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Laboratories · GMP Laboratory Compliance

GMP Laboratory Compliance Consulting

The short answer

A GMP quality control laboratory is judged on laboratory controls: qualified instruments, validated methods, controlled reference standards, complete records and investigations that reach a conclusion. We work inside the laboratory to make those controls real at operating throughput.

01

Why this matters

  • Laboratory controls are one of the most frequently cited cGMP systems, and findings there affect release decisions across the site.
  • Invalidating an out-of-specification result without a scientifically supported laboratory cause is one of the highest-risk practices in a QC laboratory.
  • Stability programs are easy to fall behind on and difficult to recover once pull points are missed.
02

Applicable regulations and standards

21 CFR 211 Subpart I
Laboratory controls, including specifications, standards and test procedures.
21 CFR 211.192 / 211.194
Investigation of discrepancies and complete laboratory records.
FDA OOS Investigations Guidance
Phase I and Phase II investigation structure and result invalidation expectations.
USP General Chapters
Method validation, verification and transfer expectations.
03

What our consultants actually do

  • Assess the laboratory quality system: sample management, reference standards, reagents, equipment and documentation practice
  • Rebuild OOS and OOT investigation procedures with a defensible Phase I laboratory assessment
  • Review analytical method lifecycle: validation, verification, transfer and periodic re-evaluation
  • Establish instrument qualification, calibration and preventive maintenance programs
  • Improve stability program management, pull point control and trend evaluation
  • Train analysts and reviewers using real records from your laboratory
04

Across the product lifecycle

  1. 01 / DEVELOP

    Methods developed with the eventual validation and transfer in mind.

  2. 02 / SCALE

    Laboratory capacity, instrumentation and staffing matched to batch volume.

  3. 03 / TRANSFER

    Method transfer executed and documented before the receiving site releases.

  4. 04 / VALIDATE

    Method validation and instrument qualification current and traceable.

  5. 05 / MANUFACTURE

    Release and in-process testing with contemporaneous records.

  6. 06 / MAINTAIN

    Stability trending, periodic method review and OOS trend analysis.

05

Problems we are usually called about

  • Phase I investigations that assume laboratory error without evidence
  • Retesting performed before a documented hypothesis exists
  • Reference standard qualification and expiry not controlled
  • Instrument qualification current but calibration performed outside the operating range used
  • Stability pull points missed and recovered without an investigation
06

Typical deliverables

  • Laboratory controls gap assessment
  • OOS/OOT investigation procedure and investigator guidance
  • Analytical method lifecycle status matrix
  • Instrument qualification and calibration program design
  • Stability program review and remediation plan
07

Frequently asked

When can an OOS result be invalidated?
Only when the laboratory investigation identifies and documents a scientifically supported assignable cause for the error. Absence of an identified cause does not permit invalidation, and the result must then be treated as valid pending full investigation.
How many retests are appropriate?
The number should be pre-defined in the procedure, based on a hypothesis being tested, and not open-ended. Testing until a passing result appears is the failure mode this rule exists to prevent.
Do you support contract laboratories?
Yes, both contract laboratories improving their own systems and sponsors qualifying and overseeing them.
08

References

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Tell us what you're working on.

Describe the product, the process or the problem. We will tell you honestly whether we are the right people to help, and who should be on the team if we are.

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