When you are auditing you will often find non-conformities. These occur when the department, process or organisation that you are auditing is not following a requirement of the standard that you are auditing against. For many of you who perform audits in the pharmaceutical industry – the standard that you will audit against is GMP. It is important that any non-conformities are linked with the standard that you are auditing against, so non-conformities against GMP must be linked to the relevant clause of GMP.
The following may be useful to you. It lists a number of common basic audit findings and the corresponding clause in EU GMP that is relevant. Readers should note that there is often some repetition in GMP, so I have tried to find the best single clause – but additional clauses may exist. You should also refer to GMP itself to understand fully the context of each clause.
Not following a procedure
4.1/5.2
Absence of a procedure
5.2
Procedure out-of-date
4.5
Not following a schedule, programme or plan
4.1/5.2
Internal audits schedule late
9.1
Untrained personnel
2.10/2.11/5.1/6.1
No GMP training
2.11
No job specific training
2.11
Item not calibrated
3.41
Poor housekeeping/ cleaning
3.1/3.2
Risk of mix-ups and contamination
3.1/3.7/3.8
Unauthorised entry of personnel
3.5/5.16
Poor design of drains
3.11
Poor temperature control
3.3
Doors and windows left open
3.3/3.4
Incorrect crossing out of data
4.9
Not completing records at the time of action
4.8
Area not identified with batch number, product and activity
5.12
Items not labelled
5.12/5.13
Pipework not labelled
3.42
Damage to facility/ equipment
3.3/5.4
Redundant and broken equipment
3.44
Not using pen
4.7
Use of correction fluid
4.9
No organisation chart
2.2
No job description
2.3
No training record
2.9/4.29
Poor control of deviations
5.15
No CAPAs
1.4xiv
No root cause analysis
1.4xiv
Inadequate change control
1.4xii/1.4xiii
Poor control of suppliers
1.4vi/5.27-5.29
There is no mention in GMP of pen colour, the use of ditto marks, post-it notes or having a specific time and date format. However, if an organisation has a policy or procedure on such things – then they must follow their own system. Otherwise this is a non-conformity against 4.1 and 5.2.
Please feel free to comment. For details of our courses in this area select this link: QMS Courses
THIS ARTICLE WAS FIRST PUBLISHED IN 2012 AND MOST RECENTLY UPDATED IN AUGUST 2022.
Related Articles
[jetpack-related-posts]
Find out about our course ranges
GMP Training
QMS Training
GDP/RP Training
GMP Compliance
QP Training
GDP Compliance
Free Taster courses
To try a free taster of our online courses to see if they are of interest visit this page.

