Mods and Pods in BioPharm

Flexible Manufacturing: Mods and Pods in BioPharm

Early facility design and BioPharm beginnings

Ever since I was a child, I have loved to build.  Like many kids of my generation, I grew up playing with Legos, Tinker Toys and Erector Sets.  These objects would fill my days, providing hours of entertainment.  The best part about these toys was their versatility.  You could build things and disassemble them to make new things over and over again.  Of all the toys, I loved Legos the most.  Perhaps that is why I love the concept of modular manufacturing in BioPharm.

When I started out in BioPharm over 20 years ago, I came in at a time when companies were spending more and more on large facilities.  I was making vaccines in bioreactors and the rooms and buildings to hold them were getting larger and larger.  Older facilities in which I worked were forced to retrofit rooms and entire buildings to fit their process.  Other sites with room and money for expansion built new large manufacturing buildings.  These newer larger facilities focused on large stainless steel bioreactors up to 10-25k liters became the norm for the industry.

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Nearly 10 years later, I was an engineer on a start-up project for a large biotech company that included four levels of process equipment for upstream and downstream processes in a new manufacturing building with additional support buildings and renovations to older buildings at a cost of nearly $1B.  Facilities like these required high initial capital investment and large overhead.   The challenge with this type of design is that these facilities have large capacities but a limited amount of flexibility.  Dramatic increases in product titers and yield coupled with the ever-expanding role and incorporation of single-use systems has offered more flexible approaches to manufacturing and has started a bit of a revolution in so called flexible facilities.  These flexible facilities offer a more flexible approach to manufacturing.

Some flexible options

Many of the new facilities and renovated older facilities now use modular systems.  There are several types of modular systems with a variety of physical configurations:

  • modular room enclosure systems (such as from Daldrop, AES, or Plascore);
  • modular room enclosure systems with utility systems (such as from G-CON Manufacturing or SmartFit Modular);
  • building modules with utility systems (such as from Pharmadule/Morimatsu);
  • or building modules with process systems (such as GE Healthcare Life Sciences’ KUBio FlexFactory platform) (1).

A full module typically is fashioned with its own mechanical, electrical, HVAC ductwork, high-efficiency particulate air filters, and plumbing systems and process equipment is usually already part of the module (2). In addition, closed modular systems are said to reduce required manufacturing area, HVAC requirements, chilled water and steam demands associated with cleaning, construction and start-up times, and potentially, cost of goods (3). Use of modularization is growing because it meets the industry needs for reduced cost, accelerated construction schedules, and quality construction.  Modularization allows parallel paths for construction activities, such as process-piping and equipment construction, in parallel with some of the activities that take place to erect the building shell.

Validation considerations

GSBlog2I am truly intrigued by the impact that these modular facilities will have on validation activities.   Many facilities make use of a pre-existing building shell and have the manufacturing pods/modules delivered to the site.  Units such as the G-CON PODs typically incorporate the mechanical and electrical systems required to operate the POD, including the air handler units, exhaust fans, fire suppression, power and control systems, and waste handling systems.  Utility connection points to the POD are typically located on the external wall of the POD mechanical area, allowing for easy integration with the facility utility systems.

Because much, if not all, of the HVAC and utilities come with the modular units, documentation and validation of these facilities are more simplified and streamlined.  And anyone who has climbed around in dark mezzanine’s between ductwork looking for tags and labels and tracing utilities and piping while holding a flashlight and a validation protocol will welcome such a change.

Real world Legos…

GSBlog3Facility design requirements in Biopharm are changing, and modular facilities are becoming a reality.  In the near future, facilities will be able to change their facility design to meet changing business needs as easily as a child can disassemble a Lego structure and build a new one.  As more companies offer modular manufacturing, the more we will see things standardized across the industry.  And industry standardization typically means better guidance, clarity of regulations, and ease of validation.

 

Written By: Greg Steele, Senior Consultant

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  1. Hernandez, “Modular Manufacturing Platforms for Biologics,” BioPharm International 28 (5) 2015.
  2. Gilroy  and G. Martini, Pharmaceut. Proc. 27, pp. 22-23 (2012).
  3. L. Nelson, “Approaches for Flexible Manufacturing Facilities in Vaccine Production” supplement to BioPharm Internat. 24, pp. s22-28 (2011).

 

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Temperature Controlled Systems: Refrigerators and Freezers

Have you ever completed the temperature mapping / qualification testing for a walk-in refrigerator or freezer and felt good about the data? That is until someone asked you to relate what the numbers mean in relation to the system and what was happening inside the unit. You knew the results met the acceptance criteria, but maybe weren’t so sure how they related to system performance.

