Programme Part 1:
Data Governance, Integrity & Quality, Regulations and Guidance
- Summary of EU and FDA GMP requirements
- MHRA, PIC/S and WHO Data Integrity Guidances
- FDA Guidance documents OOS, Inspection of QC labs
- Inspection findings 483 and warning letters
- Defining data integrity, “complete data” and „raw data“
Analytical Process Mapping and Where Are the Vulnerabilities
- Essential to map the process and identify all steps for traceability
- SOPs, analytical procedures & training of staff
- Internal and external auditing support
- Identifying data and the controls to ensure integrity
WORKSHOP I:
Assessment of an Analytical Process for Data Integrity Vulnerabilities of a Pharmacopoeial Loss on Drying Assay
Presented with a pharmacopoeial Loss on Drying (LOD) analysis attendees identify any data vulnerabilities in the process
Role of Sampling in Ensuring Data Integrity
- Why is proper sampling the key to ensuring the integrity and reliability of analysis?
- What are the key features of sampling?
Principles for the Generation of Data
- Qualified analytical instruments and validated Software
- Recording observational tests and instrument/system tests
- Identification of key vunerabilities
- Application of ALCOA++ principles
WORKSHOP II:
Generation of Data
- What are the requirements for raw data integrity?
- Three scenarios covering:
- a paper System
- a hybrid System
- a networked electronic System
Processing and Reporting of Data
- Paper / hybrid based systems
- Networked systems with electronic records and signatures
- Calculations and transformation of data manually and by computer applications
- Application of ALCOA++ principles to the process
- Calculating the reportable value and comparison with the specification
- Paper processes versus electronic processes
- Linkage with out of specification investigations (OOS)
WORKSHOP III:
Processing and Reporting of Data
- Reviewing an analytical record
- Scenario covering paper based record and an electronic system
Reviewing Data and Collating Records
- Identification and correction of errors for paper and electronic systems
- Do you have complete data?
WORKSHOP IV and facilitated Discussion: Reviewing analytical records; Do we have to check everything?
Using technical controls to aid the Reviewer
WORKSHOP V:
Data Review of an Excel Template
Application of ALCOA+ principles for the review of paper records
Second Person Review including Audit Trail Review
- Role of the second person review
- Determination that the reportable result is correctly calculated
- Identification and correction of errors for paper and electronic systems
- Facilitated Discussion: Reviewing audit trails by exception
WORKSHOP VI:
Facilitated Discussion
- Paper, Hybrid and Electronic Reporting Processes
- Discussion of the strengths and weaknesses of reporting processes
Key Learning Points and Final Discussion
End of Part 1 / Registration for Part 2
Programme Part 2:Introduction to the Course
Data Integrity Self Inspections and On-Site and Remote Audits of Hybrid and Electronic Systems- Observations and findings
- Remote audits: practicalities, limitations and Problems
- Overview of the FDA Draft Guidance on Remote Interactive Evaluations 2023
WORKSHOP VII:
Risk Assessment and Prioritisation
- So much to do but so little time – risk management in practice
- When conducting a data integrity audit which areas within a pharmaceutical quality system will be the focus?
- Feedback and discussion with the teaching team
WORKSHOP VIII:
Audit of an Excel Spreadsheet
- Attendees will be given an example of a spreadsheet
- What questions need to be asked to determine if there is sufficient Data Integrity and control?
- Feedback from the teaching team
WORKSHOP IX:
Auditing a Hybrid Standalone System
- A laboratory system is used in hybrid mode
- What questions should the auditor ask to determine if there are any data integrity problems?
- Feedback and discussion with the teaching team
WORKSHOP X:
Auditing a Networked Laboratory System – Audit Trail Review
- Review of audit trail entries is a key data integrity requirement of Annex 11
- Attendees will review the printout of an audit trail to determine if there any data integrity issues to be raised?
- Can the attendees find what those issues are?
- Feedback and discussion with the teaching team
WORKSHOP XI:
Electronic Signature Auditing
- Use of electronic signatures can mask some Data Integrity issues
- Can the attendees find what those issues are?
- Feedback from the teaching team
WORKSHOP XII:
Preparing for the Data Integrity Audit
In the first of three linked workshops, attendees will be given a laboratory scenario to answer the following questions:
- What will be the composition of the audit team?
- What will be their skills?
- What will be the duration of the audit?
WORKSHOP XIII:
Observations and Findings During a Laboratory Audit and Planning the Closing Meeting
- Each team will be provided with an audit of a laboratory with observations
- Teams will determine if there are any data integrity non-compliances with the regulations and laboratory procedures
- Teams will determine if any observations are findings (non-compliances) and grade the severity of each one
- Prepare for the closing meeting with the Head of the Laboratory and the business process owner of the systems
WORKSHOP XIV:
Feedback to the Auditees
- Teams will present the audit conclusions and the findings to the Head of the QC Laboratory and the business process owner of the Systems
- Discussion with the auditees of the findings