WorkflowManufacturing & Quality

OOS & OOT Investigation

OOS and OOT investigation that starts with the raw data already checked

Every out-of-limit result starts with its raw data already checked

See one case, screen by screen ↓
demo2,914resultsin the last 30 days, each placed inside its specification on one lab bench
demo11checkson the raw data of one assay OOS, each with a verdict and a source — 3 findings
target92%of Phase I lab investigations closed inside five working days
target100%of Phase Ia checks carry a verdict and a source before any hypothesis
In short

What is OOS & OOT Investigation?

Software that takes an out-of-specification or out-of-trend result from the LIMS to a signed conclusion: the Phase I laboratory investigation, any hypothesis testing, Phase II when no lab cause is found, and the report. OOS & OOT Investigation adds seven agents that gather and check the evidence and draft the plan and the report; the QC supervisor decides and QA approves.

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Updated

The problem

Why a Phase I investigation starts late and ends weak

When a QC result falls outside its specification, the evidence for the Phase I laboratory investigation sits in five places: the LIMS, the chromatography data system's run and audit trail, the instrument logbook, the standards and reagent logs, and the training records. The QC supervisor pulls it together by hand — most of a working day — while the lot sits on hold and the preparations count down to the end of their stability.

By then a cause has often been guessed. Hypotheses are written before the raw data is read, and an invalidation rests on a story rather than a documented test event — the kind of weak investigation FDA cites under 21 CFR 211.192. Out-of-trend stability results are found late too, because few labs fit each new result to the trend of earlier lots as it arrives.

typicalNo. 1rank of 21 CFR 211.192, investigation of discrepancies and failures, among Form 483 citations in FDA's FY2020 drug inspections
typical30citationsof 21 CFR 211.192 in FDA's FY2023 inspection-based warning letters, mostly for releasing product despite OOS results
typical3–10working dayscommonly given for Phase I, with closure in about 30 days
Where a Phase I investigation's supervisor hours goestimated
By hand9.5 days
With the solution2.2 days
  • Gathering evidence from the LIMS, CDS, logbooks and training records4.5 → 0.4 d
  • The checklist and the analyst interview2 → 0.9 d
  • Hypotheses and the hypothesis-test plan1 → 0.4 d
  • Writing the report2 → 0.5 d

Estimated: the QC lab's own estimate of supervisor hours per Phase I, by hand and with the agents, as shown on the solution's dashboard.

How it works

How an out-of-limit result moves

Seven agents check the raw data, rank the hypotheses, draft the report and watch the trends; the QC supervisor decides and QA approves.

What comes in
Result inOOS or OOT result · lab system, raw data, logs, methods
Agents at work
Result intake agentrecord + clocks
Then
Raw-data reviewer
Lab-conditions checker
Similar-event finder
Then
Checklist and hypothesis composerchecklist first, then hypotheses
A person decides
QC supervisordecides the plan and the conclusion; QA approves
What comes out
Cited Phase I checklist
Signed investigation report
Trend flags to owners
One case, step by step

One morning in the QC lab, from an OOS result to a signed conclusion

Wednesday, October 7, at the Westbrook and Leiden QC laboratories. A new impurity result lands above its limit at 08:02, and yesterday's Corventa assay OOS is ready for its lab check. Here is what happens next, screen by screen, in the working solution.

  1. 01Wednesday morning

    Every result, inside its specification

    Lena Ortiz · Head of QC laboratories

    Lena's lab bench places all 2,914 reportable results from the last 30 days inside one specification band: out of specification in red, out of trend in amber, closed investigations hollow. Below it run the investigation clocks — 30 days from result to closure, with each Phase I due date marked — and the repeated patterns the trend watcher has found.

    “Hypotheses wait for the raw data. No cause is proposed until every Phase Ia check has a verdict and a source.”

