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Risk	Assessment	for	CAPA	
Decision	
Applying	Risk	Management	principals	
to	determine	the	CAPA	Decision	
8/15/16	 Tarek	Elneil	 1
Contact	InformaBon	
•  Tarek	Elneil	
•  telneil@msn.com	
•  Tel:	(805)876-4356	
8/15/16	 Tarek	Elneil	 2
Risk	Management	Principals	
FDA	focus	on	risk	base	determinaBon	requires	that	
regulated	industries	dramaBcally	improve	their	
understanding	and	use	hazard	control	concepts	
•  Risk	management	principles	should	be	applied	
throughout	the	life	cycle	for	the	product	
•  It	is	commonly	understood	that	risk	is	defined	as	
the	combinaBon	of	the	probability	of	occurrence	
of	harm,	severity		of	the	harm,	and	the	ability	to	
determine	the	existence,	presence	or	fact	of	a	
hazard.		
8/15/16	 Tarek	Elneil	 3
CAPA	Challenges	
•  Achieving	a	common	understanding	of	the	
applicaBon	of	the	risk	management	among	divers	
stakeholders	is	difficult	because	each	stakeholder	
might	perceive	it	differently			
•  Some	OrganizaBons	pracBces	in	CAPA	
determinaBons	
–  IniBate	a	CAPA	based	on	set	of	criteria	not	related	to	
product	or	compliance	risk	evaluaBon	
–  CAPA	risk	evaluaBon	with	the	same	risk	criteria	
regardless	the	origin	of	the	failure	wither	it	is	product	
nonconformance	or	QS	noncompliance			
8/15/16	 Tarek	Elneil	 4
CAPA	DeterminaBon	
The	CAPA	will	be	determined	according	to	the	
triggers	that	iniBated	the	CAPA	
•  Product	Risk	will	be	considered	if	the	trigger	
was	due	to	product	nonconformance	
•  Compliance	Risk	will	be	considered	if	the	
trigger	was	due	to	noncompliance	issue	
8/15/16	 Tarek	Elneil	 5
Product	Severity	Risk		
Category Severity Sever
ity
Score
Very Low No adverse health consequence 1
Low Temporary or reversible impairment (without medical
intervention) / Transient, minor impairment or complaints
2
Medium Necessitates minor medical intervention 3
High Results in permanent impairment of body function or permanent
damage to a body structure / Necessitates surgical intervention
4
Very High Life threatening (death could occur) 5
8/15/16	 Tarek	Elneil	 6
Product	Frequency	Risk		
Category Frequency Frequen
cy Score
Remote Very unlikely to occur (less than 1 in 10,000) 1	
Rare Unlikely to occur (< 1 in 10,000 and > 1 in 1,000) 2	
Occasional Occurring at irregular intervals (<1 in 1,000 and > 1 in 100) 3	
Frequent Occurring at short intervals (<1 in 100 and >1 in 10) 4	
Regular Occurring often (more than 1 in 10) 5	
8/15/16	 Tarek	Elneil	 7
Product	Detectability	Risk		
Category Detectability Detect
ability
Score
Very High Verifiable by operator with standard measuring equipment 1	
High Verifiable by trained personal with specialized measuring device
or equipment
2	
Medium Verifiable by trained personal with subjective measurement or
highly specialized device or equipment
3	
Low Requires outside testing to verify 4	
Very Low Cannot be detected without destructive testing 5	
8/15/16	 Tarek	Elneil	 8
Compliance	Severity	Risk		
8/15/16	 Tarek	Elneil	 9	
Category Severity Severit
y Score
Very Low The findings is limited to one of the Quality system components
that will not impact the product or the quality system
1	
Low Internal Department or Audit finding (Minor) that need Quality
System improvement
2	
Medium Internal Audit finding (Critical or Major) that require extensive
improvement for not more than one major component of the
Quality System
3	
High Results in a repeat of regulatory violation that can lead to loss of
Business (licensing to a specific region), or limited product recall
4	
Very High Can result for a massive recall or Warning letter or Consent
Decry or Shut down the business
5
Compliance	Frequency	Risk		
Category Frequency Frequ
ency
Score
Remote Isolated event very unlikely to occur again 1	
Rare Unlikely to occur , or can occur under very specific or limited
condition
2	
Occasional Occurring at irregular intervals by not following the procedure, or
related to a single department or Unit
3	
Frequent Quality system noncompliance start occurring due to recent
changes (< 1 years)
4	
Regular Noncompliance was occurring due to Quality system setting or
was not updated to comply with the regulatory requirements
5	
8/15/16	 Tarek	Elneil	 10
Compliance	Detectability	Risk		
Category Detectability Detectab
ility
Score
Very High (Department Level) noncompliance was identified internally by
the Unit or Department
1	
High (Quality System) noncompliance was detected by the QS which
is capable to identify, verify, trend , or monitor the KPI, and
correct the noncompliance
2	
Medium The noncompliance was identified by an Internal Audit or
Management Review.
3	
Low The noncompliance was identified by Corporate Audit or
External Organization Audit
4	
Very low The noncompliance was found by Regulatory Body such as
FDA, or ISO Audit
5	
8/15/16	 Tarek	Elneil	 11
Hazard	Analysis	Calcula@on	
										Frequency			
	
Severity	
Remote	
1	
Rare	
2	
Occasional		
3	
Frequent	
4	
Regular	
5	
Very	High	5	 5	 10	 15	 20	 25	
High	4	 4	 8	 12	 16	 20	
Medium	3	 3	 6	 9	 12	 15	
Low	2	 2	 4	 6	 8	 10	
Very	Low	1	 1	 2	 3	 4	 5	
Risk	Score	(Frequency	X	Severity):	Low:	1-4			Medium:	5-9					High:	10-25	
8/15/16	 Tarek	Elneil	 12
Risk	Priority	Number	(RPN)	
Total	Risk	Score:	Low:	1-10,	Medium:	11-27,	High:	28-125	
													(F	X	S)	
	
Detectability	
Negligible	 Minor	
		
Moderate	
		
Major	
		
Cri@cal	
		
Very	Low	5		
25	(5x5)	 50	(5x10)	 75	(5x15)	 100	(5x20)	 125	(5x25)	
Low	4		
16	(4X4)	 32	(4x8)	 48	(4x12)	 64	(4x16)		 80	(4x20)	
Medium	3		
9	(3x3)	 18	(3x6)	 27	(3x9)		 36	(x15)	 45	(3x15)	
High	2		
4	(2x2)	 8	(2x4)	 12	(2x6)	 16	(2x8)	 20	(2x10)	
Very	High	1	
1	(1x1)	 2	(1x2)	 3	(1x3)	 4	(1x4)	 5	(1x5)	
8/15/16	 Tarek	Elneil	 13
CAPA	Decision	
		
Risk	 Decision	
Product	 Compliance	
High	
CriOcal	/	
Major	
Initiate CAPA & HHR 	 Initiate CAPA and evaluate if
HHR is needed	
Moderate		
Medium	
	
Evaluate if CAPA and or
HHR is needed	
Evaluate if CAPA and or
HHR is needed	
Low	
Minor	/
Negligible	
No	CAPA	or		HHR	are	required	 No	CAPA	is	required	
8/15/16	 Tarek	Elneil	 14

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Risk Management for CAPA Decision 1