Question 18 of 20 Advanced Scenario
When should you reopen a completed CAPA rather than open a new record?
Short answer
Reopen it when new evidence shows the original conclusion or its actions were wrong or incomplete for the same failure mode. Open a new, linked record when the failure has a genuinely different cause. The goal is a traceable history, so nobody can mistake a failed fix for a fresh problem.
Why
Record choice sounds administrative, but it shapes what the quality system can learn. If every recurrence is opened as a new CAPA, the history scatters, the metric shows many closed CAPAs, and nobody sees that the same problem was fixed three times. Inspectors notice this pattern.
ICH Q10 expects CAPA effectiveness to be evaluated, and EU GMP Chapter 1 says effectiveness should be monitored and assessed. A recurrence of the same failure mode is direct evidence on effectiveness, so it belongs with the record whose effectiveness it disproves. Reopening makes sense when the root cause was wrong, when an action was not implemented or not sustained, or when the effectiveness check was too weak.
A new record makes sense when investigation shows a different mechanism, such as a second source of particles unrelated to the first. Even then, link the records, because two causes producing the same symptom is itself useful knowledge. Some electronic systems cannot reopen a closed record.
In that case, open a new one that explicitly references the old and states that it supersedes its conclusion. The decision should be based on the investigation, not on what makes metrics look better or avoids reopening a closed item before an audit.
A strong answer covers
- Same failure mode with a wrong or incomplete fix means reopen
- Different mechanism means new linked record
- Recurrence is evidence about effectiveness
- Traceable history across records
- Decision driven by investigation, not metrics
Common mistakes
- Opening new records for recurrences to keep closed CAPAs closed.
- Reopening a CAPA for an unrelated failure that only looks similar.
- Leaving related records unlinked so the pattern stays invisible.
The interviewer might ask next
How would you report reopened CAPAs in management review so the metric encourages honesty?