COMPLIANCE PER DATA INTEGRITY NEI
SISTEMI DI AUTOMAZIONE SECONDO GAMPNORME ED ESEMPI
Andrea Franco
June 2016
TABLE OF CONTENTS
A Brief history of Data Integrity
Data Integrity recent deficiencies
EU/US relevant current references and New Data Integrity Guidelines
Manufacturing Automation Systems
Typical Electronic Data in Manufacturing Automation System
Attributes for Data Integrity applied to Manufacturing Automation
Systems
Conclusions
A BRIEF HISTORY OF DATA INTEGRITY
1992 - 1997
1997 - 2001
2001 - 2003
2003 - 2007
2007 - 2011
2011 - 2015
2015-2016
1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
1992
2016
ANNEX 11
21 CFR PART 11
FDA GUIDANCE
ERES & VALIDATION
FDA WITHDRAWN
GUIDANCE
FDA GUIDANCE
SCOPE &
APPLICATION
PIC/S GUIDANCE
ON CSV
First pilot sites qualified
NEW
ANNEX 11
MHRA
WHO
FDA
THREE NEW GUIDELINES WHY ?
Data Integrity has always been a requirement but has recently
become a major concern for global regulatory authorities, resulting
in a significant increase in regulatory observations in this area.
FDA have issued a huge number of Warning Letters to different
manufacturers outside US (mainly India and China) in the last 2
years and multiple other Warning Letters to Europe for issues
regarding data integrity.
Most of Warning Letters issued between 2013 and 2014 (to non
US sites) had Data integrity issues and this trend is increasing
(European Medicines Agency) In 2013 6 statements of non
Compliance related with Data Integrity
(European Medicines Agency) In 2014 6 statements of non
Compliance (August 2014) related with Data Integrity
EXAMPLE OF FDA DATA INTEGRITY
VIOLATIONS (1/2)
Examples of deficiencies in Lab:
Warning Letters issued to US based Manufacturer (Mar 2015)
Your firm failed to exercise appropriate controls over computer or related systems to
assure that only authorized personnel institute changes in master production and
control records,
Specifically, your high performance liquid chromatography (HPLC) and gas
chromatography (GC) data acquisition software, TotalChrom, did not have sufficient
controls to prevent the deletion or alteration of raw data files. During the inspection,
the investigator observed that the server that maintains electronic raw data for HPLC
and GC analyses (the J drive) contains a folder named Test, and that chromatographic
methods, sequences, and injection data saved into this folder can be deleted by
analysts. The investigator also found that data files initially created and stored in the
Test folder had been deleted, and that back-up files are overwritten.
In addition, because no audit trail function was enabled for the Test folder, your firm
was unable to verify what types of injections were made, who made them, or the date
or time of deletion. The use of audit trails for computerized analytical instrumentation
is essential to ensure the integrity and reliability of the electronic data generated
EXAMPLE OF FDA DATA INTEGRITY
VIOLATIONS (2/2)
Examples of deficiencies in Production:
Warning Letters issued to India based Manufacturer (Dec 2015)
You lacked audit trails or other sufficient controls to facilitate traceability of the
individuals who access each of the programmable logic controller (PLC) levels or ManMachine Interface (MMI) equipment.
You had no way to verify that individuals have not changed, adjusted, or modified
equipment operation parameters.
Password shared by four or five individuals
you had not established or documented a control program to describe the roles and
responsibilities of production equipment system administrators.
You suggested that traceability to the individual operator could be determined through
a hybrid system using the batch manufacturing record and equipment logbook.
However, because you used shared login credentials that did not permit identification
of a specific person using the shared login, you have not shown how your hybrid system
could link specific actions to a specific operator.
EXAMPLE OF DATA INTEGRITY FAILURE
BY EMA (HPRA)
Examples of deficiencies in Production:
A generic operator password was in use
A single generic user name and password was used to access and operate the equipment.
