Good records management
Good records management is crucial in the pharma industry. One of the most common problems we see is individuals and teams retaining their own copy of documents rather than utilising a single central source, preferably made available via an electronic document management system (EDMS). In our highly regulated environment, demonstrating the reliability and authenticity of documentation is critical, so individuals making use of a central definitive source for their records is particularly important. In addition, much time and money is wasted through duplication and mismanagement of documents when carried out in an uncontrolled manner.In some industry sectors, management have introduced strict controls over where and how documents may be saved. Some organisations, for example, prevent documents from being saved anywhere except in an authorised EDMS. Perhaps this is one step too far, but good document control is necessary to achieve regulatory compliance.
Once a pharmaceutical process has been completed—whether a clinical trial or the production of a batch of drugs—the only thing remaining to demonstrate regulatory compliance is the documentation audit trail. This is why adequate quality control is so important. It is not enough just to have a record of what happened; regulatory authorities have an expectation that you can demonstrate those records to be accurate, legible, contemporaneous, original, attributable, complete, consistent, enduring and available when needed (1). A well-designed quality system will ensure that documentation being sent off to the archive is “fit for purpose”.
Poor quality control can be recognised when a sponsor is notified of an impending regulatory inspection. All too often, there is a mad panic as documentation is retrieved from various filing systems and hours are spent checking files for completeness. This is wasted effort and diverts key personnel from their core activities. A robust quality control system should eliminate the need for these eleventh-hour activities and result in inspection-ready files. Furthermore, quality control should ideally be embedded within existing processes rather than being introduced as an additional process. It is better to prevent poor quality records from being generated rather than identifying poor quality records and having to expend effort in fixing them.
The vast majority of regulatory requirements worldwide actually say very little about records management, which has been a bone of contention for years. On the one hand, records management professionals prefer the need for explicit guidance so that there is assurance they are operating within the permitted boundaries, but on the other hand, the lack of explicit guidance gives freedom to define company-specific processes and systems. However, it would be helpful for regulators to provide more specific guidelines in areas that are troubling industry the most, particularly where they see commonly occurring inspection deficiencies.