Product: pharmaceutical manufacturing facility
Failure to prevent unauthorized access or changes to data, and to provide adequate controls to prevent omission of data.
Your laboratory systems lacked access controls to prevent raw data from being deleted or altered. For example,
a) There is no assurance that you maintain complete electronic raw data for your Gas Chromatography (GC) instrument. FDA investigators observed multiple copies of raw data files in the recycle bin connected to the GC instrument QC-04 even in the presence of ?Do Not Delete Any Data? notes posted on two laboratory workstation computer monitors.
b) Employees were allowed uncontrolled access to operating systems and data acquisition software tracking residual solvent, and test and moisture content. Our investigators noted that there was no password functionality to log into the operating system or the data acquisition software for the GC, the High Performance Liquid Chromatography (HPLC) instrument QC-17, or the Karl Fischer (KF) Titrator QC-13.
c) HPLC SpinChrome and GC Lab Station data acquisition software lacked active audit trail functions to record changes in data, including original results, who made changes, and when.
In your response, you state that your laboratory GC, HPLC and KF systems are now password-protected and that you have begun drafting analytical software password procedures for the GC, HPLC and KF laboratory instruments. However, your response does not state whether every analyst will have their own user identification and password. You also mention plans to install a validated computer system. However, you did not provide a detailed corrective action and preventive action (CAPA) plan or conduct a review of the reliability of your historical data to ensure the quality of your products distributed to the U.S. market.
Inadequate controls of your computerized analytical systems raise questions about the authenticity and reliability of your data and the quality of your APIs. It is essential that your firm implements controls to prevent data omissions or alterations. It is critical that these controls record changes to existing data, such as the individuals making changes, the dates, and the reason for changes.
FDA District Office: CDRH