Which documents can you check?
Anything a quality reviewer reads before signing. SOPs and work instructions, batch manufacturing and packaging records, logbooks, lab notebooks, deviation and OOS investigations, CAPA plans, change controls, validation protocols, audit reports, even your draft response to a Form 483.
A procedure and a record fail in different ways. A procedure fails when two people can follow it differently. A record fails when you cannot tell who did what, when, and whether anything was thrown away. The checker looks for both.
Why does FDA care about the word "periodically"?
Because an investigator will read your SOP back to you and ask how often periodically is. If the answer lives in someone's head, the procedure is incomplete, and FDA writes that up under 21 CFR 211.100(a) for production steps or 211.22(d) for the quality unit's own procedures.
That second section leads the list. In the Atlas Form 483 citation dataset, investigators cited 211.22 at 352 of 774 drug inspections that touched Part 211 between January 2025 and September 2026. These are the words the checker flags, and what to write instead:
| Word or phrase | Why it gets flagged |
|---|---|
| as appropriate | Who decides what is appropriate? State the condition. |
| as needed | Define the trigger that makes it needed. |
| as necessary | Define the trigger that makes it necessary. |
| if necessary | Name the condition, or the step is optional. |
| if required | Say what requires it. |
| where applicable | List where it applies. |
| when applicable | List when it applies. |
| if applicable | List when it applies. |
| periodically | Give a frequency: daily, each batch, every 6 months. |
| regularly | Give a frequency. |
| routinely | Give a frequency. |
| frequently | Give a frequency. |
| occasionally | Give a frequency or a trigger. |
| in a timely manner | Give a deadline, such as 30 calendar days. |
| timely | Give a deadline. |
| promptly | Give a deadline. |
| as soon as possible | Give a deadline. |
| adequate | Give the acceptance criterion that makes it adequate. |
| adequately | Give the acceptance criterion. |
| sufficient | Give the number or limit. |
| appropriate | Name the specific method, form or person. |
| properly | Describe the correct way, step by step. |
| suitable | Name the specification that makes it suitable. |
| reasonable | Give the limit. |
| approximately | Give a range with limits, such as 20 to 25 °C. |
| etc. | An open list cannot be followed or audited. List every item. |
| and/or | Say which: both, either, or one of them. |
| should | Use "must" or "shall" for a requirement; "should" reads as optional. |
| may | Optional wording in a GMP step. Use "must" if it is required. |
| could | Optional wording. State what is required. |
| normally | Say what happens in the abnormal case too. |
| usually | Say what happens when it is not usual. |
| typically | State the requirement, not the habit. |
| generally | State the requirement and its exceptions. |
| where possible | Say what to do when it is not possible. |
| if possible | Say what to do when it is not possible. |
| try to | A GMP step is done or not done. Remove "try to". |
| responsible person | Name the role, such as QA Manager. |
| TBD | An approved document cannot contain open items. |
| to be determined | An approved document cannot contain open items. |
Which sections should a GMP SOP have?
The checker looks for each of these as a heading or a label and tells you which ones it could not find. A short work instruction can skip a few. A controlled SOP without named responsibilities, records or an approval block is an easy audit finding.
| SOP section | Check |
|---|---|
| Purpose or objective | Flagged when no heading or label for it is found. |
| Scope | Flagged when no heading or label for it is found. |
| Responsibilities | Flagged when no heading or label for it is found. |
| Definitions or abbreviations | Flagged when no heading or label for it is found. |
| Procedure | Flagged when no heading or label for it is found. |
| References | Flagged when no heading or label for it is found. |
| Records or documentation | Flagged when no heading or label for it is found. |
| Training | Flagged when no heading or label for it is found. |
| Revision or change history | Flagged when no heading or label for it is found. |
| Approval signatures | Flagged when no heading or label for it is found. |
| Effective date | Flagged when no heading or label for it is found. |
Does my document get uploaded?
No. Your browser does all the work. The text you paste and the file you open stay on your computer, the checker reads them in memory, and closing the tab wipes them. Atlas never receives a word of it.
We also switched off session recording and analytics on the tool itself, so nothing you type reaches a tracking script. You can check this yourself: open the network tab in your browser's developer tools, run a check, and watch nothing leave. Your company's rules on where confidential documents can be opened still apply.