Stakeholder Ideas on FDA Electronic System Draft

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AdvaMed says it “strongly supports FDA’s efforts to provide recommendations regarding requirements in clinical investigations for when electronic systems, electronic records, and electronic signatures are considered trustworthy, reliable, and generally equivalent to paper records and handwritten signatures.” The association’s comments responded to an FDA draft Q&A guidance. Noting that the agency recommends conducting a risk-based assessment, such as for a decision to review an audit trail, AdvaMed says it would help if FDA gave examples of how a sufficient risk-based assessment can be conducted for different types of systems. The letter says it would also help to understand when FDA generally thinks that only performing user acceptance testing is adequate versus more robust types of validation.

AstraZeneca says it agrees that the guidance is necessary to supersede one earlier guidance and revise another. It provides a chart with specific line-by-line comments. Also giving a chart with specific comments was Bayer.

The International Society for Pharmaceutical Engineering suggests more clearly defining some terms in the draft and adding a comment relating to the information being maintained electronically. It also proposes specific line-by-line changes.

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