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Complying with 21 CFR Part 11 - Understanding the role of predicate rule

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To obtain knowledge and understanding of 21 CFR Part 11 as how it applies to you as well as be advised of consequences which may result in failing to comply with this regulation.

To obtain knowledge and understanding of 21 CFR Part 11 as how it applies to you as well as be advised of consequences which may result in failing to comply with this regulation.

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  • 1. 21 CFR Part 11Understanding the Role of Predicate Rule By Jasmin NUHIC
  • 2. Objective• To obtain knowledge and understanding of 21 CFR Part 11 as how it applies to you as well as be advised of consequences which may result in failing to comply with this regulation. 21 CFR Part 11 v2.1 2
  • 3. Warning Letters• At the time of search, there were 764 search results on FDA website• Example: – No objective evidence provided to show that the electronic system for control of records has been validated for its intended use 21 CFR Part 11 v2.1 3
  • 4. Topics• OVERVIEW – Timeline – Definitions• REGULATION – Subparts and Sections – Part 11 vs. Other Regulations• END-USER TAKE-A-WAYS – Advantages and Challenges – Training – Audit Questions – Options for Non-Compliance?• CLOSING – What If? – Certification Statement• Q&A 21 CFR Part 11 v2.1 4
  • 5. Timeline July 1992 August 1997 Advanced Notice In Effect November 1991 August 1994 March 1997Project Launched Proposed Rule Final Rule 1991 1992 1993 1994 1995 1996 1997 Final rule put in effect 21 CFR Part 11 v2.1 5
  • 6. Definitions• Electronic record - any combination of text, graphics, data, audio, or pictorial information represented in digital form that is created, modified, maintained, archived, retrieved or distributed by a computer 21 CFR Part 11 v2.1 6
  • 7. Definitions (cont’d)• Electronic signature - a compilation of any symbol(s) executed to be the legally binding equivalent of an individual’s handwritten signature 21 CFR Part 11 v2.1 7
  • 8. Definitions (cont’d)• Handwritten Signature - The scripted name or legal mark of an individual handwritten by that individual and executed or adopted with the present intention to authenticate a writing in a permanent form 21 CFR Part 11 v2.1 8
  • 9. Definitions (cont’d)• Digital Signature - An electronic signature based upon cryptographic methods of originator authentication, computed by using a set of rules and a set of parameters such that the identity of the signer and the integrity of the data can be verified 21 CFR Part 11 v2.1 9
  • 10. Definitions (cont’d)• FDA defines closed and open systems - difference is in who controls system.• Closed System - people responsible for data content also control system 21 CFR Part 11 v2.1 10
  • 11. Definitions (cont’d)• Open System - data could reside for some period of time on a system that is outside the control of the organization that owns the data 21 CFR Part 11 v2.1 11
  • 12. Applies Across The Reg.“The agency believes that…it is vital to have stringent controls in place to prevent impersonation. Such controls include: (1)Requiring an individual to remain in close proximity to the workstation throughout the signing session; (2)Use of automatic inactivity disconnect measures that would “de-log” the first individual if no entries or actions were taken within a fixed short timeframe; and (3)Requiring that the single component needed for subsequent signings be known to, and usable only by, the authorized individual 21 CFR Part 11 v2.1 12
  • 13. Subparts and Subsections• Subpart A – General Provisions• Subpart B – Electronic Records• Subpart C – Electronic Signatures 21 CFR Part 11 v2.1 13
  • 14. Subparts and Subsections• Subpart A – General Provisions – 11.1 Scope • (a) The regulations in this part set forth the criteria under which the agency considers electronic records, electronic signatures, and handwritten signatures executed to electronic records to be trustworthy, reliable, and generally equivalent to paper records and handwritten signatures executed on paper. • (b) This part applies to records in electronic form that are created, modified, maintained, archived, retrieved, or transmitted, under any records requirements set forth in agency regulations. This part also applies to electronic records submitted to the agency under requirements of the Federal Food, Drug, and Cosmetic Act and the Public Health Service Act, even if such records are not specifically identified in agency regulations. However, this part does not apply to paper records that are, or have been, transmitted by electronic means. 21 CFR Part 11 v2.1 14
