Authority to approve or reject components, in-process materials, labels, and finished dietary supplements
Control framework defining quality requirements — not an Org role or function
• Environmental & facility • Material & component • Sampling & acceptance
• Analytical & measurement system • Process & In-process
• Stability & lifecycle • Disposition & release
• Data integrity & records • Change & continuous improvement
System-level governance framework — not an Org role or function
• Supplier qualification • Approved supplier list
• Material status control (quarantine / released / rejected)
• Records management & data integrity (21 CFR 111 Subpart P • ALCOA+)
QA provides independent quality oversight; QA does NOT execute GMP operations.
Deviation & Quality Event Lifecycle • System Execution • Escalation • Oversight Enablement
Identification, documentation, investigation, and lifecycle oversight of deviations
Formal event classification, assessment, and escalation
Root cause analysis, corrective and preventive actions
Controlled evaluation, approval, and implementation of change
Assess compliance and quality system effectiveness
Ensure personnel are trained, qualified, and competent
Operations execute GMP activities; QA executes the quality system; QMS governs both under independent QU authority.
Authority Model Clarification: The Quality Unit (QU) holds final, non-delegable authority for GMP-related quality decisions and regulatory commitments. That authority is exercised within the governance frameworks of the Quality Management System (QMS) and the Quality Control (QC) framework.
Operational GMP activities are executed by Operations within defined Operational Process Families. The Quality System is administered by Quality Assurance (QA) through Quality System Process Families. Authority, governance, operational execution, and independent oversight are intentionally segregated.