There was no controlled recipe in place to confirm that parameter settings on the machine
were those approved.
The time on the HMI was incorrect the actual time (taken from the wall clock in the
packaging area was recorded at 12:15, the machine time was displayed as 11:08.
Audit trails were not reviewed.
The audit trail could not be generated at the time of inspection.
The print out function was not enabled and there was no assessment to determine if stored
data could be securely transferred or downloaded to storage media in an intelligible format
for review
The system and security for archiving of data was not known
The User Requirement Specification did not specifically state all the requirements for the
machine and was not linked to any critical process parameters / variables
GLOBAL RULE FOR IT COMPLIANCE
SIMILAR TO
Annex 11
TERRITORY: EU Community Market
TARGET: Computerized Systems
LEGAL BASIS: This document provides
guidance for the interpretation of the
principles and guidelines of good
manufacturing practice (GMP) for
medicinal products as laid down in
Directive 2003/94/EC for medicinal
products for human use and Directive
91/412/EEC for veterinary use.
ULTIMATE
PURPOSE:
Where
a
computerized system replaces a manual
operation, there should not be a
resultant decrease in product quality,
process control or quality assurance
REGULATORY SCOPE: GMP Pharma &
Veterinary
EFFECTIVE DATE: June 2011
21 CFR Part 11
TERRITORY: US Market
TARGET: Computerized Systems
LEGAL BASIS: Section of the US Law which
applies to electronic records submitted to
the agency under requirements of the
Federal Food, Drug, and Cosmetic Act and
the Public Health Service Act
ULTIMATE PURPOSE: To 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.
REGULATORY SCOPE: GxP
EFFECTIVE DATE: August 1997
US 21 CFR Part 11 & EU GMP Annex 11 are the equivalent
Global standards
CHINA CFDA Computer Rule
BRASIL Anvisa Title VII: Computer information systems
CANADA Health PIC/S Annex 11: Computerised Systems
AGENCIES REACTIONS
Due to the recurrent inspectional findings, almost every
Regulatory Agency has provided guidances to the
Pharmaceutical firms oriented to
Clarify Regulatory expectations
Prevent Data Integrity violations
2015-2016 NEW GUIDELINES
MHRA
This document provides MHRA
guidance on GMP data integrity
expectations for the pharmaceutical
industry. This guidance is intended
to complement existing EU GMP
relating to active substances and
dosage forms, and should be read in
conjunction with national medicines
legislation and the GMP standards
published in Eudralex volume 4
FDA
WHO
The purpose of this guidance is to
clarify the role of data integrity in
current
good
manufacturing
practice (CGMP) for drugs, as
required in 21 CFR parts 210, 211,
and 212
These guidelines highlight, and in
some
instances
clarify,
the
application of data management
procedures.
The focus is on those principles that
are implicit in existing WHO
guidelines and that if not robustly
implemented can impact on data
reliability and completeness and
undermine the robustness of
decision making based upon that
data.
KEY DEFINITIONS (1/4)
TERM
MHRA
WHO
FDA
DATA
INTEGRITY
The extent to which all data are
complete, consistent and
accurate throughout the data
lifecycle.
Data integrity is the degree to which a
collection of data is complete, consistent and
accurate throughout the data lifecycle. The
collected data should be attributable, legible,
contemporaneously recorded, original or a
true copy, and accurate. Assuring data
integrity requires appropriate quality and risk
management systems, including adherence
to sound scientific principles and good
documentation practices.
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)
DATA
Information derived or obtained
from raw data (e.g. a reported
analytical result)
Data means all original records and certified
true copies of original records, including
source data and metadata and all subsequent
transformations and reports of this data,
which are recorded at the time of the GxP
activity and allow full and complete
reconstruction and evaluation of the GxP
activity.
Data should be accurately recorded by
permanent means at the time of the activity.