Cooling and Heating…How Does It Work?

All Temperature Controlled Units (TCUs) have five main components:

  • Microprocessor
  • TCU Engine
  • Compressor
  • Condenser
  • Evaporator

An area containing all of the main components listed above with the exception of the evaporator is located outside the controlled environment space (e.g. outside the cold room).Refrigeration cycle vector illustration. Scheme with Low and high pressure, cool and hot liquid, air compressor, evaporator, expansion valve and condenser. Physics basics

The compressor pumps refrigerant through the temperature-controlled system. It works with the engine to increase pressure triggering the refrigerant to change phase from a gas to a liquid. Due to the phase change the refrigerant will heat up during compression. The liquid refrigerant is then pumped to the condenser. The condenser removes the heat absorbed by the refrigerant from the compressor and temperature-controlled area. As the heat is being absorbed the refrigerant approaches thermal equilibration with the ambient air outside the controlled environment space. Once the refrigerant has been cooled to a liquid it flows through an expansion valve into the evaporator. The evaporator then transfers heat out of or into the controlled environment space to control the area temperature. The refrigerant changes back to a gas as it absorbs heat. The heated refrigerant then flows back through the compressor and the cycle starts over. As you might have guessed, the heating process of a refrigeration unit is usually the opposite of the cooling process. The evaporator becomes the condenser and vice versa.

What about the defrost cycle you ask?

The defrost cycle is used to prevent the system from forming ice. When and how often the defrost cycle is used is based on measurements of the coils temperature at given time intervals. A timer closes the circuit which then allows air to flow to a temperature sensor. If the temperature falls within the temperature range that would allow the formation of ice, the unit will start a defrost cycle. Typically, an electric heater is used to defrost the evaporator. Obstruction of airflow due to evaporator icing may also trigger the defrost cycle to begin.

Parting Thoughts

cofAn actively temperature-controlled system is designed to maintain the air temperature within a defined space, thereby insulating the stored goods from the effects of outside conditions. To achieve this, the air inside the system must be able to flow throughout the area being controlled. If your data is meeting acceptance criteria then great, everything is probably fine. But if it’s not then your issue probably lies with a critical design parameter such as: sufficient capacity for heat exchange, proper airflow, thermal integrity, and air velocity. All of these are as crucial to a temperature control system, including monitors and alarms, as they are to the refrigeration process.

 

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Written By: Nathan Roberge, Consultant III

 

Reference:

  • Active Temperature-Controlled Systems: PDA Technical Report No. 64; 2013

Peter Broomes Joins ICQ as North East Regional Director

petePeter Broomes, an accomplished operations manager, process engineer and project engineer with over seventeen years of experience in the biopharmaceutical sector, has joined Integrated Commissioning & Qualification Corp. (ICQ) as its North East Regional Director.

In this new senior management position, Peter will oversee ICQ client relationships, resource deployment, team recruitment and business development efforts in the northeastern United States. “I’m very excited to join ICQ.  This is a great company, with a strong team, and good values,” Peter said. “I look forward to working together with the people here to help our clients succeed and to help our company grow.”

Prior to joining ICQ, Peter worked for 10 years at ADVENT Engineering a Trinity Consultants company, holding a series of operational and management positions with increasing responsibilities. He has subject matter expertise in numerous aspects of commissioning, qualification and verification of regulated processes and facilities. He has led numerous engineering and CQV engagements at Sanofi-Genzyme, GE Life Sciences, and Genentech among other companies.

“We’ve known Peter for a long time and we are pleased to be able to recruit him to our team,” said Michael Bogan, president of ICQ. “Peter’s experience, integrity, customer focus, and his ability to develop impactful solutions will be a great addition to our capabilities.”

Peter earned a Bachelor of Engineering degree in Mechanical Engineering from Stevens Institute of Technology. He earned a Master of Science degree in Mechanical Engineering from the University of California, Berkeley. In addition to his years at ADVENT Engineering, Peter worked in various engineering roles at Merck and Genentech. He resides in Grafton, MA, with his wife and two children.

Industry 4.0 and the Manufacturing Facilities of Tomorrow

On May 16, I attended the ISPE event Pharma 4.0: The Next Industrial Revolution in Manufacturing for Automation, Controls, and Decision Making. Technology is advancing at an ever-increasing pace, and it can be difficult to keep up with the newest innovations.

