Deficiencies:
There is insufficient document management process to ensure all activities will be properly addressed in the procedures including records management.
Evidences:
1. There is no SOP defined on waste disposal process and requirement e.g. disposal method, disposal record, etc. for printed materials, plates, out dated records, etc.
2. The SOP has been made effective before reviewing and approval by authorized persons
3. The list of internal auditor has not been established with qualification record to ensure that all auditors has been qualified before conducting internal audit
4. The CAPA SOP has been applied for internal audit findings only, not applied for other audit findings such as customer audit e.g. GSK audit. which will lead to ineffective root cause identification and ineffective CAPA establishment.
5. There was no process defined in the Printing Control SOP including role and responsibility of each function that who will perform checking in each step according to check list form CS01 – order, preparation, checking before and after printing
6. The check list form CS01 – order, preparation, checking before and after printing, has not been completely recorded in some field e.g. plate reference no., printer no. and date of printing
7. The check list form CS01 – order, preparation, checking before and after printing, has not been implemented for GSK Consumer Healthcare order both promotional materials and repacking components
8. There was no record of inspection result of paper which will lead to unclear of status of material and ineffective traceability
9. There was not clear instruction on standard/reference to be used for paper inspection which will lead to incorrect inspection result and using of non-conformance material
Risks:
The procedures were not covered all the current process steps, records required and record management process. This may pose the risk of failing to comply with customer requirements, loss of traceability as well as may impact regulatory compliance and quality of printed material
Recommended actions:
The procedures should be reviewed to include all process steps that may impact to Product Quality including formal records including record management process. This is to ensure the effectiveness and quality control processes are strictly followed as well as effective traceability of records.