OpenLAB ELN Supporting 21 CFR Part 11 Compliance

Similar documents
Agilent ICP-MS ChemStation Complying with 21 CFR Part 11. Application Note. Overview

Integration of Agilent OpenLAB CDS EZChrom Edition with OpenLAB ECM Compliance with 21 CFR Part 11

Integration of Agilent UV-Visible ChemStation with OpenLAB ECM

ChromQuest 5.0. Tools to Aid in 21 CFR Part 11 Compliance. Introduction. General Overview. General Considerations

Exhibitor Software and 21 CFR Part 11

SDA COMPLIANCE SOFTWARE For Agilent ICP-MS MassHunter Software

ISSUE N 1 MAJOR MODIFICATIONS. Version Changes Related Release No. PREVIOUS VERSIONS HISTORY. Version Date History Related Release No.

Compliance Matrix for 21 CFR Part 11: Electronic Records

COMPLIANCE. associates VALIDATOR WHITE PAPER. Addressing 21 cfr Part 11

Adobe Sign and 21 CFR Part 11

21 CFR Part 11 Module Design

21 CFR PART 11 COMPLIANCE

TECHNICAL BULLETIN [ 1 / 13 ]

NucleoCounter NC-200, NucleoView NC-200 Software and Code of Federal Regulation 21 Part 11; Electronic Records, Electronic Signatures (21 CFR Part 11)

REGULATION ASPECTS 21 CFR PART11. 57, av. Général de Croutte TOULOUSE (FRANCE) (0) Fax +33 (0)

WHITE PAPER AGILOFT COMPLIANCE WITH CFR 21 PART 11

EZChrom Elite Chromatography Data System. Regulatory Compliance with FDA Rule of Electronic Records and Electronic Signatures (21 CFR Part 11)

The Impact of 21 CFR Part 11 on Product Development

Agilent Response to 21CFR Part11 requirements for the Agilent ChemStation Plus

Compliance of Shimadzu Total Organic Carbon (TOC) Analyzer with FDA 21 CFR Part 11 Regulations on Electronic Records and Electronic Signatures

Sparta Systems Stratas Solution

Sparta Systems TrackWise Solution

Sparta Systems TrackWise Digital Solution

FDA 21 CFR Part 11 Compliance by Metrohm Raman

21 CFR Part 11 FAQ (Frequently Asked Questions)

ComplianceQuest Support of Compliance to FDA 21 CFR Part 11Requirements WHITE PAPER. ComplianceQuest In-Depth Analysis and Review

Using "TiNet 2.5 Compliant SR1" software to comply with 21 CFR Part 11

Validation Checklist Appendix A WiZARD2 Secure and 21 CFR 11 Requirements

System Assessment Report Relating to Electronic Records and Electronic Signatures; 21 CFR Part 11. System: tiamo (Software Version 2.

Metrohm White paper. FDA 21 CFR Part 11 Requirements for NIR Spectroscopy. Dr. N. Rühl

INFORMATION. Guidance on the use of the SM1000 and SM2000 Videographic Recorders for Electronic Record Keeping in FDA Approved Processes

21 CFR Part 11 LIMS Requirements Electronic signatures and records

System Assessment Report Relating to Electronic Records and Electronic Signatures; 21 CFR Part 11. System: StabNet (Software Version 1.

White Paper Assessment of Veriteq viewlinc Environmental Monitoring System Compliance to 21 CFR Part 11Requirements

Using "IC Net 2.2 " software to comply with 21 CFR Part 11

Electronic Data Processing 21 CFR Part 11

System Assessment Report Relating to Electronic Records and Electronic Signatures; Final Rule, 21 CFR Part 11

Technical Information

Assessment of Vaisala Veriteq viewlinc Continuous Monitoring System Compliance to 21 CFR Part 11 Requirements

System Assessment Report Relating to Electronic Records and Electronic Signatures; Final Rule, 21 CFR Part 11. System: tiamo 2.3

Using the Titrando system to comply with 21 CFR Part 11

Using Chromeleon 7 Chromatography Data System to Comply with 21 CFR Part 11

Meeting regulatory compliance guidelines with Agilent ICP-MS MassHunter and OpenLAB Server