Data may be contained in paper records
(such as worksheets and logbooks),
electronic records and audit trails,
photographs, microfilm or microfiche, audioor video-files or any other media whereby
information related to GxP activities is
recorded
Electronic record means any combination
of text, graphics, data, audio, pictorial, or
other information representation in digital
form that is created, modified,
maintained, archived, retrieved, or
distributed by a computer system.
KEY DEFINITIONS (2/4)
TERM
MHRA
WHO
FDA
METAD
ATA
Metadata is data that describe the
attributes of other data, and provide
context and meaning. Typically, these
are data that describe the structure,
data elements, inter-relationships and
other characteristics of data. It also
permits data to be attributable to an
individual.
Metadata are data about data that provide the
contextual information required to understand
those data. Typically, these are data that
describe the structure, data elements,
interrelationships and other characteristics of
data. They also permit data to be attributable
to an individual.
Metadata is the contextual information
required to understand data. A data value is
by itself meaningless without additional
information about the data. Metadata is
often described as data about data.
Metadata is structured information that
describes, explains, or otherwise makes it
easier to retrieve, use, or manage data. For
example, the number 23 is meaningless
without metadata, such as an indication of
the unit mg. Among other things,
metadata for a particular piece of data could
include a date/time stamp for when the
data were acquired, a user ID of the person
who conducted the test or analysis that
generated the data, the instrument ID used
to acquire the data, audit trails, etc.
For example, in weighing the number 8 is
meaningless without metadata, i.e. the unit,
mg. Other examples of metadata may include
the time/date stamp of the activity, the
operator ID of the person who performed the
activity, the instrument ID used, processing
parameters, sequence files, audit trails and
other data required to understand data and
reconstruct activities.
RAW
DATA
Original records and documentation,
retained in the format in which they
were originally generated (i.e. paper
or electronic), or as a true copy. Raw
data must be contemporaneously and
accurately recorded by permanent
means. In the case of basic electronic
equipment which provides only a
printed data output (e.g. balance or
pH meter), the printout constitutes
the raw data.
No clear definitions available
Source data included in the definition of data.
No clear definitions available
KEY DEFINITIONS (3/4)
TERM
MHRA
WHO
FDA
AUDIT TRAILS
Audit trails to show all changes
to the data while retaining
previous and original data. It
should be possible to associate
all changes to data with the
persons making those changes,
and changes should be time
stamped and a reason given.
Users should not have the ability
to amend or switch off the audit
trail
An audit trail is a process that captures
details such as additions, deletions, or
alterations of information in a record, either
paper or electronic, without obscuring or
over-writing the original record
Computer generated audit trails shall retain
the original entry and document the user ID,
time/date stamp of the action, as well as a
reason for the action, as required to
substantiate and justify the action.
Computer-generated audit trails may
include discrete event logs, history files,
database queries or reports or other
mechanisms that display events related to
the computerized system
Audit trail means a secure, computergenerated, time-stamped electronic
record that allows for reconstruction of
the course of events relating to the
creation, modification, or deletion of an
electronic record.
An audit trail is a chronology of the
who, what, when, and why of a
record.
Electronic audit trails include those that
track creation, modification, or deletion
of data (such as processing parameters
and results) and those that track actions
at the record or system level (such as
attempts to access the system or
rename or delete a file).
DATA LIFE CYCLE
All phases in the life of the data
(including raw data) from initial
generation
and
recording
through processing (including
transformation or migration),
use, data retention, archive /
retrieval and destruction.
A planned approach to assessing and
managing risks to data in a manner
commensurate with potential impact on
patient safety, product quality and/or the
reliability of the decisions made throughout
all phases of the process by which data is
created, processed, reviewed, analyzed and
reported, transferred, stored and retrieved,
and continuously monitored until retired
No indications
KEY DEFINITIONS (4/4)
MHRA
WHO
FDA
COMPUTERIZED
SYSTEM
No definition
A computerized system collectively
controls the performance
of one or more automated business
processes.
