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Standards and regulations such as ISO and FDA stress CAPA, referring to Corrective Action, Preventive Action, creating the impression that they are one and the same thing or a continuous process.
Although they both address nonconformance, the timing and the steps taken to implement those actions shows the difference between corrective action and preventive action.
Corrective Action is initiated after a nonconformity has been detected. It is a reactive measure where any deviation is analyzed after it has occurred to identify the root cause and the appropriate action to be taken to prevent its recurrence.
According to the US FDA 21 CFR 820.100, medical device manufacturers must incorporate CAPA in their Quality Management System (QMS). Any deviation or issue will have obvious causes and root causes. Businesses often address the obvious causes. While this may seem effective in the short term, the problem may persist or lead to unforeseen consequences.
The root cause may be less obvious, but that would be why a deviation was triggered. Businesses must identify this root cause or root causes since there could be more than one, and address them to contain the problem effectively.
Preventive Action, on the other hand, is proactive. It anticipates a potential nonconformity and appropriate controls are implemented to reduce the likelihood of its occurrence. While an existing nonconformity and root cause analysis may be one of the triggers for Preventive Action, it can also happen because of effective Quality Management Systems that help to continuously identify and assess risks, capture trends, and implement controls to prevent their occurrence.
Key difference between corrective action and preventive action include:
Keep the Heart of QMS Robust: Master How to Ensure Effective Corrective Action in the CAPA Process, watch the webinar: https://www.compliancequest.com/webinar/master-capa-process/
In a wish to eliminate all issues, businesses may look at CAPA as a solution. However, it is a complex process and must be approached with caution, forethought, and planning. Corrective and preventive action needs a tremendous understanding of the issues and probably the involvement of multiple teams to address an issue. It can also be time-consuming and costly.
Therefore, it must be worth the effort. Also, CAPA itself may introduce new risks. Understanding these risks and their impact is also essential before implementing CAPA. Since CAPA addresses systemic issues, it must be implemented after assessing the following:
An issue may occur or recurring due to the system or lack of or improper implementation of policies, practices, or procedures. The impact of corrective action must be evaluated, and appropriate controls must be implemented to prevent future recurrence.
Risk analysis may also reveal high-risk areas leading to deviations and nonconformities. In such cases, preventive action must be taken to avoid the risks becoming a real issue. It must be data-driven and collaborative to be truly effective.
Implementing CAPA is a regulatory requirement for medical device companies that are compliant with Good Manufacturing Practice (GMP) as defined by the FDA. The FDA 21 CFR 820.100 requires manufacturers to:
Identify and overcome Challenges Related to Escalating Complaints to CAPA. Download whitepaper: https://www.compliancequest.com/whitepaper/challenges-escalating-complaints-to-capa/
Reducing deviations not only improves compliance but also minimizes rework, recalls, and warning letters. This helps with improved product quality, lower cost of manufacturing, and improved brand reputation.
Adopting the following best practices will improve the effectiveness of CAPA and ensure continuous improvement of the Quality Management System. The best practices include:
First and foremost, CAPA is a mandatory requirement for manufacturers of medical devices. Therefore, it is essential for compliance.
Second, corrective action helps to identify the root cause and improve the quality of processes to ensure the quality of the product/service.
Third, It helps with the continuous improvement of the quality management system.
Fourth, it enables a risk-based approach to quality, another requirement of regulations, to prevent potential problems.
Fifth, it reduces nonconformance and noncompliance while improving product quality and workplace safety.
Sixth, it helps build brand reputation, resource optimization, employee engagement, and customer satisfaction.
Seventh, it helps reduce the risk of warning letters and recalls.
Eighth, it reduces the cost of manufacturing by preventing errors and deviations that can result in rework.
ComplianceQuest EQMS, a cloud-based solution, enables the end-to-end automation of the CAPA process. It facilitates collaboration, root cause analysis, risk assessment, management review, communication, and risk mitigation.
Watch the demo video: CAPA Management: Managing Quality Using Corrective and Preventive Actions here: https://www.compliancequest.com/demo-video/corrective-and-preventive-actions-management/
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