One of the major advances in recent years is called the Internet of Things, or IoT. IoT is a series of technologies that allow things to connect to the internet, so that they can be remotely controlled or can interact with other things. It seems like stuff of the future, but in the past few years IoT-enabled devices have become household names (Alexa, turn on the living room light). Many of us use these devices in our everyday lives, but how can IoT be applied to manufacturing facilities? Very easily, it turns out.

Reality Check

One of the easiest ways to integrate IoT is through Virtual and Augmented Reality. Augmented Reality (AR) is a method used to overlay virtual aspects to a real-world view. For example, training modules can be developed using an overhead camera and a screen to display the recording. As the worker goes through tasks, images are overlaid on the real-time recording on the screen to direct the worker on the next task.

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Virtual Reality (VR) is similar, but instead of images overlaid on a real-time recording, an immersive environment is created, and the user’s vision is through a VR headset. VR can be used for training workers on remote or expensive pieces of equipment, or for performing remote site walkthroughs. VR modules can even be integrated with motors so that the user can feel the experience they’re seeing. An example would be for truck driver training, where the trainee would sit in a simulated truck cab with a VR headset. As they go over bumps and around turns in the simulation, the truck cab would move in a responsive manner.

Thanks for Sharing

Some IoT technologies rely on data sharing, which might be a difficult concept in an industry where data is a closely-guarded secret.

One of the easiest ways to see where data sharing might be useful is for predictive supply chain management. Many of us have taken advantage of Amazon’s subscription service, where you select an item and a delivery interval. Planned delivery like this is particularly useful when it’s something with a known usage rate. However, what if the material is used at a variable rate? By sharing material usage data with suppliers, material can be automatically ordered when the on-hand supply reaches a pre-set level, independent of the rate of usage. If usage patterns are known by the suppliers, supplies could even be automatically ordered in advance if the supplier is facing long lead times.

Self Diagnosis

Predictive Maintenance is another potential use for IoT integration in manufacturing facilities. When equipment breaks down, it can cause delays, deviations, and even batch discards. However, by analyzing certain indicators of equipment performance and status, you might be able to see an issue emerging before it becomes a batch-ruining disaster. Now, what if the equipment reported these indicators itself, without the need for operator intervention? With correct integration, the equipment could even order maintenance for itself, with no need for oversight or intervention by an operator, long before an equipment performance issue causes an error or ruins a batch.

Final IoT Thoughts

These are just a few examples of the technologies available to us today, and it’s easy to get overwhelmed by the options. The most important thing to remember when integrating new technologies is to select technology to make an existing task easier and more efficient. Adopting a technology to try and find a use for it can complicate and slow progress. Remember to not get caught up in the hype, and you, too, can participate in designing the manufacturing facility of the future.

Cartoon Color Smart Factory Inside Interior. Vector

Written By: Taylor Frederick, Consultant III

Hiring: Raleigh – Durham Area, CQV Professionals

softcoputerguyICQ is currently hiring for multiple openings in the Greater Raleigh Area.  If you or anyone you know may be interested, please apply here or email a copy of your resume to [email protected].

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Validation 101: System Requirements

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Why are requirements and specifications needed in validation?

Validation is testing a system to standards or acceptable criteria. If your own requirements are not in place, then you will end up validating a system to someone else’s standards. There are thousands of features and conditions to consider and considering them beforehand allows your company to make an informed decision about the products you’re looking to buy.

Checklist with businessmanThink of validation like the final check list before you say “I do” at your wedding. If you simply want to be married, anyone will do, very little vetting is needed. However, to ensure a long-lasting, happy marriage, the wise bride or groom will have in place a checklist of attributes and behaviors that their perfect partner should possess. Having a vendor perform validation is like having your spouse’s parent perform the validation – it runs the risk of being biased, and so it should be supplemented. Whether creating specifications and requirements for a partner in marriage or for a piece of equipment, you’re making sure that match is perfect.

There are several types of specifications that we use in the biopharmaceutical industry.

User requirements are just that, the requirements needed by the end user as required by the product, the process, safety standards, and engineering principles. At a minimum, there will always be at least one user requirement – this is the driving factor behind the purchase. Does the system perform well in the given range needed? Can it operate for the length of time needed? Performance qualifications governed by User requirements make sure that all needs are addressed, and nothing get overlooked in validation. Having these URS documents make you validation fluid and traceable.