Cell Therapy Data Management

Using Chromeleon Chromatography Management Software to Comply with 21 CFR Part 11

21 CFR 11 Assistant Software. 21 CFR Part 11 Compliance Booklet

Electronic Records and Signatures with the Sievers M9 TOC Analyzer and DataPro2 Software

Introduction 2. History. Adapted to zenon version 6.20 (MH) January 13 th, 2006

Part 11 Compliance SOP

Spectroscopy Configuration Manager (SCM) Software. 21 CFR Part 11 Compliance Booklet

Real World Examples for Part 11 Technical Controls

Using the Titrando system to comply with 21 CFR Part 11

Guidelines for applying FactoryTalk View SE in a 21 CFR Part 11 environment

Agilent Technologies Dissolution Workstation Software Electronic Records and Data Storage Background

OM-MICROLITE-8 AND OM- MICROLITE-16 DATA LOGGERS AND OM-MICROLAB

Guidance for a 21 CFR Part 11 implementation on Microsoft Office SharePoint Server 2007

eprost System Policies & Procedures

System Assessment Report Relating to Electronic Records and Electronic Signatures; Final Rule, 21 CFR Part 11. System: tiamo 2.0

MySign Electronic Signature

Achieving 21 CFR Part11 Compliance using Exaquantum/Batch Authored by Stelex

Statement of 21 CFR Part 11 Validation Results

Automation Change Management for Regulated Industries

Introduction. So what is 21 CFR Part 11? Who Should Comply with 21CFR Part 11?

SECURITY & PRIVACY DOCUMENTATION

State of Colorado Cyber Security Policies

Oracle Eloqua HIPAA Advanced Data Security Add-on Cloud Service

Password Standard Version 2.0 October 2006

DFARS Requirements for Defense Contractors Must Be Satisfied by DECEMBER 31, 2017

Criminal Justice Information Security (CJIS) Guide for ShareBase in the Hyland Cloud

Support for the HIPAA Security Rule

EU Annex 11 Compliance Regulatory Conformity of eve

How to get your Movicon 11 project FDA 21 CFR Part 11 ready. Document: RAC-4105 Released: Updated: Rel. Movicon: 11.

User Manual. Version 1 1/10/ of 26

21 CFR Part 11 Fundamentals

21 CFR PART 11 FREQUENTLY ASKED QUESTIONS (FAQS)

Access to University Data Policy

21 CFR Part 11 Compliance DELMIA Apriso 2018 Implementation Guide

90% 191 Security Best Practices. Blades. 52 Regulatory Requirements. Compliance Report PCI DSS 2.0. related to this regulation

TECHNICAL AND ORGANIZATIONAL DATA SECURITY MEASURES

Electronic Signature Policy

Rev.1 Solution Brief

HIPAA Compliance Checklist

TECHNICAL AND ORGANIZATIONAL DATA SECURITY MEASURES

ORA HIPAA Security. All Affiliate Research Policy Subject: HIPAA Security File Under: For Researchers

Premium HMI and FDA 21 Part 11 regulations TN0009. Version Description Date 1 First emission 10/04/2012

Red Flags/Identity Theft Prevention Policy: Purpose

Implementing Electronic Signature Solutions 11/10/2015

Virginia Commonwealth University School of Medicine Information Security Standard

Interagency Advisory Board Meeting Agenda, December 7, 2009

NIST Compliance Controls

Integration of GC/MSD ChemStation with OpenLAB ECM

Tennessee Technological University Policy No Password Management

INFORMATION TECHNOLOGY COMMITTEE ESCB-PKI PROJECT

Annex 3 to NIST Special Publication Recommended Security Controls for Federal Information Systems

ABB Limited. Table of Content. Executive Summary

Summary. Implementing CFR21 Part 11 with Movicon 11 Page 2

Policy Document. PomSec-AllSitesBinder\Policy Docs, CompanyWide\Policy

Table of Contents. Overview of the TEA Login Application Features Roles in Obtaining Application Access Approval Process...