It includes computer hardware,
software, peripheral devices,
networks, personnel and
documentation, e.g. manuals and
standard operating procedures
Computer or related systems can refer to
computer hardware, software, peripheral
devices, networks, cloud infrastructure,
operators, and associated documents
(e.g., user manuals and standard
operating procedures)
VALIDATION
Computerised systems should
comply with the requirements of
EU GMP Annex 11 and be validated
for their intended purpose.
implementation and confirmation
during validation of computerized
systems that all necessary controls for
good documentation practices for
electronic data are in place
and that the probability of the
occurrence of errors in the data is
minimized
The collection and evaluation of data
which establishes scientific evidence that
a process is capable of consistently
delivering quality products
AUTOMATION SYSTEM FOR
MANUFACTURING (1/5)
7
DOMAIN
CONTROLLER
DOMAIN
CONTROLLER
SERVER DB
SERVER
HISTORIAN
SERVER WEB
SCADA CLIENT
SCADA CLIENT
LEVEL 2
SCADA SERVER
MACHINE AND AUTOMATION SYSTEMS
LEVEL 1
DEVICES AND INSTRUMENTS
LEVEL 0
MAIN FUNCTIONS
OPERATOR PANELS
[1] [7] Access Control and Security of information
[1] Recipe Management
[1] Alarm monitoring and controls
[2] Recording and monitoring of process parameters
[3] Archiving of process parameters
[4] Printing of ERs
MAIN ELECTRONIC RECORDS
[1] [2] Recipes (Static)
[2] [3] Trends (Dynamic)
[1] [2] Alarms (Static)
[3] Process Results (Static)
AUTOMATION SYSTEM FOR
MANUFACTURING (2/5)
2
SERVER DB
SCADA SERVER typical functions
SCADA SERVER
MACHINE AND AUTOMATION
SYSTEMS
Communication with machines/equipment and real-time
database data with information exchanged between level
1 and level 2.
Capturing and Recording of alarms on the Database Server
Capturing and Recording of process variables (Trends) on
the Database Server
Management of process sequences (Recipes)
Recording of process events included in the reports on the
Database Server
Monitoring and Diagnostic functions on the network
Alarm Management Real Time
AUTOMATION SYSTEM FOR
MANUFACTURING (3/5)
2
SERVER DB
SCADA SERVER
MACHINE AND AUTOMATION
SYSTEMS
SERVER
HISTORIAN
DB SERVER DB, where these (typical) data are
maintained:
TREND: process values recorded by the system
Historical ALARMS: alarms detected by the system and related
notes / comments (if any)
Historical EVENTS: access to the systems and system operations
AUDIT TRAIL
GENERAL PARAMETERS: parameters used by more than one
recipe
RECIPES: it contains recipe data and relevant recipe-specific
parameters
PROCESS EVENTS: process events related to the execution of a
recipe
APPLICATION DATA: configurations and settings used by the
applications
AUTOMATION SYSTEM FOR
MANUFACTURING (4/5)
2
SERVER DB
SCADA SERVER
MACHINE AND AUTOMATION
SYSTEMS
SERVER
HISTORIAN
SCADA CLIENT
SCADA CLIENT typical functions
Monitoring of the plant through animated graphical pages in
real time
Management of devices
Management of general parameters
Management of Process Recipes
Alarm Managements
Display of Graphical Trends
Display of Audit Trail
Display of Historical Alarms
Display of Historical Events
Display of Process Reports
AUTOMATION SYSTEM FOR
MANUFACTURING (5/5)
2
SERVER DB
SCADA SERVER
MACHINE AND AUTOMATION
SYSTEMS
SERVER
HISTORIAN
SCADA CLIENT
HISTORIAN - typical functions
It contains historical data (trend) managed by the system.
