What is review by exception?
It is a way of reviewing the batch record. Everything stays recorded in the record, passed results and deviations alike. But the reviewer no longer reads every line. The MES presents only the items to examine: an out-of-limit value, a failed visual inspection, a data correction, an intervention requiring justification.
What does it change for your reviewers?
They spend less time on records with no issues and more time on the real ones. On one of our projects, review of media preparation records went from three weeks to half a day.
How do you decide what the MES flags?
Through a risk assessment, element by element. For each piece of data in the record, you ask two questions. Where does it come from: manual entry, automatic calculation, a qualified interface? And what happens if it is wrong, for the process and for the patient? Elements at risk stay under review. The others leave systematic review.
Quality assurance approves this assessment. Without its agreement, nothing changes in how records are reviewed. On our project, the assessment covered more than ten thousand MES elements.
What about audit trails?
They matter mostly for what happens outside the batch record. For example, an operator manually changes the cleaning status of a piece of equipment. This action appears in no record, but it may affect the batch. The review strategy must state which actions of this kind are flagged for review, with their author and time.
Who checks what?
Three actors can check a piece of data. The equipment or SCADA, which evaluates its own cycle. The operator, who observes and records a result. The MES, which checks a value or a rule at the relevant step. For each check, you decide which of the three is responsible. Then you configure the master batch record (MBR) with that data, those rules and access to evidence.
Next you organise the review workflow: who assesses, who justifies, who signs, on the production side and on the quality side. And you specify what blocks production immediately, and what can wait for the review.
Finally you test the full path with users, from the equipment result to the reviewer’s decision. And you update the rules whenever the process or the interfaces change.
