DEFINITION: "data integrity refers to the completeness, consistency, and accuracy of data. Complete, consistent, and accurate data should be attributable, legible, contemporaneously recorded, original or a true copy, and accurate (ALCOA)" - FDA Guidance Data Integrity and Compliance With Drug CGMP
In recent years, FDA has increasingly observed cGMP violations involving data integrity during cGMP inspections. This is troubling because ensuring data integrity is an important component of industry’s responsibility to ensure the safety, efficacy, and quality of drugs, and of FDA’s ability to protect the public health. These data integrity-related cGMP violations have led to numerous regulatory actions, including warning letters, import alerts, and consent decrees. The underlying premise in §§ 210.1 and 212.2 is that cGMP sets forth minimum requirements to assure that drugs meet the standards of the FD&C Act regarding safety, identity, strength, quality, and purity. Requirements with respect to data integrity in parts 211 and 212 include, among other things:
When considering how to meet many of these regulatory requirements, it may be useful to ask the following questions:
What is ALCOA? The five data integrity attributes as defined by the FDA:
MEDVACON delivers leading Data Integrity and Computer System Validation services that are designed to help reduce the overall cost of compliance for Life Sciences organizations. We offer our clients comprehensive services, including leadership and a range of strategic solutions and tactical services that provide cost-effective and comprehensive compliance and validation. The MEDVACON team of highly-qualified consultants can deliver a broad suite of solutions in areas of computer systems validation, infrastructure qualification, IT Quality Management, and process improvement.
Computer Software Validation is a formalized, documented process for testing computer software and systems, required by 21 CFR 11.10(a) and Annex 11, Section 4. The FDA and other regulatory bodies require validation to demonstrate that computer systems are in compliance with all regulations for electronic data management systems. Failure to validate systems is one of the leading reasons a business is issued a 483. MEDVACON can validate all of your software, databases, spreadsheets, and computer systems, and develop the appropriate documentation for all phases of the software life cycle. We have written and executed validation packages for systems of all sizes. We can provide any level of service required, from executing test scripts generated from your existing specifications to writing the entire validation package. MEDVACON will follow your existing validation procedures or provide your company with validation standards. Our validation methodology ensures validation deliverables that are in line with industry standards & best practices, focus resources towards the most critical system functions, and complete the validation projects efficiently.