Figure 1 Nine steps of procedure CAPA
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This article systematically introduces the background and procedures of the quality management CAPA tool and compares it with the common quality tools used in sterilization supply, discusses the application of CAPA in the sterilization supply center, and helps to achieve the quality prevention and management level improvement of sterilization supply.
The sterilization supply center is known as “The heart of the hospital”. High quality sterilization supply service can effectively reduce the infection rate and mortality rate of patients, ensure medical quality and safety, and quality management is the core of its whole process control. In China, quality management tools such as quality control circle and PDCA cycle have been widely used in the field of sterilization supply, while CAPA has not been reported in this field as an effective tool. Therefore, this article introduces and discusses the origin, construction and characteristics of CAPA, hoping to provide reference for related research and management of practitioners.
CAPA is the abbreviation of Corrective and Preventive Actions, it refers to taking actions against existing or potential nonconformities or unexpected situations to prevent their recurrence and occurrence. Its definition originated from the US FDA quality system specification 21CFR820.100[
As a system of reactive and active dual loop operation, CAPA incorporates the concept of risk management, including the three independent concepts in
No. | Concept | Description | Purpose |
---|---|---|---|
1 | Correction | Remedial actions for the discovered nonconformities. |
Solve direct issues Save for the moment |
2 | Corrective Action | Actions taken to eliminate nonconformities or other undesirable situations with identified root causes. |
Stop germination in time Prevent recurrence |
3 | Preventive Action | Actions taken to prevent potential nonconformities or other unexpected situations. |
Prevent issues before they occur Prevent occurrence Is the most fundamental action |
Based on the above and in combination with the actual application of the sterilization supply center, a set of practical procedures conforming to the quality management of sterilization supply is formed, which is divided into nine steps as shown in
Figure 1 Nine steps of procedure CAPA
In order to take effective action, first of all, it is necessary to identify the issue or potential issue, identify the sources accurately, and take appropriate statistical methods to confirm and detect the issue if necessary. These issues may come from all directions, such as nonconforming products, complaints, review feedback, preventive matters for continuous improvement, trend audit results of disinfection and sterilization quality data sources, etc. In order to evaluate and ensure its accuracy, the exact evidence of the issue shall be confirmed and recorded during identification.
Once the issue is identified, it should be judged at the first time whether immediate response is required, this “Fire Fighting” remedy is Correction. If necessary, the confirmed nonconformities shall be corrected immediately before risk assessment, to weaken and maximize reduction the continuous impact and loss of nonconformities in a timely manner. If unnecessary, it can directly enter the risk assessment beyond correction.
Before Initiate CAPA, risk assessment must be carried out to determine the risk level, severity, impact and urgency of the issue. In the process of disinfection and sterilization, when any nonconforming product or adverse condition is identified as a risk or potential risk, or the quality data becomes an unexpected trend, or there is an opportunity to eliminate the cause of the possible unacceptable nonconformity, defect or adverse condition, it is necessary to start CAPA to investigate and respond. Even if it’s not necessary, the reason shall also be described, recorded and ended.
After CAPA is initiated, it is necessary to establish a CAPA team (can cross departments) and determine whether root cause investigation is required. If the risk level is low, the sterilization supply center can determine the CAPA team leader by itself; if it is found by the health administration department or the health law enforcement department, or the risk level of infection outbreak is high, the sterilization supply center shall jointly confirm the CAPA team structure and investigation plan with the management or the director in charge or the competent department. If the risk level is high, such as the health administrative department or health law enforcement, or the outbreak of infection, etc., the team structure and plan of the CAPA shall be jointly confirmed by the sterilization supply center and the management (or the director in charge or the competent department). If the root cause investigation is not required, the CAPA plan can be identified directly.
2.5.1 Issue Investigation
Effective corrective and preventive actions can be formulated only after the root cause investigation is clear. In order to accurately determine the root cause, the investigation activities should not be limited to all persons, matters, materials, etc. responsible for and related to non-compliance, issues, improvement opportunities, etc., sometimes also rely on the understanding of sterilization supply process, equipment design and consumable parameters. In this process, if any information that changes the risk is found, it is necessary to re analyze the risk.
2.5.2 Root Cause analysis
Presenting the cause and effect is the difficulty and core of CAPA investigation. The root causes can be divided into three categories in
No. | Type | Description |
---|---|---|
1 | Confirmed | where data clearly supports this as the root cause. |
2 | Concluded | where data exists to support this conclusion, but cannot be confirmed, or 3; |
3 | Potential Contributor | where the root cause cannot be confirmed or concluded but considered related to the event and CAPA are planned to mitigate this potential in the future. |
CAPA plan includes all corrective actions and preventive actions that need to be taken based on the root cause. The actions should correspond to the impact of the issue and related risks. All proposed actions should be revalidated to ensure that there will be no adverse impact on the qualified items. CAPA may also be started due to peripheral reasons such as suppliers or customers. The CAPA team should confirm the plan content with them and update the batch number, release notes or potential failure modes in a timely manner. In addition, in order to inspect and confirm the effectiveness of CAPA implementation, the CAPA team should also develop an effectiveness plan.
After approval of the CAPA Plan, the source document such as complaints or sterilization data can be archived. Each party shall implement the assigned actions according to the approved CAPA plan and target end date. If the actions cannot be completed by the assigned deadline, the basis shall be recorded and the new CAPA plan shall be approved.
After the implementation of CAPA, it shall be tracked regularly and reported to the Health Commission, Quality Supervision and other functional departments in documents. In addition, CAPA needs to be reviewed and verified according to the effectiveness plan prepared in advance to assess whether the root cause has been successfully solved and can be eliminated sustainably. If it is invalid, it shall at least return to the root cause investigation for recycling; In case of delay, the CAPA plan shall be prepared at least for re approval.
CAPA can be closed only when it is confirmed that all the corrective actions have been completed on time and are effective. The “completion” here not only includes the completion of all the corrective actions, but also includes the evaluation and confirmation of the rationality, effectiveness and adequacy of all the actions. Before closing, ensure that all information related to CAPA has been transferred to relevant personnel. After closing, the sterilization supply center should review and summarize regularly.
QCC is the abbreviation of Quality Control Circle in this article,it’s a standing group formed spontaneously, which regularly carries out quality promotion activities of preset themes. It emphasizes that all staff participate and work from bottom to top to promote members to effectively solve issues and enjoy their sense of achievement through brainstorming, thus improving their enthusiasm and quality of work. QCC is a people-oriented quality management and pays more attention to attitude, culture and atmosphere [
PDCA is a continuous and spiral quality improvement management method[
At the beginning of the 20th century, some countries such as the United States successively implemented total quality management. PDCA is the most widely used management method in many management methods that emerged at the historic moment. QCC is also a quality management activity developed from its extension. The former two have high industrial universality, as a derivative tool under the most rigorous pharmaceutical management, CAPA has complicated procedures, and it is also used in the field of medical devices. As a combination of medical devices and medical services, the sterilization supply center can use the unique three-tier response of CAPA to prevent “minor issues from being excessive and core issues from being ignored”, prevent quality issues from being “treated equally”, and make issues have priority [
In summary, CAPA is conducive to ensuring the quality safety and operating efficiency of disinfection and sterilization, contributing to the continuous improvement of the quality prevention and management level of sterilization supply, promoting the development process of fine management of the sterilization supply center, and is worthy of further promotion and use.
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