ELM-F001-06

How to Avoid FDA Data Integrity System Access Warning Letters (21 CFR Part 11) [Video]

In this warning letter breakdown, we are going to examine how you can avoid data integrity warning letters pertaining to unauthorized system access.

Reference From Actual Warning Letter

“1. Failure to prevent unauthorized access or changes to data, and to provide adequate controls to prevent manipulation and omission of data.

During the inspection, FDA investigators discovered a lack of basic laboratory controls to prevent changes to your firm’s electronically stored data and paper records. Your firm relied on incomplete records to evaluate the quality of your drugs and to determine whether your drugs conformed with established specifications and standards.

Our investigators found that your firm routinely re-tested samples without justification and deleted analytical data. We observed systemic data manipulation across your facility, including actions taken by multiple analysts, on multiple pieces of testing equipment, and for multiple drugs. You are responsible for determining the causes of these deviations, for preventing recurrence, and for preventing other deviations from CGMP.”

Learn More About 21 CFR Part 11

Taken from our 21 CFR Part 11 Online Program.

21 CFR Part 11 – An Introduction
21 CFR Part 11 – Electronic Records
21 CFR Part 11 – Electronic Signatures
21 CFR Part 11 – Guidance

Author

Graham O'Keeffe

General Manager - Veeva LearnGxP