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How should we handle a ‘deviation’ (Deviation) if one occurs during day-to-day operations?

A complete explanation of the regulatory basis, Drew Tang’s recommendations and risk alerts. The original material dates from 2025; read it alongside the latest official requirements.

Original guide, 2025 edition: These FAQs are provided for topic-based reference and have not all been individually checked against current rules. Please confirm fees, personnel, renewal, changes and product requirements against the professional in-depth guide for the relevant licence type and the official requirements in force at the time.

Drug Office, Department of Health Chinese Medicines Board

Q375 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
A “deviation” is any event in which approved instructions or an established Standard Operating Procedure (SOP) is not followed. All deviations, whether planned or accidental, must be formally managed and addressed. The correct procedure is: 1. Report and record immediately: any employee who identifies a deviation is responsible for reporting it promptly to their supervisor and the quality department. A deviation report must be created immediately, detailing when and where the event occurred, the personnel and materials involved, and how the SOP was not followed. 2. Assess the impact: the quality department must promptly assess the potential impact of the deviation on product quality, safety and efficacy. If the impact is serious, the relevant batches may need to be quarantined and release suspended. 3. Investigate the root cause: investigate the cause thoroughly, rather than stopping at “human error”. Examine whether the process was poorly designed, training was inadequate or there was an equipment problem. 4. Establish CAPA: develop and implement effective corrective and preventive action (CAPA) based on the root cause. 5. Close the deviation: after the investigation and corrective actions are complete, the quality department reviews and formally closes the deviation report.

📘 Regulatory basis

The core principle of GMP and GDP is to operate in accordance with established procedures. Deviation management is therefore a key element of the quality management system. Chapter 1 of the PIC/S GMP Guide emphasises the requirements for recording, investigating and handling deviations.

📗 Drew Tang's recommendations

We encourage clients to establish a “blame-free” reporting culture that encourages employees to report deviations proactively rather than conceal them. Treat deviation management as a tool for continual improvement. Regular trend analysis of deviations can help identify systemic weaknesses. For example, frequent deviations in a particular role may indicate that the relevant SOP is too complex or impractical and needs revision.

📕 Risk notice

Failing to report, investigate or document deviations is a serious data integrity issue and a “critical deficiency” in regulatory inspections. It indicates that your quality system is out of control. An unevaluated deviation may conceal a significant product quality risk. If a concealed deviation leads to a product recall, the consequences will be disastrous.

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