CGMP Integrity and Compliance Q&A Guidance
FDA has issued a guidance, Data Integrity and Compliance with Drug CGMP Questions and Answers, to clarify the role of data integrity in current good manufacturing practice (CGMP) for drugs. The document says the term CGMP basically refers to CGMPs for drugs, including biologics. “This guidance provides the agency’s current thinking on the creation and handling of data in accordance with CGMP requirements,” it says.
The guidance says the agency expects that all data will be reliable and accurate. The CGMP regulations and guidance allow for flexible and risk-based strategies to prevent and detect data integrity issues. “Firms should implement meaningful and effective strategies to manage their data integrity risks based on their process understanding and knowledge management of technologies and business models,” FDA writes. “Meaningful and effective strategies should consider the design, operation, and monitoring of systems and controls based on risk to patient, process, and product. Management’s involvement in and influence on these strategies is essential in preventing and correcting conditions that can lead to data integrity problems. It is the role of management with executive responsibility to create a quality culture where employees understand that data integrity is an organizational core value and employees are encouraged to identify and promptly report data integrity issues. In the absence of management support of a quality culture, quality systems can break down and lead to CGMP noncompliance.”