Site Master File for Pharmaceutical Manufacturing Units: Format, Contents and Preparation Guide

A Site Master File, commonly abbreviated as SMF, is one of the most important documents maintained by a pharmaceutical manufacturing facility.

It presents a concise, factual and organized description of:

  • The manufacturing site
  • Products and dosage forms
  • Pharmaceutical quality system
  • Personnel and responsibilities
  • Premises and utilities
  • Major equipment
  • Production operations
  • Quality assurance
  • Quality control
  • Validation
  • Documentation
  • Warehousing and distribution
  • Complaints and recalls
  • Self-inspection
  • Contract and loan-licence activities

The document allows a licensing authority, auditor, customer or technical reviewer to understand how the manufacturing site is organized and how it maintains Good Manufacturing Practices.

Under the revised Schedule M, manufacturers must prepare and maintain an updated Site Master File according to Appendix I.

What Is a Site Master File?

A Site Master File is a controlled document containing specific and factual information about the Good Manufacturing Practices followed at a named manufacturing site.

It provides an overview of:

  • The products manufactured
  • The operations performed
  • The quality systems implemented
  • The people responsible for critical activities
  • The manufacturing and testing facilities
  • The control of materials and products
  • The systems for handling quality failures

The document should describe what actually happens at the site.

It should not contain:

  • Promotional language
  • Unsupported statements
  • Future plans presented as current systems
  • Copied procedures that are not followed
  • Machinery not installed at the premises
  • Employees who do not actually work at the site
  • Products not endorsed on the manufacturing licence

Purpose of a Site Master File

The Site Master File is used for several purposes.

Regulatory Inspection Planning

The licensing authority can review the file before inspection to understand:

  • Site size
  • Dosage forms
  • Critical manufacturing processes
  • Sterile or non-sterile operations
  • High-risk products
  • Utilities
  • Contracted activities
  • Quality-control arrangements

WHO guidance identifies the Site Master File as an important tool for planning and conducting GMP inspections.

Manufacturing-Licence Applications

Depending on the state and product category, an SMF may be requested with:

  • New manufacturing-licence application
  • Licence amendment
  • Addition of a dosage form
  • Addition of a manufacturing section
  • Change of constitution
  • Change of technical staff
  • Expansion of premises
  • GMP certification
  • Export certification

Customer and Contract-Manufacturer Audits

Marketing companies and contract-givers may review the SMF before approving a manufacturer.

Export and International Audits

Foreign regulators and importers may request an SMF when assessing:

  • Manufacturing capability
  • GMP status
  • Product registration
  • Contract manufacturing
  • Export authorization

Internal Management

A properly prepared SMF also helps management understand whether:

  • Responsibilities are clearly defined.
  • All areas appear in the approved layout.
  • Equipment and utilities are qualified.
  • Outsourced activities are controlled.
  • Complaint and recall systems are documented.
  • Regulatory information is current.

Site Master File Is Not a Site Plan

These terms should not be used interchangeably.

DocumentMain purpose
Site Master FileOverview of the entire manufacturing site and its GMP systems
Site planShows factory location, boundaries, surrounding areas and access
Plant layoutShows manufacturing rooms, warehouses, laboratory and utilities
Personnel-flow diagramShows employee entry and movement
Material-flow diagramShows movement of raw materials, packing materials, products and waste
HVAC schematicShows air-handling units, filtration, pressure zones and air distribution
Water-system diagramShows generation, storage, circulation and sampling points
Site Master PlanMay refer to a site-development or facility plan; it is not necessarily the same as an SMF
Validation Master PlanDescribes the site’s overall qualification and validation programme
Quality ManualDescribes the organization’s quality-management principles
Product dossierContains product-specific formula, process, specifications, stability and regulatory data
Device Master FileContains information relating to a particular medical device

The site plan and plant layout are normally included as annexures or referenced drawings within the Site Master File.

Who Should Prepare the Site Master File?

The SMF should be prepared through cooperation between departments such as:

  • Quality assurance
  • Quality control
  • Production
  • Engineering
  • Warehouse
  • Regulatory affairs
  • Human resources
  • Information technology
  • Safety and environment

Quality assurance should ordinarily coordinate the preparation, review, document control and updating of the file.

Approval of the Site Master File

The approval structure may include:

  • Prepared by: Quality Assurance
  • Reviewed by: Production, Quality Control and Engineering
  • Approved by: Head of Quality or authorized senior management
  • Authorized by: Site Head or Technical Director

The approval system should be defined in the company’s document-control procedure.

