COMPLIANCE

How to Prepare for a Regulatory Inspection

An inspection assesses whether your records show a system working, not whether you can explain one. Have the records retrievable, answer accurately, record what was observed and act on it in writing.

RecordsRetrievable
AnswersAccurate
NotesKeep your own
ActionIn writing

What an Inspection Looks At

This guide is for brand owners and small manufacturers in India preparing for a regulatory inspection.

An inspection is largely a records exercise. The question is whether your documentation demonstrates that a system exists and operates: that materials are specified and tested, that batches are made to a record, that products are released against a specification by someone authorised, and that problems are investigated.

A verbal explanation of how things work carries little weight if the records do not show it. Conversely, a modest operation with complete, retrievable records generally fares better than a larger one whose records are scattered.

Preparation therefore means making sure the records exist, are current, and can be produced on request. It does not mean preparing a presentation.

This is general guidance on preparation and conduct. For anything concerning the applicable requirements, your obligations or how to respond to specific observations, take advice from a qualified professional adviser.

Important: This is general guidance on preparation. Take qualified professional advice on the applicable requirements and on responding to any specific observation.

Records to Have Retrievable

Retrievable means findable within minutes, not existing somewhere.

Category Records
Licences Current licences with scope, and any certifications
Specifications Raw material, packaging and finished product, signed and versioned
Raw materials Certificates of analysis per lot, with your incoming checks
Batch records Completed, with in-process values and signatures
Testing Finished product results with methods, and the laboratory’s details
Release Release decisions with the authorising person named
Retention samples The log, and the samples themselves, properly stored
Stability Protocols and results supporting your shelf lives
Artwork Approved versions with sign-off, linked to batches
Complaints The register, with investigations and outcomes
Deviations Any out-of-specification results and their investigations
Recall procedure Written, with any drill records
Training Records for personnel, where applicable
Cleaning and maintenance Records, where applicable
Distribution Dispatch records linked to batch numbers

Out-of-specification investigations are worth particular attention. Having them, with a documented investigation and a decision, demonstrates a functioning system. Having had such results and no record of investigating them does the opposite.

Preparing in Advance

Work worth doing before any inspection is announced.

  1. Audit your own records against the list above and fill the gaps.
  2. Check every licence and certification is current by date.
  3. Confirm licence scope covers everything you actually make.
  4. Index records so any batch can be retrieved by number.
  5. Verify retention samples exist, are labelled and are stored as specified.
  6. Confirm stability data supports every shelf life you declare.
  7. Confirm each product’s label matches its approved artwork version.
  8. Review the complaint register for anything unclosed.
  9. Review any out-of-specification results for missing investigations.
  10. Run a mock traceability exercise and fix what it cannot find.
  11. Confirm one named person can speak to each record category.
  12. Keep the records in one place rather than across several people’s files.

During the Inspection

Conduct matters.

Answer Accurately

Including when the answer is that something is not in place. An inaccurate answer that records contradict is worse than an acknowledged gap.

Do Not Guess

If you do not know, say you will find out and then find out. Speculation that turns out wrong becomes a separate problem.

Produce What Is Asked

Rather than volunteering explanations around it. The records speak for themselves.

Take Your Own Notes

Record what was asked, what was produced and what was said. You will need this afterwards.

Have one person designated to accompany the inspection and one person responsible for retrieving records. Multiple people answering the same question differently creates an impression of disorganisation even where the records are sound.

Afterwards

The response matters as much as the inspection.

Record every observation made, in writing, as precisely as you can. Where a written report is provided, keep it with your own notes.

Take professional advice on each observation: what it means, what response is appropriate and within what timeframe.

Respond in writing where a response is required or appropriate, setting out what you have done or will do, with dates and named owners.

Then actually do it, and keep the evidence. An observation addressed with documented corrective action demonstrates a system that responds; the same observation recurring at a later inspection demonstrates the opposite.

And treat the observations as information about your system rather than only as a compliance task. An observation usually points at a real weakness, and fixing it properly has value beyond the inspection.

Checklist

Preparation and response.

  1. Audit your records against the categories above.
  2. Confirm all licences and certifications are current and cover what you make.
  3. Index records so any batch is retrievable by number.
  4. Verify retention samples exist, are labelled and stored correctly.
  5. Confirm stability data supports every declared shelf life.
  6. Confirm labels match approved artwork versions.
  7. Close any open complaints and document any out-of-specification investigations.
  8. Run a mock traceability exercise and fix the gaps.
  9. Designate one person to accompany and one to retrieve records.
  10. Answer accurately, including about gaps, and never guess.
  11. Produce what is asked without volunteering explanations.
  12. Keep your own written notes of what was asked and produced.
  13. Record every observation precisely afterwards.
  14. Take professional advice on each observation and the appropriate response.
  15. Respond in writing with actions, dates and named owners.
  16. Complete the actions and retain the evidence.

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Frequently Asked Questions

What does an inspection mainly assess?

Records. The question is whether your documentation demonstrates that a system exists and operates: materials specified and tested, batches made to a record, products released against a specification by someone authorised, and problems investigated.

Is a verbal explanation enough?

No. An explanation of how things work carries little weight if the records do not show it. A modest operation with complete, retrievable records generally fares better than a larger one whose records are scattered.

What does retrievable mean?

Findable within minutes, not merely existing somewhere. Index records so any batch can be retrieved by number, and keep them in one place rather than across several people’s files.

What should I do if I do not know an answer?

Say you will find out, and then find out. Speculation that turns out wrong becomes a separate problem, and an inaccurate answer that your own records contradict is worse than an acknowledged gap.

What matters after the inspection?

Recording every observation precisely, taking professional advice on each one, responding in writing with actions, dates and named owners, and then completing them with evidence retained. An observation recurring at a later inspection is worse than the original.

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