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.
| Document | Main purpose |
| Site Master File | Overview of the entire manufacturing site and its GMP systems |
| Site plan | Shows factory location, boundaries, surrounding areas and access |
| Plant layout | Shows manufacturing rooms, warehouses, laboratory and utilities |
| Personnel-flow diagram | Shows employee entry and movement |
| Material-flow diagram | Shows movement of raw materials, packing materials, products and waste |
| HVAC schematic | Shows air-handling units, filtration, pressure zones and air distribution |
| Water-system diagram | Shows generation, storage, circulation and sampling points |
| Site Master Plan | May refer to a site-development or facility plan; it is not necessarily the same as an SMF |
| Validation Master Plan | Describes the site’s overall qualification and validation programme |
| Quality Manual | Describes the organization’s quality-management principles |
| Product dossier | Contains product-specific formula, process, specifications, stability and regulatory data |
| Device Master File | Contains 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:
| Revision | Effective date | Reason for change | Sections affected |
| 00 | 01 January 2026 | Initial issue | All |
| 01 | 15 April 2026 | New liquid section added | Premises, equipment and production |
| 02 | 01 August 2026 | Water system upgraded | Premises 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:
- General information
- Personnel
- Premises
- Equipment
- Sanitation
- Documentation
- Production
- Quality assurance and control
- Manufacture under loan licence
- Distribution, complaints and product recall
- Self-inspection
- 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.
| Department | Employees |
| Production | 28 |
| Quality assurance | 8 |
| Quality control | 12 |
| Warehouse | 9 |
| Engineering | 6 |
| Distribution | 5 |
| Administration | 7 |
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:
| Position | Qualification | Experience | Main responsibility |
| Head–Production | B.Pharm | 12 years | Production operations |
| Head–Quality Assurance | M.Pharm | 14 years | Quality system and release |
| Head–Quality Control | M.Sc. Chemistry | 10 years | Laboratory controls |
| Engineering Manager | B.Tech | 11 years | Utilities 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.
| Equipment | Identification number | Capacity | Location |
| Rapid mixer granulator | TAB-RMG-01 | 250 litres | Granulation room |
| Fluid-bed dryer | TAB-FBD-01 | 120 kg | Drying room |
| Tablet press | TAB-CMP-02 | 45 station | Compression room |
| Coating machine | TAB-CTG-01 | 48-inch pan | Coating 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:
- Preparation
- Review
- Approval
- Issuance
- Distribution
- Revision
- Withdrawal
- Archiving
- 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:
- Manufacturing licence
- GMP certificate
- WHO-GMP certificate, where granted
- Dosage-form and product list
- Organization chart
- Site location map
- Site plan
- Building layout
- Personnel-flow diagram
- Material-flow diagram
- Waste-flow diagram
- HVAC zoning diagram
- Pressure-differential diagram
- Water-system schematic
- Utility schematic
- Major production-equipment list
- Major laboratory-equipment list
- Contract-manufacturer list
- Contract-laboratory list
- Warehouse layout
- Dosage-form process flow charts
- Export-country and product list
Suggested Table of Contents
A practical SMF index may be:
- Cover page
- Approval page
- Revision history
- Distribution list
- Table of contents
- Abbreviations
- General information
- Personnel
- Premises
- Equipment
- Sanitation
- Documentation
- Production
- Quality assurance and control
- Loan-licence and contract activities
- Distribution, complaints and recall
- Self-inspection
- Export activities
- 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.
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