Clear cut line by line interpretation on 21 cfr part 11

Clear cut Line by Line interpretation on 21 CFR PART 11
Objective:
If you see the last few decades, the paharmaceutical industries facing serious problems due to the data
management issues. Please find the below trend that clearly shows that the major threat to
pharmaindusry is due to data integrity. If you see the warning letters trend of indian and chinees pharma
industry, more then 60% of the issue due to data miss management. How to make your data more
integral and accurate ?. I have written step by step way forward by explaing the regualtion given in 21
CFR Part 11 and I interpreted regulations with semple examples for clear understanding.

• 21: Short for ―Title21,‖which is the section of the CFR that applies to food and drugs. The CFR contains 50 ―titles.‖
federal•CFR: Short for ―Codeof Federal Regulations,‖ which is a coded (numbers and letters) set of laws published by the
government of the United States.
• Part 11: Scope is specific to electronic records and electronic signatures, which includes electronic submissions to the FDA.
Title 21 is the portion of the Code of Federal Regulations that governs food and drugs within the United
States for the Food and Drug Administration (FDA), the Drug Enforcement Administration (DEA), and
the Office of National Drug Control Policy (ONDCP).
It is divided into three chapters:
 Chapter I — Food and Drug Administration
 Chapter II — Drug Enforcement Administration
 Chapter III — Office of National Drug Control Policy
•Chapter 1: Part 11 falls under ―ChapterI,‖which applies to the Food and Drug Administration (FDA) and is largely based on
the Food, Drug, and Cosmetic Act from 1938. Chapters II and III of Title 21 are related to other agencies focused on illegal
drugs.
•Subchapter A: Part 11 falls under ―SubchapterA – General‖of Chapter I. Within each ―Part‖of a ―Subchapter,‖the content is
further organized in lettered ―Subparts‖and, within the Subparts, ―Sections‖that have numerical codes and
additional layers of letters and numbers for granularity. Before we dive into the rest of the guide, please note that
the descriptions and explanations we provide represent our interpretations of the 21 CFR Part 11 regulations. We
do not represent any government agency and nothing in the ―Interpretation‖column in this guide should be taken
as fact.
SUBPART A – GENERAL PROVISIONS
•11.1 – Scope
•11.2 – Implementation
•11.3 – Definitions
SUBPART B – ELECTRONIC RECORDS
•11.10 – Controls for closed systems
•11.30 – Controls for open systems
•11.50 – Signature manifestations
•11.70 – Signature/record linking
SUBPART C – ELECTRONIC SIGNATURES
•11.100 – General requirements

• 11.200 – Electronic signature components and controls
• 11.300 – Controls for identification codes/passwords
GENERAL PROVISIONS: 11.1 – SCOPE
S.No. Regulation Interpretation
1 The regulations in this part set forth the criteria under which the
agency considers electronic records, electronic signatures, and
handwritten signatures executed to electronic records to be
trustworthy, reliable, and generally equivalent to paper records
and handwritten signatures executed on paper.
The purpose of Part 11 is to ensure that electronic records
and electronic signatures can be trusted as much as paper
records and ink signatures.
2 This part applies to records in electronic form that are created,
modified, maintained, archived, retrieved, or transmitted, under
any records requirements set forth in agency regulations. This
part also applies to electronic records submitted to the agency
under requirements of the Federal Food, Drug, and Cosmetic
Act and the Public Health Service Act, even if such records are
not
specifically identified in agency regulations. However, this part
does not apply to paper records that are, or have been,
transmitted by electronic means
All electronic records that are used for regulated purposes
are subject to Part 11.
One clarification made – a paper record that is transmitted
Electronically (e.g., as an email attachment) is NOT subject
to Part 11.
3 Where electronic signatures and their associated electronic
records meet the requirements of this part, the agency will
consider the electronic signatures to be equivalent to full
handwritten signatures, initials, and other general signings as
required by agency regulations, unless specifically excepted by
regulation(s) effective on or after August 20, 1997.
If an organization can prove, typically via computer system
validation, that its electronic signatures comply with Part 11,
the FDA will accept electronic signatures instead of ink.
One exception is noted – if some other regulation
specifically requires ink, that regulation supersedes Part 11.
4 Electronic records that meet the requirements of this part may
be used in lieu of paper records, in accordance with 11.2,
unless paper records are specifically required.
If an organization can prove that its electronic records
comply with Part 11, the FDA will accept electronic
records instead of paper.
One exception is noted – if some other regulation
specifically requires paper, that regulation supersedes
Part 11.
5 Computer systems (including hardware and software), controls,
and attendant documentation maintained under this part shall
be readily available for, and subject to, FDA inspection.
The proof required in the previous two letters (c and d) must
be maintained in such a way that the FDA can inspect it
(i.e., documentation is king).
6 This part does not apply to records required to be established
or maintained by 1.326 through 1.368 of this chapter. Records
that satisfy the requirements of part 1, subpart J of this chapter,
There are a few obscure types of records that are excluded
from Part 11, because they fall under other regulations, but
the vast majority needs to comply.