  • 15. Subparts and Subsections• Subpart A – General Provisions – 11.1 Scope • (c) Where electronic signatures and their associated electronic records meet the requirements of this part, the agency will consider the electronic signatures to be equivalent to full handwritten signatures, initials, and other general signings as required by agency regulations, unless specifically excepted by regulation(s) effective on or after August 20, 1997. • (d) Electronic records that meet the requirements of this part may be used in lieu of paper records, in accordance with §11.2, unless paper records are specifically required. 21 CFR Part 11 v2.1 15
  • 16. Subparts and Subsections• Subpart A – General Provisions – 11.1 Scope • (e) Computer systems (including hardware and software), controls, and attendant documentation maintained under this part shall be readily available for, and subject to, FDA inspection. • (f) This part does not apply to records required to be established or maintained by §§1.326 through 1.368 of this chapter. Records that satisfy the requirements of part 1, subpart J of this chapter, but that also are required under other applicable statutory provisions or regulations, remain subject to this part. 21 CFR Part 11 v2.1 16
  • 17. Subparts and Subsections• Subpart A – General Provisions – 11.2 Implementation • (a) For records required to be maintained but not submitted to the agency, persons may use electronic records in lieu of paper records or electronic signatures in lieu of traditional signatures, in whole or in part, provided that the requirements of this part are met. • (b) For records submitted to the agency, persons may use electronic records in lieu of paper records or electronic signatures in lieu of traditional signatures, in whole or in part, provided that: • (1) The requirements of this part are met; and 21 CFR Part 11 v2.1 17
  • 18. Subparts and Subsections• Subpart A – General Provisions – 11.2 Implementation • (2) The document or parts of a document to be submitted have been identified in public docket No. 92S–0251 as being the type of submission the agency accepts in electronic form. This docket will identify specifically what types of documents or parts of documents are acceptable for submission in electronic form without paper records and the agency receiving unit(s) (e.g., specific center, office, division, branch) to which such submissions may be made. Documents to agency receiving unit(s) not specified in the public docket will not be considered as official if they are submitted in electronic form; paper forms of such documents will be considered as official and must accompany any electronic records. Persons are expected to consult with the intended agency receiving unit for details on how (e.g., method of transmission, media, file formats, and technical protocols) and whether to proceed with the electronic submission. 21 CFR Part 11 v2.1 18
  • 19. Subparts and Subsections• Subpart A – General Provisions – 11.3 Definitions • (a) The definitions and interpretations of terms contained covered already. These are some additional • (b) The following definitions of terms also apply to this part: – (1) Act means the Federal Food, Drug, and Cosmetic Act (secs. 201–903 (21 U.S.C. 321–393)). – (2) Agency means the Food and Drug Administration. 21 CFR Part 11 v2.1 19
  • 20. Subparts and Subsections• Subpart B – Electronic Records – 11.10 Control for closed systems (cont’d) • Persons who use closed systems to create, modify, maintain, or transmit electronic records shall employ procedures and controls designed to ensure the authenticity, integrity, and, when appropriate, the confidentiality of electronic records, and to ensure that the signer cannot readily repudiate the signed record as not genuine. Such procedures and controls shall include the following: 21 CFR Part 11 v2.1 20
  • 21. Subparts and Subsections• Subpart B – Electronic Records – 11.10 Control for closed systems (cont’d) • (a) Validation of systems to ensure accuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records. • (b) The ability to generate accurate and complete copies of records in both human readable and electronic form suitable for inspection, review, and copying by the agency. Persons should contact the agency if there are any questions regarding the ability of the agency to perform such review and copying of the electronic records. 21 CFR Part 11 v2.1 21
  • 22. Subparts and Subsections• Subpart B – Electronic Records – 11.10 Control for closed systems (cont’d) • (c) Protection of records to enable their accurate and ready retrieval throughout the records retention period. • (d) Limiting system access to authorized individuals. • (e) Use of secure, computer-generated, time- stamped audit trails to independently record the date and time of operator entries and actions that create, modify, or delete electronic records. Record changes shall not obscure previously recorded information. Such audit trail documentation shall be retained for a period at least as long as that required for the subject electronic records and shall be available for agency review and copying. 21 CFR Part 11 v2.1 22
