21 CFR Part 11 Compliance.com

Word Version Control

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  • Lack of Compliance Features 
    - Security:              Files are stored on local hard drives or network
                                 servers, and may be easily accessible to unauthorized
                                 individuals.
    - Audit Trail:          There are no audit trail of changes made to the file,
                                  even when made by authorized personnel.
    - eSignatures:         There is no provision of electronic signatures.
    - Version Control:  There is no provision to create a controlled version
                                  for each modification made to the file.

  • FDA Inspections, 483's and Warning Letters
    GxP (GLP, GMP, GCP) reports generated by word applications are electronic records and should comply with FDA’s 21 CFR Parts 11/58. For critical records 21 CFR Part 11 controls should be implemented. Most critical are data integrity, data accuracy, audit trails and electronic signatures. Currently there are no specific FDA guidelines on using word applications utilizing macros and VBA in regulated environments. On the other hand word based applications using VBA and macros have been audited as part of FDA inspections and many warning letters have been issued. While the original inspection resulted in several observations and a warning letter, the findings from the follow up have been accepted and can be considered as good practices for using word applications in FDA regulated environments.

  • Damaged reputation
    Using word based applications that are not completely validated, in a non-compliant mode can damage your company's reputation and even delay FDA's approval process.

  • Productivity Loss 
    Legal costs and fines, damaged reputation issues all negatively affect your efficiency and the efficiency of your employees.

 

 

 

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