Functional specifications lay out the desired behavior of the equipment or system you’re looking to purchase. Does the equipment perform within any required tolerances for analytical data? Does the system need to provide maintenance reminders? Does the system need to print out reports immediately? How many users will be using the system, and can it operate effectively with all users? Does the device need compliant software? Can it be integrated with the existing automation system? Can the system interface with mobile devices?

Business, Technology, Internet and network concept. Young busine

Design specifications are the conditions that are required for your process or that are already present at your business. What are your space requirements? Can it take up as much space of a biosafety cabinet, or must it fit on your bench top? Do you need 220 V or 120 V electrical supply? Does associated software require a specific operating system?  Can it work in a room where harsh chemicals are being used?

Closing Thoughts

Purchasing equipment is going into a long-term relationship with a company. It should be an informed decision. By having a URS, FS, and DS in place for each piece of equipment, you provide your employees with the tools to make them active and informed purchasers. Once the equipment has been purchased and is on site, your validation team will have solid, effective references beyond tribal engineering knowledge. Validating the system becomes straight forward. The tests performed, and the reasons behind performing them are present. So, when you’re at the altar looking at that equipment, you’ll know that all the tests have been performed, all the deviations resolved, all the needs addressed, and the doubt removed. You can say “I do” to your  beautifully validated system.

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WRITTEN BY:  SHAZIB SYED, ENGINEER I
ICQ, CONSULTANTS CORP.

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ICQ Consultants is Re-Branding

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We are very excited to announce the launch of our newly designed website.  The new interactive website has a bold, clean look as does our new ICQ logo.

Our more user-friendly website interface and homepage layout providescompass current and prospective clients with useful information about our services and our company.  For our prospective future employees, our new website provides an easy to navigate application site where they can directly apply to our open positions.

ICQ Website:

ICQ’s new website offers maneuverability throughout our different tabs offering content such as:

  • A direct means for our  clients to contact us
  • Case studies and client testimonials
  • Latest news, events and blogs
  • ICQ Careers
  • An introduction ICQ’s management team

We would love to hear from you…

Please take a moment and check out our new website.  We would love to hear your feedback, please send any thoughts or comments to [email protected].

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GMP and Product Development Phases

HeaderGoodThousands of biotech pharma companies are conducting excellent research for the development of novel medicines for existing and unmet needs. According to clinicaltrails.gov, there are at this time more than 115,000 clinical trials being conducted in the US alone with around 22,000 studies in pre or clinical phase 1, 29,000 in clinical phase 2 and 13,000 in clinical phase 3 representing different stages of product development. While the major focus of the pharma developing early clinical trials materials is on the R&D, it is important to note that GMP knowledge and implementation is equally important.

How much GMP?

The plain and simple answer could be “never enough”. However, unless the company has a constant flow of revenues, never enough may not be the right approach. In this article, I will discuss the minimum GMP requirements for early phase companies, at different stages of development.dreamstime_xs_133354704

The question, a clinical phase company should ask is when was the last time, some expert quality personnel audited the process from receipt of raw material like a cell line to clinical trials material release and subsequently to clinical outcomes if any. If the answer is “never” or “a long time ago” then the company may be in for surprises in the data generated. Another important point to remember is that R&D should never be controlled yet must be challenged from time to time through development life cycle documents and quality personnel.

The failure rate of clinical trial materials and outcomes is sometime alarmingly high, which leads to failure of the company to progress. Could the excessive failure rate be because of this lack of challenge to the process in general and R&D in particular? The answer could very well be YES. GMP is a state of mind which in a strange way closely resembles R&D with the queries of how and why.

The common perception of no GMP for phase 1 and pre-clinical studies is totally misleading, partly confused by 21 CFR 210 final rule which states that 21 CFR Part 211 does not apply to investigational drugs for use in phase 1 clinical trials.  The reason for this confusion is that we tend to miss the requirements that follow it up as “unless the investigational drug has been made available for use by or for the sponsor in a phase 2 or phase 3 study” and the requirement of GMP for this phase in the form of different FDA and other guidance. In short, GMP is needed at all stages where a product is intended for human use regardless of its development phase. The difference of the state of GMP in different phases of development is the degree of GMP in terms of the knowledge acquired as the product moves from pre-clinical to phase 1 to phase 2 to phase 3 and commercial.

