In GxP environments, a change to a process, system, specification or document is assessed for its impact, approved by the right people, implemented in a controlled way, and recorded with the reason. EU GMP Annex 11 includes a clause on change and configuration management for computerized systems, and ICH Q10 describes a change management system as part of a pharmaceutical quality system.
Why it matters for labeling
Every label revision is a change. Without change control, an edit can reach a production file without being reviewed again, or be approved against a version that no longer exists. A good process states what is changing and why, which markets and variants are affected, who has to re-review, and what the released version is.
Common mistakes
- Late changes applied directly to near-final artwork without re-review
- Changes made to one language version or packaging level but not the others
- No recorded reason for a change
- No check that the released file matches the approved change