Document-Control Details

The cover page should include:

  • Company name
  • Manufacturing-site name
  • Complete address
  • Document title
  • Document number
  • Version or revision number
  • Effective date
  • Review date
  • Superseded version
  • Copy number
  • Controlled-copy status
  • Confidentiality classification
  • Preparation, review and approval signatures

Revision History

Maintain a table such as:

RevisionEffective dateReason for changeSections affected
0001 January 2026Initial issueAll
0115 April 2026New liquid section addedPremises, equipment and production
0201 August 2026Water system upgradedPremises and utilities

Do not replace the document without maintaining a traceable revision history.

Recommended Length

WHO guidance recommends that an SMF should generally remain concise—normally not more than approximately 25–30 pages plus annexures, although the actual length depends on the complexity of the site. It should remain current and carry edition, effective and review dates.

A very large file is not necessarily better.

Detailed SOPs, protocols, reports and specifications should normally be referenced rather than reproduced completely.

Recommended Writing Style

The SMF should be:

  • Concise
  • Factual
  • Site-specific
  • Easy to navigate
  • Technically accurate
  • Consistent with licences and layouts
  • Supported by annexures
  • Regularly updated

Use:

  • Short paragraphs
  • Tables
  • Flow diagrams
  • Organization charts
  • Schematics
  • Controlled annexures

Avoid vague statements such as:

  • “All activities are performed according to GMP.”
  • “Best-quality raw materials are used.”
  • “Highly qualified employees are appointed.”
  • “World-class machines are installed.”

Instead, provide factual information.

For example:

Weak statement:
“The company has a modern purified-water system.”

Better statement:
“Purified water is generated through pretreatment, reverse osmosis and electrodeionization, stored in a 2,000-litre stainless-steel tank and circulated through a continuously recirculating loop.”

Complete Site Master File Structure

Appendix I of revised Schedule M organizes the SMF around the following major sections:

  1. General information
  2. Personnel
  3. Premises
  4. Equipment
  5. Sanitation
  6. Documentation
  7. Production
  8. Quality assurance and control
  9. Manufacture under loan licence
  10. Distribution, complaints and product recall
  11. Self-inspection
  12. Export of drugs

1. General Information

1.1 Company and Site Information

Provide:

  • Legal name of the manufacturer
  • Registered-office address
  • Manufacturing-site address
  • Telephone and email
  • Website, where applicable
  • Contact person
  • Emergency contact
  • Geographic coordinates, where useful
  • Brief history of the site
  • Ownership and constitution
  • Relationship with parent or group companies

1.2 Manufacturing Licences

Mention:

  • Manufacturing-licence numbers
  • Licence forms
  • Date of grant
  • Retention status
  • Dosage forms approved
  • Product categories
  • GMP certificate details
  • WHO-GMP or CoPP status, where formally granted
  • Other regulatory approvals

Copies may be placed in annexures.

Do not describe an application under process as an approval already granted.

1.3 Authorized Manufacturing Activities

Describe the manufacturing operations permitted at the site, such as:

  • Tablets
  • Hard-gelatin capsules
  • Oral liquids
  • Dry syrups
  • External preparations
  • Powders
  • Sterile products
  • Biological products
  • APIs
  • Medical devices

1.4 Other Activities at the Site

Identify any other operations, such as:

  • Cosmetics
  • Nutraceuticals
  • Medical devices
  • Research and development
  • Warehousing
  • Secondary packaging
  • Contract testing
  • Export packing

Clearly explain how separate product categories and operations are segregated.

1.5 Products and Process Flow

Provide dosage-form-wise process flow charts.

For example:

Tablet manufacturing

Raw-material receipt
→ Quarantine
→ Sampling
→ Approval
→ Dispensing
→ Sifting
→ Granulation
→ Drying
→ Milling
→ Blending
→ Compression
→ Coating
→ Packing
→ Finished-product testing
→ QA release
→ Distribution

Separate flow charts should be prepared for:

  • Tablets
  • Capsules
  • Liquids
  • Ointments
  • Sterile products
  • Other dosage forms

1.6 Employees

Provide department-wise employee numbers.

