Handrails
Pharmaceutical manufacturers

Prove your recall and CAPA. Before the inspector does.

Simulate recalls, deviations and CAPA response under realistic operational conditions.

What if the entire exercise, from scenario to inspection-ready report, took less than 60 minutes? You could run it this week.

Mapped to 21 CFR Part 211 · EU GMP · PIC/S · ICH Q10 · TGA · and more

Report · inspection-ready
Live
Report · 21 CFR 211 · ICH Q10 · TGA PRACReady
Lot quarantineConfirmed across distribution in 22 min
Lot-traceability timePharmacy-level trace took 5h
Regulator notificationsFDA + TGA + EU drafted in parallel
CAPA openedEffectiveness plan named and dated
Public statementApproval path unclear
What's changed

Why now

01

Most recall delays start with coordination, not traceability

Quality, regulatory, manufacturing and supply chain teams often operate well independently, but pressure exposes escalation gaps and slow decision-making between functions.

02

Modern inspections focus on operational execution

Inspectors increasingly probe how recalls, deviations and CAPA processes work in practice, especially under time pressure and cross-functional disruption.

03

Global supply chains have expanded GMP exposure

CDMOs, API suppliers, packaging providers and logistics partners now sit directly inside your quality and compliance perimeter. A single weak process can rapidly become a regulatory event.

Says who

The frameworks behind every FDA inspection, GMP audit and regulatory submission

Every exercise maps to a real clause your regulators, inspectors and auditors are asking about.
Recall & Distribution
Recall ExerciseUS FDA + TGA + EU GMP
Maintain procedures; periodically evaluate

21 CFR 211.150 requires written procedures for distribution and lot-traceability to facilitate recall. In Australia, the TGA Procedure for Recalls, Product Alerts and Product Corrections (PRAC) has replaced URPTG and now governs all sponsor market actions. EU GMP Chapter 8 requires recall arrangements to be periodically evaluated.

If skipped: Form 483; warning letter; consent decree; TGA mandatory recall under Therapeutic Goods Act 1989 s30EA-30ED; commercial loss from delayed execution.
CAPA & Investigations
CAPA ExerciseUS FDA + TGA + EU GMP + ICH
Periodic effectiveness verification

CAPA framed as an investigation-and-effectiveness system. CAPA discipline is the single most-cited Form 483 deficiency. The TGA adopts the PIC/S Guide to GMP for medicinal products by reference, so PIC/S Chapter 1 quality system expectations apply to Australian licensed manufacturers.

If skipped: Form 483; warning letter for systemic failure; TGA GMP Clearance suspension; EMA and PIC/S non-conformance.
Also available

Don't see your framework?

Handrails covers more than recall and CAPA. If your obligation is listed here, or you don't see it at all, let us know.

  • Pharmacovigilance
    Reporting under expedited and periodic clocks. AE clusters and signal detection drive the timing. The TGA requires sponsors to report serious unexpected ADRs within 15 days and to submit Periodic Safety Update Reports on schedule. Primarily relevant for innovators, branded manufacturers and QPPVs.
  • Data Integrity
    Part 11 covers electronic records and signatures. Annex 11 covers computerized systems and data integrity. Relevant when cyber events affect validated systems, data integrity, batch disposition or release decisions.
How it works

From scenario to inspection-ready report, in under 60 minutes.

Weeks of planning. Hours of facilitation. Days more for the report. Handrails compresses the whole thing into under 60 minutes.
1Context in
Context
TypeGeneric + sterile injectable
Frameworks21 CFR 211 · EU GMP · ICH Q10
RegulatorsFDA · EMA · TGA · PIC/S
ManufacturingSite + CDMO
Recall SOPLot trace · distribution
CadenceAnnual + on deviation
TypeGeneric + sterile injectable
Frameworks21 CFR 211 · EU GMP · ICH Q10
RegulatorsFDA · EMA · TGA · PIC/S
ManufacturingSite + CDMO
Recall SOPLot trace · distribution
CadenceAnnual + on deviation
ScenarioSterility failure · parenteral lot
ClocksFDA + TGA + EU competent authorities
RoomQA · RA · Mfg · PV · Supply chain
CAPAEffectiveness verification
CommsWholesalers · pharmacies · public
OutputInspection-ready packet
ScenarioSterility failure · parenteral lot
ClocksFDA + TGA + EU competent authorities
RoomQA · RA · Mfg · PV · Supply chain
CAPAEffectiveness verification
CommsWholesalers · pharmacies · public
OutputInspection-ready packet

