Capa Sop
Capa Sop
Capa Sop
RESEARCH
TITLE: Corrective and Preventive Action (CAPA) Plan Prior Version: None
SOP Number: QA 503
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1. PURPOSE:
The purpose of this SOP is to provide guidance to investigators and key study personnel in
writing a CAPA plan to address and develop plans for existing or potential problems identified
during the conduct of human subjects research.
2. SCOPE:
All human subjects research protocols conducted and approved by the UH Institutional Review
Board (IRB), Centralized IRBs, or studies conducted at any UH facility or affiliate facility. This
SOP will serve as a guide to research personnel with the steps to writing a CAPA plan.
3. RESPONSIBLE INDIVIDUALS:
All Investigators, research, regulatory and key study personnel who engage in human subjects
research.
4. DEFINITIONS:
Corrective and Preventive Action (CAPA) Plan: actions taken to collect information and
identify a problem, determine root cause, identify and implement a corrective and/or preventive
action to prevent further recurrence.
Root Cause: factor that caused a nonconformance and should be permanently eliminated through
process improvement
Root Cause Analysis: is a class of problem solving methods used to identify the root causes
of problems or events.
Corrective Action: Immediate action to a problem that has already occurred or has been
identified.
Preventative Action: Taken to eliminate the root cause of a potential problem including the
detection/identification of problems.
5. POLICY STATEMENT:
A CAPA is written to identify a discrepancy or problem in the conduct of the clinical research
study, note the root cause of the identified problem, identify the corrective action taken to prevent
recurrence of the problem, and document that the corrective action has resolved the problem.
6. PROCEDURES:
6.5 Implementation
Describe the procedures implemented to resolve the problem and indicate whos
responsible for the procedure.
6.9 Comments-Optional
Document observations
7. REFERENCES
Feinstein Institute for Medical Research
http:// carllanderson. wordpress.com / 20 11/ 02/ 22capa-plans- for-clinic a l-trials-2/
FDA 21 CFR 820.100
Preventive/Corrective Actions (CAPA) Guidelines. R.M. Baldwin, Inc.
8. FORMS OR ATTACHMENTS
Appendix A - CAPA Template
APPROVALS
Approved by Dr. Grace McComsey, Associate Chief Scientific Officer, University Hospitals
Health System, Director, UH Clinical Research Center June 1, 2017
Clarify or add information regarding site specific regulatory file requirements, Clarify or
add information regarding source document standards,
Document and address any issue that is protocol- and/or site-specific that cannot be
resolved without a change from previous procedures.
1) Root Cause Analysis: A class of problem solving methods used to identify the root
causes of problems or events.
2) Corrective Action: Immediate action to a problem that has already occurred or has been
identified.
3) Preventative Action: Taken to eliminate the root cause of a potential problem including
the detection/identification of problems.
A CAPA should be printed on institution letterhead and should be initiated and authored by the
individual or organization responsible for its content, as follows:
If the issue relates to actions taken by the sponsor or monitor (e.g., clarification of a protocol
section), an appropriate credentialed individual from the sponsor should write and sign on the
CAPA.
CAPA should be signed by the author, submitted to the IRB for review, kept on file in the site
regulatory file and made available to the clinical site monitors reviewing the sites documents
and procedures.
In addition, if a data safety monitoring board is handling the data management of the clinical
research study, please forward a copy to the DSMB.
Hints for working on your CAPA: PICCC: Problem, Investigate, Comparison, Clues, Cause
Corrective Action: [Description of the corrective actions taken or planned by the site
personnel. If the site was instructed to perform these corrective actions
(i.e., by the sponsor or monitor), indicate by whom and as of what date. If
status of reports, records, or data will remain incomplete or unavailable,
make a statement regarding your failed attempts or describe when/how
the records will be retrieved or completed.]
Effective date of [Effective date for corrective action (may be the same date as in the
resolution: memo header)]
Preventive Action: [Description of the preventive actions taken or planned by the site
personnel. If the site was instructed to perform these preventive
actions, indicate by whom and as of what date.]