but that also are required under other applicable statutory
provisions or regulations, remain subject to this part.
GENERAL PROVISIONS: 11.2 – IMPLEMENTATION
1 For records required to be maintained but not submitted to the
agency, persons may use electronic records in lieu of paper
records or electronic signatures in lieu of traditional signatures,
in whole or in part, provided that the requirements of this part
are met.
For regulated records that are NOT submitted to the FDA,
an organization can use electronic instead of (or in addition
to) paper, as long as it can prove that its electronic records
comply with Part 11.
2 For records submitted to the agency, persons may use
electronic records in lieu of paper records or electronic
signatures in lieu of traditional signatures, in whole or in
part, provided that:
a)The requirements of this part are met; and
b)The document or parts of a document to be submitted have
been identified in public docket No. 92S-0251 as being the type
of submission the agency accepts in electronic form. This
docket will identify specifically what types of documents or parts
of documents are acceptable for submission in electronic form
without paper records and the agency receiving unit(s) (e.g.,
specific center, office, division, branch) to which such
submissions may be made. Documents to agency receiving
unit(s) not specified in the public docket will not be considered
as official if they are submitted in electronic form; paper forms
of such documents will be considered as official and must
accompany any electronic records. Persons are expected to
consult with the intended agency receiving unit for details on
how (e.g., method of transmission, media, file formats, and
technical protocols) and whether to proceed with the electronic
submission.
For regulated records that ARE submitted to the FDA, an
organization can use electronic instead of paper as long as
these two conditions are met:
1.It can prove that its electronic records comply with
Part 11
2.The FDA is capable of accepting those types of records
electronically.
The types of e-records that the FDA accepts are listed in
public docket No. 92S-0251.
If there is any doubt as to whether a record can be
submitted electronically, contact the receiving unit at the
FDA before attempting submission.
GENERAL PROVISIONS: 11.3 – DEFINITIONS
1 a) The definitions and interpretations of terms contained in
section 201 of the act apply to those terms when used in this
part.
Some terms that are defined in the Food, Drug, and
Cosmetic Act also apply to Part 11.
2 (b) The following definitions of terms also apply to this part: Here are those terms and their definitions:

(1)Act means the Federal Food, Drug, and Cosmetic Act (secs.
201-903 (21 U.S.C. 321-393)).
(2)Agency means the Food and Drug Administration.
(3)Biometrics means a method of verifying an individual’s
identity based on measurement of the individual’s physical
feature(s) or repeatable action(s) where those features and/or
actions are both unique to that individual and measurable.
(4)Closed system means an environment in which system
access is controlled by persons who are responsible for the
content of electronic records that are on the system.
(5)Digital signature means an electronic signature based upon
cryptographic methods of originator authentication, computed
by using a set of rules and a set of parameters such that the
identity of the signer and the integrity of the data can be
verified.
(6)Electronic record means any combination of text, graphics,
data, audio, pictorial, or other information representation in
digital form that is created, modified, maintained, archived,
retrieved, or distributed by a computer system.
(7)Electronic signature means a computer data
compilation of any symbol or series of symbols executed,
adopted, or authorized by an individual to be the legally
binding equivalent of the individual’s handwritten
signature.
(8)Handwritten signature means the scripted name or legal
mark of an individual handwritten by that individual and
executed or adopted with the present intention to authenticate a
writing in a permanent form. The act of signing with a writing or
marking instrument such as a pen or stylus is preserved. The
scripted name or legal mark, while conventionally applied to
paper, may also be applied to other devices that capture the
name or mark.
(9)Open system means an environment in which system
access is not controlled by persons who are responsible
Act: Short for Food, Drug, and Cosmetic Act.
Agency: Short for FDA.
Biometrics: A way to verify someone’s identity through
a unique physical trait (e.g., fingerprint) or a repeatable
action (e.g., typing style).
Closed System: A computer system whose user access
is controlled by the same people responsible for its contents.
Digital Signature: A type of electronic signature that
includes a way of verifying the identity of the signer, the
validity of their signature, and the integrity of the record
they signed.
Electronic Record: Information in a digital form that is
created or used in some way by a computer system.
Electronic Signature: A set of symbols that is as unique
and legally binding as a handwritten signature, but that is
used to sign records in a computer system.
Handwritten Signature: A scripted name or legal mark
created by an individual that is unique to that individual and
is used to authenticate something in writing.
Open System: A computer system where user access
is NOT controlled by the same people responsible for its

