10.6 Quality Assurance & Quality Control Programs

Key Takeaways

  • USP <797> Section 18 requires formal, written QA and QC programs that ensure every part of CSP preparation meets the chapter and the law, with the roles, duties and training of QA staff described in the SOPs.

  • The designated person must ensure the program establishes a system of adherence to procedures, prevention and detection of errors and quality problems, evaluation of complaints and adverse events, and appropriate investigations and corrective actions.

  • USP's FAQ lists nine integrated QA components: training, SOPs, documentation, verification, testing, cleaning and safety, containers and labeling and storage, outsourcing (if used), and responsible personnel.

  • Quality control is the set of specific checks and tests (component checks, release inspection, sterility and endotoxin tests, environmental and personnel monitoring, equipment verification); quality assurance is the system that plans, reviews and improves them.

  • Outsourced CSPs are part of the program. A 503B supplier is qualified by its FDA registration, inspection and recall history, product testing and expiration data, and a written quality agreement.

Last updated: September 2026

10.6 Quality Assurance & Quality Control Programs

Every requirement in USP <797> produces data: fingertip plates, pressure logs, visual inspection results, sterility tests, complaints. A quality program turns those data into decisions. The BCSCP outline lists quality control programs (task 3A4) under quality management.

QA versus QC

Quality assurance (QA)Quality control (QC)
FocusThe system: planning, procedures, review, improvementThe checks and tests on products, processes and environment
TimingContinuous, forward-lookingAt defined points (in process, at release, on a schedule)
ExamplesSOP program, training program, trend review, CAPA, supplier qualificationACD accuracy check, visual inspection, sterility test, GFT, surface sampling
Question it answers"Will our process keep producing acceptable CSPs?""Does this CSP, room or person meet specification right now?"

USP <797> Section 18 requirements

  • The facility's QA and QC programs must be formally established and documented in its SOPs. They must make sure that every part of CSP preparation meets USP <797> and the laws of the jurisdiction.
  • The designated person must make sure there are formal, written QA and QC programs that establish a system of:
    1. Adherence to procedures
    2. Prevention and detection of errors and other quality problems
    3. Evaluation of complaints and adverse events
    4. Appropriate investigations and corrective actions
  • The SOPs must describe the roles, duties and training of the people responsible for each part of the QA program.
  • Sections 18.1 to 18.3 add recall of out-of-specification CSPs, complaint handling and adverse event reporting (see 12.2).

USP's FAQ adds that a QA program should include nine integrated components: (1) training, (2) SOPs, (3) documentation, (4) verification, (5) testing, (6) cleaning, disinfecting and safety, (7) containers, packaging, repackaging, labeling and storage, (8) outsourcing, if used, and (9) responsible personnel.

QC activity map

QC activityMinimum frequency or triggerReference
Order and component verification; calculation checksEvery CSPUSP <797> 9.3, 11
Visual inspection, label check, closure integrity checkEvery CSP before release; again before release if not dispensed the same dayUSP <797> 12.1
Sterility testingCategory 2 CSPs that need it for their BUD; every Category 3 batchUSP <797> 12.2
Bacterial endotoxin testingInjectables from nonsterile components when the BUD requires sterility testing; all Category 3 injectables from nonsterile componentsUSP <797> 12.3
Viable air samplingAt least every 6 months (Category 1 and 2); monthly (Category 3)USP <797> 6.2
Surface samplingAt least monthly (Category 1 and 2); weekly plus after each batch (Category 3)USP <797> 6.3
Certification and particle countsAt least every 6 monthsUSP <797> 5
Pressure differentialsContinuous monitoring; documented daily reviewUSP <797> 4.2.5
GFT and media fill3 initial garbing evaluations; every 6 months (Category 1 and 2) or 3 months (Category 3)USP <797> 2.2, 2.3
ACD accuracyBefore first use and each day of useUSP <797> 9.1
Storage temperaturesDaily or continuousUSP <797> 9.3.4, 19.1
Cleaning documentationEach activity, per Table 10USP <797> 7

Quality metrics and trend review

Collecting data is not enough; USP <797> requires regular review for trends, and it requires environmental data to be looked at together with personnel data. A practical quality dashboard reviewed monthly by a quality committee might track:

  • Environmental results by site, with alert and action excursions and the organisms recovered
  • GFT and media-fill pass rates by person and by shift
  • Errors and near misses caught by workflow technology, per 1,000 CSPs
  • Sterility or endotoxin test failures and OOS investigations
  • Complaints, adverse events and recalls
  • Certification findings and pressure excursions
  • On-time completion of SOP reviews and training

Use statistical process control (trend charts) to spot drift before an action level is breached, and feed the findings into CAPA (see 12.1). The plan-do-check-act cycle gives the structure: plan a change, test it, check the data, then standardize or adjust.

Outsourcing oversight

When a facility buys CSPs from a 503B outsourcing facility, those products are still part of its quality program. Qualify the supplier before first purchase and review it periodically:

  • FDA registration as an outsourcing facility, and the products it reports making
  • Inspection history: Forms 483, Warning Letters, recalls and import alerts
  • Quality agreement covering specifications, testing, expiration dating, change notification, complaints and recalls
  • Certificates of analysis or test summaries for each lot, and confirmation that labels meet 503B requirements
  • Receiving checks: shipping temperature, label, lot and expiration, physical inspection
  • Performance data: complaints, delivery problems, shortages

State rules may add their own licensing requirements for out-of-state suppliers.

Common audit findings

  • Monitoring data collected but never reviewed or trended
  • Excursions without a documented investigation or proof that the fix worked
  • QA roles not defined in SOPs, or no deputy for the designated person
  • Outsourced CSPs received with no supplier qualification file
Test Your Knowledge

Under USP <797> Section 18, the designated person must ensure the facility's written QA and QC programs establish a system of which elements?

A

Adherence to procedures; prevention and detection of errors and quality problems; evaluation of complaints and adverse events; and appropriate investigations and corrective actions

B

Only annual certification of the cleanroom

C

Marketing of CSPs to prescribers

D

Pricing and billing accuracy

Test Your Knowledge

Which of these is a quality control activity rather than a quality assurance activity?

A

Writing the facility's training program

B

Qualifying a new 503B supplier and signing a quality agreement

C

Performing the daily gravimetric accuracy check on the automated compounding device

D

Leading the monthly quality committee's trend review

Test Your Knowledge

A hospital plans to start buying premixed syringes from a 503B outsourcing facility. Which step best qualifies the supplier?

A

Choose the lowest-priced supplier and inspect the first delivery

B

Ask the supplier to follow the hospital's USP <797> BUD tables

C

Rely on the supplier's marketing brochure

D

Confirm FDA outsourcing facility registration, review FDA inspection history (Forms 483, Warning Letters, recalls), get a quality agreement covering testing, expiration dating, change notification and recalls, and set receiving checks

Sections you finish are checked off in the contents.