Data integrity PIC S
good practices for data management and integrity in regulatory GMP/GDP environments
good practices for data management and integrity in regulatory GMP/GDP environments
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8.5.2 Records should be appropriately controlled in these areas by designated
persons or processes in accordance with written procedures.
8.6 Filling out records
8.6.1 The items listed in the table below should be controlled to assure that a record
is properly filled out.
Item Completion of records
1. Expectations
Handwritten entries should be made by the person who executed the task 7 .
Unused, blank fields within documents should be voided (e.g. crossed-out),
dated and signed.
Handwritten entries should be made in clear and legible writing.
The completion of date fields should be done in an unambiguous format
defined for the site. E.g. dd/mm/yyyy or mm/dd/yyyy.
Potential risk of not meeting expectations/items to be checked
Check that handwriting is consistent for entries made by the same
person.
Check the entry is legible and clear (i.e. unambiguous; and does not
include the use of unknown symbols or abbreviations, e.g. use of ditto
(“) marks.
Check for completeness of data recorded.
Check correct pagination of the records and are all pages present.
2. Expectation
Records relating to operations should be completed contemporaneously 8 .
7 Scribes may only be used in exceptional circumstances, refer footnote 8.
8 The use of scribes (second person) to record activity on behalf of another operator should be considered
‘exceptional’, and only take place where:
The act of recording places the product or activity at risk e.g. documenting line interventions by sterile
operators.
To accommodate cultural or staff literacy / language limitations, for instance where an activity is performed
by an operator, but witnessed and recorded by a scribe. In these cases, bilingual or controlled translations
of documents into local languages and dialect are advised.
In both situations, the scribe recording should be contemporaneous with the task being performed, and should
identify both the person performing the observed task and the person completing the record. The person performing
the observed task should countersign the record wherever possible, although it is accepted that this countersigning
step will be retrospective. The process for a scribe to complete documentation should be described in an approved
procedure, which should; specify the activities to which the process applies and assesses the risks associated.
PI 041-1 25 of 63 1 July 2021