Important Questions and Answers concerning the Audit Trail Review – Part 3

Important Questions and Answers concerning the Audit Trail Review – Part 3

1. How do you justify the reintegration of chromatograms versus the method specification in the audit trail? 
Answer: A reintegration should only be necessary if the analysis wasn’t carried out for one reason or another. The reason has to be specified and must be signed by the management. The laboratory employee is not allowed to take the decision himself.

2. Audit trail review only for critical data: Does this mean that it has to be carried out only for systems with data which influence the product directly? And not for systems which only have an indirect influence? 
Answer: You decide this by yourself by means of the risk analysis. No audit trail review is required for a training system for example.

3. How or where (guidance document) is it advisable to define raw data? 
Answer: (Unfortunately) there is no uniform definition. This means you are flexible to define this for your company.

4. When parts of data are printed it becomes static data. But the audit trail review has to be carried out for all critical and electronically produced data in the system. It is not possible to refer to the printed version? 
Answer: Static data is data the user cannot change. It is only important if the user had the possibility to change the data PRIOR to the data being printed. I do not think that a reference to the paper record will be accepted.

5. Can the review of a printout of the drying temperature profile be considered to be part of the audit trail review of the batch? 
Answer: In my opinion this is a good example for static data for which no audit trail review has to be carried out. The reason is that the user cannot change or access this data.

6. Is analytical data (raw data, metadata) from the validation of analytical procedures classified as being non critical? In this case the audit trail review would not be required. 
Answer: The validation of analytical procedures precedes the daily analyses for the batch release and constitutes the basis for them. The validation data is released with a report. The audit trail review is not required. (updated on 20/12/2020)

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