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FDA and EU requirements on data integrity and implementation

Data integrity and its implementation in cGMP records are major requirements from the FDA. The FDA considers these as important requirements to ensure the integrity of data in these records. The FDA’s, as well as the EU’s requirements are set out for ensuring both data integrity and its implementation are set out in 21 CFR Part 11 and Annex 11 respectively.

Data integrity is part of FDA 21 CFR Part 11, which essentially deals with the veracity of electronic records and electronic signatures. It applies to records designated or set forth in Parts 210, 211 and 212 of FDA regulations. The FDA’s 21 CFR Part 11 has its counterpart in Eudralex Annex 11, which also has more or less the same intention, but varies in some ways. Both the FDA’s 21 CFR Part 11 and Annex 11 are required for medicines that are introduced into the US and European markets. Annex 11 is basically about the implementation part of cGMP records.

What is data integrity?

First, a small understanding of data integrity: The FDA defines data integrity as a state in which the data is complete, consistent and accurate. The FDA uses the acronym ALCOA to describe this quality of data: Attributable, Legible, Contemporaneously recorded, Original or a true copy, and Accurate.  The requirements set out by the FDA on data integrity are applicable to metadata and audit trails as well, as also static and dynamic data. Static data is a physical record of which a paper record is an example. By contrast, dynamic data is the kind of record in which it is possible to make some interaction between the user and the creator.

Part 11 lists out criteria that the FDA considers all these: electronic signatures, handwritten signatures and electronic records that are done on electronic records to be reliable, truthful, and generally the same as paper records and handwritten signatures that are done on paper.

Get to understand 21 CFR Part 11 and Annex 11 better

The ways of actually ensuring and implementing data integrity as set out in both FDA 21 CFR Part 11 and Annex 11 of the Eudralex will be the learning a two-day seminar from GlobalCompliancePanel, a leading provider of professional trainings in the areas of regulatory compliance, will be imparting.

At this seminar, Angela Bazigos, CEO of Touchstone Technologies Silicon Valley, and a senior Regulatory Affairs professional who carries four decades of experience in regulatory affairs, will be the Director. To enroll for this highly enriching learning session on FDA 21 CFR Part 11 and Annex 11, please register for this session by visiting . This seminar has been pre-approved by RAPS as eligible for up to 12 credits towards a participant's RAC recertification upon full completion.

Explaining the history of these regulations

Angela will start this seminar with an explanation of how 21 CFR Part 11 and Annex 11 evolved, which will set the background to these laws. She will explain why these two regulations are now being talked about all over again. Offering an overview and key requirements of Part 11 & Annex 11, Angela will describe how to use a Risk Based Assessment to reduce work while still achieving Data Integrity and Compliance. She will then also illustrate how the FDA & other regulatory authorities inspect computerized systems for data integrity.

During the course of this seminar, the Director will cover the following areas:

o  What is Data Integrity and how is it implemented

o  How to use Risk Based Assessments to reduce work while still achieving Data Integrity and Compliance?

o  Data Integrity Frequently Asked Questions

o  Validation Master Plan

o  Risk Based Assessment

o  Complete Validation for a System (software development lifecycle)

o  Automated Test Tools

o  Infrastructure Requirements

o  Change Control

o  SOPs.

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