Data integrity has been a focus for pharmaceutical regulatory inspections for a number of years and looks set to remain of concern to regulators and manufacturers for many years to come. Many inspection reports from regulatory agencies around the world cite data integrity as a cause of observations and enforcement action, and measures taken by regulators to restrict the commercial activities of manufacturers on the grounds of data integrity violations have serious consequences.
This 2-day course explains the background to the data integrity regulations and sets out the expectations of pharmaceutical regulators. All the current data integrity guidances emphasise a risk-based approach to compliance, and the course explains how to evaluate and control data integrity risks. Not all data integrity risks require control, and regulated companies should focus effort on the most critical risks. A key resource in relation to electronic records is GAMP 5 (second edition), which deals with controlling risk and managing computerised systems over their life cycle. GAMP 5 recommendations will be dealt with in detail, and practical advice on the appropriate use of Excel spreadsheets given. Data integrity should not be thought of as an exclusively analytical problem, and examples of data integrity violations in production will illustrate the risks in other areas.
The course includes practical exercises which are designed to reinforce the taught component. These include data integrity risk assessments, categorising of computerised data systems and conducting a data integrity audit.
Learning Objectives:
Attendees will:
- Understand what data integrity is and why it is so important for patient safety
- Recognise that there are many causes of data integrity breaches apart from deliberate fraud
- Know the current regulatory expectations
- Appreciate the difference between static and dynamic records, and be able to apply acceptable strategies for the retention of both types of record
- Be able to categorise and validate GxP computerised systems according to GAMP 5
- Understand the importance of training and quality culture in avoiding regulatory enforcement action
- Learn how to respond to data integrity observations in inspection reports
- Learn how to prevent, detect and remedy data integrity problems
Who will Benefit:
- QA managers and personnel
- Laboratory managers and supervisors
- Production managers and supervisors
- Analysts
- IT/IS managers and system administrators
- Software developers
- Regulatory affairs
- Training departments
- Documentation departments
- Consultants
- Auditors
Companies and departments:
- Pharmaceutical development and Quality control laboratories
- API manufacturers
- Medical device companies
- Contract laboratories
- Clinical research organisations
- Suppliers and service providers of instruments and computer systems
- 08.30 AM - 09.00 AM: Registration
- 09.00 AM: Session Start
- Day 1 – Lectures and Workshop Exercises
- Historical background and data integrity definitions
- Data integrity and patient safety/product efficacy
- The evolution of GxP regulations – driven by both criminal activity and honest mistakes
- The US FDA’s debarment policy
- Evolution of data integrity guidances
- Introduction to GAMP 5
- Early data integrity cases
- Regulatory expectations
- ALCOA and ALCOA+
- Static and dynamic records
- Essential elements of data governance
- Non-conformance trends
- Data integrity controls
- Data integrity risks in sample analysis and production
- Investigating data integrity problems
- Metadata, audit trails and audit trail review
- Exercise: deliberate falsification
- Data integrity risk assessment
- Quality risk management: ICH Q9
- Risk management process
- Approaching a data integrity risk assessment
- Controlling risk in computerised systems
- Configuration and life cycle management
- Operating system and application software considerations
- Computerised systems
- Audit trails, access controls and user permissions
- Exercise: reviewing records for data integrity violations
- Excel spreadsheets
- Introduction to computerised data system validation
- Day 1 conclusions
- Extracts from regulatory enforcement letters
- Addressing data integrity problems
- Day 2 - Lectures and Workshop Exercises
- Managing computerised data systems
- Guidance
- 21 CFR Part 11
- EU Annex 11
- GAMP 5
- Life cycle management and risk assessment
- Supplier assessment
- Guidance
- Computerised system validation
- Validation planning
- Policy
- Plans
- Documentation
- System description
- Introduction to software testing
- Validation planning
- Conducting a data integrity audit
- Planning the audit
- Conducting the audit
- Policies, procedures, practices
- Training
- Quality culture
- Evaluating quality risk
- Mitigating data integrity risks
- Managing client audits and regulatory inspections
- The importance of data integrity risk assessments/action plans
- The audit/inspection process
- Client audits
- Confidentiality
- Result checking and reporting
- Regulatory inspections
- Behaviour during inspection
- Responding to non-conformance observations
Mark Powell
Director, Mark Powell Scientific Limited
Dr Mark Powell is a Fellow of the Royal Society of Chemistry (RSC) with over thirty years’ experience as an analytical chemist. Mark was Honorary Treasurer of the RSC’s Analytical Division and led a working group on continuing professional development until July 2016, when his term of office ended. Between 2003 and 2013, he was the Analytical Development Manager, and later Scientific Manager, of a UK-based contract research organization which specialized in early-stage oral drug development. During this time, he was responsible for method validation, verification and transfer activities, as well as the qualification of laboratory instruments and computerized data systems. In 2013, he set up Mark Powell Scientific Limited, which provides training and consultancy services to pharmaceutical companies. Mark has since enjoyed working with companies of all sizes around the world on a variety of training and consultancy assignments, and has recently co-authored a White Paper on Pharmaceutical Data Integrity for the laboratory supply company VWR.