Built around your context

Answer a few questions about your setup, including your business type (innovator, generic, biologic, CMO), regulatory regimes, manufacturing footprint and OT / data integrity exposure. The scenario is tuned to the obligations actually in scope, not a generic template. Hours of consultant prep, designed in minutes.

2Virtual session
Live · virtual47:32
Holly, the Handrails AI agent, facilitating a session
Speaking
Holly · Handrails AI
Aarav · QA
Lina · RA
Transcript
Holly

Run it live, virtually

Your team joins a video call. QA, RA, Manufacturing, PV / QPPV, Supply Chain and senior management observers in the same call; each function makes the decisions they'd actually make. The recording is the evidence stream. Scheduling is the only setup.

3Report out
Report · 21 CFR 211 · ICH Q10 · TGA PRACReady
Lot quarantineConfirmed across distribution in 22 min
Lot-traceability timePharmacy-level trace took 5h
Regulator notificationsFDA + TGA + EU drafted in parallel
CAPA openedEffectiveness plan named and dated
Public statementApproval path unclear

The report is ready before you close the call

Results generated in minutes, logged against your internal SOPs and what regulators demand. See areas for improvement and re-run quarterly to show the improvement curve inspectors and senior management now want to see.

Example scenarios

Tailored, not templated

Every scenario is generated from your context, not chosen from a library. Based on your business type, regulatory regimes, manufacturing footprint, even the plans and policies you upload. Three lightweight examples below.
01Scenario

Critical deviation requiring CAPA

Sterility failure on a parenteral lot. Root-cause investigation, batch release decision, FDA notification, TGA PRAC market action assessment, EU competent authority notification, effectiveness verification.

02Scenario

Adverse-event cluster

AE signal in a recently launched product. Pharmacovigilance triage, FDA 15-day expedited reporting clock, TGA pharmacovigilance reporting under the Australian Requirements, periodic safety report implications, cross-region notification.

03Scenario

Counterfeit detection in legitimate supply

Suspect product surfaces in distribution. DSCSA response (US), TGA market action and ARTG-listing review (AU), EU FMD response, supplier qualification review, regulator notification.

Inspection-readiness firms

Your clients are preparing for the inspector. Make sure the exercise evidence is ready too.

Inspection-readiness engagements cover SOPs, training records and deviation history. The one thing most clients arrive without is a dated, named exercise record showing their recall and CAPA processes were tested under pressure. Handrails produces that evidence in a single session, in under 60 minutes, without disrupting the rest of your engagement.

Partner with Handrails

Be the partner that makes inspection prep feel lighter for your clients.

For most pharma consultancies, CDMO advisors and inspection-readiness firms, tabletop exercises are the most time-consuming deliverable in any readiness engagement. Days of scenario prep, hours of facilitation, more hours producing an inspection-ready report. Handrails can now carry that load for you. Stay in the advisory role your clients need you in, run more engagements, and earn on every session.
Revenue share, every cycle
Get paid on every session your clients run.
Inspection-ready evidence
Reports pre-map to 21 CFR Part 211, EU GMP, ICH Q10, EU GVP, TGA PRAC, DSCSA, EU FMD, Part 11 and Annex 11. One scenario set, regulator-specific evidence packs.
Reports written for you
Don't spend hours writing up inspection-ready evidence. Handrails delivers it in minutes, straight from the session.
Already working withPharma consultanciesCDMO advisorsInspection-readiness firms

Run your first pharma exercise this week.

Sign up, pick a scenario, invite the team. The report is ready before the session ends.