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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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Where appropriate, the reason for the correction should be clearly recorded

and verified if critical.

Initial and date the change made.

Specific elements that should be checked when reviewing records:

Check that the original data is readable not obscured (e.g. not

obscured by use of liquid paper; overwriting is not permitted).

If changes have been made to critical data entries, verify that a valid

reason for the change has been recorded and that supporting

evidence for the change is available.

Check for unexplained symbols or entries in records.

2. Expectation

Corrections should be made in indelible ink.

Specific elements that should be checked when reviewing records:

Check that written entries are in ink, which is not erasable, and/or will

not smudge or fade (during the retention period).

Check that the records were not filled out using pencil prior to use of

pen (overwriting).

8.8 Verification of records (secondary checks)

Item When and who should verify the records?

1. Expectation

Records of critical process steps, e.g. critical steps within batch records,

should be:

- reviewed/witnessed by independent and designated personnel at the

time of operations occurring; and

- reviewed by an approved person within the production department before

sending them to the Quality unit ; and

- reviewed and approved by the Quality Unit (e.g. Authorised Person /

Qualified Person) before release or distribution of the batch produced.

Batch production records of non-critical process steps is generally reviewed

by production personnel according to an approved procedure.

Laboratory records for testing steps should also be reviewed by designated

personnel (e.g.: second analysts) following completion of testing. Reviewers

are expected to check all entries, critical calculations, and undertake

appropriate assessment of the reliability of test results in accordance with

data-integrity principles.

Additional controls should be considered when critical test interpretations are

made by a single individual (e.g. recording of microbial colonies on agar

PI 041-1 27 of 63 1 July 2021

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