WorkflowManufacturing & Quality

Batch Record Review by Exception

Batch record review by exception: every page read by agents, only the exceptions for QA

Every executed batch record read page by page, so QA opens only the entries that break a rule, each linked to its page.

See one case, screen by screen ↓
target10.8hmedian review time per record, against about 31 h line by line
target4.2%of pages opened by a person; the rest are read and checked by the agents
demo12of 312pages carry an exception on the hero record — 9 exceptions, 300 pages clean
demo0missesin 298 clean pages spot-checked by reviewers last month
The problem

Why batch record review holds up release

An executed batch record for one batch of tablets runs to 300 pages or more: dispensing, granulation, drying, compression, coating, packaging, the reconciliation. Before the batch can go to disposition, a QA reviewer reads every one of them — every value against its limit, every “Done by” and “Checked by”, every correction, every date and time.

Almost all of those pages are clean. The few problems that matter hide in the gaps between pages: a hold time that only shows when you put the granulation end on page 58 next to the drying start on page 81, a quantity that differs between the step and the reconciliation 246 pages later, an overwrite with no initials. Line-by-line review finds them by reading everything, slowly — and the release date waits.

target31hmedian to review one record line by line
typical3rdmost cited FDA 483 observation at sterile sites in 2024: production record review, 21 CFR 211.192
demo312pagesin one executed paper record of Corventa 20 mg tablets
Where one record’s review hours goestimated
By hand31 days
With the solution10.8 days
  • Reading every page and entry16 → 2.5 d
  • Checking entries against the master record6 → 3.5 d
  • Hold times, step order, yields, reconciliation4 → 1.3 d
  • Writing queries and correction lists3 → 1.5 d
  • Re-checking corrected pages and signing2 → 2 d

Estimated split of the 31 h line-by-line review and the ≈10.8 h target by exception, for one paper record.

How it works

How a batch record moves

Six agents read every page, check every entry and write each exception; the QA reviewer decides and signs.

What comes in
Records inPaper, hybrid or electronic · 200–500 pages per batch
Agents at work
Record intake & page readerprint + handwriting
Then
Entry extractorevery box, cited
Then
Master record comparatorlimits + critical steps
Signature & GDP checkersignatures + corrections
Cross-page reconcilerholds + balances
Then
Exception writercited, with a suggestion
A person decides
QA reviewerdecides each exception, e-signs
What comes out
Exceptions with page links
Documentation error log
Signed review to release
One case, step by step

One batch record, from scan to signed review

CR26-1108 — 312 paper pages for a batch of Corventa 20 mg film-coated tablets made at Plant 2, Westbrook, with a release target of Oct 9. Here is its review, screen by screen, in the working solution.

  1. 01Morning

    From pages to the few that need her

    Dana Okafor · QA batch record reviewer

    Dana opens the review bench for three plants: 2,115 pages read on six records, 34,589 entries checked, 22 exceptions raised, 15 that need her — 2 of them critical. Each record is drawn as one bar per page, with a mark wherever there is an exception.

    “You open 1 page in 85 · Clean pages spot-checked at 2 %”

  2. 0207:40

    A new record arrives, and six agents read it

    Record intake & page reader

    CR26-1109 came in from the Plant 2 scan station: 304 of 304 pages of the issued copy present. The agents read 41 handwritten pages with 0 illegible boxes, extract 4,270 entries, check 188 master-record steps and 14 hold times, and list 4 exceptions — the first a final blend time of 12 minutes against 15 ± 1 min. 300 pages come out clean.

    “Six agents read every page before you open it.”

  3. 03Critical

    A hold time no single page shows

    Cross-page reconciler

    On CR26-1108, granulation ended on Oct 1 at 21:40 (page 58) and drying started on Oct 2 at 23:55 (page 81): the wet granule was held 26 h 15 min. Step 6.4 of master batch record MBR-CRV-020 v7.2 allows 24 hours and calls hold time a critical process parameter. The drying page records “N/A” for a deviation, so none was raised. Both pages sit side by side, with the calculation between them.

    Suggested: raise a deviation — “Dissolution and bioburden impact must be assessed before disposition.”

  4. 04One click

    The deviation, drafted from the record

    Dana Okafor · QA batch record reviewer

    The exception writer has pre-filled DEV-26-0631: batch, title, the evidence on p.58 → p.81 and master record step 6.4, classification “Critical — CPP outside limit”, owner Sam Patel in production with Dana for QA, batch on hold. Dana checks it and raises it; because it is critical, Omar Haddad, the QA operations lead, second-signs.