for the content of electronic records that are on the
system.
contents.
SUBPART B – ELECTRONIC RECORDS
ELECTRONIC RECORDS: 11.10 – CONTROLS FOR CLOSED SYSTEMS
1 Persons who use closed systems to create, modify, maintain, or
transmit electronic records shall employ procedures and
controls designed to ensure the authenticity, integrity, and,
when appropriate, the confidentiality of electronic records, and
to ensure that the signer cannot readily repudiate the signed
record as not genuine. Such procedures and controls shall
include the following:
An organizations using electronic records must document
the procedures it follows and the controls it has in place
for ensuring that their electronic records have these
qualities:
•Authenticity
•Integrity
•Confidentiality (when appropriate)
•Irrefutability (i.e., no way to deny that a record is
genuine)
The documented procedures and controls must address
the following topics:
2 Validation of systems to ensure accuracy, reliability, consistent
intended performance, and the ability to discern invalid or
altered records.
Validation: How an organization proves (to itself and
auditors) that the data in a computer system can be trusted.
3 The ability to generate accurate and complete copies of records
in both human readable and electronic form suitable for
inspection, review, and copying by the agency. Persons should
contact the agency if there are any questions regarding the
ability of the agency to perform such review and copying of the
electronic records.
Rendering Records: How an organization makes sure that
all electronic records that an auditor might want to see
and/or copy can be provided in a language/format that
humans (not just computers) can understand.
4 Protection of records to enable their accurate and ready
retrieval throughout the records retention period.
Document Storage & Record Retention: How an
organization protects documentation and keeps it readily
available for as long as it’s required to be stored.
5 Limiting system access to authorized individuals. System Access: How an organization ensures that only
the right people have access to each computer system.
6 Use of secure, computer-generated, time-stamped audit trails
to independently record the date and time of operator entries
and actions that create, modify, or delete electronic records.
Record changes shall not obscure previously recorded
information. Such audit trail documentation shall be retained for
a period at least as long as that required for the subject
electronic records and shall be available for agency review and
copying.
Audit Trails: How an organization ensures that a complete
history of an electronic record is automatically captured
by a computer system, retained in the system for the
right amount of time, and viewable by humans.

7 Use of operational system checks to enforce permitted
sequencing of steps and events, as appropriate.
Workflows: How an organization makes sure that electronic
workflows in computer systems function correctly.
8 Use of authority checks 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.
Authority Checks: How an organization limits user access
(system level and record level) and verifies that the users
performing functions in the system are authorized to do so.
9 Use of device (e.g., terminal) checks to determine, as
appropriate, the validity of the source of data input or
operational instruction.
Device Checks: How an organization verifies that
equipment being used for regulated purposes is functioning
properly.
10 Determination that persons who develop, maintain, or use
electronic record/electronic signature systems have the
education, training, and experience to perform their assigned
tasks.
Personnel Qualifications: How an organization makes
sure only trained and qualified people perform functions on
or within the system.
11 The establishment of, and adherence to, written policies that
hold individuals accountable and responsible for actions
initiated under their electronic signatures, in order to deter
record and signature falsification.
Personnel Accountability: How an organization holds
individuals accountable for the integrity of their actions
related to electronic records and electronic signatures.
12 Use of appropriate controls over systems documentation
including:
1)Adequate controls over the distribution of, access to, and use
of documentation for system operation and maintenance.
2)Revision and change control procedures to maintain an
audit trail that documents time-sequenced development
and modification of systems documentation.
Document Control: How an organization controls
documents related to system operation and maintenance
and preserves the complete history of changes made to
these documents.
ELECTRONIC RECORDS: 11.30 – CONTROLS FOR OPEN SYSTEMS
1 Persons who use open systems to create, modify, maintain, or
transmit electronic records shall employ procedures and
controls designed to ensure the authenticity, integrity, and, as
appropriate, the confidentiality of electronic records from the
point of their creation to the point of their receipt. Such
procedures and controls shall include those identified in 11.10,
as appropriate, and additional measures such as document
encryption and use of appropriate digital signature standards to
ensure, as necessary under the circumstances, record
authenticity, integrity, and confidentiality.
For an organization using open systems*, everything for
closed systems (Section 11.10) still applies. In addition, it
must take more steps (whatever makes the most sense,
given the risks and available options) to ensure the same
record qualities described in Section 11.10:
•Authenticity
•Integrity
•Irrefutability (i.e., no way to deny that a record is
genuine)
* A computer system where user access is NOT controlled by the same
people responsible for its contents.

