GMP audit readiness
Gap Report
- Generated
- 12 September 2026
- Facility
- ██████████ (redacted), medicinal cannabis producer
- Target certification
- EU-GMP
Decision-support document. Findings must be reviewed and signed by a qualified person before use.
Overall assessment
Would not pass as it stands. One critical finding on its own would put the qualification of autoclave AC-02 in question, and the two major findings sit in the same area: the OQ is unexecuted where it matters, overdue for repeat, and measured with a reference whose status is unknown. The documentation system itself looks orderly; the gaps are in execution and calibration control, and all of them are closable before an inspection with a few weeks of work.
Findings (5 total: 1 critical, 2 major, 2 other)
Severity follows the EU-GMP inspection deficiency classification: critical, major, other.
OQ acceptance criteria ticked as met while the measurement columns are empty
- Affected
- IQ/OQ protocol, autoclave AC-02, section 7.3, page 14
- Reference
- EU-GMP Annex 15, section 3 (Operational Qualification); Chapter 4 (Documentation)
The temperature-distribution test is marked "complies" but no readings, no probe identifiers and no test time are recorded. An inspector cannot tell whether the test was run, and neither can you. Without data, the OQ is not executed and the equipment is not qualified.
Recommended action. Repeat the test with a calibrated reference, record every reading on the page, and open a deviation for the original blank execution rather than filling the columns in afterwards.
Requalification interval not reconciled; the repeat OQ is overdue
- Affected
- IQ/OQ protocol section 9, page 19; Validation Master Plan rev 3, section 6
- Reference
- EU-GMP Annex 15, section 3.14 (re-qualification) and the site's Validation Master Plan
The manufacturer's protocol states an annual OQ, the site plan states two years, and nothing records which one applies. On either reading the repeat was due by March 2026 and no record is on file.
Recommended action. Record the governing interval in the plan with the rationale, then schedule and execute the repeat OQ. If a repeat exists, upload it and this finding closes.
Reference thermometer used for the OQ has an expired calibration
- Affected
- Calibration certificate TH-117, page 2; IQ/OQ protocol, test instruments table, page 6
- Reference
- EU-GMP Chapter 3, section 3.41 (calibration of measuring equipment); Annex 15, section 3
The certificate shows a calibration date but no next-due date, and the only certificate on file expired on 14 May 2026, before the OQ date. The status of the reference on the day of the test cannot be established, so the measurements it produced are not traceable.
Recommended action. Obtain the current certificate or recalibrate, record the due date on the instrument list, and assess the impact on every test that used this reference.
Template placeholder text left in an approved document
- Affected
- IQ/OQ protocol, section 5.2, page 9
- Reference
- EU-GMP Chapter 4 (Documentation)
Section 5.2 still reads "[insert equipment ID]". The identity is stated correctly on the cover page, so the file can be tied to the unit, but the residue shows the approval review did not read every page.
Recommended action. Correct in the next revision and record the change under document control.
Cleaning SOP cites a superseded procedure number
- Affected
- SOP-CL-004 rev 4, section 2 (references)
- Reference
- EU-GMP Chapter 4 (Documentation)
The reference list points to SOP-EQ-011 rev 2, which was replaced by rev 3 in 2025. The current procedure is in use on the floor; only the cross-reference is stale.
Recommended action. Update the reference at the next revision; no deviation needed.
Open questions
- Was the OQ repeated in 2026? No record was uploaded. If one exists, upload it and the second finding closes.
- Which of the two identical units in room 2 does the calibration certificate TH-117 belong to? The serial on the certificate is not on the instrument list.
Outstanding validation activities
- Performance Qualification for AC-02 is not on file; IQ and OQ exist.
- Deviation for the blank OQ execution to be opened and closed.
Documents reviewed
- IQ/OQ protocol, autoclave AC-02 (14 pages, read visually)
- Calibration certificates 2025 (3 pages, read visually)
- SOP-CL-004 Cleaning of sterile equipment, rev 4 (text)
Documents not reviewed
These uploaded documents were not part of this review. Nothing in this report applies to them.
- Qualification binder, room 2 (126 pages): over the 100-page limit for one review. Review it in parts.
Decision-support document. Findings must be reviewed and signed by a qualified person before use. Page 1 of 3.