CAPA Procedure Working Template

STATUS: DRAFT EXAMPLE — NOT APPROVED — NOT EVIDENCE OF CONFORMITY

Adapt this structure to approved processes, applicable requirements, product risk, and authorized roles. A completed template or passing script cannot establish compliance, close a CAPA, or replace RA/QA, management, legal, regulatory, auditor, or certification-body judgment.

Controlled-document metadata

Field	Entry
Document ID/revision	`<ID>` / `<revision>`
Owner	`<accountable role>`
Status	`draft` / `in-review` / `approved`
Effective date	`<YYYY-MM-DD after approval>`
Evidence repository	`<controlled location>`
Supersedes/change record	`<IDs>`

Approval role	Named approver	Status	Date	Approval evidence
Process owner	`<name/role>`	`pending`	`<date>`	`<ID>`
RA/QA	`<name/role>`	`pending`	`<date>`	`<ID>`
Authorized management	`<name/role>`	`pending`	`<date>`	`<ID>`

1. Purpose and scope

Controlled purpose: <organization-specific statement>
Products, sites, processes, and records covered: <scope>
Interfaces: complaints, audit, suppliers, nonconformity, risk, vigilance, design/production change, validation, training, and management review.
Exclusions or interfaces outside this procedure: <approved rationale/evidence>

2. Roles and authority

Role	Responsibility and decision authority	Escalation	Competence evidence	Approval
CAPA system owner	`<entry>`	`<entry>`	`<ID>`	`<ID>`
CAPA owner	`<entry>`	`<entry>`	`<ID>`	`<ID>`
Independent effectiveness reviewer	`<entry>`	`<entry>`	`<ID>`	`<ID>`
RA/QA reviewer	`<entry>`	`<entry>`	`<ID>`	`<ID>`
Closure approver	`<entry>`	`<entry>`	`<ID>`	`<ID>`

3. CAPA intake and decision

Define controlled inputs and the approved criteria for opening, escalating, linking, combining, or declining a CAPA. Do not use an arbitrary priority label as a substitute for product/process risk and reportability review.

Input	Owner	Decision method	Evidence	Status	Approval
Complaint/feedback	`<role>`	`<method>`	`<ID>`	`draft`	`<ID>`
Audit/nonconformity	`<role>`	`<method>`	`<ID>`	`draft`	`<ID>`
Supplier issue	`<role>`	`<method>`	`<ID>`	`draft`	`<ID>`
Trend/risk/postmarket signal	`<role>`	`<method>`	`<ID>`	`draft`	`<ID>`

Each decision record must include:

unique CAPA ID and source-event links;
factual problem statement and known scope;
correction/containment and evidence;
product, patient/user, process, and regulatory/reportability impact review;
decision owner, status, rationale, evidence, and approval.

4. Investigation and systemic extent

The record must define the method before drawing a conclusion and preserve the evidence reviewed.

Field	Required entry
Investigation owner/status	`<role>` / `draft`
Scope and plan	`<entry>`
Data and evidence IDs	`<IDs>`
Analysis method and rationale	`<entry>`
Root cause or justified conclusion	`<entry>`
Similar/systemic issue review	`<entry>`
Risk-file/design/supplier/process impacts	`<entry>`
Reviewer and approval evidence	`<role/ID>`

Do not force a preferred root-cause method. Select and approve a method appropriate to the evidence, complexity, and risk.

5. Action planning and change control

Action ID	Description	Owner	Due date	Change/validation/training links	Implementation evidence	Status	Approval
`<ID>`	`<entry>`	`<role>`	`<date>`	`<IDs>`	`<IDs>`	`planned`	`<ID>`

Actions must address the supported cause or risk, include objective acceptance criteria, and route affected documents, software, validation, suppliers, products, training, risk files, and postmarket controls through approved change control.

6. Effectiveness plan and review

Define the effectiveness plan before closure.

Field	Required entry
Effectiveness owner	`<role>`
Independent reviewer	`<role>`
Objective acceptance criteria	`<measurable criteria>`
Baseline/comparator	`<entry>`
Data source and evidence IDs	`<IDs>`
Sample or observation window	`<risk-based rationale>`
Review date	`<YYYY-MM-DD>`
Result	`pending` / `effective` / `ineffective`
Conclusion and evidence	`<entry/IDs>`
Approval	`<approver/date/record ID>`

Fail-closed gate: pending, insufficient data, or ineffective cannot support closure. Re-open the investigation/action cycle or document authorized escalation.

7. Closure, cancellation, and extension

Closure requires:

all actions implemented with evidence;
approved effectiveness result of effective;
linked risk, design, production, supplier, postmarket, document, validation, and training changes completed or explicitly dispositioned;
complete source/version references;
closure summary, date, owner, status, evidence, and authorized approval.

Cancellation or due-date changes require a documented rationale, risk/reportability impact review, owner, status, evidence, and approval. Neither changes the need for immediate safety or regulatory action when applicable.

8. Records, metrics, and management visibility

Record/measure	Owner	Retention basis	Location	Review method	Evidence	Approval
CAPA record set	`<role>`	`<approved basis>`	`<location>`	`<method>`	`<ID>`	`<ID>`
Aging/overdue status	`<role>`	`<basis>`	`<location>`	`<method>`	`<ID>`	`<ID>`
Recurrence/effectiveness trend	`<role>`	`<basis>`	`<location>`	`<method>`	`<ID>`	`<ID>`
Management-review input	`<role>`	`<basis>`	`<location>`	`<method>`	`<ID>`	`<ID>`

Release checklist

[ ] Placeholders are resolved.
[ ] Interfaces to risk, complaints/vigilance, suppliers, design, production, validation, software, training, and change control are explicit.
[ ] No fixed timeline is used without an approved risk/process basis.
[ ] Effectiveness criteria are objective and approved before closure.
[ ] Records carry owner, status, evidence, source/version, and approval fields.
[ ] Authorized human approvers released the procedure.
[ ] The procedure makes no compliance or certification claim.