  2. 0208:02

    A new OOS lands, and the raw data is read first

    Result intake agent

    OOS-26-0152 arrives from the LIMS: Corventa 20 mg tablets, lot CV26-0415, related substances — an unspecified impurity at RRT 1.32 at 0.24% against NMT 0.20%, on HPLC-09, analyst Marco Ruiz. Lena clicks the red dot. The Phase Ia lab check opens on the chromatogram, the sample against the diluent blank, and the agents check the raw data: the diluent blank shows a 0.09% peak at RRT 1.31, and the diluent was made from a new methanol lot on its first use.

    “Now the hypotheses. 2 ranked from the 2 findings — most likely: diluent contamination from the new methanol lot (71 %).”

  3. 03The queue

    Every open investigation, its phase, its clock and its next step

    Lena Ortiz · Head of QC laboratories

    Seven investigations are open. OOS-26-0152 has its checklist ready and the plan to send to QA. The Talmirex dissolution OOS — a Stage 3 average of 79.8% against Q — has plan HTP-0149-1 with Omar Haddad for approval. The Veltrimab SEC result, HMW 2.4% against NMT 2.0%, is in Phase II with Jonas Weber in Leiden, and two out-of-trend stability results sit with Dr. Maya Chen.

  4. 04Yesterday's OOS

    A Corventa assay at 93.1% — five agents read ten records

    The agents

    OOS-26-0147: lot CV26-0412 assayed at 93.1% against 95.0–105.0% on HPLC-07, analyst Sam Patel. Lena runs the lab check. The raw-data reviewer reads run CV-ASY-1007 and its 64 audit trail entries, the lab-conditions checker reads HPLC-07, the standards and the training records, and the similar-event finder finds 4 pump events on HPLC-07 since June and no earlier assay OOS in 312 results.

    Every step is shown as it runs, with what it found — read-only on the LIMS and CDS.

  5. 05The checklist

    Eleven checks on the raw data, each with its source

    Checklist and hypothesis composer

    The supervisor's seven steps from the FDA OOS guidance, filled in: 11 checks, 8 pass, 3 findings. Sam Patel was trained on TM-CV-021 v6, the processing method was locked with no manual integration, and the calculation re-performs to 93.04% and 93.18%. The findings: the bracketing standard, the pump events in the audit trail, and a check-valve service due Sep 30 that was not done. Lena accepts the verdicts one by one or all at once, and each acceptance is recorded in the audit trail.

  6. 06Raw data

    The bracket that failed and the pump that rippled

    Raw-data reviewer

    The bracketing standard after the Corventa preparations recovered 97.1%; the method needs 98.0–102.0% and says bracketed samples are not valid. The CDS audit trail shows pump A pressure ripple of 4.2% at 10:41 (injection 12) and 3.8% at 10:47 (injection 14), against an alert at 2.0%. Each finding opens the record at the cited line.

  7. 07Only then

    Four hypotheses, ranked by the evidence

    Checklist and hypothesis composer

    A transient pump malfunction on HPLC-07 leads at 86%, with the ripple alarms, the failing bracket and the overdue service as evidence for, and none against. A sample preparation or dilution error is 8% — weights and dilutions recalculate exactly and the two preparations agree at 93.0% and 93.2%. A reference standard error is 4%, and a true product result 2%.

    The composer never proposes a cause before every check has a verdict, and never proposes averaging, unplanned retests or outlier tests for a chemical assay.

  8. 08Plan approved

    QA approves the test before anyone runs it

    Omar Haddad · QA lab oversight

    Plan HTP-0147-1 re-injects the retained preparations 1 and 2 on HPLC-04 with fresh bracketing standards, two injections each. Lena sends it to Omar, who approves it with his e-signature. The brackets pass on HPLC-04; preparation 1 gives 99.4% and preparation 2 gives 99.7%, agreeing within 0.3% against a criterion of 2.0%.

    “Re-injection results are investigational: they are never reported and never averaged with the original 93.1 %.”

  9. 09Signed

    She proposes the invalidation; QA approves it

    Lena Ortiz and Omar Haddad

    The justification is drafted from the evidence and Lena edits it freely. She signs “Invalidate — assignable laboratory cause (instrument)” with the meaning “proposed as QC supervisor”, and Omar Haddad approves for QA. The 93.1% is not used for the batch: Aisha Bello retests the original sample twice on Oct 8 under QC-SOP-114 §7.2, and those retests decide lot CV26-0412.