Achieving 21 CFR Part 11 Compliance using CENTUM VP

Data Integrity: Technical controls that demonstrate trust

Transcription:

OpenLAB ELN Supporting 21 CFR Part 11 Compliance White Paper Overview Part 11 in Title 21 of the Code of Federal Regulations includes the US Federal guidelines for storing and protecting electronic records and applying electronic signatures. The intent of these guidelines is to ensure that electronic records subject to these guidelines are reliable, authentic and maintained with high integrity. This document examines each section of 21 CFR Part 11 and provides a recommended remediation approach using Agilent OpenLAB ELN v4.0. OpenLAB ELN manages experiments and documents that are very similar to paper notebooks (i.e. a set of pages). The Electronic Records managed by OpenLAB ELN are herein termed OpenLAB ELN documents. According to recent guidance from FDA Guidance for Industry, Part 11, Electronic Records; Electronic Signatures Scope and application, part 11 would apply when persons choose to use records in electronic format in place of paper format. OpenLAB ELN support of all compliance requirements mandated by 21CFR part 11 for a closed system. In particular it ensures: Accurate and complete copies of records Versioning of all relevant records for traceability Controlled copies of the data Records of changes captured in user-independent time-stamped audit trails These settings can be configured during or after installation to meet your specific standard operation procedures and security guidelines. This includes granular OpenLAB ELN user roles and privileges providing restricted access to ELN functionality for particular users. Changes to the configuration can be done at any time by a dedicated system administrator.

Electronic Records Closed System E-Sig Enhancements 11.10a The system has been validated in order to ensure accuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records. Agilent develops its products according to the well established product lifecycle concept, which is a phase review process for software and hardware development, to ensure consistent product quality. Documents and attachments within OpenLAB ELN are digitally signed so that any modification not controlled by the ELN will be detected by internal checks. 11.10b The system is capable of generating accurate and complete copies of all required records in both human readable and electronic form suitable for inspection, review and copying by the FDA. OpenLAB ELN centrally stores all data types, from raw machine data to printable reports. All files are unaltered and stored in the original format. OpenLAB ELN documents are also stored in PDF formats (PDF 1.7: ISO 32000-1:2008). Every record can be extracted for review without the source application being installed on the client machine. These reports can include all data and audit trails. Validated Software 11.10c The records are protected to enable the accurate and ready retrieval throughout the record retention period. Data stored within OpenLAB ELN resides in a protected centralized storage location. The functionality is complemented by additional procedural controls that should be defined and implemented by the system administrator based on company-wide security policies. These policies should manage practices such as access to client computers and password renewal frequency. 11.10d The system access is limited to authorized individuals. Access to OpenLAB ELN is controlled through a unique user name, password, and account login. Once a user has authenticated himself successfully, all file and software functionality access is controlled by privileges and roles assigned to individual users or groups of users. The system administrator determines levels of access. 11.10e There is a secure, computer-generated, time-stamped audit trail that independently records the date and time of operator entries and actions that create, modify, or delete electronic records. All actions related to creating, modifying or deleting electronic records are recorded in a secure, computergenerated, time-stamped audit trail. Once the experiment is created, the audit trail lists all modifications, date and time of the change, the user name and reason for the change if applicable. Entries in the audit trails cannot be switched off, altered or deleted by the user. 2

