Hello all,
We (QA) noticed that we have sometimes been manufacturing a product first, then updating/approving specifications for the product that we have already manufactured, just before release.
Similarly, we have sometimes been testing a product that we have made using a certain method, then updating/approving the specification to require the method that we have already used, just before release.
This appears to me to be backwards in my QA-oriented mind. The way I read them, GMP's instruct that we write specifications first, then test to determine whether the specifications have been met. See for example 21 CFR 111.70 and 21 CFR 111.75©. [https://www.ecfr.gov...ection-111.70, 21 CFR 111.75©]
That makes sense to me because you first establish the requirements (specifications), then manufacture the product and test it to determine whether the specifications are met. From a regulatory standpoint, would this (the first two paragraphs, what we are sometimes doing) be viewed as noncompliant in the sense that it is kind of like writing the specs to make it so you can comply with the specs? Or, is this not important? (I seem to remember our laboratory defending the way we sometimes do this, saying we need to make sure a method works before we update the specifications to require the method.)
This is for manufacturing dietary supplements in the United States, and we have SQF and NSF GMP certifications.
Thank you,
Matthew