Question 19 of 20 Advanced Scenario
What should happen when a qualified supplier later shows adverse quality trends?
Short answer
Qualification is a starting point, not a permanent status. Escalate in proportion to risk: raise the trend with the supplier, increase incoming testing, request an investigation and CAPA, audit for cause, and suspend or disqualify if control is not restored, while protecting supply with risk-based decisions.
Why
ICH Q10 says the company remains responsible for the quality of purchased materials and should monitor supplier performance and implement improvements, not just qualify once. EU GMP Chapter 5 asks for supplier selection, qualification, approval and maintenance, with the supporting evidence documented and the risk of the supply chain considered. US regulation lets a manufacturer accept a supplier's report of analysis instead of full testing only if it runs at least one identity test and validates the supplier's results at appropriate intervals.
A trend undermines that reliance. Suppose an excipient supplier's particle size results creep toward the upper limit over six lots, and your own blend uniformity worsens. The first step is to confirm the trend in your own data, then notify the supplier formally and ask for their investigation.
Meanwhile, go back to full testing of incoming lots rather than relying on the certificate, and assess lots already used. If the supplier cannot explain or correct it, a for-cause audit is justified. Suspension depends on risk and alternatives.
Losing a sole source can harm patients through shortage, which ICH Q9(R1) counts as a quality risk too, so the decision balances product risk against supply risk and is documented. Changing to a new supplier is itself a change needing qualification and possibly regulatory notification.
A strong answer covers
- Qualification maintained through ongoing monitoring
- Confirm the trend and notify the supplier
- Restore full incoming testing and assess used lots
- For-cause audit and escalation up to disqualification
- Balance against supply risk and change control for alternatives
Common mistakes
- Continuing to accept the certificate of analysis after the trend appears.
- Disqualifying a sole supplier instantly without assessing shortage risk.
- Switching suppliers without treating it as a controlled change.
The interviewer might ask next
What evidence would you need before reducing incoming testing back to certificate review for this supplier?