DepartmentEmployees
Production28
Quality assurance8
Quality control12
Warehouse9
Engineering6
Distribution5
Administration7

State whether employees work in:

  • General shift
  • Two shifts
  • Three shifts
  • Seasonal operations

1.7 Outsourced Technical Assistance

Identify outsourced activities such as:

  • Specialized testing
  • Microbiological testing
  • Calibration
  • Pest control
  • Equipment servicing
  • Waste disposal
  • Laundry
  • Transportation
  • Stability testing
  • Computer-system support

Include:

  • Service-provider name
  • Address
  • Approval status
  • Scope of activity
  • Qualification or audit process

1.8 Foreign Registrations

Where applicable, identify:

  • Countries where products are registered
  • Foreign inspections
  • Export certifications
  • Products exported
  • Regulatory approvals

1.9 Pharmaceutical Quality System

Provide a concise description of:

  • Quality policy
  • Management responsibility
  • Quality assurance
  • Quality control
  • Product release
  • Deviations
  • CAPA
  • Change control
  • Quality-risk management
  • Product-quality review
  • Management review
  • Knowledge management
  • Continual improvement

The revised Schedule M SMF framework specifically includes the pharmaceutical quality system and quality-risk-management approach.

1.10 Quality-Risk Management

Describe:

  • Risk-management policy
  • Risk-assessment tools
  • Responsible committee
  • Risk-review procedure
  • Risk register
  • Application to changes, deviations and validation

Possible tools include:

  • Failure Mode and Effects Analysis
  • Risk ranking
  • Hazard analysis
  • Fishbone analysis
  • Preliminary hazard assessment

2. Personnel

2.1 Organization Chart

Attach an organization chart showing:

  • Site Head
  • Production Head
  • Quality Assurance Head
  • Quality Control Head
  • Engineering Head
  • Warehouse Head
  • Regulatory Affairs
  • Human Resources

The chart should demonstrate independence between production and quality functions.

2.2 Key Personnel

Provide a table containing:

PositionQualificationExperienceMain responsibility
Head–ProductionB.Pharm12 yearsProduction operations
Head–Quality AssuranceM.Pharm14 yearsQuality system and release
Head–Quality ControlM.Sc. Chemistry10 yearsLaboratory controls
Engineering ManagerB.Tech11 yearsUtilities and maintenance

2.3 Responsibilities

Briefly state the responsibilities of:

  • Production Head
  • Quality Assurance Head
  • Quality Control Head
  • Authorized batch-release person
  • Engineering Head
  • Warehouse Head

Detailed job descriptions should be controlled separately.

2.4 Training

Describe:

  • Induction training
  • GMP training
  • Job-specific training
  • SOP training
  • Safety training
  • Data-integrity training
  • Refresher training
  • Training effectiveness
  • Training records

2.5 Employee Health

Describe:

  • Pre-employment medical examination
  • Periodic medical examination
  • Communicable-disease reporting
  • Injury reporting
  • Restrictions for ill employees
  • Occupational-health monitoring

2.6 Personnel Hygiene

Include:

  • Gowning
  • Handwashing
  • Protective clothing
  • Jewellery restrictions
  • Food and drink prohibition
  • Entry restrictions
  • Visitor controls
  • Garment washing
  • Male and female changing arrangements

3. Premises

3.1 Site Plan

Attach a site plan showing:

  • Property boundary
  • Buildings
  • Entry and exit
  • Roads
  • Security
  • Utility areas
  • Waste-storage area
  • Effluent-treatment plant
  • Warehouse
  • Manufacturing building
  • Quality-control laboratory
  • Administrative block
  • Future expansion area

3.2 Manufacturing Layout

Provide floor-wise layouts drawn to an identified scale.

Show:

  • Room names
  • Room numbers
  • Dimensions
  • Doors
  • Airlocks
  • Change rooms
  • Manufacturing equipment
  • Pass boxes
  • Warehouses
  • Wash areas
  • Utility areas
  • Emergency exits

3.3 Personnel Flow

Show:

  • Entry
  • Change sequence
  • Movement into production
  • Movement between cleanliness zones
  • Exit
  • Visitor movement

3.4 Material Flow

Show separate movement of:

  • Raw materials
  • Packing materials
  • In-process materials
  • Finished products
  • Rejected materials
  • Waste
  • Returned products

3.5 Construction Details

Describe:

  • Floors
  • Walls
  • Ceilings
  • Doors
  • Windows
  • Drains
  • Lighting
  • Surface finishes
  • Coving
  • Cleaning suitability

3.6 HVAC System

Provide a concise description of:

  • Air-handling units
  • Areas served
  • Filtration
  • HEPA filters
  • Air changes
  • Temperature
  • Relative humidity
  • Pressure differentials
  • Return-air percentage
  • Fresh-air percentage
  • Dust extraction
  • Monitoring and alarms

For sterile facilities, identify:

  • Clean-room classifications
  • Terminal HEPA filtration
  • Unidirectional airflow
  • Environmental monitoring
  • Pressure cascade

Attach HVAC schematics as annexures.