Security and Traceability 11.10e When records are changed, previously recorded information is left unchanged. The combination of audit trails and strict revision control ensures that previous information is not obscured. When modifications are made to OpenLAB ELN documents, the difference between the current version and the preceding one is recorded and cannot be altered. 11.10e Electronic audit trails are kept for a period at least as long as their subject electronic records and available for agency review and copying. All OpenLAB ELN audit trail information is stored in the ELN repository as part of a file s meta data and kept throughout the electronic records retention period. The ELN audit trails are unbreakably linked to the record, or the system for system-related activities such as logon events. Audit trails are kept in the same protected centralized storage as experiments. They can be exported for further auditing. 11.10f Operational system checks are used to enforce permitted sequencing of steps and events. When a sequence of events is required, system checks enforce it. OpenLAB ELN allows implementing business rules to enforce a particular workflow or to force the user to enter particular information in the course of use. System Checks & Controls 11.10g Authority checks are in place to ensure that only authorized individuals can use the system, electronically sign a record, access the operation or computer system input or output device, alter a record, or perform the operation at hand. Users cannot gain access to OpenLAB ELN without a valid user name, password and account. Only a successful logon to the system offers access to files and general software functionality. This includes file signing, value input, or altering a record. The user must authenticate with a valid user name, password and account. This applies at program initiation and after every inactivity timeout on the computer program. User access to specific functionality in the software is further restricted by the privileges and roles assigned to the individual user. 11.10h Device checks are used to determine, as appropriate, the validity of the source of data or operational instruction. User entry fields provide feedback to the user about the entry types and ranges that are valid for that field. These features are controlled by defining business rules in OpenLAB ELN. 3

11.10i The persons who develop, maintain, or use electronic records/signature systems have the education, training, and experience to perform their assigned tasks. All Agilent Technologies employees who work with regulations have attended training workshops for regulatory requirements. Agilent provides a basic familiarization during the installation of the product for system users. Training courses for administrators as well as users are available. 11.10j Written policies have been established, and adhered to, that hold individuals accountable and responsible for actions initiated under their e-signatures in order to deter record and signature falsification. It is the responsibility of the organization implementing electronic signatures to develop written policies that ensure that individuals responsible for signing documents understand that their electronic signature is as equally binding as their handwritten signature. 11.10k(1) 11.10k(2) There are adequate controls over the distribution of, access to, and use of documentation for system operation and maintenance. While documentation is available for OpenLAB ELN users and administrators; controls over the storage and distribution of this material are the responsibility of the organization that implements and uses the system. There are formal revisions and change control procedures to maintain an audit trail that documents time-sequenced development and modification of systems documentation. The quality process includes written formal revision and change control procedures for system documentation. Controls for Open Systems 11.30 There are procedures and controls used to protect the authenticity, integrity and confidentiality of the electronic records from their creation point to the point of their receipt. OpenLAB ELN according to definition is a Closed System. 11.30 Additional measures are used to ensure the confidentiality of the electronic records from the point of their creation to the point of their receipt. Even if not applicable (same remark as preceding point), OpenLAB ELN supports the use of Secure Socket Layer (SSL) encryption for security during data transmission between the client interface and the central server. SSL breaks a single file into very small data packets. These data packets are individually encrypted with configurable 64-bit or 128-bit encryption before being transmitted. On the receiving side the data packets are decrypted and reassembled. 4

Signature Manifestations 11.50 (a) Do the signed electronic records contain information associated with the signing that clearly indicates the following: 1. Printed name of signer 2. Date and time that the signature was executed 3. The meaning associated with the signature? OpenLAB ELN s electronic signature manifestation includes: 1. User name in addition to the full name of the signer 2. Date and time that the signature was applied 3. User configurable field associated with the signature (approve/reject) to associate a desired meaning. 11.50 (b) Are these items part of any human readable form of the electronic record? Signature information is part of a text box that is visible within the PDF document itself. Signature / Record Linking 11.70 The electronic signature is linked to its respective electronic record to ensure that the signature cannot be excised, copied or otherwise transferred to falsify an electronic record by ordinary means. General Requirements The electronic signature is part of the document which is digitally signed. 11.100 (a) Each electronic signature is unique to one individual and not reused by, or reassigned to, anyone else. OpenLAB ELN uses the user name/password combination (unique to each user) in the electronic signature feature. User names within OpenLAB ELN are required to be unique and cannot be reused or reassigned to another individual. 11.100 (b) The identities of the individual are verified prior to the establishment, assignment, and certification or otherwise sanctioning an individual s electronic signature or any element of an electronic signature. This would be a requirement of the organization that plans, implements and operates the system before implementing electronic signature procedures and/or assigning electronic signature privileges to an individual. 5

