Question 21: What requirements
are made concerning physical protection?
Best Answer: Physical
protection must be adequate to the risk. Physical protection comprises the
protection of data storage
devices from unauthorised parties as well as the environmental impacts
influencing the respective
data storage devices.
A
DVD should not be put in the sun; but this will be less problematic with a hard
disk.
Question 22: What is the
difference between a clear printed printout and a normal printout?
Best Answer: “Clear
printed” means that apart from the values themselves, the units and the
respective context can
also
be seen in the printout.
Question 23: What controls are
required in the case of a change of configuration?
Best Answer: This
has to be defined system-specifically. Measures need to be defined according to
a risk
assessment.
Here,
a distinction can be drawn between configurations that are for intended use and
are only documented by means of a logbook (such as infrastructure, virus
scanner, …) and configurations which have to be formally authorised and
documented by means of a change control (such
as release work flow with electronic signature).
Question 24: Must changes which
are not GMP-relevant also be carried out in a controlled manner?
Best Answer: If
the whole system is not GMP-relevant = NO. If the system is GMP-relevant = YES,
because in an
integrated
system it must also be evaluated that there is no negative influence.
It
can also only be ascertained by means of a “risk assessment” that a standard
update or standard patch poses no risk and that it therefore can be registered
and performed.
Question 25: What does periodic
mean? What period of times is expected as a minimum, for example?
Best Answer: Periodic
in this case means regularly and recurrently. No minimum period of time is
defined. It must be
substantiated that the period of time is adequate in order to control the
process risk.
Question 26: Can such periodical
evaluations be incorporated in the annual report or PQR? Must they be incorporated
there?
Best Answer: They
can be incorporated in the Annual Product Review, but they need not be.
I
would not recommend to generally incorporate them in the Annual Product Review
as the periods of time in the Periodic Review can usually be longer than the
Annual Product Review since the systems are subject to strict change control
and possible deviations in the company are controlled by means of the CAPA
process.
Question 27: How often do users
have to change their passwords? How often must user profiles be checked?
Best Answer: The
frequency of change as well as the frequency of control of user profiles
depends on the risk.
Annex
11 does not pose any requirements on the frequency of password changes.
Question 28 : What exactly does
“all incidents” mean? Does it also mean service requests (such as resetting a password)?
Best Answer: It
means per definition all incidents. But the company can define what an incident
is and what the intended
use is.
Resetting
a password, for instance, can be a regular task of the administration and therefore
it is no incident since the system documents resetting via log files. Here, you
can limit the
incidents.
Question 29: Are workarounds
accepted for preventive actions?
Best Answer: Yes,
provided they are described and regulated – for instance, in SOPs.
Question 30: How often should
the readability of archived data be checked?
Best Answer: This
is to be defined by the company and depends on a set of further factors apart
from the type of system or data.
There
is no simple and general answer to this question since the readability of a
data storage device depends on various factors; including the technology used,
the storage conditions of the data storage devices and the reliability of the
requisite disk drives.
That
is the reason why the period of review should be defined based on the
identified risks, the criticality of the data and, if applicable, experience.
This point should in any case be a subject of the periodical evaluation.
“Trust but Verify “ Ronald Reagan
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