3.7 Dedicated and Segregated Areas

Identify dedicated arrangements for products such as:

  • Beta-lactams
  • Sex hormones
  • Cytotoxic products
  • Highly sensitizing substances
  • Biological products
  • Highly potent materials
  • Hazardous chemicals

Do not merely state that products are “handled separately.” Explain the physical and procedural controls.

3.8 Water System

Describe:

  • Source water
  • Pretreatment
  • Reverse osmosis
  • Purified-water generation
  • Water-for-injection generation, where applicable
  • Storage tank
  • Distribution loop
  • Material of construction
  • Sanitization
  • Sampling points
  • Monitoring
  • Alert and action limits

Attach:

  • Water-flow schematic
  • Sampling-point diagram
  • User-point list

3.9 Other Utilities

Describe critical utilities such as:

  • Compressed air
  • Nitrogen
  • Clean steam
  • Pure steam
  • Vacuum
  • Chilled water
  • Boiler
  • Power backup
  • Dust extraction
  • Effluent treatment

3.10 Preventive Maintenance

Explain the system for:

  • Building maintenance
  • HVAC maintenance
  • Utility maintenance
  • Work orders
  • Breakdown maintenance
  • Preventive-maintenance schedules
  • Maintenance records
  • Post-maintenance cleaning and release

4. Equipment

4.1 Major Production Equipment

List major equipment department-wise.

EquipmentIdentification numberCapacityLocation
Rapid mixer granulatorTAB-RMG-01250 litresGranulation room
Fluid-bed dryerTAB-FBD-01120 kgDrying room
Tablet pressTAB-CMP-0245 stationCompression room
Coating machineTAB-CTG-0148-inch panCoating room

Detailed equipment lists may be attached as annexures.

4.2 Laboratory Equipment

List major instruments such as:

  • HPLC
  • Gas chromatograph
  • UV-visible spectrophotometer
  • Dissolution apparatus
  • Stability chambers
  • Microbiology equipment
  • TOC analyser
  • Particle counter

4.3 Preventive Maintenance

Describe:

  • Maintenance scheduling
  • Responsible department
  • Status labels
  • Breakdown handling
  • Spare-parts controls
  • Maintenance records
  • QA release after critical maintenance

4.4 Calibration

Explain:

  • Calibration programme
  • Internal and external calibration
  • Calibration frequency
  • Traceability
  • Calibration labels
  • Out-of-calibration investigation
  • Impact assessment
  • Record retention

4.5 Equipment Qualification

Describe the site’s policy for:

  • User-requirement specification
  • Design qualification
  • Installation qualification
  • Operational qualification
  • Performance qualification
  • Requalification

4.6 Computerized Systems

Briefly describe:

  • ERP
  • Laboratory systems
  • Building-management system
  • Environmental-monitoring system
  • Electronic batch records
  • Access control
  • Audit trails
  • Backup
  • Disaster recovery
  • Computerized-system validation

5. Sanitation

Describe written systems for:

  • Cleaning manufacturing rooms
  • Cleaning equipment
  • Cleaning utensils
  • Cleaning warehouses
  • Cleaning laboratories
  • Disinfectant preparation
  • Disinfectant rotation
  • Cleaning verification
  • Pest control
  • Waste removal
  • Laundry
  • Drain cleaning

Provide references to principal SOPs without reproducing every procedure.