    “This decision is yours. The agents propose; you sign with your password, and Omar Haddad approves.”

  10. 10The report

    A cited report, the impact on the run and the CAPA

    Report writer

    The report writer drafts the laboratory investigation report on form QC-FRM-114-2 in six sections, every statement with its citation. It names the other results the failing bracket touches — injections 15–17, lots CV26-0409 and CV26-0410, marked for re-injection — and proposes the CAPA: service the pump A check-valves before next use and shorten the service interval from 120 to 60 days on all quaternary pumps.

Who it’s for

Built for everyone who owns an out-of-limit result.

The same investigation, seen by the four people who carry it — what their week looked like, and what it looks like now.

LO
Lena OrtizHead of QC laboratories · Westbrook and Leiden
Head of QC laboratories
Before
Owns every open OOS and OOT, and pulls the run, the audit trail and the logbooks by hand before she can judge a cause: “Show me the run before you tell me the cause.”
Now
Opens every out-of-limit result with the raw data already checked and cited; accepts the verdicts, sends the plan and signs the conclusion.
OH
Omar HaddadQA lab oversight · approves plans and invalidations
QA lab oversight
Before
“An invalidated result needs a cause I can defend to an inspector.”
Now
Approves each hypothesis-test plan before any testing and each invalidation with the evidence, the test result and the justification on one record.
MC
Dr. Maya ChenStability lead · confirms or closes OOT flags
Stability lead
Before
“I want the trend flag months before the failure.”
Now
Gets the nightly trend watch: each stability result fitted to the trend of earlier lots, out-of-trend flags and repeated patterns, for her to confirm or close.
SP
Sam PatelQC analyst · HPLC
QC analyst
Before
“I noticed the pressure wobble; nobody asked me until day three.”
Now
His account of the run, including the pressure wobble he noticed near 10:45, sits in the checklist next to the audit trail entries that confirm it.
Built on the engine

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

Seven agents check the raw data, rank the hypotheses, draft the report and watch the trends; the QC supervisor decides and QA approves.

Result intake agent

Opens an investigation from each OOS or OOT result in the LIMS — product, lot, test, method, specification, analyst, instrument, run — and starts the clocks.

  • Never edits a LIMS result
  • Never closes or invalidates
  • Reads the specification from the product specification, never from the result
Raw-data reviewer

Reads the chromatography run: system suitability, bracketing standards, integration events, processing-method version and the audit trail in the run window.

  • Never reprocesses or re-integrates data
  • Read-only access to the CDS
  • Cites every statement
Lab-conditions checker

Checks the instrument (calibration, maintenance, events), the standards and reagents (lot, expiry, standardisation) and the analyst (training on the current method version).

  • Never contacts the analyst without the supervisor
  • Cites every statement
Similar-event finder

Finds earlier OOS, OOT and lab deviations on the same product, method, instrument or analyst, and the result history.

  • Similar is evidence, never a conclusion
Checklist and hypothesis composer

Fills the seven-step Phase I checklist with verdicts and citations, then ranks hypotheses with evidence for and against and drafts the hypothesis-test plan.

  • Never proposes a cause before every check has a verdict
  • Invalidation is a human decision
  • No testing into compliance: no averaging, unplanned retests or outlier tests for chemical assays
Report writer

Drafts the Phase I or Phase II report section by section with citations, the CAPA proposal and the impact on other results in the run.

  • Draft only — a person signs
  • Cites every statement
Trend watcher

Every night fits the stability results to the trend of earlier lots and flags out-of-trend results; finds repeated patterns and pushes them to the team that owns the cause.

  • Flags only — the stability lead decides
  • Never closes an OOT
QC supervisor

Decides; QA approves. The agents propose; a named person decides.

Ask in plain words

Ask about any investigation, result or trend

Ask about any investigation, result or trend in plain words — or tell it what to change. Every answer points to its record.

