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CDMO Finding Disposition Register

A plug-and-play log for tracking every finding from a CDMO technical assessment through to closure: field definitions, disposition categories, retention, and a filled sample row, so no open item quietly becomes permanent.

Document typeLog
Topic areaCDMO Governance
LevelIntermediate
UpdatedSeptember 2026
How to use this document

Copy the template below into your quality system. Replace every <<FILL: ...>> placeholder with your company, system, and process specifics, then route it through your own document control, review, and approval. The filled specimen shows one worked example; adapt the numbers and scope to your operation and verify each cited regulation or standard against the current source before you rely on it.

This is a generic, originally worded starting point. It contains no confidential, proprietary, or employer material, it is drafted with AI assistance and reviewed, it is not legal or compliance advice, and adopting it does not by itself create or prove compliance. See the Disclaimer and Terms.

This is a ready-to-use log for tracking every finding a CDMO technical assessment produces, from initial identification through to a documented, closed disposition. It is the working record referenced throughout the technical assessment article: every finding gets a row, every row gets an owner and a date, and nothing is carried forward silently. Replace every <<FILL: ...>> placeholder with your own specifics. A filled sample row and instructions follow.

Document control header

FieldEntry
Document titleCDMO Finding Disposition Register for <<FILL: program / CDMO name>>
Document number<<FILL: e.g. DD-2026-04-REG>>
Version<<FILL>>
Linked assessment<<FILL: reference to the technical due diligence plan and scorecard>>
Register owner<<FILL>>

1. Purpose

This register captures every finding identified during the technical assessment of <<FILL: CDMO name>>, its disposition, its owner, and its closure status, so that no finding is dropped between the assessment record and the technical agreement, and so the same register can be extended into ongoing oversight after the contract is signed.

2. Field definitions

FieldFormatRequiredWho enters itWhen
Finding ID<<FILL: e.g. F-001>>, sequentialYesLead assessorAt identification
Finding descriptionFree text, specific and factualYesAssessor who identified itAt identification
SourceWhich assessment activity surfaced it (e.g. equipment gap table, quality audit, reference call)YesAssessor who identified itAt identification
Scope-critical (Yes/No)Per the decision flow in the technical assessment articleYesLead assessor with the relevant SMEWithin 3 business days of identification
DispositionAccept as is / Accept with interim control / Require remediation before first GMP batchYesLead assessor, confirmed by QA for any red flagBefore the assessment is marked complete
OwnerNamed individual, not a function or teamYesLead assessorAt disposition
Target dateCalendar date, not “before PPQ” aloneYesOwner, confirmed by lead assessorAt disposition
QA risk acceptance (if applicable)Name and date, or N/ARequired for any risk-accepted red flagQuality AssuranceBefore disposition is finalized
StatusOpen / In progress / ClosedYesOwnerUpdated at each review
Closure evidenceReference to the document, record, or data that closes the findingRequired at closureOwnerAt closure
Closure verified byName and dateRequired at closureLead assessor or QAAt closure

3. Instructions

Open a row the moment a finding is identified, even before its disposition is decided; an undated, unowned finding sitting in someone’s notes is the exact failure mode this register exists to prevent. Do not close a row on the owner’s own assertion alone; closure requires a named piece of evidence and a second person verifying it. Review the register’s open items on a fixed cadence, at minimum weekly during active diligence, and carry it forward unchanged into ongoing CDMO oversight after the contract is signed rather than starting a new, disconnected tracker.

4. Retention

Retain this register for the life of the CDMO relationship plus your organization’s standard record retention period after relationship close, consistent with retention for other quality records supporting product disposition and regulatory filings. Do not delete or overwrite closed rows; a closed finding with its evidence trail is itself part of the audit record.

5. Register

Finding IDDescriptionSourceScope-criticalDispositionOwnerTarget dateQA risk acceptanceStatusClosure evidence
<<FILL>><<FILL>><<FILL>><<FILL: Yes/No>><<FILL>><<FILL>><<FILL>><<FILL>><<FILL>><<FILL>>

6. Revision history

VersionDateAuthorSummary of change
<<FILL: 1.0>><<FILL>><<FILL>>Initial issue.

Filled specimen

Sample row from the assessment of a fill-finish CDMO for Acme Therapeutics’ ATX-410 lyophilized biologic.

FieldEntry
Finding IDF-003
DescriptionCDMO’s lyophilizer chamber is roughly three times the scale ATX-410 was characterized on
SourceEquipment gap-assessment table
Scope-criticalYes, shelf-load and heat-transfer profile at full load is unverified at this scale
DispositionRequire remediation before first GMP batch
OwnerCDMO tech transfer lead, jointly with Acme process SME
Target dateBefore PPQ protocol approval, calendar date set at plan approval
QA risk acceptanceN/A, remediation path, not a risk acceptance
StatusClosed
Closure evidenceBridging engineering run report ER-2026-014, showing shelf temperature uniformity at full load within the qualified range

A second row from the same assessment, this one risk-accepted rather than remediated:

FieldEntry
Finding IDF-005
DescriptionPotency reference standard sourced from a single, non-redundant vendor
SourceAnalytical transfer readiness review
Scope-criticalNo, a qualified backup lot already exists on Acme’s side
DispositionAccept as is
OwnerAcme QC
Target dateN/A, documented risk acceptance on file
QA risk acceptanceJ. Alvarez, Acme QA, 2026-08-14
StatusClosed
Closure evidenceRisk acceptance memo RA-2026-021

The two rows show the pattern the register exists to force: the same table structure carries both a remediation and a risk acceptance, with the difference visible in the disposition and QA risk acceptance fields, not buried in prose that a later reader has to reinterpret.

Common inspection findings this register prevents

  • A finding mentioned in a report or a meeting but never entered into a tracked register, so it has no owner, no date, and no visible status.
  • A finding marked closed with no referenced evidence, closed on the owner’s own word alone.
  • A red flag accepted informally in conversation with no documented Quality Assurance risk acceptance on file.
  • A separate, disconnected tracker started for post-signature oversight, breaking the audit trail from the original assessment finding to its eventual resolution.

How to adapt this register

  1. Set your document number and the linked assessment plan reference in the header.
  2. Extend the field list in section 2 only if your quality system genuinely needs another field; do not drop any of the fields shown, each closes a specific gap seen in real diligence records.
  3. Set your review cadence in section 3 to match assessment intensity, at minimum weekly during active diligence.
  4. Set your retention period in section 4 to your organization’s documented retention schedule.
  5. Carry this same register forward into post-signature oversight rather than starting a new one.
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