Requalification and periodic review
Qualified status is not permanent. Change control, periodic review and monitoring data together decide when a system must be requalified.
Annex 15 requires equipment, facilities, utilities and systems to be evaluated at an appropriate frequency to confirm they remain in a state of control, and requalification to be considered where changes occur. The evaluation should use evidence rather than repeat the original studies by default.
Evidence for periodic review of a storage area
- Continuous monitoring data at the mapped worst-case locations, compared with the mapping baseline.
- Excursion and alarm history.
- Calibration history of monitoring sensors.
- Changes since the last review: racking, HVAC service, door usage, product range.
- Any seasonal extremes not covered by the original mapping.
The review concludes either that the qualified state is maintained, or that targeted re-mapping is needed — and records why.
Frequently asked questions
- Is annual re-mapping mandatory?
- No regulation fixes an interval. A documented risk-based decision, supported by monitoring data, is what is expected.
References
- [1]EudraLex Volume 4, Annex 15: Qualification and Validation (2015)
- [2]ICH Q9(R1): Quality Risk Management
General technical guidance written against the cited sources. It is not regulatory or legal advice and does not replace the applicable standard, guideline or a qualified reviewer's judgement.
Have a question on this topic?
Ask ValiTrac AI and see the evidence and calculation behind the answer.
Ask ValiTrac AIFree calculator: MKT & logger data check
Paste logger readings and get MKT per ICH Q1A(R2) alongside min, max, mean and out-of-limit runs with durations.
Open the calculatorRelated articles
EU GMP Annex 15: the qualification stages explained
Annex 15 describes URS, DQ, FAT/SAT, IQ, OQ and PQ as a sequence that builds evidence a system is fit for its intended use — with requalification when things change.
Seasonal mapping: when one study is not enough
If ambient conditions drive the space, the study must cover the ambient conditions that matter.