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Root Cause Analysis of Label Mix-Up in Pharmaceutical Industry

RCA of Label Mix-Up in Pharmaceutical Industry

Label mix-ups in pharmaceuticals are serious failures that can result in the wrong medication or dosage reaching patients, putting lives at risk and exposing companies to regulatory penalties, recalls, and long-term reputational damage. Despite tight controls, these incidents still occur—and when they do, they demand more than surface-level fixes. Root causes often span multiple domains and involve a combination of human error, procedural lapses, and systemic breakdowns across manufacturing, packaging, and quality functions.

Such incidents are rarely the result of a single fault. They often involve packaging errors like incorrect label application or operators selecting the wrong label roll. Label design flaws—such as similar-looking layouts, lack of color differentiation, or poor template control—can make it easy to confuse products. Material handling missteps, including improper segregation of labels, multiple label types in one area, or incorrect label issuance to the line, contribute further. Training gaps and non-compliance with SOPs, along with equipment issues like labeler malfunctions or the lack of barcode verification, can all play a role. Compounding this are quality oversight misses, such as skipped inspections or failed reconciliation of label counts.

Root Cause Analysis (RCA) is critical to uncovering these contributing factors in a structured, repeatable way. Rather than relying on ad-hoc discussions or unstructured documentation, a disciplined RCA approach allows teams to systematically explore all potential failure points—across people, process, materials, methods, equipment, and environment. Visual tools like fishbone diagrams are especially effective in this regard, as they enable teams to map interconnected causes clearly and facilitate more productive, cross-functional collaboration.

This is where ProSolvr adds value. As an AI-assisted visual RCA platform, ProSolvr helps teams structure their analysis, organize brainstorming outcomes, and document causes and CAPA plans within a clear, categorized framework. It guides users in building fishbone diagrams aligned with Six Sigma principles and supports consistent RCA practices across investigations. While the root cause insights still come from human expertise, ProSolvr eliminates the friction of manual documentation, reduces ambiguity, and ensures that every investigation is well-organized, audit-ready, and easier to act upon. In critical scenarios like label mix-ups, that clarity makes all the difference.

Label Mix-Up in Pharmaceutical Industry

    • Packaging Process
      • Mixed label rolls on packaging line
        • Labels not segregated by batch
      • Incorrect label applied
        • Operator selected wrong label
    • Label Design & Approval
      • Similar looking labels for different products
        • No differentiation in label color or layout
      • Incorrect label template approved
        • Lack of cross-functional review
    • Material Handling
      • Incorrect label issued to line
        • Line clearance procedure not followed
      • Label stock stored improperly
        • Multiple label types in same location
    • Training & SOP Compliance
      • Failure to follow SOPs
        • No periodic SOP refresher training
      • Inadequate employee training
        • Staff unaware of label verification steps
    • Equipment Issues
      • No barcode verification system
        • Label accuracy not validated in-line
      • Automated labeler malfunction
        • Misfeeds or label jams
    • Quality Oversight
      • Release process failed to catch error
        • No final reconciliation of label count
      • Inadequate line clearance checks
        • Visual inspection steps skipped

Suggested Actions Checklist

Here are some corrective actions, preventive actions and investigative actions that organizations may find useful:

