.
9. Date and methods of filtration.
10. Sterility test reference on bulk batch wherever applicable. (If bulk lot is
divided into various batches and processed separately, a batch number
distinctly different from that of the bulk lot should be assigned to each of the
processed batch.
11. Date of filling.
12. Records of tests employed :--
(a) To ensure that sealed ampules are leak-proof, (b)
To check the presence of foreign particles.
(c) For pyrogens wherever applicable.
13. Records of sterilisation in case of parenteral preparation which are
heat sterilised including particulars of time temperature and pressure
employed.
14. Number and size of containers filled and number rejected.
15, Reference to Analytical Report numbers stating whether of
standard quality or otherwise.
16. Records of the disposal of rejected batch and batches with-drawn from
the market.
17. Actual production and packing particulars.
18. Date of release finished packings for distribution or sale.
19. Particulars regarding the precautions taken during manufacture to ensure
that aseptic conditions are maintained.
20. Control reference numbers in respect of the lot of glass
containers used for filling.
21. Signature of the expert staff responsible for manufacture.
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A. Tablets and capsules:
1. Analytical report number.
2. Name of the sample.
3. Date of receipt of sample,
4. Batch number.
5. Protocols of tests applied:
(a) Description.
(b) Identification.
(c) Uniformity of weight.
(d) Uniformity of diameter (if applicable).
(e) Disintegration test (time in minutes). (f)
Any other tests.
(g) Results of assay.
6. Signature of the Analyst.
7. Opinion and signature of the approved Analyst.
B. Parenteral Preparations
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1. Analytical report number.
2. Name of the sample.
3. Batch number.
4, Date of receipt of sample.
5. Number of containers filled.
6. Number of container packed
7. Protocols of tests applied
(a) Clarity,
(b) PH wherever applicable
(c) Identification.
(d) Volume in container,
(e) Sterility--(/) Bulk sample wherever applicable (ii) container sample. (f)
Pyrogen test, wherever applicable.
(g) Toxicity test, wherever applicable. (h)
Any other teats.(i) Results of assay.
8. Signature of the Analyst.
9, Opinion and signature of the approved Analyst
Pyrogen Tests:-
1. Test Report number.
2. Name of the sample.
3. Batch number.
4. Number of rabbits used.
5. Weight of each rabbit.
6. Normal temperature of each rabbit.
7. Mean initial temperature of each rabbit,
8. Dose and volume of solution injected into each rabbit and time of
injection.
9. Temperature of each rabbit noted at suitable intervals,
10. Maximum temperature.
11. Response.
12. Summed response,
13. Signature of the Analyst,
14. Opinion and signature of the approved Analyst
Toxicity Test:
1. Test Report number.
2. Name of the Sample
3, Batch number
4. Number of mice used and weight of each mouse, Strength and
volume of the drug injected,
6, Date of injection,
7. Results and remarks,
8. Signature of Analyst,
9. Opinion and signature of the approved Analyst.
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D. Raw materials:
1. Serial number
2. Name of the material
3. Name of the manufacturer/supplier.
4. Quantity received.
5. Invoice/Challan number and date.
6. Protocols of tests applied.
Manufacturer’s A B C D
over all rating Good Fair Poor Non-compliance
Compliance l Compliance Compliance
Consequences Needs Needs active Needs active Stoppage of
improvements improvements improvements and production and
stoppage of cancellation of
production License
Note:
i. The format provides guidance to the Inspectors for reporting, so that no mandatory parameters are
left unreported.
ii. Adequate space may be provided for reporting as may be needed, by using soft copy.
iii. Mark “N.A.” against the parameter which is Not Applicable, with reasons thereof.
iv. Take in to consideration non compliance to the „Critical Parameters‟ which may endanger public
health and report accordingly.
Annex-I
Detailed list of Machinery/ Equipment
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S. No. Name Validation/ Calibration status Capacity/ shift Section
Annex-II
Detailed list of Management and technical staff
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