ELECTRONIC RECORDS: 11.50 – SIGNATURE MANIFESTATIONS
1 (a) Signed electronic records shall contain information
associated with the signing that clearly indicates all of the
following:
(i)The printed name of the signer;
(ii) The date and time when the signature was executed; and
(iii)The meaning (such as review, approval, responsibility,
or authorship) associated with the signature.
Any time an electronic record is signed, the following
information must be visible and associated with the
signature:
•Printed name of signer
•Date and time of signature
•Meaning of signature (e.g., content is accurate,
format is correct, data calculations were verified)
2 (b) The items identified in paragraphs (a)(1), (a)(2), and (a)
(3) of this section shall be subject to the same controls as
for electronic records and shall be included as part of any
human readable form of the electronic record (such as
electronic display or printout).
The three bullets of data above are also subject to Part 11
and must be in human-readable format.
ELECTRONIC RECORDS: 11.70 – SIGNATURE/RECORD LINKING
1 Electronic signatures and handwritten signatures executed to
electronic records shall be linked to their respective electronic
records to ensure that the signatures cannot be excised,
copied, or otherwise transferred tofalsify an electronic record by
ordinary means.
Any kind of signature (ink or electronic) executed to an
electronic record must remain connected to that record
forever. It can’t be removed, covered over, erased,
transferred, etc.
ELECTRONIC SIGNATURES: 11.100 – GENERAL REQUIREMENTS
1 (a) Each electronic signature shall be unique to one individual
and shall not be reused by, or reassigned to, anyone else.
Each person must have a unique electronic signature that
has never been and never will be used by anyone else.
2 Before an organization establishes, assigns, certifies, or
otherwise sanctions an individual’s electronic signature, or any
element of such electronic signature, the organization shall
verify the identity of the individual.
Before someone can use an electronic signature, his/her
identity must be verified.
3 Persons using electronic signatures shall, prior to or at the time
of such use, certify to the agency that the electronic signatures
in their system, used on or after August 20, 1997, are intended
to be the legally binding equivalent of traditional handwritten
Before an organization implements electronic signatures,
it must notify the FDA of its intention and state that it will
consider electronic signatures to be as legally binding as
ink signatures.

signatures.
(1)The certification shall be submitted in paper form and signed
with a traditional handwritten signature, to the Office of egional
Operations (HFC-100), 5600 Fishers Lane, Rockville, MD
20857.
(2)Persons using electronic signatures shall, upon agency
request, provide additional certification or testimony that a
specific electronic signature is the legally binding equivalent of
the signer’s handwritten signature.
The first step in the process is to write and mail the FDA a
paper letter signed with ink signatures
.
If the FDA asks for additional proof that an organization
will consider electronic signatures to be legally binding,
the organization must provide it.
ELECTRONIC SIGNATURES: 11.200 – ELECTRONIC SIGNATURE COMPONENTS AND CONTROLS
1 (a) Electronic signatures that are not based upon
biometrics shall:
Electronic signatures that are NOT biometric (i.e., not
based on a physical feature, like a fingerprint) must be
designed as follows:
2 (1) Employ at least two distinct identification components such
as an identification code and password.
(i)When an individual executes a series of signings during a
single, continuous period of controlled system access, the first
signing shall be executed using all electronic signature
components; subsequent signings shall be executed using at
least one electronic signature component that is only
executable by, and designed to be used only by, the individual.
(ii)When an individual executes one or more signings not
performed during a single, continuous period of controlled
system access, each signing shall be executed using all of
the electronic signature components.
They must be made up of at least two distinct parts (i.e.,
user ID and password).
•The first time a user signs a record after logging into a
system, the system must require them to enter ALL of the
parts of their signature (i.e., user ID and password).
Subsequent signings during that same session only require
the use of ONE part (i.e., password).
•Each time a user logs out and logs back in (or gets
timed out by the system), the clock restarts and
the first record signed after logging in must require
ALL parts of the signature.
3 (2) Be used only by their genuine owners; and Electronic signatures can only be used by the individuals
to whom they are assigned.
4 (3) Be administered and executed to ensure that
attempted use of an individual’s electronic signature
by anyone other than its genuine owner requires
collaboration of two or more individuals.
However, if an individual’s electronic signature must be
used by someone it’s not assigned to, the system must
require at least two people to work together to do so.
The subtext here is something like, “The system
administrator and the individual’s supervisor would need
to work together to use the individual’s signature.” This
would only come into play if the individual who should
have signed was unavailable (e.g., left the company, out
on medical leave) and there was no workaround available.

