Q: What are the requirements of 21 CFR 11?
A: 21 CFR 11 requires that closed computer systems must have a collection of technological and procedural controls to protect data within the system. Open computer systems must also include controls to ensure that all records are authentic, incorruptible, and (where applicable) confidential.
Q: What computer systems must be compliant with 21 CFR 11?
A: All computer systems which store data which is used to make Quality decisions or data which will be reported to the FDA must be compliant with 21 CFR 11. In laboratory situations, this includes any laboratory results used to determine quality, safety, strength, efficacy, or purity. In clinical environments, this includes all data to be reported as part of the clinical trial used to determine quality, safety, or efficacy. In manufacturing environments, this includes all decisions related to product release and product quality.
Q: What is computer system validation?
A: Validation is a systematic documentation of system requirements, combined with documented testing, demonstrating that the computer system meets the documented requirements. It is the first requirement identified in 21 CFR 11 for compliance. Validation requires that the System Owner maintain the collection of validation documents, including Requirement Specifications and Testing Protocols.
More information about requirements for computer system validation
Q: What is accurate record generation?
A: Accurate record generation means that records entered into the system must be completely retrievable without unexpected alteration or unrecorded changes. This is generally tested by verifying that records entered into the system must be accurately displayed and accurately exported from the system.
More information about requirements for accurate record generation
Q: How must records be protected?
A: Electronic records must not be corrupted and must be readily accessible throughout the record retention period. This is usually performed through a combination of technological and procedural controls.
More information about requirements for protection of records
Q: What is limited system access?
A: System owners must demonstrate that they know who is accessing and altering their system data. When controlled technologically, this is commonly demonstrated by requiring all users have unique user IDs along with passwords to enter the system.
More information about requirements for limited system access
Q: What is an audit trail?
A: An audit trail is an internal log in a program that records all changes to system data. This is tested by demonstrating that all changes made to data are recorded to the audit trail.
More information about audit trails
Q: What are operational system checks?
A: Operational system checks enforce sequencing of critical system functionality. This is demonstrated by showing that business-defined workflows must be followed. For example, data must be entered before it can be reviewed.
More information about operational system checks
Q: What are device checks?
A: Device checks are tests to ensure the validity of data inputs and operational instructions. Generally speaking, Ofni Systems does not suggest testing keyboards, mice, etc., because these input devices are implicitly tested throughout other testing. However, if particular input devices (optical scanners, laboratory equipment, etc.) these devices should be tested to ensure the accuracy of system inputs.
More information about input and device checks
Q: What training requirements are required for 21 CFR 11 compliant programs?
A: Users must be documented to have the education, training, and experience to use the computer system. Typically training can be covered by your company training procedures.
More information about education, training, and experience required for 21 CFR 11
Q: What is a policy of responsibility for using electronic signatures?
A: Users must state that they are aware that they are responsible for all data they enter or edit in a system. This can be accomplished technologically through accepting conditions upon signing into the system or procedurally by documenting this responsibility as part of training.
More information about policies for using electronic signatures
Q: What documentation requirements are required for 21 CFR 11 compliant programs?
A: Documentation must exist which defines system operations and maintenance. Typically these requirements are met by company document control procedures.
More information about document control systems
Q: What are the requirements for electronic signatures?
A: All electronic signatures must:
» Include the printed name of the signer, the date/time the signature was applied, and the meaning of the electronic signature.
» Be included in human readable form of the record. Electronic signatures must not be separable from their record.
» Must be unique to a single user and not used by anyone else.
» Can use biometrics to uniquely identify the user. If biometrics are not used, they need at least two distinct identifiers (for example, the user ID and a secret password).
Q: Does 21 CFR 11 have any requirements for passwords or identification codes?
A: Yes. Procedural controls should exists to ensure that:
» No two individuals have the same user ID and password.
» Passwords are periodically checked and expire.
» Loss management procedures exists to deauthorize lost, stolen, or missing passwords.
Glossary
» Closed Systems are computer systems where system access is controlled by people who are responsible for the content of electronic records in the system. Most applications are considered to be closed systems.
» Open Systems are computer systems where system access is not controlled by people responsible for the content of electronic records in the system. The internet or wikis are examples of open systems.
» Procedural Controls are documented SOPs which ensure that a system is only used in a particular manner.
» Technological Controls are program-enforced compliance rules, like requiring that a user have a password to log into a computer system. Technological controls are generally considered to be more secure than procedural controls.
» Biometrics are means of identifying a person based on physical characteristics or repeatable actions. Some examples of biometrics include identifying a user based on a physical signature, fingerprints, etc.
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