What happened on OOS-26-0147?

Corventa 20 mg lot CV26-0412 assayed at 93.1% against 95.0–105.0% on HPLC-07. The evidence points at the instrument, not the tablets: pump A pressure ripple of 4.2% at 10:41 and 3.8% at 10:47, a bracketing standard right after the samples at 97.1% where the method needs 98.0–102.0%, and a check-valve service due Sep 30 that was not done. Calculations, standards and Sam Patel's training are all fine.

Can we average the retests?

No. The original result is never averaged with retests — it hides variability. When a method itself averages replicate injections into one reportable result, that average is one test, and that is allowed. The setting is locked in Settings.

Who can invalidate a result?

Only people. The QC supervisor proposes with an e-signature, and QA lab oversight approves — the agents can draft, never decide. Invalidation needs a documented test event that reasonably caused the result; for OOS-26-0147 that is the pump ripple and the failing bracket.

Which out-of-trend results need the stability team?

Three are open: Corventa impurity B at 12 months, 0.31% against a trend limit of 0.24%; Veltrimab acidic variants at 6 months, 24.8% against 23.9%; and Talmirex assay at 18 months, 96.2% against 96.8%. The Corventa one matters most: it is the only lot made with route B API, and at that slope it would reach 0.50% around 21 months.

Every screen

The working solution, as it ships.

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

The lab benchEvery reportable result inside its specification band — out of specification in red, out of trend in amber — with the Phase Ia lab check beside it.
Phase Ia lab checkA new impurity OOS with its chromatogram against the diluent blank, each raw-data check with its verdict and source, and the hypotheses only after.
InvestigationsEvery OOS and OOT with its result against specification, phase, owner, clock and next step.
Agents at workThe evidence the agents read, who does what, and each step as it runs with what it found.
Phase I laboratory checklistThe supervisor's seven steps from the FDA OOS guidance, 11 checks with verdicts and citations, each to accept.
Raw dataBracketing standard recoveries against the method limit and pump pressure ripple read from the CDS audit trail.
Ranked hypothesesEach hypothesis with its likelihood, the evidence for and against, and how it would be tested.
Hypothesis-test plan and resultThe plan QA approved, the criterion, and the re-injection results on a second instrument.
Signed conclusionThe supervisor's proposal and QA's approval with the meaning of each signature, the justification and the retest ordered.
The investigation reportA laboratory investigation report in six sections, every statement with its citation.
Stability trendsStability results against the trend of earlier lots with a 95% prediction interval, the nightly trend watch and repeated patterns to push.
DashboardInvestigations opened and closed, how they ended, causes found, where results fall out by lab and test, and ageing.
Your rulesClocks, approvers, locked FDA testing rules, alerts, lab rules, the out-of-trend method, people and connected systems.
Governance

Built for inspection: cited, approved, signed.

Every verdict cites its recordEach check, finding and hypothesis cites the record it comes from — the CDS audit trail, the injection sequence, the instrument log, the training record — and opens at the cited passage.
Hypotheses wait for the raw dataNo cause is proposed until every Phase Ia check has a verdict and a source. The supervisor accepts each verdict, and every acceptance is recorded in the audit trail.
QA approves the test before it runsEvery hypothesis-test plan names what is tested, why and the criterion, and is approved by QA before any investigational testing. Re-injection results are never reported.
Only people invalidate a resultThe QC supervisor proposes the conclusion and QA approves it, each with an e-signature that records the meaning, the signer and the time.
No testing into complianceRetests are fixed before testing and done by a second analyst; they are never averaged with the original result, and outlier tests are not used to invalidate a chemical assay. These settings are locked.
Read-only agents, versioned rulesThe agents have read-only access to the LIMS, the CDS and every other connected system. Every change to a setting or lab rule is versioned and recorded in the audit trail.
Configuration

Your SOP, not ours

Clocks, approvers, testing rules and the out-of-trend method are settings — every change versioned and recorded in the audit trail.

