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Welcome to your weekly serving of data integrity wisdom. This week, weâre diving into the A for Accurate in ALCOA. No shortcuts, no guessing gamesâaccurate data is the heart of compliance, safety, and, letâs face it, your peace of mind.
You wouldnât eyeball the salt when baking a soufflĂŠ, right? Same goes for your GMP activities. Accurate data is what keeps patients safe and auditors happy. Letâs get into it!
Accurate data is data thatâs error-free, truthful, and precise. In the world of GMP, that means no fudging numbers, no guessing values, and no sneaky tweaks. Accuracy builds trust in your processes and productsâand the FDA has no tolerance for anything less.
Hereâs how accuracy plays out across different settings, along with the FDA requirements that keep things in check:
Scenario: A lab technician uses HPLC to test raw material samples for identity, purity, and strength.
FDA Expectations in Action:
Equipment must be calibrated and validated to ensure reliable readings (21 CFR 211.68).
Test results must be documented immediately and reflect the actual observed valuesâno âguesstimatesâ (211.160).
A second technician or automated system must verify test data and calculations (211.194).
Audit trails must show no unauthorized changes to data (21 CFR Part 11).
⨠Lesson: In the lab, accuracy starts with calibrated equipment and ends with clear, tamper-free records.
Scenario: An operator measures the volume of an API for a batch.
FDA Expectations in Action:
Weighing and measuring equipment must be routinely calibrated (211.68).
The operator must record the exact weight or volume, no rounding or editing (211.100).
Any deviations must be documented, investigated, and resolved (211.192).
Supervisors must verify the records for accuracy before batch approval (211.186).
⨠Lesson: Precision on the shop floor ensures every batch meets its intended qualityâand protects patient safety.
Scenario: A QC analyst documents stability test results on a paper form.
FDA Expectations in Action:
Results must be written clearly and legiblyâno white-out or creative cover-ups (211.186).
Any corrections must include the original data, reason for the change, and initials of the person making the correction (211.194).
A reviewer must verify the accuracy and completeness of the data (211.194).
Forms must be stored securely to prevent tampering (211.68).
⨠Lesson: Paper records are like your grandmaâs recipesâkeep them clean, complete, and untouched by questionable edits.
Scenario: A technician logs batch test results into a LIMS.
FDA Expectations in Action:
LIMS software must be validated to ensure accurate data entry and calculations (21 CFR Part 11).
Audit trails must show timestamps for data entry, modifications, and approvals (21 CFR Part 11).
Access to the system must be controlled, allowing only authorized personnel to modify data (211.68).
Electronic records must include raw results, calculations, and all supporting data (211.194).
⨠Lesson: Electronic records donât just store data; they tell a story. Make sure itâs an accurate one.
Whether youâre in the lab, on the shop floor, or managing records, accurate data is non-negotiable. The FDAâs expectations are clear:
Use validated systems and calibrated equipment.
Record data immediately and exactly as observed.
Protect data integrity with controlled access and audit trails.
Getting it right every time doesnât just keep you compliantâit keeps patients safe and builds trust in your work.
Whatâs the â+,â you ask? Itâs the extra garnish on your compliance sundaeâthe modern extensions to ALCOA that take data integrity to the next level. Think of it as the âchefsâ kissâ to your GMP practices. đ
Stay tuned for next weekâs edition, where weâll explore what the + stands for, why it matters, and how it helps you go above and beyond in the world of data integrity.
Have a data accuracy dilemma or a scenario youâd like us to explore? Drop us an email, and weâll cook up some answers in the next edition! đŠâđł
Stay accurate and awesome,
The Data Dish Team
Email: [email protected]