The SW module to display the trend allows to:
Select a group of process parameters
Select specific process units
Zoom specific trend areas
Move the pointer within the trend
Select a temporal window
Export data
Print the trend
ELECTRONIC RECORDS SCADA
SYSTEMS
Electronic records usually managed by a SCADA system
Record
Description
Trends of
environmental
and process
parameters
Pressure, Temperature and Relative
Humidity values
Recipe
Process steps in a predefined sequence
Alarm Log
Alarms generated by the system
No Impact SetPoints
Field level automation data settings (i.e.
valve or shutter opening rate, fan speed, etc)
Critical Alarm
Set-Points
Admitted thresholds of critical
environmental parameters aimed at avoiding
OOS conditions
IT
Process
REGULATED ELECTRONIC RECORDS
SCADA SYSTEMS
GMP Electronic records usually managed by a SCADA system
Record
Trends of process or
environmental
parameters
Recipe
Alarm Log
No Impact Set-Points
IT
Critical Alarm Set-Points
GMP
Process
Predicate Rule
211.42 (b) (c); 211.68 (a);
211.180 (a); 211.188
GMP
YES
211.100 (b)
YES
211.42 (b) (c); 211.68 (a);
211.180 (a); 211.188
YES
---
NO
211.42 (b) (c); 211.68 (a);
211.180 (a); 211.188
YES
ANNEX 11 vs 21 CFR PART 11 MIND
MAPS
INFRASTRUCTURE
QUALIFICATION
QUALITY
AGREEMENT
RISK
MANAGEMENT
SUPPLIERS &
SERVICE PROV.
VALIDATION STDS
PROTOCOLS
RISK BASED
SUPPLIER
ASSESSMENT
REVIEW OF COTS
DOCUMENTATION
INVENTORY
USER
REQUIREMENTS
SUPPLIER
ASSESSMENT
BUILT-IN CHECKS
VALIDATION
VALIDATION
TESTING
ANNEX
11
DATA
INTEGRITY
ACCURACY
CHECKS
AUDIT TRAIL
DATA STORAGE
PRINTOUTS
DATA MIGRATION
CHANGE
CONTROL
PERSONNEL
PROCEDURES
ELECTRONIC
SIGNATURE
21 CFR PART 11
(REQUIREMENTS EXPLICITLY
ADDRESSED)
INCIDENT
MANAGEMENT
BUSINESS
CONTINUITY
PERIODIC REVIEW
ULTIMATE PURPOSE OF COMPUTER
REGULATIONS
21 CFR Part 11
Annex 11
ULTIMATE PURPOSE
Access Control
Authority Check
Security
Integrity
Link Raw Data and Result
Prevent Data Alteration
Archiving
Backup
Critical Process Steps
DATA
RELIABILITY
Change Control
Printout and eCopies
Who did what, when and why.
Previous entries must not be
obscured (Audit trail)
Traceability
Accountability
Who is Accountable from a
regulatory perspective?
DATA INTEGRITY PILLARS
CONTINUOS
MONITORING
Process Supervision
Audit Trail Review
Internal Audit
Periodic Review
SYSTEM
VALIDATION
SECURITY
FOUNDATION
DATA
GOVERNANCE
Security implementation
Configuration
User Profiling
System Intended Use
Verification
Security implementation
Documented Evidence of
System Compliance
Data Integrity Verification
Data Integrity Policy
System Inventory
Computer Validation Policy
Staff Training
Historical Data Integrity Assessment
ULTIMATE REQUIREMENT: REGULATORY
RECORDS ARE ALCOA (1/3)
Access Control
Authority Check
Security
Change Control
Traceability
Who did what, when and why.
Previous entries must not be obscured
ALCOA
ELECTRONIC CONTROL
AUTOMATION SYSTEMS AND RELATED
FUNCTIONS
ATTRIBUTABLE
Electronic Sign-In Log ons
Access Control: historical information regarding
user access level is available.
