‘Controlled Evidence Ecosystem’ Needed: Expert Column
A review of FDA complete response letters issued between 2018 and 2025 using the keyword “validation” indicates that in about 2% of the letters, the agency raised concerns about audit trails, system validation, spreadsheet controls, data lineage, and incomplete source data traceability. Writing in a BioProcess International column, clinical research and quality professional Sidharth Amanthanarayan says that while those issues may seem minor and limited to a small group within a given company, “they can have a significant impact on a product’s timeline to approval.”
He says that while sponsors might have used various systems to track their data, the information presented to FDA inspectors could not be trusted or accepted because there was limited visibility into the audit trail or the systems’ validation histories.
According to Amanthanarayan, the solution is not to create more documents but to create a controlled evidence ecosystem in which data origin, movement, transformation, review, and approval are visible and defensible. “In that environment,” he says, “audit trails, validation packages, requirements traceability, defect management, migration controls, and secure data traceability are not administrative extras but are the evidence foundation that allows regulators to trust the conclusions built on the data.”