Faculty: Carolyn Troiano
Electronic record/electronic signature (ER/ES) capabilities are extremely important and should be built into FDA-regulated computer systems to meets compliance with 21 CFR Part 11. This webinar will help you to strategize the development of a company philosophy and approach, as well as how to incorporate it into the overall computer system validation program for individual systems that have this capability. In the late 1990s, the FDA enacted the 21 CFR Part 11 Guidance. Successful implementation across the pharmaceutical and other regulated industries resulted in mixed responses. There are explicit restrictions that arise when using ER/ES capability; this would include the elimination of print capability. This is done to prevent users from making decisions based on a paper records as opposed to the electronic records. Specific identification of users is mandatory to ensure the person signing the record is the same person whose credentials are being entered and verified by the system. Rules for changing passwords must be rigorously adhered to and the passwords must be kept secure. It’s crucial that the system specify the exact meaning of the signature. It may be that the person conducted the work, recorded the result, reviewed the result, or approved the result. There should be appropriate and clear segregation of duties i.e., the person recording the result is not the same as either the person reviewing or the person giving the final approval.
Get a detailed understanding of the FDA regulations that are application to the FDA’s 21 CFR Part 11 guidance on electronic records/electronic signatures (ER/ES) for computer systems. This will help ensure you develop an appropriate validation strategy and achieve the meticulousness required to prove that a system does what it purports to do. We will also be able to ensure that a system is maintained in a validated state throughout its entire life cycle, from conception through retirement. ER/ES capability can vary, however, the approach should be based on the specific case and the risk of failing to meet the guidance associated with it.
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