Electronic Signature (where used) with associated
meaning ( Author / Review)
Effective segregation of duties and related rolebased security
Audit Trail for create / modify / delete
Login Logout capabilities
Access log and query / filter functions
Electronic Signature (single or double) associated to
predefined reasons (e.g. Approval)
User Rights Definition
Event Logs
Segregation of Areas and Data
Audit Trail for process and administrative operations
LEGIBLE,
TRACEABLE,
PERMANENT
Long term archiving of process variables through Historian
Server
Sequence can be defined within versioned Recipes
Audit Trail for process and administrative operations
(printable / exportable, filter functions)
Configuration settings that limit access to enhanced security
rights
Readable Printing Functions
Export of Data in standard electronic format and store in
other memory devices.
Archiving, Keeping all records
Controls on sequence of events
Time Stamped - Audit Trails
Controls on overwriting
Controls on hidden fields or voided records (access
control, audit trail records)
Controls on voiding records.
ULTIMATE REQUIREMENT: REGULATORY
RECORDS ARE ALCOA (2/3)
Integrity
Link Raw Data and Result
Prevent Data Alteration
ALCOA
ELECTRONIC CONTROL
AUTOMATION SYSTEMS AND RELATED FUNCTIONS
ORIGINAL
Electronic Backup and verification in place,
either manual or by use of an automated tool
Back-up logs are often maintained but have
not been seen in the past as GMP records.
Archiving records should be locked such that
they cannot be altered or deleted without
detection and audit trail. The archive
arrangements must be designed to permit
recovery and readability of the data and
metadata throughout the required retention
period.
Review of Electronic Data
Review of Audit Trail
Backup can be defined with internal application functions or
through infrastructure tools.
Archiving and Retrieval of information from the Database Server or
from the Historian Server
Servers Access Controls and Segregation of Duty prevents data
alteration
Metadata are maintained together with raw data (e.g. Trend)
Recipe can be reviewed and approved according to pre-defined
workflow (numbers of a roles of reviewer / approver)
Audit Trail can be filtered for specific pre-defined critical
operations this makes easier and effective the review.
ACCURATE
correct, truthful,
Records review confirms the accuracy,
completeness, content and meaning of the
record or documented verification that the
printed records are representative of original
records
(preserving
all
accuracy,
completeness, content and meaning)
Recipe can be reviewed and approved according to pre-defined
workflow (numbers of a roles of reviewer / approver)
Audit Trail can be filtered for specific pre-defined critical
operations this makes easier and effective the review.
Trends are stored and archived together with the related metadata
Data are recorded in Database and Archiving System without any
human operation.
valid and reliable
ULTIMATE REQUIREMENT: REGULATORY
RECORDS ARE ALCOA (3/3)
Change Control
Traceability
Who did what, when and why.
Previous entries must not be obscured
Accountability
Who is Accountable from a
regulatory perspective?
ALCOA
ELECTRONIC CONTROL
AUTOMATION SYSTEMS AND RELATED FUNCTIONS
CONTEMPORANEOUS
Time and date stamps from system
clock networked or standalone,
operating or server clock Time and date
stamps are more easily adjusted on unnetworked systems.
Synchronization of clock between
systems
Locking of clocks on PCs if data is
captured locally
Secure system time/date stamps that cannot be altered by personnel
Time/date stamps can be synchronized across the GxP operations
It is possible discerning of the timing of one activity relative to
another (e.g. time zone controls).
Sequence can be defined within versioned Recipes
Critical processing step can be defined within the recipe with
parameter that must be within an appropriate limit, range..
An authorized signer can be accountable of each step
(contemporaneous)
Accountable Attributable
CONCLUSIONS
Prevent Data Integrity Violation through system functionalities
Meet the current Regulatory expectations:
Identify regulated electronic Records & Signatures
Implement control measures
Verify reliability of control measures within Validation process
Monitor effectiveness of these control measures
Routinely verify the adequacy of records content (e.g. Audit Trail
review)
WHO Guidance:
Implementation and confirmation during validation of computerized systems that all
necessary controls for good documentation practices for electronic data are in place and that
the probability of the occurrence of errors in the data is minimized;
