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Form: PAI Objective 1 Risk-Based Scope Triage

A plug-and-play form for triaging which Objective 1 sub-objectives (1a through 1e) an inspection-readiness team should stage for under FDA Compliance Program 7346.832's 2026 revision, with the trigger factors for each and a filled specimen.

Document type: Form

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use triage form for deciding, ahead of a Pre-Approval Inspection, which of the five Objective 1 sub-objectives under FDA Compliance Program 7346.832 (revised 29 June 2026, implemented 10 August 2026) are likely in scope, so the back room stages the right evidence instead of everything. Sub-objectives 1a and 1e are covered on every PAI; 1b, 1c, and 1d are risk-based. Replace every <<FILL: ...>> placeholder. A filled specimen follows. This is educational reference to help a team prepare; it does not predict or control what FDA’s own risk assessment will actually cover, and it is not legal or regulatory advice.

Form control

FieldEntry
Application<<FILL: NDA / BLA / ANDA / supplement number>>
Product and site<<FILL>>
Completed by<<FILL>>
Date<<FILL>>
Anticipated inspection window<<FILL>>

Sub-objective 1a: manufacturing and laboratory readiness (mandatory, every PAI)

Covers capabilities, changes, deviations, and trends relating to development of the drug substance and drug product.

Item to stageOwnerReady (Y/N)
Manufacturing and laboratory capability summary for the commercial process<<FILL>><<FILL>>
Recent change control and deviation trend summary for the product<<FILL>><<FILL>>
SMEs for process development and technical services briefed<<FILL>><<FILL>>

Sub-objective 1b: sampling, testing, and supplier qualification (risk-based)

Trigger presentY/NEvidence
The application assessment identified issues in sampling, testing, or supplier qualification<<FILL>><<FILL>>
A previous inspection or remote regulatory assessment identified issues in this area<<FILL>><<FILL>>

If any trigger is Y, stage: supplier qualification files for critical materials, the sampling plan rationale, and the release-testing SME. If all triggers are N, note the basis for treating 1b as lower priority and revisit if new information emerges before the window.

Sub-objective 1c: facility and equipment controls against contamination (risk-based)

Trigger presentY/NEvidence
Facility has never been inspected<<FILL>><<FILL>>
A new building has been added and not yet inspected<<FILL>><<FILL>>
Equipment is new or not covered on a prior inspection<<FILL>><<FILL>>
Facility has undergone major changes since the last inspection<<FILL>><<FILL>>
Product requires special containment or separation<<FILL>><<FILL>>
Application assessment or prior facility information flagged this area<<FILL>><<FILL>>

If any trigger is Y, stage: facility and equipment qualification packages, the contamination control strategy, and the facilities/engineering SME. If all triggers are N, note the basis and stage a lighter, summary-level packet.

Sub-objective 1d: batch release, change management, and investigations (risk-based)

Trigger presentY/NEvidence
No history of prior coverage of these elements<<FILL>><<FILL>>
The quality system has changed since the last inspection<<FILL>><<FILL>>
Prior facility information flagged deficiencies here<<FILL>><<FILL>>

If any trigger is Y, stage: batch disposition records, change control and CAPA files, complaint and adverse-event handling records, and the Field Alert Report log with the QA disposition SME. If all triggers are N, note the basis for a lighter staging.

Sub-objective 1e: feasibility and justification of the commercial process (mandatory, every PAI, depth varies)

Item to stageOwnerReady (Y/N)
Process validation status and reports for the commercial process<<FILL>><<FILL>>
Scientific justification for processing parameters and control measures in the batch record<<FILL>><<FILL>>
Process validation SME briefed, including any application-assessment issues raised<<FILL>><<FILL>>

Objectives 2 through 4 (covered separately)

Objective 2 (Conformance to Application) and Objective 3 (Data Integrity Audit) are covered on every PAI regardless of the Objective 1 triage above; stage per the PAI readiness checklist. Objective 4 (Commitment to Quality in Pharmaceutical Development) is mandatory on the initial PAI for the product and risk-based afterward; confirm with regulatory affairs which applies before finalizing staging.

Triage summary and sign-off

Sub-objectiveIn scope (Y/N/uncertain)Staging priority
1aY (mandatory)<<FILL>>
1b<<FILL>><<FILL>>
1c<<FILL>><<FILL>>
1d<<FILL>><<FILL>>
1eY (mandatory)<<FILL>>
RoleNameSignatureDate
Inspection readiness lead<<FILL>>
Quality Assurance<<FILL>>

References

FDA Compliance Program 7346.832, Preapproval Inspections, revised 29 June 2026, implemented 10 August 2026, Objective 1 coverage table. For CDER-regulated biologics, Compliance Program 7346.832M, Prelicense and Preapproval Inspections, issued 14 April 2026. FD&C Act sections 501, 704; 21 CFR Parts 210, 211, and, for biologics, Part 600.

Confirm the current version of the compliance program and its coverage criteria against the FDA-published document before relying on this form; FDA revises compliance programs periodically and the specific triggers may change.


Filled specimen

A completed triage for an example supplemental NDA at a site with one prior FDA inspection.

Sub-objectiveIn scopeBasis
1aY, mandatory-
1bNNo issues flagged in the application assessment; prior inspection had no findings in sampling or supplier qualification
1cYNew filling suite installed since the last inspection, never inspected
1dYQuality system changed: new electronic batch record system implemented since the last inspection
1eY, mandatory, moderate depthPPQ complete, no application-assessment issues raised on the process description

This specimen shows the point of the triage: the site correctly deprioritized 1b, where nothing changed and no issue was flagged, and concentrated back room staging on 1c (a genuinely new, never-inspected filling suite) and 1d (a new electronic batch record system, the kind of quality-system change the trigger criteria specifically call out). That is a more efficient use of a short preparation window than treating all five sub-objectives as equally likely.

Common inspection findings this form prevents

  • Back room staging spread evenly across every possible topic, leaving the genuinely likely areas under-prepared relative to the unlikely ones.
  • A new or never-inspected facility element (1c) discovered as a live topic with no qualification package staged and ready.
  • A quality-system change since the last inspection (1d, for example a new electronic system) that no one flagged as a likely inspection focus.
  • Treating remote interactive evaluations or records requests as lower-stakes than an on-site PAI, when the 2026 compliance program gives them equal standing for meeting these same objectives.

How to adapt this form

  1. Set the application, product, and site in the control block.
  2. Work through each trigger table with the people who actually know the site’s inspection history and recent changes, not from memory alone.
  3. Where a trigger is uncertain, mark it uncertain rather than guessing N, and revisit as more information becomes available before the window.
  4. Feed the triage summary directly into back room document staging and SME scheduling.
  5. Confirm the compliance program’s current coverage criteria against the FDA-published document before relying on this form for a real inspection.
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