11.100 (c) Has the Company delivered its corporate electronic signature certification letter to the FDA? 11.100 (c)(1) Is it in paper form with a traditional handwritten signature? 11.100 (c)(2) Can additional certification or testimony be provided that a specific electronic signature is the legally binding equivalent of the signer s handwritten signature? It is the company s responsibility, before submitting electronically signed documentation to the FDA, to register their intent to use electronic signatures. In addition, training programs must be in place to ensure that users signing documents electronically understand the legal significance of their electronic signature. Electronic Signature Components and Controls 11.200 (a)(1) The e-signature employs at least two distinct identification components such as User ID and password. The OpenLAB ELN electronic signature tools consist of two components, username (unique) and password. To ensure an extra level of security, signature passwords can be different than login passwords in OpenLAB ELN. 11.200 (a)(1)(i) When an individual executes a series of signings during a single, continuous period of controlled system access, is the first signing executed using all the electronic signature components? OpenLAB ELN does not allow several signings under a single authentication and requires explicit full signature for every single operation that requires signature. 11.200 (a)(1)(i) When an individual executes a series of signings during a single, continuous period of controlled system access, is each subsequent signing executed using at least one electronic signature component that is only executable by, and designed to be used by, the individual? Same as 11.200(a)(1)(i). 11.200 (a)(1)(ii) When an individual executes a series of signings not performed during a single, continuous period of controlled system access; does each signing executed require all signature components? Same as 11.200(a)(1)(i). 11.200 (a)(2) Controls are in place to ensure that only their genuine owners can use the electronic signature. OpenLAB ELN can be configured such that only an administrator can assign a password to a user for a new account or forgotten password. 6

11.200 (a)(3) The electronic signatures are to be administered and executed to ensure that the attempted use of an individual s electronic signature by anyone other than its genuine owner requires the collaboration of two or more individuals. OpenLAB ELN uses the user s user name and password to initiate the electronic signature. An OpenLAB ELN user s password is stored encrypted within the database and is displayed as asterisks in all locations within the software. OpenLAB ELN is configured such that only an administrator can assign a password to a user for a new account or forgotten password. ID Control 11.200 (b) Electronic signatures are based on biometrics designed to ensure that only their genuine owners can use them. No OpenLAB ELN does not support signatures based on biometrics at this time. Controls for Identification Codes / Passwords 11.300 (a) Controls are in place to ensure the uniqueness of each combined identification code and password maintained, such that no two individuals have the same combination of identification code and password. OpenLAB ELN administrates users so that no two users can have the same username. Safeguards Notifications Automated Notifications 11.300 (b) Controls are in place to ensure that the identification code and password issuance is periodically checked, recalled, and revised. OpenLAB ELN can be configured such that user passwords are automatically, periodically revised and users are prevented from reusing passwords. 11.300 (c) There are loss management procedures in place to electronically disable lost, stolen, missing, or otherwise potentially compromised tokens, cards, and other devices that bear or generate identification code or password information. An OpenLAB ELN administrator can at any time disable a user account, or issue a new password to an existing account in the event the account becomes compromised. If a user forgets his / her password, the system administrator can issue a new one. 11.300 (d) Transaction safeguards are in use to prevent unauthorized use of passwords and/or identification codes. OpenLAB ELN can be configured such that only the user knows their user-name / password identification code. Passwords are always displayed as asterisks and are stored encrypted within the database so that even an administrator cannot see them. 7

11.300 (d) Transaction safeguards are in use to detect and report in an immediate and urgent manner, any attempts at their unauthorized use to the system security unit, and, as appropriate, to organizational management. OpenLAB ELN can be configured such that a user defined number of unauthorized access attempts lock out the user account and send email notification to a system administrator. 11.300 (e) There are controls in place to initially test devices that bear or generate identification code or password information to ensure that they function properly and have not been altered in an unauthorized manner. Controls are in place to ensure tokens function properly in the OpenLAB ELN environment. OpenLAB ELN stores password information in an encrypted manner limiting the possibility to insert forged passwords. This information is subject to change without notice. Agilent Technologies, Inc. 2010 Printed in U.S.A. April 6, 2010 5990-5593EN