Cleaning Status

Explain the status-identification system, such as:

  • Cleaned
  • To be cleaned
  • Under maintenance
  • In use
  • Under qualification
  • Not for use

Cleaning Validation

Provide a concise statement covering:

  • Product selection
  • Worst-case approach
  • Residue limits
  • Sampling method
  • Analytical method
  • Acceptance criteria
  • Revalidation

6. Documentation

Describe the document-management system covering:

  • SOPs
  • Specifications
  • Master formula records
  • Batch manufacturing records
  • Batch packing records
  • Test methods
  • Protocols
  • Reports
  • Logbooks
  • Forms
  • Electronic records

Document Lifecycle

Explain:

  1. Preparation
  2. Review
  3. Approval
  4. Issuance
  5. Distribution
  6. Revision
  7. Withdrawal
  8. Archiving
  9. Destruction
Data Integrity

Briefly describe controls for ensuring records are:

  • Attributable
  • Legible
  • Contemporaneous
  • Original
  • Accurate
  • Complete
  • Consistent
  • Enduring
  • Available

Record Retention

Identify the general retention policy for:

  • Batch records
  • Testing records
  • Training records
  • Validation documents
  • Complaints
  • Recalls
  • Distribution records
  • Electronic data

7. Production

7.1 Production Operations

Provide concise process descriptions and flow charts for each dosage form.

Identify critical stages such as:

  • Dispensing
  • Granulation
  • Drying
  • Blending
  • Compression
  • Coating
  • Filling
  • Sterilization
  • Packaging

7.2 Material Management

Describe the systems for:

  • Receipt
  • Quarantine
  • Sampling
  • Testing
  • Approval
  • Rejection
  • Dispensing
  • Storage
  • Issuance
  • Reconciliation

7.3 Packaging Materials

Explain controls for:

  • Printed materials
  • Labels
  • Foils
  • Cartons
  • Coding components
  • Issuance
  • Reconciliation
  • Destruction

7.4 In-Process Materials

Describe:

  • Identification
  • Status control
  • Hold-time limits
  • Storage
  • Sampling
  • In-process testing

7.5 Finished Products

Explain:

  • Quarantine
  • Sampling
  • Testing
  • Batch review
  • QA release
  • Storage
  • Dispatch

7.6 Rejected Materials

Describe:

  • Identification
  • Segregation
  • Investigation
  • Reprocessing or destruction
  • Authorization
  • Records

7.7 Process Validation

Briefly state the policy covering:

  • Prospective validation
  • Concurrent validation where justified
  • Continued process verification
  • Revalidation
  • Validation batches
  • Acceptance criteria

7.8 Cross-Contamination Control

Explain:

  • Facility segregation
  • Pressure differentials
  • Dust extraction
  • Closed processing
  • Cleaning
  • Gowning
  • Campaign manufacture
  • Material and personnel flow
  • Risk assessment

8. Quality Assurance and Control

The revised Schedule M heading is broader than only “Quality Control.” It should describe both quality assurance and laboratory-control systems.

8.1 Quality Assurance

Describe:

  • Batch-document review
  • Batch release
  • Deviation management
  • CAPA
  • Change control
  • Risk management
  • Product-quality review
  • Validation oversight
  • Supplier qualification
  • Self-inspection
  • Market complaints
  • Recalls

8.2 Change Control

Explain:

  • Change initiation
  • Classification
  • Risk assessment
  • Departmental review
  • Regulatory impact
  • Validation requirement
  • Approval
  • Implementation
  • Effectiveness review
  • Closure

8.3 Deviations

Describe the process for:

  • Recording deviations
  • Immediate correction
  • Investigation
  • Root-cause analysis
  • Product-impact assessment
  • CAPA
  • Quality approval

8.4 Out-of-Specification Results

Explain the general approach to:

  • Laboratory investigation
  • Manufacturing investigation
  • Retesting
  • Resampling
  • Root cause
  • Batch decision
  • Trending

8.5 Product-Quality Review

Describe:

  • Review frequency
  • Products covered
  • Trends assessed
  • Deviations
  • OOS results
  • Complaints
  • Recalls
  • Stability
  • Process capability
  • CAPA
  • Recommendations

8.6 Quality-Control Department

Describe:

  • Laboratory organization
  • Sampling
  • Specifications
  • Analytical methods
  • Reference standards
  • Reagents
  • Instrument calibration
  • Microbiology
  • Stability studies
  • Retention samples

8.7 Batch Release

Explain:

  • Production-record review
  • Packing-record review
  • Laboratory-result review
  • Deviation assessment
  • Yield and reconciliation
  • Label verification
  • Final authorization

9. Manufacture Under Loan Licence and Contracted Activities

Where the site manufactures products for loan licensees or contract-givers, describe:

  • Approval of the customer
  • Technical or quality agreement
  • Product transfer
  • Formula control
  • Material responsibility
  • Manufacturing responsibility
  • Testing responsibility
  • Batch release
  • Complaints
  • Recalls
  • Regulatory communication

Assessment of the Loan Licensee

Explain how compliance is assessed through:

  • Document review
  • Technical agreement
  • Audit
  • Product review
  • Complaint history
  • Change notification
  • Periodic performance evaluation

Where no loan-licence activity exists, write:

“Not applicable to the present manufacturing site.”