SettingDefaultChoose from
Phase I due5 working days from the result3 · 5 · 10 working days
Investigation closes within30 calendar days20 · 30 · 45 calendar days; an extension needs QA approval
Hypothesis-test plans approved byOmar HaddadOmar Haddad · Dana Okafor
Retests after an invalidation2 retests, by a second analyst2 · 3 retests, number fixed before testing
Average retests with the original resultNever — hides variabilityLocked
Outlier tests to invalidate a chemical assayNot allowedLocked
Bracketing standard drift alert2.0% from 100%2.0% · 1.5% · 1.0%
Out-of-trend methodRegression control chart, 95% prediction intervalRegression control chart · By time point · Slope control chart; 95% or 99% interval
Connections

Works with the systems a QC lab already runs on

LIMSresults, specifications and sample status
Chromatography data systemruns, chromatograms and audit trails
Instrument logbookcalibration, maintenance and events
Learning systemtraining records against the current method version
QMSdeviations, CAPA and change control
ERPbatch genealogy and materials
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.

estimated
2.2h
of supervisor time per Phase I investigation, down from 9.5 h
By hand9.5 h
With agents≈ 2.2 h
target
92%
of Phase I lab investigations closed inside five working days
Phase I on time
target
100%
of Phase Ia checks carry a verdict and a source before any hypothesis
Raw data checked first

“demo” = seen in the working solution, on its sample laboratory data · “target” = the design goal, measured in the live solution · “estimated” = the lab's own estimate, shown in the working solution · “typical” = published figures (FDA FY2020 drug inspection observations — 21 CFR 211.192 the most cited; FDA FY2023 inspection-based warning letters — 211.192 cited 30 times; Phase I and closure timelines from an industry OOS investigation guide; FDA, Investigating Out-of-Specification Test Results for Pharmaceutical Production, May 2022). People, products, lots and laboratories named on this page are fictional — characters and sample data in the working solution.

Questions

What QC and QA leaders ask us.

What is OOS investigation software?

Software that takes an out-of-specification or out-of-trend result from the LIMS to a signed conclusion: the Phase I laboratory investigation, any hypothesis testing, Phase II when no lab cause is found, and the report. OOS & OOT Investigation adds seven agents that gather and check the evidence and draft the plan and the report; the QC supervisor decides and QA approves.

How does the Phase Ia lab check work?

When a result lands outside its limits, the agents read the chromatography run, its audit trail, the instrument records, the standards and reagents, and the analyst's training, and fill the checklist with a verdict and a citation for each check. Hypotheses stay locked until every check has its verdict and source; only then are they ranked and a hypothesis-test plan drafted.

How does it find out-of-trend stability results?

Every night the trend watcher fits each stability study to the trend of earlier lots and flags results outside the prediction interval — a regression control chart by default, with by-time-point and slope control chart methods and a 95% or 99% interval in Settings. It also finds repeated patterns, such as several pump events on one instrument, and pushes them to the team that owns the cause. The stability lead confirms or closes each flag.

Can the AI invalidate an OOS result?

No. Invalidation is a human decision: the QC supervisor proposes it with an e-signature and QA approves it. A result is invalidated only on a documented test event that reasonably caused it, and the agents never edit a LIMS result or reprocess data.

Does it allow averaging retests or outlier tests?

No. Retests are never averaged with the original result, and outlier tests are not used to invalidate a chemical assay; both rules are locked. Retests after an invalidation are done by a second analyst, with the number fixed before testing.

Which systems does it read?

The LIMS, the chromatography data system, the QMS, the instrument logbook, the learning system and the ERP — all read-only for the agents. Each verdict links to the record and passage it came from.

Do people stay in control?

Yes. The QC supervisor accepts every verdict, sends the plan and signs the conclusion; QA approves every hypothesis-test plan before testing and every invalidation; the stability lead confirms or closes out-of-trend flags. Every step and every change to a rule is recorded in the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your investigation SOP, test methods, specifications and a sample of past investigations — and it goes live once every quality gate has passed. We will walk you through it on your own results first.

See it on
your OOS results.

We'll run OOS & OOT Investigation on a sample of your own past investigations.