  • 23. Subparts and Subsections• Subpart B – Electronic Records – 11.10 Control for closed systems (cont’d) • (f) Use of operational system checks to enforce permitted sequencing of steps and events, as appropriate. • (g) Use of authority checks to ensure that only authorized individuals can use the system, electronically sign a record, access the operation or computer system input or output device, alter a record, or perform the operation at hand. • (h) Use of device (e.g., terminal) checks to determine, as appropriate, the validity of the source of data input or operational instruction. • (i) Determination that persons who develop, maintain, or use electronic record/electronic signature systems have the education, training, and experience to perform their assigned tasks. 21 CFR Part 11 v2.1 23
  • 24. Subparts and Subsections• Subpart B – Electronic Records – 11.10 Control for closed systems (cont’d) • (j) The establishment of, and adherence to, written policies that hold individuals accountable and responsible for actions initiated under their electronic signatures, in order to deter record and signature falsification. • (k) Use of appropriate controls over systems documentation including: • (1) Adequate controls over the distribution of, access to, and use of documentation for system operation and maintenance. • (2) Revision and change control procedures to maintain an audit trail that documents time- sequenced development and modification of systems documentation. 21 CFR Part 11 v2.1 24
  • 25. Subparts and Subsections• Subpart B – Electronic Records – 11.30 Control for open systems • Persons who use open systems to create, modify, maintain, or transmit electronic records shall employ procedures and controls designed to ensure the authenticity, integrity, and, as appropriate, the confidentiality of electronic records from the point of their creation to the point of their receipt. Such procedures and controls shall include those identified in §11.10, as appropriate, and additional measures such as document encryption and use of appropriate digital signature standards to ensure, as necessary under the circumstances, record authenticity, integrity, and confidentiality. 21 CFR Part 11 v2.1 25
  • 26. Subparts and Subsections• Subpart B – Electronic Records – 11.50 Signature manifestations • a) Signed electronic records shall contain information associated with the signing that clearly indicates all of the following: • (1) The printed name of the signer; • (2) The date and time when the signature was executed; and • (3) The meaning (such as review, approval, responsibility, or authorship) associated with the signature. 21 CFR Part 11 v2.1 26
  • 27. Subparts and Subsections• Subpart B – Electronic Records – 11.50 Signature manifestations (cont’d) • (b) The items identified in paragraphs (a)(1), (a)(2), and (a)(3) of this section shall be subject to the same controls as for electronic records and shall be included as part of any human readable form of the electronic record (such as electronic display or printout) 21 CFR Part 11 v2.1 27
  • 28. Subparts and Subsections• Subpart B – Electronic Records – 11.70 Signature / Record Linking • Electronic signatures and handwritten signatures executed to electronic records shall be linked to their respective electronic records to ensure that the signatures cannot be excised, copied, or otherwise transferred to falsify an electronic record by ordinary means. 21 CFR Part 11 v2.1 28
  • 29. Subparts and Subsections• Subpart C – Electronic Signatures – 11.100 General requirements • (a) Each electronic signature shall be unique to one individual and shall not be reused by, or reassigned to, anyone else. • (b) Before an organization establishes, assigns, certifies, or otherwise sanctions an individuals electronic signature, or any element of such electronic signature, the organization shall verify the identity of the individual. • (c) Persons using electronic signatures shall, prior to or at the time of such use, certify to the agency that the electronic signatures in their system, used on or after August 20, 1997, are intended to be the legally binding equivalent of traditional handwritten signatures. 21 CFR Part 11 v2.1 29
  • 30. Subparts and Subsections• Subpart C – Electronic Signatures – 11.100 General requirements (cont’d) • (1) The certification shall be submitted in paper form and signed with a traditional handwritten signature, to the Office of Regional Operations (HFC–100), 5600 Fishers Lane, Rockville, MD 20857. • (2) Persons using electronic signatures shall, upon agency request, provide additional certification or testimony that a specific electronic signature is the legally binding equivalent of the signers handwritten signature. 21 CFR Part 11 v2.1 30
