Question Regarding Time Stamps

The Question posed on LinkedIn:

Hello Dear LinkedIn friends. I have few questions related to computerized system.

1. In a country where there is a change in time due to day light saving. How does audit trails and reports are managed in software? ( Here software is operated in multiple time zones) Example: if someone logs in at 9:55 AM and start activity which lasts for 15 mins (means completion at 10:10). What if, in between there is day light saving happened at 10 AM and time goes 1 hr back. It will show that personnel logged in at 9:55 and activity was completed at 9:10. How shall we handle impact of day light savings in such case for reports and audit trails?

2. Do we require Audit trails for each activity. ? E.g. If software is prepared to manage documents. And we have some activities like News and Events on dash board for employees which is not critical step or basic requirement of application.

So do we require audit trail for such activities which are not critical for intended use of software. And if yes, do we require reason for each step?

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Ten GMP Self Inspection or Internal Audit Considerations

Posted as a LinkedIn article on 20190718

Preamble

I am a microbiologist with over 15 years’ experience in the pharmaceutical industry supporting the manufacture of liquids, creams, ointments and tablets. I have a strong interest sterile manufacturing, leading and developing others. Recently I have been working closely with data security. I have an arty streak, an affinity for computers and ride bicycles…a lot.

Introduction

Good Manufacturing Practice in Australia uses recommendations presented in the PIC/s Guide to GMP (PE009-13). The section on Quality Management states, “there is a procedure for self-inspection and/or quality audit, which regularly appraises the effectiveness and applicability of the Pharmaceutical Quality System”. Chapter 9 deals entirely with Self Inspection and lists 3 points – not entirely helpful. Continue reading

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Developing a Quality Management System

Why would anyone want a Quality Management System, or QMS?  To quote the ISO, “It helps businesses and organisations be more efficient and improve customer satisfaction.”  The document that details such a system is ISO 9001 (2015) Quality Management Systems.  A large part of this ISO reads as a business plan – improve performance; sustainable development; identify opportunities / enhance customer satisfaction etc.  Overall, the ISO employs the approach of Plan-Do-Check-Act and requires risk-based thinking. Continue reading

Notes on PIC/S Guide for Good Manufacturing Practice for Medicinal Products (2009)

When I was working in the sterile pharmaceutical industry, I reviewed the The Australian Code of Good Manufacturing Practice for Medicinal Products (2002) as part of my self-development.  This code was  revoked effective from 1 July 2010 and replaced by the PICS Guide for Good Manufacturing Practice for Medicinal Products 2009, as adopted in Therapeutic Goods (Manufacturing Principles) Determination No. 1 of 2009.  Here’s the original review.

I have now reviewed the PICS Guide for Good Manufacturing Practice for Medicinal Products 2009, from the stand point of a microbiologist working collaboratively in a sterile pharma plant.  What my review does is make note of the salient points and I add comments to some.

Both the revoked 2002 Australian GMP code and the 2009 PICs guide are based on ICH Q&A Good Manufacturing practice Guide for Active Pharmaceutical Ingredients which was last modified in 2000.  In 2015 21 pages worth of clarifications were published to clear up some technical questions and to remove ambiguities.  Looking at them, I’m not sure why clarification was needed as they all seem straight forward and answerable by anyone experienced working within a pharmaceutical manufacturing environment.  This means that despite having “no recent experience” as deemed by some potential employers, my knowledge is still bang up to date. Combine that with my fantastic memory and impressive technical skills and I’d be an asset to your company. Continue reading

FDA Guide To Inspections

A great reference for ensuring you are audit ready are the FDA’s Guide to Inspections documents and Guidance for Industry documents.

The FDA Inspection guides are freely available from here.

For my own reference and review, I’ve saved some of the Guidance for Industry documents below.  However, you can get them all from this link.