Do not leave the section blank.

10. Distribution, Complaints and Product Recall

10.1 Distribution System

Describe:

  • Approved customers
  • Warehouses
  • Dispatch procedures
  • Transporters
  • Temperature-sensitive products
  • Batch traceability
  • Proof of delivery
  • Distribution records

10.2 Product Complaints

Explain:

  • Complaint receipt
  • Registration
  • Classification
  • Sample collection
  • Investigation
  • Batch-record review
  • Trend review
  • Regulatory reporting
  • Customer response
  • CAPA

10.3 Product Recall

Describe:

  • Recall committee
  • Recall classification
  • Decision authority
  • Customer communication
  • Stock blocking
  • Retrieval
  • Quantity reconciliation
  • Effectiveness checks
  • Regulatory notification
  • Final report

10.4 Mock Recall

State:

  • Frequency
  • Scope
  • Traceability target
  • Reconciliation target
  • Report and CAPA

11. Self-Inspection

Describe the internal-audit programme covering:

  • Audit frequency
  • Audit team
  • Auditor independence
  • Audit checklist
  • Observation classification
  • CAPA
  • Follow-up
  • Management review
  • Record retention

State whether external experts are used for:

  • GMP gap assessment
  • Data-integrity audits
  • Sterile-facility assessment
  • Engineering assessment
  • Regulatory readiness

12. Export of Drugs

Provide:

  • List of export countries
  • Exported products
  • Foreign registrations
  • Foreign inspections
  • Export certificates
  • Export complaints
  • Product recalls
  • Regulatory actions

Where the facility does not export, state that the section is not presently applicable.

Recommended Annexures

WHO guidance identifies annexures such as licences, dosage-form lists, organization charts, site layouts, personnel and material flows, water schematics, contract laboratories and major-equipment lists.

A practical annexure list is:

  1. Manufacturing licence
  2. GMP certificate
  3. WHO-GMP certificate, where granted
  4. Dosage-form and product list
  5. Organization chart
  6. Site location map
  7. Site plan
  8. Building layout
  9. Personnel-flow diagram
  10. Material-flow diagram
  11. Waste-flow diagram
  12. HVAC zoning diagram
  13. Pressure-differential diagram
  14. Water-system schematic
  15. Utility schematic
  16. Major production-equipment list
  17. Major laboratory-equipment list
  18. Contract-manufacturer list
  19. Contract-laboratory list
  20. Warehouse layout
  21. Dosage-form process flow charts
  22. Export-country and product list

Suggested Table of Contents

A practical SMF index may be:

  1. Cover page
  2. Approval page
  3. Revision history
  4. Distribution list
  5. Table of contents
  6. Abbreviations
  7. General information
  8. Personnel
  9. Premises
  10. Equipment
  11. Sanitation
  12. Documentation
  13. Production
  14. Quality assurance and control
  15. Loan-licence and contract activities
  16. Distribution, complaints and recall
  17. Self-inspection
  18. Export activities
  19. Annexure list

Sample General-Information Opening

Company and Site

ABC Pharmaceuticals Private Limited operates a pharmaceutical formulation manufacturing facility at [complete address]. The site manufactures non-sterile tablets, hard-gelatin capsules and oral liquids under manufacturing licences [licence numbers] granted by [State Licensing Authority].

The facility consists of a production block, raw- and packing-material warehouse, finished-goods warehouse, quality-control laboratory, utility area, engineering workshop and administrative block.

The site operates under an established pharmaceutical quality system covering material control, production, quality control, batch release, deviation management, change control, CAPA, validation, complaints, recalls and self-inspection.

This sample must be adapted to the actual licensed site.