  • 31. Subparts and Subsections• Subpart C – Electronic Signatures – 11.200 Component and Controls • (a) Electronic signatures that are not based upon biometrics shall: • (1) Employ at least two distinct identification components such as an identification code and password. • (i) When an individual executes a series of signings during a single, continuous period of controlled system access, the first signing shall be executed using all electronic signature components; subsequent signings shall be executed using at least one electronic signature component that is only executable by, and designed to be used only by, the individual. 21 CFR Part 11 v2.1 31
  • 32. Subparts and Subsections• Subpart C – Electronic Signatures – 11.200 Component and Controls (cont’d) • (ii) When an individual executes one or more signings not performed during a single, continuous period of controlled system access, each signing shall be executed using all of the electronic signature components. • (2) Be used only by their genuine owners; and • (3) Be administered and executed to ensure that attempted use of an individuals electronic signature by anyone other than its genuine owner requires collaboration of two or more individuals. 21 CFR Part 11 v2.1 32
  • 33. Subparts and Subsections• Subpart C – Electronic Signatures – 11.200 Component and Controls (cont’d) • (b) Electronic signatures based upon biometrics shall be designed to ensure that they cannot be used by anyone other than their genuine owners. 21 CFR Part 11 v2.1 33
  • 34. Subparts and Subsections• Subpart C – Electronic Signatures – 11.300 Control for ID, Codes & Passwords • Persons who use electronic signatures based upon use of identification codes in combination with passwords shall employ controls to ensure their security and integrity. Such controls shall include: • (a) Maintaining the uniqueness of each combined identification code and password, such that no two individuals have the same combination of identification code and password. • (b) Ensuring that identification code and password issuances are periodically checked, recalled, or revised (e.g., to cover such events as password aging). 21 CFR Part 11 v2.1 34
  • 35. Subparts and Subsections• Subpart C – Electronic Signatures – 11.300 Control for ID, Codes & Passwords • (c) Following loss management procedures to electronically deauthorize lost, stolen, missing, or otherwise potentially compromised tokens, cards, and other devices that bear or generate identification code or password information, and to issue temporary or permanent replacements using suitable, rigorous controls. 21 CFR Part 11 v2.1 35
  • 36. Subparts and Subsections• Subpart C – Electronic Signatures – 11.300 Control for ID, Codes & Passwords • (d) Use of transaction safeguards to prevent unauthorized use of passwords and/or identification codes, and to detect and report in an immediate and urgent manner any attempts at their unauthorized use to the system security unit, and, as appropriate, to organizational management. • (e) Initial and periodic testing of devices, such as tokens or cards, that bear or generate identification code or password information to ensure that they function properly and have not been altered in an unauthorized manner. 21 CFR Part 11 v2.1 36
  • 37. Part 11 Vs. Other Regulations• QSR• MDR• Corrections and Removals• Good Laboratory Practices Regulations 21 CFR Part 11 v2.1 37
  • 38. Part 11 vs. Part 820 PART 820PART 11 21 CFR 820.4021 CFR 11.10(d) Document ControlsLimit Access to authorized 21 CFR 820.20 individuals Mgmt. Responsibility21 CFR 11.10(e) 21 CFR 820.40Use of computer Document Controls generated audit trails 21 CFR Part 11 v2.1 38
  • 39. Part 11 vs. Part 820 (cont’d)PART 11 PART 82021 CFR 11.10(f) 21 CFR 820.70Operational checks Prod./Process control21 CFR 11.10(g) 21 CFR 820.20Authority checks Mgmt. responsibility21 CFR 11.10(h) 21 CFR 820.25Device checks Personnel 21 CFR Part 11 v2.1 39
  • 40. Part 11 vs. Part 820 (cont’d)PART 11 PART 82021 CFR 11.10(a) 21 CFR 820.70 (i)Validation of Systems Production/Process Controls21 CFR 11.10(b) 21 CFR 820.40 –Controls – Closed Systems Document ControlsGenerate copies of records for 21 CFR 820.180 – inspection General Requirements21 CFR 11.10(c) 21 CFR 820.40, 820.180Protection of Records to enable * Intent of Predicate Rules is the retrieval same as Part 11 Regulations,Limit access to authorized but less prescriptive individualsOperational system checks 21 CFR Part 11 v2.1 40
  • 41. Part 11 vs. Part 820 (cont’d)PART 11 PART 82021 CFR 11.10(i) 21 CFR 820.25Education - personnel Personnel 21 CFR 820.2021 CFR 11.10(j) Mgmt. ResponsibilityAccountability21 CFR 11.10(k) 21 CFR 820.40Controls – system Document Controls documentation 21 CFR Part 11 v2.1 41
  • 42. Part 11 vs. MDRPART 1121 CFR 11.10(b) MDRControls – generate copies of records for 21 CFR 803.1 inspection Maintain Records21 CFR 11.10(c)Protection of records to enable retrieval 21 CFR Part 11 v2.1 42
