Quality events lose their risk rationale before effectiveness review, weakening CAPA traceability
A labeling discrepancy involving two label versions during finished-unit release reached final effectiveness review with a seemingly complete record, but an independent reviewer could not easily trace the original risk rationale. The affected units were contained, labeling was corrected, verification instructions were strengthened, and staff were retrained, all reasonable steps. The core problem was not missing records but the absence of a connected evidence chain linking the original event assessment to the final conclusion. The article argues that a quality event should not automatically become a CAPA, and that the rationale connecting event scope, risk assessment, escalation decisions, root cause, and action effectiveness must be formally documented. It frames this as a traceability problem tied to ISO 13485:2016, which requires corrective action review but prescribes no specific format.
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