Issue & CAPA Log — GLPI-103 Program
📚 Part of the GLPI-103 Regulatory Dossier — Reader's Guide. This article shows the live document; edits to the source appear here automatically.
This is a mock / simulation document, made for a portfolio and for learning. The drug (GLPI-103), the sponsor, the people, and the data are all fictional. It is not a real regulatory submission and has no clinical, legal, or regulatory standing. What is real is the shape of the thing — the document structure, the standards it follows, and the analysis methods; the content inside is illustrative.
What it is. The issue and CAPA (Corrective and Preventive Action) log.
Why it exists. When quality issues arise, a mature system records them, fixes the immediate problem (corrective) and prevents recurrence (preventive). The log is the evidence that quality is actively managed (ICH Q10).
How it is produced here. It is a quality record: a plan or log that shows how the program controls quality and builds the audit trail sitting behind every other document.
Format & governing standard. ICH Q10 (CAPA) · Q9(R1) (QRM) · E6(R3)
Issue & CAPA Log — GLPI-103 Program
| Field | Value |
|---|---|
| Document ID | QA-ISSUE |
| Version | 2.0 |
| Standard | ICH Q10 (CAPA) · Q9(R1) (QRM) · E6(R3) |
| Confidentiality | Confidential |
Central register of program issues and Corrective and Preventive Actions (CAPA) across CMC, nonclinical, clinical, and data-pipeline workstreams. Each entry records the issue, root-cause analysis, correction, corrective and preventive action, and verification before closure — the program's worked record of issue management.
Change History
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0 | 2026-06-29 | Quality Assurance | Initial log (resolved data-pipeline issues) |
| 2.0 | 2026-06-30 | Quality Assurance | Expanded — added CMC manufacturing/analytical/stability, nonclinical, and clinical issues with full RCA/CAPA |
A. Data-Pipeline / Analysis Issues
| ID | Severity | Description | Root cause | Corrective action | Preventive action | Status |
|---|---|---|---|---|---|---|
| ISS-001 | High | TFL Table 1 identical across arms | Broken pivot collapsed arms | Rewrote generate_table1 per-arm | verify_pipeline "Table 1 differs by arm" | Closed |
| ISS-002 | High | TEAE table/prop-test hardcoded vs AE data | Demonstration hardcode | Derived from ae_events.csv | reconcile/verify safety checks | Closed |
| ISS-003 | High | ADSL strata randomly generated | build_adsl rng.choice | Carry real STRAT from IRT record | "STRAT≈baseline" check | Closed |
| ISS-004 | Medium | SC Korean values garbled in XPORT | cp949/UTF-8 in XPORT v5 | Map to English CDISC CT | validate_cdisc CT checks | Closed |
| ISS-005 | Low | Build crash on em-dash (cp949 console) | Non-ASCII console output | ASCII console messages | — | Closed |
| ISS-006 | Medium | 5 docs missing Change History | Template not applied | Added Change History | check_format C2 (R1) | Closed |
| ISS-016 | Medium | SDTM DM did not carry 2 deaths present in AE/ADSL | Death flag not propagated when data enrichment added deaths | Derive DM DTHFL/DTHDTC from disposition | DM↔AE↔ADSL death-count cross-check | Closed |
| ISS-017 | Low | config.yaml parameters inconsistent with code/data | Config not wired to the build path | Corrected values + documented authoritative source | — | Closed |
B. CMC / Manufacturing & Analytical Issues
| ID | Severity | Description | Root-cause investigation | Corrective action | Preventive action (CAPA) | Status |
|---|---|---|---|---|---|---|
| ISS-007 | High | OOS — IV drug product: batch DP-IV-003 exceeded the sub-visible-particle / aggregate limit (SE-HPLC 2.4% vs ≤2.0%) | Temperature excursion of bulk solution during a hold step promoted interfacial aggregation; confirmed by reproduction study | Batch rejected; investigation per OOS SOP (Phase Ia/Ib) | Increased polysorbate-80 control range; added a bulk-hold temperature CPP + alarmed monitoring; re-trained operators | Closed |
| ISS-008 | High | OOT — oral tablet stability: a 40 °C/75% RH batch trended toward the related-substances limit by 6 months | Moisture ingress; desiccant capacity insufficient for the hygroscopic SNAC/peptide tablet | Extended testing + risk assessment (no marketed impact) | Packaging change to Alu/Alu blister (primary) / increased desiccant (HDPE); tightened water-content release limit | Closed |
| ISS-009 | Medium | Analytical method transfer: related-substances RP-HPLC gave variable resolution of a critical impurity pair at the QC site | Column lot-to-lot selectivity variability | Re-qualified the transfer with bracketing standards | Added column-qualification (system-suitability resolution ≥1.5) and a designated column chemistry to the method (M3-AMV) | Closed |
| ISS-010 | Medium | PPQ deviation: drug-substance PPQ batch 2 showed a transient blend/charge inhomogeneity flag at the lyophiliser load | Uneven shelf loading at scale | Batch met all CQAs (deviation assessed not impacting quality) | Revised loading pattern + IPC; added to CPV monitoring | Closed |
| ISS-011 | Medium | Impurity above ID threshold: an early DS lot showed a des-Gly deletion sequence at 0.18% | Incomplete coupling at a sterically hindered residue | Re-purified; impurity structurally characterised & qualified (Q3A) | Switched the difficult coupling to a pre-formed dipeptide fragment; added coupling-completion IPC | Closed |
C. Nonclinical Issues
| ID | Severity | Description | Investigation | Action | Status |
|---|---|---|---|---|---|
| ISS-012 | High | Carcinogenicity finding: dose-related thyroid C-cell hyperplasia/adenoma in the 2-year rat | Mechanistic follow-up (C-cell GLP-1R density, calcitonin, species comparison) established the effect as rodent-specific | Human-relevance assessment filed (M4-2.3 §4); risk carried as a labeled class contraindication (MTC/MEN-2) + RMP | Closed (managed) |
| ISS-013 | Medium | Bioanalytical interference: ADA assay drug-tolerance insufficient at high concentrations | Free-drug interference in the bridging ELISA | Added acid-dissociation pre-treatment; re-validated | Closed |
D. Clinical / Operational Issues
| ID | Severity | Description | Investigation | Action | Status |
|---|---|---|---|---|---|
| ISS-014 | Medium | Enrollment: screen-failure rate ~45% vs ~30% planned → slower randomization | Realistic source-population HbA1c/BMI distribution stricter than assumed | Activated additional sites; protocol re-training on eligibility | Closed (documented in CSR-301 §10.1; PROT deviation note) |
| ISS-015 | Low | Visit-window deviations flagged by DQE (>±7 days) | Site scheduling around holidays | Queries issued & resolved; categorised minor (no PPS impact) | Closed (QA-002; DQE query log) |
Process
Issues are logged with severity and a documented root-cause analysis (e.g., fishbone/5-Whys); a correction addresses the immediate issue and a CAPA (preferably verified by an automated check or a validated control) is implemented before closure. Quality-impacting issues are escalated to program governance per PM-005; CMC issues feed the Product Quality Review and Continued Process Verification (M3-PV).
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