How to Prepare a Site Master File

Step 1: Collect Regulatory Documents

Collect:

  • Current manufacturing licences
  • Product permissions
  • GMP certificates
  • Export certificates
  • Approved layouts
  • Technical-person approvals

Step 2: Verify the Actual Site

Walk through the facility and verify:

  • Room names
  • Room numbers
  • Installed equipment
  • Utilities
  • Material flow
  • Personnel flow
  • Warehouses
  • Laboratories

Step 3: Collect Departmental Information

Request controlled information from:

  • Production
  • QA
  • QC
  • Engineering
  • Warehouse
  • HR
  • Regulatory affairs
  • Distribution

Step 4: Prepare Current Layouts

Ensure drawings match:

  • Actual walls
  • Doors
  • airlocks
  • Equipment
  • Utilities
  • Approved regulatory layout

Step 5: Draft Concise Sections

Describe the system and refer to:

  • SOP numbers
  • Master plans
  • Qualification documents
  • Annexures

Step 6: Conduct Cross-Functional Review

Verify that statements match:

  • SOPs
  • Licences
  • Layouts
  • Employee records
  • Equipment lists
  • Actual practices

Step 7: Approve Through Document Control

Assign:

  • Document number
  • Version
  • Effective date
  • Review date
  • Controlled-copy status

Step 8: Train Relevant Personnel

Key employees should understand the information stated in the SMF.

Updating the Site Master File

Update the document whenever there is a significant change involving:

  • Manufacturing licence
  • Company constitution
  • Site address
  • New dosage form
  • New production section
  • Major equipment
  • HVAC
  • Water system
  • Warehouse
  • Laboratory
  • Organization chart
  • Key technical personnel
  • Outsourced testing
  • Contract manufacturer
  • Loan licensee
  • Distribution system
  • Recall procedure
  • Export countries

Minor annexure changes may be controlled separately where the document-control procedure permits.

Periodic Review

The company should define a periodic review interval even where no major change has occurred.

A practical review may confirm:

  • Licence validity
  • Current personnel
  • Current products
  • Current equipment
  • Updated layouts
  • Current service providers
  • Export status
  • Accuracy of contact information

WHO guidance requires the file to remain current and to carry effective and review dates.

Common Site Master File Mistakes

Avoid:

  • Treating the SMF as only a factory layout
  • Copying another company’s SMF
  • Showing uninstalled machinery
  • Using an outdated organization chart
  • Mentioning resigned technical staff
  • Omitting outsourced testing
  • Showing proposed systems as operational
  • Using old licence numbers
  • Omitting rejected and returned-goods areas
  • Providing unreadable drawings
  • Describing QA and QC as one uncontrolled function
  • Omitting validation and change control
  • Leaving non-applicable sections blank
  • Using promotional claims
  • Failing to update annexures
  • Maintaining conflicting information in different sections

Inspection Red Flags

Inspectors may question the SMF where:

  • Layouts do not match the facility.
  • Equipment numbers differ from logbooks.
  • Employee details differ from licensing records.
  • Water-system diagrams are incomplete.
  • Contract laboratories are not approved.
  • Flow diagrams show cross-contamination risks.
  • The document claims systems that have no SOP or record.
  • The revision date is old despite major changes.
  • The batch-release authority is unclear.
  • Complaints and recalls have no responsible committee.
  • Computerized systems are mentioned without validation controls.

Applicability to Different Industries

Pharmaceutical Formulations

For pharmaceutical manufacturing units, revised Schedule M requires the SMF to be prepared and maintained according to Appendix I.

Medical-Device Manufacturing

The Medical Devices Rules use a Site or Plant Master File and a separate Device Master File.

The Site or Plant Master File describes the manufacturing site and quality system, while the Device Master File contains information about the individual device, design, manufacturing, risk management, verification and validation.

The two documents should not be combined indiscriminately.

Ayurvedic, Siddha and Unani Units

These facilities operate under the applicable ASU licensing provisions and Schedule T GMP requirements.

Some State Licensing Authorities specifically request a Site Master File or Site Master Plan with the manufacturing application. The exact structure should follow:

  • Schedule T
  • State checklist
  • Approved product categories
  • Actual manufacturing operations

A pharmaceutical Schedule M template should not be copied without adapting it to ASU manufacturing.

Homoeopathic Manufacturing Units

Homoeopathic manufacturing premises are governed by Schedule M-I and applicable state licensing requirements.

A state authority may ask for an SMF or detailed site documentation, but it should reflect:

  • Homoeopathic manufacturing operations
  • Schedule M-I requirements
  • Mother tinctures
  • Potentisation
  • Alcohol storage
  • Homoeopathic quality control

Cosmetic Manufacturing Units

Cosmetic manufacturers apply under the Cosmetics Rules, 2020 and provide a GMP self-certificate in Form COS-7 with the applicable manufacturing or loan-licence application.

