Showing posts with label GUIDELINES UPDATES. Show all posts
Showing posts with label GUIDELINES UPDATES. Show all posts

Sunday 26 June 2016

21 CFR 11

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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:

Sunday 17 April 2016

Revised ISO 14644


Most awaited update to ISO 14644-1 is released and it has good changes those are useful for pharmaceutical manufacturing.

ISO 14644 Part 1 is a useful guideline to maintain the good manufacturing practices in sterile pharmaceutical manufacturing as well as the oral dosage forms. This document provides the standards for the clean room classification. Revision of the guidance was started since 2007 and its drafts are already published in 2011, 2012, 2014 and 2015 but none was finalized and 1999 version was applicable and expecting a new version.

Finally a 2015 version is released and following are the major changes those are made in 1999 version of the ISO 14644-1.

1. Title of the ISO 14644-1 is changed from “Classification of air cleanliness” to “Classification of air cleanliness by particle concentration”.

2. The number of sampling points in the area is no longer calculated as the square root of the surface area formula but it is now taken from the table given below.

3. Formula to calculate the particle concentration (Cn) in respective classification number is no longer used and value is taken directly from the table.

4. Particles of 5 µm in ISO 5 class have been removed from the limit value table as given below.

5. UCL calculation is not required now: there is no need to perform an observation of all measuring points in the room any longer. Each single measuring point is considered individually and has to meet the limit value.

6. The length of tubing used in particle counter should be less than 1 meter. 

7. The classification number, the air sample volumes, measuring time as well as the cancellation criterion is not changed and remains as same to the version ISO14644-1:1999.

All SOPs and qualification protocols in pharmaceutical manufacturing related to the HVAC system andcleanroom management should be changed accordingly.

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