Considering that roles of head of quality & regulatory functions are with separate persons.
can head of RA, initiate the change control for modifying/updating a quality procedure. (viz., change control)
my opinioin is Yes, “initiating/triggering quality procedure ( change control or for that matter any procedure” can be done by any one. (especially at head of function role)
the counter opinion is that, change control SOP belongs to QA, hence RA cannot initiatie/review the change control initiated for modifying the CC-procedure.
your thoughts plz