The premises must comply with the Seventh Schedule. A State Licensing Authority may request an SMF as supporting documentation, but the pharmaceutical Schedule M Appendix I should not automatically be treated as the statutory cosmetic format.

Nutraceutical and Food-Supplement Units

Food and nutraceutical manufacturing is regulated through FSSAI and FoSCoS.

Licensing documentation commonly includes:

  • Form B
  • Plant blueprint and layout
  • Equipment list
  • Food-category list
  • Water-analysis report
  • Food Safety Management System plan
  • Supporting business and premises documents

A pharmaceutical SMF is not automatically a statutory FSSAI licensing document. A food manufacturer may prepare a similar plant overview for management or customer audits, but it should be aligned with FSSAI’s FSMS and hygiene requirements.

Frequently Asked Questions

1. Is a Site Master File compulsory for pharmaceutical manufacturers?

Yes. Revised Schedule M requires a pharmaceutical manufacturing site to prepare and maintain an updated SMF according to Appendix I.

2. Is the Site Master File the same as the plant layout?

No. The plant layout is an important annexure or component of the SMF.

3. Who should prepare the Site Master File?

Quality assurance should ordinarily coordinate it with input from production, QC, engineering, warehouse, HR and regulatory affairs.

4. How many pages should an SMF contain?

WHO recommends a concise document, generally not exceeding approximately 25–30 pages plus annexures. A more complex site may require additional information.

5. Does every product need a separate SMF?

No. The SMF is site-specific. Product-specific information belongs in product dossiers or master files.

6. Should every machine be described in detail?

Major equipment should be listed. Detailed operating principles, SOPs and qualification records should normally be referenced rather than copied into the SMF.

7. Should SOPs be attached?

Usually not in full. Relevant SOP numbers and titles may be referenced.

8. How often should the SMF be updated?

It should be updated whenever significant site, licence, product, equipment, utility, personnel or quality-system changes occur and reviewed periodically.

9. Is a separate SMF required for every manufacturing address?

Generally, one SMF should cover one named manufacturing site. Separately licensed locations ordinarily require separate site documentation.

10. What should be written where a section does not apply?

Write “Not applicable” and briefly explain why.

11. Is the Validation Master Plan part of the SMF?

The validation policy should be summarized in the SMF, while the complete Validation Master Plan remains a separate controlled document.

12. Is a Device Master File the same as an SMF?

No. The Device Master File is device-specific, while the Site or Plant Master File is facility-specific.

Final Conclusion

A Site Master File should enable a technically qualified reader to understand:

  • What the site is authorized to manufacture
  • How the factory is organized
  • Who controls production and quality
  • How materials and personnel move
  • Which utilities and machines are used
  • How processes are validated
  • How batches are tested and released
  • How complaints and recalls are handled
  • How compliance is internally assessed

The correct preparation sequence is:

Verify licences
→ Verify the actual premises
→ Collect current departmental information
→ Prepare layouts and flow diagrams
→ Draft according to Appendix I
→ Conduct cross-functional review
→ Approve through document control
→ Maintain it under change control

The Site Master File should never be treated as a one-time consultant document prepared only for obtaining a licence.

It should remain a current and accurate representation of the manufacturing site throughout its operational life.

Looking for Ayurvedic Franchise or Distribution Opportunities?

Looking to start an Ayurvedic franchise, become a distributor, or launch your own herbal product range?

Elzac Herbal India offers:

  • Ayurvedic & Herbal Product Range
  • Franchise & Distribution Opportunities
  • Third-Party Manufacturing Services
  • Product Development Support
  • Marketing Guidance
  • PAN India Business Opportunities

Whether you are an entrepreneur, retailer, distributor, or healthcare professional, our team can help you explore the right business opportunity in the growing Ayurvedic sector.

Contact us today to discuss ayurvedic franchise, distribution, or third-party manufacturing opportunities.

Ajay Kamboj

Ajay Kamboj is an entrepreneur and business owners associated with many Ayurvedic and Pharmaceutical start-ups. With years of experience in Ayurvedic product marketing, pharmaceutical distribution, franchise development, and client relationship management, he regularly shares practical business insights based on real-world experiences. His articles focus on business growth, entrepreneurship, customer management, and lessons learned from the healthcare and wellness industry.

Leave a Reply