  • 43. Part 11 vs. MDR (cont’d)PART 11 MDR21 CFR 11.10(b) 21 CFR 803.10Controls Required Reports21 CFR 11.10(b) 21 CFR 803.14Controls Electronic Reporting21 CFR 11.10(k) 21 CFR 803.17Controls – System Documentation Written MDR Procedures 21 CFR Part 11 v2.1 43
  • 44. Part 11 vs. MDR (cont’d)PART 11 MDR21 CFR 11.10(e) 21 CFR 803.18 Audit trails File/Distributor Reports (MDR events)21 CFR 11.10(k) Controls – system documentation 21 CFR Part 11 v2.1 44
  • 45. Part 11 vs. Corrections and RemovalsPART 11 C&R21 CFR 11.10(b) - 21 CFR 806.1Controls Maintain Records21 CFR 11.10 (c)Protection of Records 21 CFR Part 11 v2.1 45
  • 46. Part 11 vs. Corrections and Removals (cont’d)PART 11 C&R21 CFR 11.10(b) 21 CFR 806.10Controls Corrections and Removals Reports 21 CFR Part 11 v2.1 46
  • 47. Part 11 vs. Corrections and Removals (cont’d)PART 11 C&R21 CFR 11.10(b) 21 CFR 806.30Controls FDA Access to Records 21 CFR Part 11 v2.1 47
  • 48. Part 11 vs. Good Lab PracticesPART 11 GLP21 CFR 11.10(b) 21 CFR 58.15Records for inspection Inspection of records21 CFR 11.10(i) 21 CFR 58.29Education/training of Personnel – education personnel and training 21 CFR Part 11 v2.1 48
  • 49. Part 11 vs. Good Lab Practices (cont’d)PART 1121 CFR 11.10 ( c ) GLPProtection of records 21 CFR 58.33 Study Director – responsibility for21 CFR 11.10 (k) documentationAppropriate controls over system documentation 21 CFR Part 11 v2.1 49
  • 50. Part 11 vs. Good Lab Practices (cont’d)PART 1121 CFR 11.10(g)Authority system checks GLP21 CFR 11.10(k) 21 CFR 58.35Appropriate controls over Quality Assurance Unit system documentation21 CFR 11.30Controls over open systems 21 CFR Part 11 v2.1 50
  • 51. Part 11 vs. Good Lab Practices (cont’d)PART 11 GLP21 CFR 11.10 ( c ) 21 CFR 58.81 Written standardControls over system operating documentation procedures 21 CFR Part 11 v2.1 51
  • 52. Part 11 vs. Good Lab Practices (cont’d)PART 11 GLP21 CFR 11.10(c) 21 CFR 59.190Protection of records Storage and retrieval of records21 CFR 11.10(k)Appropriate controls over system documentation 21 CFR Part 11 v2.1 52
  • 53. Part 11 vs. Good Lab Practices (cont’d)PART 11 GLP21 CFR 11.10( c)Protection of records 21 CFR 58.195 Retention of records21 CFR 11.10(k)Appropriate controls for system documentation 21 CFR Part 11 v2.1 53
  • 54. Advantages and ChallengesAdvantages Challenges• Electronic Batch records can eliminate mountains • Firms planning on using of paper work, speed processing and allow for electronic signatures in FDA statistical and trend analyses. regulated environments will be required to validate the• NDA’s and other submissions can be submitted computer related systems. electronically in place of paper submission. • Design of systems must be• Increases the speed of information exchange. well thought out and tested thoroughly.• Cost savings from reduced need for storage space. • Critical control points must be identified which can be• Manufacturing process streamlining. monitored through electronic audit trails.• Job creation in industries involved in electronic record and electronic signature technologies. • Adequate testing of security. 21 CFR Part 11 v2.1 54
  • 55. Training• Training should be completed by all users of any and all systems which are (to be) Part 11 compliant• Training should be conducted by qualified individuals on a continuing basis• Training should be specific to the operations that a user will perform• Training should be documented 21 CFR Part 11 v2.1 55
  • 56. Audit Questions - Examples• What is the source of data entered into the computer?• Who enters data and when?• Who has computer access? What are the security procedures?• How do data changes occur?• Who is authorized to access system and enter and change data?• Is data transcribed from paper records into the electronic record?• Is there an audit trail? Edit checks and data logic checks?• If sponsor discovers data errors, how are investigators informed and corrections made? 21 CFR Part 11 v2.1 56
  • 57. Five Options for Non-Compliance • Stop the activity • Retire the system and return to paper • Validate the system • Replace the system with a new one • Upgrade the existing system 21 CFR Part 11 v2.1 57
  • 58. What If?• FDA Inspection – Routine (new PMA product, two-year schedule) – For Cause (recalls, new product) – 483 Form / Report • Formal response – Warning Letter – Corporate Letter – Financial penalties – Other Regulatory (enforcement) actions • Consent decree 21 CFR Part 11 v2.1 58
  • 59. Certification StatementPursuant to section 11.100 of Title 21 of the code of Federal Regulations, thisis to certify that __________________ intends that all electronic signatures Name of organizationexecuted by our employees, agents, or representatives, located anywhere in theworld, are the legally binding equivalent of traditional handwritten signatures. 21 CFR Part 11 v2.1 59
  • 60. Thank You! By Jasmin NUHIC21 CFR Part 11 v2.1 60

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