1. Document Control

FieldValue
Document IDQC-UTIL-002
TitleWater Quality Classification Specification
Document TypeAuthoritative QC Specification
OwnerQuality Unit (QU)
ApproverQuality Unit (QU)
Effective DateYYYY-MM-DD
Versionv1.2
Change Control ReferenceCC-XXXX

QC-UTIL-002 — Water Quality Classification Specification

Authority Statement: This document is controlled by the Quality Unit (QU). Final product disposition, approval, release, rejection, and quality decision authority remain exclusively with QU and shall not be delegated.

2. Purpose

This specification establishes formal water quality classifications, measurable acceptance criteria, escalation thresholds, and authorization gates governing water used in GMP-relevant operations.

This control mitigates microbial, chemical, and conductivity-related contamination risks that may impact product identity, purity, strength, or composition.

Failure to define and enforce objective water quality controls creates regulatory exposure under 21 CFR Part 111 for sanitation, utilities, and production controls.

3. Regulatory Basis

4. Scope

Applies To: Potable Water (PW), Process Water (PRW), and Purified Water (PUW) systems supplying GMP-designated areas.

Excludes: Municipal source governance beyond facility control. Confirmed impacts to water entering the GMP envelope remain within scope.

5. Definitions

Compliant State: All acceptance criteria satisfied and documented.

Nonconforming State: One or more objective acceptance limits exceeded.

Invalid State: Required monitoring, testing, or documentation missing or incomplete.

Escalation Trigger: Objective condition requiring mandatory QMS process entry.

Stop-Execution Condition: Execution is prohibited when PUW exceedance occurs at a point-of-use serving open product exposure.

6. Acceptance Criteria

Attribute Compliant State Nonconforming State Invalid State Escalation Trigger Required QMS Process Entry QU Authorization Required?
PUW Total Microbial Count ≤ 100 CFU/mL > 100 CFU/mL Test record missing Exceedance at point-of-use during open product exposure Deviation + Quality Defect Yes
PUW TOC ≤ 500 ppb > 500 ppb Test record missing Exceedance during active batch production Deviation + Quality Defect Yes
PUW Conductivity ≤ 1.3 µS/cm at 77°F > 1.3 µS/cm Monitoring record missing Exceedance persisting >1 hour during production Deviation + Quality Defect Yes

7. Decision Logic Matrix

Trigger Condition Execution May Continue? Required Action QMS Process Entry Workflow (W)? QU Authorization (A)? Required Record
Compliant State Yes Continue operation None No No Water Monitoring Log
Nonconforming State Conditional Enter deviation Deviation Yes No Deviation Record
Escalation Trigger No Stop affected use Deviation + Quality Defect Yes Yes Defect Record + QU Authorization
Invalid State No Invalidate record Deviation Yes No Deviation Record

8. Exception Handling

When objective limits are exceeded, Deviation entry is mandatory.

When PUW contamination risk conditions occur, Quality Defect entry is mandatory.

When systemic recurrence thresholds are met, CAPA entry is mandatory.

When system redesign or architecture change occurs, Change Control entry is mandatory.

9. Required Records

10. Authority Classification

E — Execution: Perform monitoring and record results.

W — Workflow Entry: Mandatory QMS workflow initiation when limits are exceeded.

A — Authorization: Quality Unit retains final authority for disposition and system modification decisions.

11. Control State Definitions

Compliant: All criteria satisfied.

Nonconforming: Any objective limit exceeded.

Invalid: Required documentation missing.

Escalation Trigger: PUW contamination risk condition or recurrence threshold met.

Stop-Execution Condition: PUW exceedance at point-of-use during open product exposure.

12. Change Control

Change Control entry is required for modifications to classification, treatment, monitoring parameters, distribution architecture, or limits.

Independent Quality Unit approval is required prior to implementation.

No implementation is permitted without QU authorization.

13. References