  5. 05Next exception

    A weighing with no second person

    Signature & GDP checker

    Page 21: the API was weighed at 12.004 kg, inside 12.000 ± 0.010 kg, but the “Checked by” box is empty — and the master record makes this a second-person verification. The suggestion is a production query, not a signature.

    “A check cannot be signed afterwards — if nobody witnessed it, raise a deviation instead.”

  6. 06Across pages

    Quantities and times that disagree

    Cross-page reconciler

    Step 6.3 on page 52 records 41.6 kg of purified water for the binder; the material reconciliation on page 298 shows 46.1 kg used and nothing returned — 4.5 kg apart. Coating spray on page 181 started at 13:10, while compression on page 174 ended at 14:25. Loss on drying of 2.9 % was re-dried to 1.8 % as step 7.6 allows, so Dana accepts that one with a reason.

  7. 07Decided

    One correction list to production

    Dana Okafor · QA batch record reviewer

    Nine exceptions decided: one deviation, one accepted, seven corrections — the missing check, the water quantity, the coating time, an overwritten tablet weight, a blank line clearance field, a yield recorded as 98.4 % that the entries give as 96.1 %, and a late entry not marked. They go to Sam Patel, production supervisor at Westbrook, on one list, due Oct 8 at 16:00.

    “Rescan only the corrected pages — the agents re-read those pages.”

  8. 08Pages back

    Only the corrected pages are read again

    Sam Patel · Production supervisor

    Sam returns 9 rescanned pages. The page reader matches them to the issued copy, the entry extractor reads the 7 corrected entries with the originals still legible, the GDP checker confirms each one is initialled, dated and has a reason, and the reconciler confirms times, quantities and yields are consistent.

  9. 09Before signing

    Proof that clean pages are clean

    Dana Okafor · QA batch record reviewer

    Dana opens a random 2 % sample of the 300 clean pages — 6 pages, every entry already checked by the agents. If she finds something, “I found something” raises it as an exception and logs a miss against the validation, and the validation lead is notified. This time: clean.

  10. 10Signed · Oct 7, 09:45

    The review, signed and sent to disposition

    Dana Okafor · QA batch record reviewer

    The summary reads: 9 decided — 1 deviation, 7 corrected, 1 accepted; 300 clean pages, 6 spot-checked, no misses; DEV-26-0631 open. Dana signs with her password and the meaning “Production record review complete — 21 CFR 211.192”, and the record goes to Dr. Maya Chen, Qualified Person, with the deviation attached.

    “Your name, the time and the meaning are bound to this record and shown on every copy. Agents cannot sign.”

Who it’s for

Built for everyone who touches a batch record.

The same record, seen by the five people who carry it to release — what their week looked like, and what it looks like now.

DO
Dana OkaforQA batch record reviewer
Reviewer
Before
Reads all 312 pages of a record to find the dozen that matter, and lines up times across pages by hand.
Now
Opens the exceptions, each with its page and the rule beside it, decides each one, spot-checks the clean pages and signs.
SP
Sam PatelProduction supervisor, Westbrook
Production
Before
Gets queries one by one, and rescans whole sections to fix a single entry.
Now
Gets one correction list per record, with the page, what to correct and the rule — and rescans only the corrected pages.
OH
Omar HaddadQA operations lead
Approver
Before
Hears about a critical finding late, when the release date is already close.
Now
Second-signs every critical exception after the reviewer’s decision, and can see every plant’s records.
MC
Dr. Maya ChenQualified Person
Disposition
Before
Receives a signed review and has to ask what was found and what is still open.
Now
Reads the signed review and the open deviations raised from it at disposition.
LO
Lena OrtizValidation lead
Rule-set approver
Before
Has to trust review rules without a running measure of how they perform.
Now
Approves each rule-set version, and sees spot-check misses and reviewer agreement measured every month.
Built on the engine

6 agents. Each with one job, and hard limits.

Six agents read every page, check every entry and write each exception; the QA reviewer decides and signs.

Record intake & page reader

Receives scanned, hybrid and eBR records, checks the page count against the issued copy, classifies every page and reads print and handwriting.

