FDA Final Data Integrity Guidance Reviewed
The FDA 12/12/18 final guidance on data integrity and compliance with CGMP (current good manufacturing practice) says that management with executive responsibility has the role of creating a quality culture in which employees understand the importance of data integrity and are encouraged to identify and promptly report data integrity issues. Duane Morris attorneys write in an online alert that the absence of management support of a quality culture can lead to breakdown of quality systems and to CGMP noncompliance. To ensure CGMP compliance, they write, FDA recommends that management ask whether:
- controls in place to ensure that data is complete;
- activities are documented at the time of performance;
- activities are attributable to a specific individual;
- only authorized individuals can make changes to records;
- there is a record of changes to data;
- records are reviewed for accuracy, completeness, and compliance with established standards; and
- data are maintained securely from data creation through disposition after the record retention period.
“FDA links data integrity to the CGMP data lifecycle,” the alert says, “including creation, modification, processing, maintenance, archival, retrieval, transmission, and disposition of data after the record’s retention period ends. FDA recommends the use of system design and controls to simplify the detection of errors, omissions, and aberrant results.”