Critical GMP Parameters

Here are some critical GMP parameters with respect to different phases of development:

GMP

  1. Calibrated equipment shall be used and a strong equipment maintenance program shall be in place starting with the R&D and be finalized before the start of the phase 1 development.
  2. The proposed design of the facilities, utilities and equipment used shall be suitable for intended purpose. Design Review / Qualification shall be initiated before systems / equipment are shipped to the site.
  3. Analytical methods shall be qualified at the pre-clinical (Tox) phase with qualification completed by phase 1. A method can only be considered qualified if the system it is executed on is qualified first. The degree of system qualification in turn need associated impact and risk assessment of the system, its functions and components for its impact on the quality of the product in the given development phase. Therefore, it is recommended that system impact assessment, function criticality assessment, and component criticality assessment be initiated as soon as possible, preferably in the pre-clinical phase.
  4. Analytical method validation shall proceed from phase 1 and continue into phase 3 as more information is accumulated during product development.
  5. Systems / Equipment shall be qualified for phase 1 development use, with the risk and criticality assessments completed at the beginning of this phase.
  6. Bioburden and Endotoxin Controls shall be in place at the beginning of phase 1 development and continue into BLA submission phase (phase 2b or 3) as more information is collected about the product.
  7. Process validation shall begin at the latest at the start of BLA submission phase and completed before the end of this phase.

Final Thoughts:

While the GMP rules are considered as designed to ensure patient safety, let us not miss out on the opportunity that these rules give us in ensuring smooth sailing from development to approval. The era of keeping clinical trial outcomes separate from development, manufacturing, and quality control departments is over as Biotech products are extremely sensitive to minor CMC changes. The separate phases of clinical trials and development are fading as we enter the world of biotech products where cohort studies are used for BLA submissions in phase 2.

Written By: Abdul Zahir, Project Manager III

ICQ

 

References:

PDA Technical Report 56

EudraLex Volume 4

21 CFR Parts 210, 211, 600

International Committee on Harmonization (ICH) Q8, Q9, Q10

Analytical Procedures and Methods Validation for Drugs and Biologics: July 2015

FDA Quality Issues for Clinical Trial Materials: The Chemistry, Manufacturing and Controls (CMC) Review

ASTM International – Designation E2500-07

Statistical Process Control, Friend or Foe?

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In my experience, I see a lot of companies using trend charts and statistics to get a view of their process, when what they are actually doing is avoiding looking at their processes and waving meaningless numbers around.  While this doesn’t seem to make sense, when I look at the misuse of the data, I see many of the same issues across many different sites.

It seems a lot of companies get asked to look at metrics or trend their performance. While the trending of discreet process outputs, yield etc. is easy and straightforward, they sometimes get bogged down in reviewing more in-depth process performance.  This would include things like the health of a quality system, or of something like a manufacturing process.

Same Old, Same Old…The Same Old Thinking The Same Old Results

In general, I see a lot of companies take this typical approach.

  • Get asked to trend a process
  • See what data is readily available
  • Put that data in a trend chart
  • Review that data regularly
  • Initiate no formal projects, or take any meaningful action when the process isn’t trending well
    1. Typical responses are to tell people to work better to fix the metrics
    2. Change the metric they are looking at
    3. Ignore it and hope it goes away – primarily because they haven’t really accepted that this is a true measure of the process success

Taking a Different Vantage Point

Conceptual hand writing showing Think Outside The. Business photo text Creative Thinking Looking in different perspective

It’s interesting that the idea of statistical process control can be traced back to some of the Deming principles and the system perspective, however most people don’t even consider a system perspective when developing statistics.  Let’s look at the system perspective and the best way to develop statistics and how to use them for improvements.

In the system perspective we recognize that all outputs are part of a system, and not independent results.  In the system perspective we can view a system as a long pipe.  At the end of the pipe is the expected output (what we think of as success).  At the beginning of the pipe are the inputs to the system.  The pipe is the system that transforms the inputs to the outputs.  We want to determine how to measure the system success we need to evaluate what successful outputs are to that system.

This is a staged process.

  • What are the outputs of the process?
  • Who are the customers (stakeholders) for those outputs?
  • What are the needs of those customers?
  • How can we measure those needs?

By walking through these questions, you can develop the key metrics to determine the success of the system. You may have to take new measurement or generate data that isn’t already available, but it can also lead us to the best way to make improvements to the process.  Too often we just rely on the easy data that we already have available without even thinking what this tells us about our process.

Set up for Success

We need to follow the steps below which are above and beyond what is typically done;

  • Determine the system you want to look at
  • Go through the previous 4 step process to determine key metrics
  • Measure the system metrics
  • When something statistically does not meet out criteria, evaluate what in the system we can do to improve the output (initiate a project team as needed to evaluate process improvement)Strategy Execution Success concept words
    1. Process improvements should look at all inputs to a system (Man, Machine, Methods, Environment, and Materials)
  • Make Improvements
  • Measure success of the updated system
  • Continue to monitor

This is a very high-level view on how to truly measure and improve our systems.

