21 CFR: The Umbrella Of FDA Compliance
The U.S Food and Drug Administration (FDA), the Office on
National Drug Control Policy (ONDCP) and the Drug Enforcement Agency (DEA) all
use Title 21 Code of Federal Relations (CFR) to govern food, drugs, cosmetics
and other public health products. When it comes to enforcement, inspections can
be conducted for the purpose of pre-qualification, routine inspection, or
“for-cause” to investigate a specific problem reported to the FDA – so you need
to be consistently ready.
Title 21 CFR, Part 11
Title 21 CFR Part 11, in particular, is all about electronic
signatures, electronic records, and ensuring that both components are
trustworthy, reliable and equivalent to paper records (ERES). Generally
speaking, part 11 applies to medical device manufacturers, drug makers, biotech
companies, and other FDA-regulated industries.
This focus on electronic records may seem oddly specific,
but establishing a trustworthy, consistent electronic paper trail is a major
time-saver and necessary for maintaining record standards in a modern age.
Before part 11 was established in 1997, institutions had to submit physical
documents to be audited, and it cost a lot of time, physical space and efficiency. 21 cfr part 11 compliance makes it much easier to prove compliance and to comply with other
regulatory sections.
Make Sure 21 CFR Part 11 Applies To Your Company
According to section 11.3, the term “electronic record” is
defined as, “any combination of text, graphics, data, audio, pictorial, or
other information representation in digital form that is created, modified,
maintained, archived, retrieved or distributed by a computer system.” This is a
broad definition that shows that Part 11 will apply to many companies.
For this reason, even if you have paper-based systems, it’s
likely that 21 CFR Part 11 can apply to your business.
Follow 21 CFR Part 11
Password Protection Best Practices
Part 11 is ultimately all about data security and the security of your electronic records. Facilitating compliance, then, will require that you follow security practices and set the right roles and permissions when it comes to your data. It also requires effective password protection.
Validate For IQ, OQ And PQ
Most validation projects follow the IQ, OQ, PQ process for
system validation. This, of course, stands for installation qualification,
operational qualification and performance qualification. The process can
ultimately demonstrate that:
The installation of the facility, product line, equipment,
and systems are installed with a high degree of quality assurance and in
accordance with all FDA quality requirements.
The quality of the production process meets FDA standards.
The quality of the documentation about the process and equipment
meets FDA standards.
It’s important to get right, and the right FDA compliance
software can help.
4. Create Clear Audit Trails
If you have a clear and accurate audit trail, it can make
the entire auditing process easy and intuitive. This can help with part 11
compliance because it can allow your team and auditors to understand, at a
glance, when records were created, changed, deleted or superseded.
To get this right, you need comprehensive change management
processes.
5. Make Sure Your Compliance Is Properly Handled
The responsibility of Part 11 compliance will always fall on
your shoulders – and, since you’re ultimately responsible, you should be the
one crossing your T’s and dotting your I’s. That said, in-house validation is
often costly, time-consuming and complex – particularly as regulations change
over time.
The right validation-as-a-service system, like Meridian
Cloud for Life Sciences, can help take the majority of the validation process
of your plate using features like:
Pre-validated Meridian implementation
Templated validation documentation
Customer-specific validation documentation modifications
Data migration (test and production)
User acceptance testing
Deployment, with the execution of the OQ and data
migration protocol
Additionally, Accruent will be there every step of the way
from system design through deployment. Then, once your system is
deployed, Accruent Managed Services (AMS) will provide your team with ongoing
support in the form of:
Re-validation of the core solution for each
Quarterly Release
Templates updated, if necessary
Re-testing of core solution
Risk assessment of changes relative to your configuration
(assigned a risk level of 1, 2 or 3)
Re-validation on level 3 items against your configuration
This not only saves time but also decreases your team’ IT
burden and frees up time for the execution of other business-critical tasks.