Warning Letters Focus on Document Control, Data Integrity
Recent Warning Letters show that document control and data integrity (as well as complaint handling and corrective and preventive actions) remain key concerns of FDA investigators, according to an analysis by AssurX. “Today, FDA cGMPs and ISO standards require a document control system that demonstrates product safety and reliability,” the group says. “Automated systems drive processes that integrate workflow and data capture with applications, databases, notifications and tracking. Getting rid of paper and investing in the right electronic solution can eliminate untold outlays for compliance violations.”
To illustrate FDA concerns, AssurX reviewed a 2/24 Warning Letter to Megafine Pharma that cited a lack of document control, including:
- Failure to control the issuance, revision, superseding, and withdrawal of all documents by maintaining revision histories
- Failure to establish and follow adequate written procedures for cleaning equipment and its release for use in API manufacture, and to maintain adequate records of major equipment usage
Another Warning Letter cited by Assurx that highlights the agency’s concerns was issued to medical device maker Denttio. The letter noted several document control system compliance issues including:
- Failure to establish a design history file
- Failure to provide records to demonstrate that it had conducted a risk analysis to identify potential hazards and control measures
- Failure to implement and maintain device master records
- Failure to establish procedures for finished device and incoming product acceptance