Electronic Signature Posts

Beware: Annex 11 Has Implications for Medical Devices

Beware: Annex 11 Has Implications for Medical Devices

Mark Crawford

In January 2011 the European Medicine Evaluation Agency (EMEA) released an updated version of the European Union’s GMP Annex 11 for computerized systems (Annex 11), as well as an expanded version of Chapter 4 on document management.

These are significant changes for the pharmaceutical industry—the new Annex 11, for example, is about four times larger than the older version. EMEA decided to overhaul Annex 11 to keep up with the increased use of computerized systems in all aspects of good manufacturing practice (GMP), as well as their increased complexity. Annex 11 now addresses the regulatory needs of modern IT systems and imparts extensive requirements for compliance at all levels—for example, it dictates how computer printouts of critical records must indicate if any data has been changed since the original entry. Other key topic areas include business continuity, incident management, electronic signatures, migrating and archiving documents, and more comprehensive security controls. (more…)

Moving Into the New Generation of 21 CFR Part II

In 1997, it wasn’t uncommon to hear “You’ve got mail!” when you used your telephone to log onto the Internet. This is the same year that the Food and Drug Administration (FDA) issued 21 CFR Part 11, electronic records. Six years later, in 2003, you were probably using broadband and going directly to the Internet. In this year, the FDA issued a Guidance for Industry of Part 11, Electronic Records; Electronic Signatures. It shouldn’t be any surprise that seven years later, the FDA is piping up about Part 11 again. This time, it is in the form of revised enforcement discretion of Part 11.  (more…)