(b) Electronic signatures based upon biometrics shall be
designed to ensure that they cannot be used by anyone
other than their genuine owners.
Electronic signatures that are biometric (e.g., fingerprint
scan, retinal scan) can only be used by the individuals to
whom they are assigned.
ELECTRONIC SIGNATURES: 11.300 – CONTROLS FOR IDENTIFICATION CODES/PASSWORDS
1 Persons who use electronic signatures based upon use of
identification codes in combination with passwords shall employ
controls to ensure their security and integrity. Such controls
shall include:
1 Maintaining the uniqueness of each combined
identification code and password, such that no two
individuals have the same combination of identification
code and password.
2 Ensuring that identification code and password issuances are
periodically checked, recalled, or revised (e.g., to cover such
events as password aging).
Following loss management procedures to electronically
deauthorize lost, stolen, missing, or otherwise potentially
compromised tokens, cards, and other devices that bear or
generate identification code or password information, and to
issue temporary or permanent replacements using suitable,
rigorous controls.
Use of transaction safeguards to prevent unauthorized
use of passwords and/or identification codes, and 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.
Initial and periodic testing of devices, such as tokens or cards,
that bear or generate identification code or password
information to ensure that they function properly and have not
been altered in an unauthorized manner.
For electronic signatures that make use of identification
codes (i.e., user IDs) and passcodes/passwords, the
following controls need to be in place:
No two users can have the same combination of user ID
and password – each combination must be unique – and
each user ID can only be assigned to one individual, ever
(no re-use allowed).
Passwords must be checked, recalled, or changed from
time to time.
If a passcode token/device is lost or stolen, it must be
deauthorized and a secure replacement must be issued.
Unauthorized attempts to access user IDs or
passwords/passcodes must be detected and reported
to the appropriate person/group in the organization for
investigation.
Passcode tokens must be tested before they are issued
for use and periodically while in use to make sure they’re
functioning correctly.

21 CFR PART 11 KEY TAKEAWAYS
Before tucking away this guide and returning to business as usual, here is a summary of the key points to keep in mind.
GENERAL
•―21CFR Part 11‖refers to a particular chunk of the Code of Federal Regulations issued by the United
States to regulate drugs. Specifically, it means: Title 21 > Chapter 1 > Subchapter A > Part 11.
•21 CFR Part 11 consists of three Subparts:
•A – General Provisions
•B – Electronic Records
•C – Electronic Signatures
• Part 11 applies to all electronic records that fall under FDA regulations.
•If an organization can prove to an auditor that their electronic records/signatures are as trustworthy as paper records/ink
signatures, the FDA will accept electronic instead of paper.
•The FDA will accept electronic submission instead of paper IF those submissions 1) adhere to Part 11
requirements and 2) are included among the types of documents that the FDA accepts electronically
SUBPART B – ELECTRONIC PROVISIONS
•Organizations using electronic records must establish and document procedures andcontrols that ensure the following
qualities in their electronic records:
•Authenticity
•Integrity
•Irrefutability (i.e., no way to deny that a record is genuine)
•The following topics must be addressed in documented procedures and controls: computer systems validation (CSV), record
rendering, document storage and record retention, system access, audit trails, workflows, authority checks, device checks,
personnel qualifications, personnel accountability, and document control.
•Systems that fall into the category of ―Open‖(as defined in Subpart A) require additional procedures/ controls.
•Electronic signatures must include the printed name of the signer, the date and time of thesignature, and the meaning of the
signature.
•Electronic signatures must be forever linked to their respective records.
•Organizations that wish to use electronic signatures must inform the FDA in writing prior to making the switch.
•Each individual who will be using an electronic signature must 1) have their identity confirmed and 2) use a unique signature
that has never been and will never be used by another individual.
•There are specific design requirements for electronic signatures that are biometric (e.g.,fingerprint scan) and those that are
not (e.g., user ID and password).
•For electronic signatures that make use of user IDs and passwords/passcodes, there are specific requirements for
passwords and for passcode generating

Conclusion:
If you have very good data management and audit trail program for the date generated by your
instruments and have full accountability and justification for the data’s, nobody( Regulatory Auditors)
can figure out noncompliance pertaining to your data which has been produced under GMP
environment.
Written By
Pari.s

Clear cut line by line interpretation on 21 cfr part 11

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