Final Thoughts

We as an industry need to get past the idea of just asking our people to be the sole way to improve outputs when there may be something else broken in the system. We need to be sure we are looking at true measures of success, so that we really do feel motivated to make improvements when we don’t meet expectation.

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Written By: Michael Murphy, Managing Consultant

21 CFR Part 11 Compliance Summarized……..Simply

HeaderGood21 CFR part 11 can be summed up in three words: Verify, Audit, and Track with one guiding compass, honesty. Companies must be able to prove without a shadow of a doubt that any person taking any action within a system is who they say they are. Any action taken within a given environment cannot be changed without documentation and everything done should be accessible for inspection at a later time.

So from this, we can establish that an electronic signature needs to be as trusted as a paper signature, documentation is key, and actions taken can be inspected or audited.

Two key concepts

dreamstime_xs_101635745A closed system is a computer system whose user access is controlled by the same people responsible for its contents. I like to think a good example is being a diary for a company’s equipment. All the juicy secrets are written down or stored and the owner chooses who has access and who doesn’t and mainly known vetted people would be using it.

An open system is a computer where user access is NOT controlled by the same people responsible for its contents. A good example would be Wikipedia, you are given an account with a personally identifying code, but you can add or subtract whatever you want within the platform. Wikipedia can’t confirm who they are prior to giving access to the document so you want to have all the time and date details of when the information was accessed, what was changed and what was original content as well as ensuring that the identifying code given for them to use is on everything they touch

Now for the technical….

A great resource I read was The Ultimate Guide to 21 CFR Part 11 by Marin Richeson, I think the summary was on point and it took legalese and made it digestible. Read it below.

21 CFR Part 11 consists of three Subparts:

A – General Provisions

B – Electronic Records

C – Electronic Signatures

SUBPART A – GENERAL PROVISIONS

  • Part 11 applies to all electronic records that fall under FDA regulations.
  • If an organization can prove to an auditor that their electronic records/signatures are as trustworthy as paper records/ink signatures, the FDA will accept electronic instead of paper.
  • The FDA will accept electronic submission instead of paper IF those submissions 1) adhere to Part 11 requirements and 2) are included among the types of documents that the FDA accepts electronically.

SUBPART B – ELECTRONIC PROVISIONS

  • Organizations using electronic records must establish and document procedures and controls that ensure the following qualities in their electronic records:

– Authenticity

– Integrity

– Confidentiality (when appropriate)

– Irrefutability (i.e., no way to deny that a record is genuine)

  • The following topics must be addressed in documented procedures and controls: computer systems validation (CSV), record rendering, document storage and record retention, system access, audit trails, workflows, authority checks, device checks, personnel qualifications, personnel accountability, and document control.
  • Systems that fall into the category of “Open” (as defined in Sub-part A) require additional procedures/ controls.dreamstime_xs_49436796
  • Electronic signatures must include the printed name of the signer, the date and time of the signature, and the meaning of the signature.
  • Electronic signatures must be forever linked to their respective records.

SUBPART C – ELECTRONIC SIGNATURES

  • Organizations that wish to use electronic signatures must inform the FDA in writing prior to making the switch.
  • Each individual who will be using an electronic signature must

1) have their identity confirmed and

2) use a unique signature that has never been and will never be used by another individual.

  • There are specific design requirements for electronic signatures that are biometric (e.g., fingerprint scan) and those that are not (e.g., user ID and password).
  • For electronic signatures that make use of user IDs and passwords/passcodes, there are specific requirements for passwords and for passcode generating devices.

Final Thoughts

Good stuff, right? At the end of the Day why do you need to be compliant with the FDA?

Because H-O-N-E-S-T-Y.

Altering data is like altering the story the record tells and who put the data changes the record as well. Imagine if you could attribute your name to the great literary arts and say you did it rather than Hemingway or Shakespeare. The difference between a 1 and a 0 have strong implications in binary code. Being compliant or making your equipment complaint with 21CFR part 11 keeps the story true and if it is false, you can see it and find out who is responsible.

Please find a link to the Regulation bellow:

https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=11

Link to The Ultimate Guide to 21 CFR Part 11.

https://www.perficient.com/-/media/files/guide-pdf-links/the-ultimate-guide-to-21-cfr-part-11.pdf

 

Written By: Shazib Syed, Engineer I

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