Corrective and Preventive Action
Systematic process to investigate and resolve quality issues and prevent recurrence.
Definition
CAPA is a quality system process for identifying, investigating, and addressing the root causes of nonconformities, complaints, and other quality events, and for preventing their recurrence.What this means in practice
CAPA is one of the most frequently cited subsystems in FDA inspections and forms one of the four Quality System subsystems FDA reviews under QSIT. Regulators expect a documented procedure covering identification of quality data sources, investigation, root cause analysis, action planning, implementation, verification of effectiveness, and communication of information to management review.Examples
- A complaint trend showing repeated battery under-performance triggering a CAPA that redesigns the charge circuit and updates the risk file.
- An internal audit finding on inconsistent supplier evaluation records leading to a preventive action that revises the supplier control procedure.
Use cases
1 scenarioPattern of pump occlusion complaints
QA / Complaint handlingTrending shows occlusion complaints rising 30% quarter over quarter. A CAPA is opened: root cause traced to a tubing supplier change, corrective action requalifies the prior supplier, preventive action adds incoming inspection criteria for tubing durometer.
- •Treating CAPA as a paperwork exercise without verification of effectiveness (VoE). VoE is what regulators look for first when reviewing closed CAPAs.
- •Jumping to a corrective action without a documented root cause analysis (5 Whys, fishbone, fault tree).
- •Opening a CAPA for every nonconformance. CAPA should be reserved for systemic issues; individual NCRs are handled through the nonconformance process.
- •Not feeding CAPA outputs into management review, risk management, and design controls.
Frequently asked questions
Cross-references
Related terms
Shared paths + categoryProcess for receiving, evaluating, and responding to device complaints.
FDA's harmonized successor to the QSR, incorporating ISO 13485:2016 by reference.
FDA's current good manufacturing practice (cGMP) requirements for medical devices.
International standard for medical device quality management systems.
Top-management evaluation of QMS performance at planned intervals.
Failure of a product, process, or system to meet specified requirements.
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Primary references
3 sources- 121 CFR 820.100 (CAPA)UncheckedeCFRecfr.gov
- 2FDA Inspections Observations DataUncheckedFDAfda.gov
- 3MDIC Case for QualityVerifiedMDICmdic.org
Inline markers like [1] jump to the matching reference above.