    • Packaging Process
      • Mixed label rolls on packaging line
        • Corrective Actions:
          • Remove and segregate all mixed label rolls from the line immediately.
        • Preventive Actions:
          • Implement color-coded bins and dedicated storage for different label rolls.
        • Investigative Actions:
          • Review recent batch history to determine how and when rolls were mixed.
      • Incorrect label applied
        • Corrective Actions:
          • Quarantine affected products and initiate relabeling or destruction.
        • Preventive Actions:
          • Introduce a second-level verification step before label application.
        • Investigative Actions:
          • Analyze incident timing and operator actions through shift reports and CCTV if available.
    • Label Design & Approval
      • Similar looking labels for different products
        • Corrective Actions:
          • Redesign labels for high-risk products to include distinct color and shape markers.
        • Preventive Actions:
          • Mandate unique visual identifiers for all SKUs during design phase.
        • Investigative Actions:
          • Conduct a risk assessment of all existing labels for look-alike potential.
      • Incorrect label template approved
        • Corrective Actions:
          • Withdraw incorrect templates and reissue corrected versions with updated approvals.
        • Preventive Actions:
          • Implement checklist-based template reviews with sign-off from QA and Regulatory.
        • Investigative Actions:
          • Trace back the approval workflow to identify the point of failure.
    • Material Handling
      • Incorrect label issued to line
        • Corrective Actions:
          • Stop line activity and recall all mislabeled units.
        • Preventive Actions:
          • Introduce barcode scanning and verification before issuing labels.
        • Investigative Actions:
          • Review issuance records and check label requisition against production schedule.
      • Label stock stored improperly
        • Corrective Actions:
          • Reorganize label storage to meet GMP standards.
        • Preventive Actions:
          • Implement FIFO and dedicated shelf labeling for each SKU and batch.
        • Investigative Actions:
          • Audit storage area for environmental and organizational compliance.
    • Training & SOP Compliance
      • Failure to follow SOPs
        • Corrective Actions:
          • Conduct retraining for staff involved and perform competency assessments.
        • Preventive Actions:
          • Implement random SOP audits and reinforcement through team briefings.
        • Investigative Actions:
          • Evaluate deviation reports and identify recurring compliance failures.
      • Inadequate employee training
        • Corrective Actions:
          • Enroll employees in targeted training sessions with practical evaluations.
        • Preventive Actions:
          • Revamp onboarding and continuous training modules based on criticality.
        • Investigative Actions:
          • Review employee training histories and correlate with incident involvement.
    • Equipment Issues
      • No barcode verification system
        • Corrective Actions:
          • Manually verify all labels for current batch until system is installed.
        • Preventive Actions:
          • Procure and install an in-line barcode verification scanner.
        • Investigative Actions:
          • Benchmark industry practices and assess justification for lack of verification equipment.
      • Automated labeler malfunction
        • Corrective Actions:
          • Repair or replace malfunctioning components and recalibrate the machine.
        • Preventive Actions:
          • Schedule preventive maintenance and routine validation of equipment.
        • Investigative Actions:
          • Analyze breakdown logs and maintenance history of the labeler.
    • Quality Oversight
      • Release process failed to catch error
        • Corrective Actions:
          • Hold affected batch and conduct 100% label verification.
        • Preventive Actions:
          • Implement dual-layer batch release sign-off with visual inspection steps.
        • Investigative Actions:
          • Review batch release checklists and deviation history for lapses.
      • Inadequate line clearance checks
        • Corrective Actions:
          • Suspend production and perform a full line clearance revalidation.
        • Preventive Actions:
          • Include photographic or QA-verified evidence of line clearance in batch records.
        • Investigative Actions:
          • Interview line managers and review previous batch transition logs.
 

Who can learn from the Label Mix-Up in Pharmaceutical Industry template?

  • Quality Assurance Teams:They can gain insights into how lapses in compliance and procedural checks can lead to critical errors, reinforcing the importance of thorough documentation, auditing, and line clearance protocols.
  • Production and Packaging Personnel: This group can understand how operational discipline, adherence to SOPs, and careful attention during labeling and packing can prevent downstream risks and product recalls.
  • Regulatory and Compliance Officers: They can use the RCA to assess how internal controls align with regulatory expectations and identify areas where preventive systems must be strengthened to avoid non-compliance
  • Training and HR Departments: RCA findings help highlight training gaps and competency issues, guiding the development of more effective onboarding, periodic refresher sessions, and employee skill assessments.
  • Engineering and Equipment Maintenance Teams: They can identify how equipment reliability and system design influence labeling accuracy, motivating the adoption of more robust verification systems and better maintenance schedules.
  • Management and Decision-Makers: Leaders can use the RCA to evaluate organizational culture, resource allocation, and the effectiveness of cross-functional collaboration, enabling more strategic investments in quality systems and continuous improvement.

Why use this template?

Label mix-ups aren’t just procedural errors as they represent serious patient safety risks. Addressing them effectively requires a structured, cross-functional approach to problem-solving. The Label Mix-Up RCA template, built around proven tools like fishbone diagrams and supported by platforms like ProSolvr, brings consistency, speed, and clarity to what is otherwise a complex investigation.

By aligning your RCA with Six Sigma principles and organizing your findings in a visual, collaborative format, ProSolvr helps teams not only resolve the current incident but also build stronger preventive practices. It standardizes the investigative process, encourages thorough root cause identification, and simplifies the documentation of CAPA outcomes.

With ProSolvr by smartQED, pharmaceutical teams can drive more effective resolution and ultimately, safer products.

Curated from community experience and public sources:

  • https://www.freyrsolutions.com/blog/pharmaceutical-labels-and-errors-to-avoid
  • https://pmc.ncbi.nlm.nih.gov/articles/PMC7744299/