  • Never guesses an illegible entry — flags it
  • Read-only on the original scan
  • Page count must match the issued copy
Entry extractor

Turns every box on every page into a typed entry — value, unit, initials, signature, date and time — with page and position, and marks overwrites, strike-throughs, blanks and N/A.

  • Every value cites its page and box
  • Original text kept beside the normalised value
Master record comparator

Checks each entry against the master batch record and specifications — limits, critical process parameters, required steps and checks — and follows the retest and rework paths the master record allows before raising an exception.

  • Cites the master-record step for every exception
  • Critical process parameters always reach a person
Signature & GDP checker

Applies the good documentation practice rules: signatures, second-person checks, corrections, blanks, late entries, date formats, and initials against the signature roster and training records.

  • Quotes the GDP rule section
  • Does not judge product quality — only documentation
Cross-page reconciler

Builds the batch timeline and material balance: hold times between paired steps, step order, every yield and reconciliation recomputed, each quantity compared with every other mention of it.

  • Shows both pages for every cross-page exception
  • Shows the calculation
Exception writer

Merges duplicate findings and writes one plain exception per problem, with page citations, the rule, severity, confidence and a suggested decision — raise a deviation, send a correction, or accept.

  • Suggests only — a named QA reviewer decides
  • No exception without a page citation
QA reviewer

Decides and signs. The agents propose; a named person decides.

Ask in plain words

Ask about any record, in plain words

Ask about any record, exception or rule — or say what to change. Every answer points to its page.

What needs me on CR26-1108?

9 open on CR26-1108 (Corventa 20 mg, 312 pages; 300 clean). First, critical — wet granule held 26 h 15 min, limit 24 h: granulation ended Oct 1 21:40, drying started Oct 2 23:55; step 6.4 makes hold time a CPP. Suggested: raise a deviation. Then the majors, the GDP corrections for Sam Patel, and one check — loss on drying re-dried as step 7.6 allows.

Which records can I sign today?

One now, and one more after a single decision. VL26-0428 came through clean — 478 eBR pages, nothing raised; spot-check 10 pages and sign. VL26-0427 needs one decision: buffer BF-12 used at 74 h against a 72 h expiry.

Flag any value within 5 % of its limit

Done — added as a check-only rule. On the open records it finds 1: tablet hardness 8.3 kP at 07:00 on Oct 3, CR26-1108 p.147, inside 8.0–12.0 kP — the press was adjusted and the next check was 9.6 kP. Saved as rule set v3.2; check-only rules add exceptions and never hide one, and Lena Ortiz signs the validation addendum.

How do I know the clean pages are clean?

Every record gets a random spot-check of 2 % of its clean pages. Last month reviewers opened 298 clean pages and found 0 misses, and reviewers kept the agents’ suggestions 91 % of the time. The one miss this quarter, an unmarked late entry, became a rule in v3.1.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Review benchPages read, entries checked, exceptions raised and what needs the reviewer — every record drawn as one bar per page.
Six agents read the recordPage count, handwriting, entries, master-record steps, GDP rules and hold times, each step shown as it runs.
The record reviewExceptions on the left, both pages of evidence in the middle, the decision and the rule on the right.
Raise a deviationDrafted from the record — batch, evidence, classification, owner and disposition — then checked and raised.
Missing second-person checkA blank “Checked by” on a verified weighing, with the master-record rule beside it.
Cross-page checksA quantity at the step and in the reconciliation, 4.5 kg apart, with both pages shown.
Correction listOne list to the production supervisor: page, what to correct and the rule, with a due date.
Corrected pages re-readOnly the rescanned pages are read again, and each correction is checked against the GDP rules.
Spot-check of clean pagesA random 2 % of clean pages, opened before signing — any miss is raised and logged.
Sign the reviewDecisions, spot-check and open deviations summed up; signed with a password and its meaning.
GDP logEvery documentation error by type and area, so corrections and training go where they matter.
DashboardReview time per record, what the agents raise, exceptions by area and how often reviewers agree.
Review rulesWhat reaches a person, spot-check rate, approvals, correction routing, signature meaning and validation.
Governance

Built for production record review: cited, decided, signed.

