Any action related to medicinal products must be traceable, because the life and health of humans and animals are at stake.
The requirement that have to be fulfilled, in particular the multitude of regulations and meticulous documentation of all actual values and observations, are very different from the practices in other industries. Even though instructions are often read on screen and many records are entered directly into a computer system, an ironic interpretation of the acronym GMP still works: a Great Mass of Paper.
All work carried out in a GMP environment involves instructions, records and checklists.
Whether on paper or in electronic documents, careful handling is a prerequisite when dealing with large volumes of data. It is vital that documents or different versions of documents are not mistakenly or intentionally mixed up and data is not lost (data integrity). This is why a document management system must be in place which ensures that each member of staff can access an up-to-date approved version of a document when necessary. If an electronic system is used, the software must be validated, i.e. the main functions must be tested in advance to ensure that data or documents cannot be modified or deleted by mistake.
Companies are increasingly phasing out paper documents. Work instructions, specifications, reports and other documents are not only created using a computer system, they are also electronically approved and distributed. Anyone who needs process instructions, SOPs or other documents, must open the document in the computer system and read it directly on screen. Many of these documentation systems facilitate the printing of forms, checklists and work instructions. Staff members should only use these print-outs for the period of time specified (usually 24 or 48 hours) to ensure that older versions are not used by mistake.
Informal memos are not permitted in a GMP environment. This applies to both instructions and records.
All documents must state clearly:
These documents are referred to as controlled documents. They are only distributed to relevant persons and are subject to version control, i.e. they cannot be modified at random by any member of staff.
Particular care should be taken when copying documents: every copy, e.g. of instructions, records or printouts, must be complete and legible to ensure that no information is lost. The creation of uncontrolled copies is not permitted. There is a danger that changes to the original or new versions have already been authorised, and somebody is still working with these uncontrolled copies. Errors are inevitable. Companies that use paper-based documentation must define who is authorised to make copies, how originals and authorised copies are identified (e.g. using numbers, watermarks or special paper), and how older versions are taken out of circulation.
In a GMP environment, only up-to-date authorised instructions must be used. Drafts or uncontrolled copies must never be used.
Some data and documents are repeatedly used during a normal working day, e.g. for evaluations and reviews. Other data will supposedly never be used again – until a customer files a complaint or a quality issue is discovered. Every single detail is suddenly important when the frantic search for the cause of an error commences. Even documents that have not been used in a long time are examined. It pays off if everything has been recorded and all of the required documents can be retrieved immediately.
Accurate, complete and comprehensive documentation has many advantages:
To ensure that all of the collected data is available until the life cycle of a medicinal product ends or until the decommissioning of a production facility, the data must be archived for many years – 10 to 15 years is a common time frame. An SOP describes in which form (on paper or storage media), at which storage sites and for what periods of time the individual types of document must be archived and how the company ensures that the information can be retrieved at any time.
If electronic storage media are used for archiving, the company must ensure that suitable software and qualified hardware is archived as well and that the storage media are protected against damage. A major problem when archiving electronic data for an extended period of time remains the question of how long the stored data will remain accessible and unchanged. For this reason, the law requires that significant data is backed up on a regular basis.
Dr. Christine Oechslein
GMP Instructor, Germany
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