Every exception cites its pageEach exception shows the page images with the entry highlighted, the master-record or GDP rule it breaks, and how the agents found it, step by step.
Agents suggest, a reviewer decidesRaise a deviation, send a correction or accept with a reason — a named QA reviewer chooses, and an acceptance needs a reason on the audit trail.
Critical parameters always reach a personSteps with critical process parameters are shown to the reviewer even when every entry is inside its limit, and critical exceptions need a second signature from the QA operations lead.
Clean pages are spot-checkedA random sample of clean pages is opened on every record before signing. A problem found there is raised as an exception and logged as a miss against the validation.
Versioned, approved rulesEvery rule change is a new rule-set version approved by the validation lead before use. Rule set v3.1 was approved against a challenge set of 40 seeded records, with 0 misses.
Signed with its meaningThe reviewer signs with a password; name, time and the meaning of the signature are bound to the record and shown on every copy. Agents cannot sign.
Configuration

Your review rules, not ours

What reaches a person, who signs and who corrects are settings — each change versioned and approved.

SettingDefaultChoose from
Steps with critical process parametersAlways shown to the reviewerOn · Off
Values close to a limitOffOn (raise a “check” within 5 % of a limit) · Off
Late entries not marked “late entry”Raise an exceptionOn · Off
Spot-check of clean pages2 % of clean pages2 · 5 · 10 %
Record types in scopePaper, hybrid, electronicPaper · Hybrid · Electronic
Second signature on critical exceptionsOn — the QA operations lead signs after the reviewer’s decisionOn · Off
Deviation ownerProduction supervisor of the plantProduction supervisor · QA operations lead
Signature meaningProduction record review complete — 21 CFR 211.192Production record review complete — 21 CFR 211.192 · Batch record reviewed — EU GMP Chapter 4
Connections

Works with the records you already keep

Paper and hybrid recordsPDF scans from the plant scan station
eBR exportsentries, e-signatures, alarms and overrides
Master batch recordssteps, limits and critical process parameters
Specifications and hold-time limitsthe values each entry is checked against
GDP rules and signature rosteryour GDP SOP, initials and training status
Your quality systemdeviations raised and linked to the batch
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
10.8h
median review time per record, down 65% on line-by-line review
Line by line31 h
By exception≈ 10.8 h
target
4.2%
of pages opened by a person; clean pages are spot-checked
target
91%
of suggested decisions kept by the reviewer
reviewer agreement

“demo” = seen in the working solution, on its sample plant data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (FDA 483 observations for sterile sites, 2024 — production record review, 21 CFR 211.192, the third most cited). People, companies and products named on this page are fictional — characters and sample data in the working solution.

Questions

What QA teams ask us.

What is batch record review by exception?

Instead of a QA reviewer reading every page of an executed batch record, every page is read and checked first, and the reviewer sees only the entries that break a limit, miss a signature or contradict another page — each linked to its page. Here, six agents do the reading and checking; the QA reviewer decides each exception and signs the review.

Does it work on paper, hybrid and eBR records?

Yes. The same agents read paper scans, hybrid bundles and eBR exports. On eBR records they work through the event log too: alarms acknowledged without a comment, overrides of an eBR check, and e-signatures by people not yet trained on the current procedure.

How does it find problems that span several pages?

The cross-page reconciler builds the batch timeline and material balance from every entry. It computes hold times between paired steps, checks step order, recomputes yields and reconciliations, and compares each quantity with every other mention of it — then shows both pages and the calculation.

Does the AI decide or sign anything?

No. The agents suggest raising a deviation, sending a correction or accepting; a named QA reviewer decides each exception and signs the review. Critical exceptions need a second signature from the QA operations lead, and agents cannot sign.

How do we know the clean pages are really clean?

Every record gets a random spot-check of its clean pages — 2 % by default — before it can be signed. A problem found there is raised as an exception and logged as a miss against the validation, and spot-check misses and reviewer agreement are measured every month.

How are corrections handled?

Corrections go to the plant’s production supervisor on one list, with the page, what to correct and the rule. Production corrects by your GDP SOP and rescans only the corrected pages; the agents re-read those pages and confirm each correction before the reviewer signs.

Can we set our own review rules?

Yes. Which steps always reach a person, near-limit checks, late-entry rules, the spot-check rate, record types in scope, second signatures, deviation owners, who receives corrections and the signature meaning are all settings. Each change is a new rule-set version approved by your validation lead.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your master batch records, specifications, GDP SOP and a sample of executed records — and it goes live once every quality gate has passed. We will walk you through it on your own records first.

See it on
your batch records.

We’ll run Batch Record Review on a sample of your own executed records.