Good documentation practice

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Good documentation practice (recommended to abbreviate as GDocP to distinguish from "good distribution practice" also abbreviated GDP) is a term in the pharmaceutical and medical device industries to describe standards by which documents are created and maintained. While some GDocP standards are codified by various competent authorities, others are not but are considered cGMP (with emphasis on the "c", or "current"). Some competent authorities release or adopt guidelines, and they may include non-codified GDocP expectations. While not law, authorities will inspect against these guidelines and cGMP expectations in addition to the legal requirements and make comments or observations if departures are seen. In the past years, the application of GDocP is also expanding to cosmetic industry, excipient and ingredient manufacturers.

Contents

GDocP standards

Documentation creation

Document approval

Handwritten entries

Copies of documents

Document maintenance

Document modification

GDocP interpretation

From the regulatory guidance above, additional expectations or allowances can be inferred by extension. Among these are:

Enforcement

The competent authorities are empowered to inspect establishments to enforce the law and the interpretations of the law (e.g., the content of guidance documents and the cGMPs).

Departures from GDocP that involved the regulator have included: documentation not contemporaneous, [11] [12] use of ditto marks, [13] signature stamps., [14] [15] obscured original data, [16] Use of pencil, [16] inaccurate records, [16] and not dating changes. [17]

See also

References

  1. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 "Chapter 4. Documentation" (PDF). Volume 4. Good Manufacturing Practice: Medicinal Products for Human and Veterinary Use (Report). Brussels: European Commission, Health and Consumer Directorate-General. 2010. Archived (PDF) from the original on 19 July 2022. Retrieved 15 October 2022.
  2. 1 2 3 4 5 6 7 PD-icon.svg This article incorporates public domain material from "Guidance for Industry - COMPUTERIZED SYSTEMS USED IN CLINICAL TRIALS". U.S. Food and Drug Administration. April 1999. Archived from the original on 24 September 2020. Retrieved 15 October 2022.
  3. 1 2 3 4 5 6 7 8 9 WHO Expert Committee on Specifications for Pharmaceutical Preparations (2011). "Annex 3. WHO good manufacturing practices for pharmaceutical products: main principles" (PDF). Forty-fifth Report (PDF) (Technical report). WHO Technical Report Series. World Health Organization. 961. Archived (PDF) from the original on 1 September 2022.
  4. 1 2 3 4 5 6 "ICH Official web site : ICH". www.ich.org. Retrieved 7 March 2023.
  5. 1 2 3 4 5 6 European Commission Directive 2003/94/EC. (Article 9)
  6. 1 2 "Part I, Chapter 6 Quality Control" (pdf), The rules governing medicinal products in the European Union, vol. 4, EU Guidelines to Good Manufacturing Practice, Medicinal Products for Human and Veterinary Use., 1 June 2006, p. 3
  7. 1 2 3 4 5 "Code of Federal Regulations Title 21". U.S. Food and Drug Administration. 21CFR211 Subpart J. Archived from the original on 10 October 2009. Retrieved 7 March 2023.
  8. US FDA. "HUMAN DRUG CGMP NOTES" (Volume 8, Number 3) September, 2000 [ dead link ]
  9. 1 2 3 Japan MHLW. Ministerial Ordinance No. 169, 2004, "Ministerial Ordinance on Standards for Manufacturing Control and Quality Control for Medical Devices and In-Vitro Diagnostic Reagents" (Chapter 2, Section 2, Article 8, Paragraphs 2 and 4) Archived 22 July 2011 at the Wayback Machine – Accessed 7 January 2011
  10. 1 2 3 4 5 Hurd, Don (2010), Good Documentation Practices (PDF), et al., Premier Validation, pp. 11, 17, 30, 39, ISBN   978-1-908084-00-2, archived from the original on 13 November 2012
  11. US FDA. "Warning Letter" UCM271708. Observation #1 – Accessed 27 June 2013
  12. Caraco Pharmaceutical Laboratories, Ltd. Response to the FDA's May 12, 2009, 483. Observation #14a – Accessed 1 June 2011
  13. US FDA. "Warning Letter" FLA-99-29
  14. US FDA. "Warning Letter" UCM075960 – Accessed 4 February 2010
  15. US FDA. "Warning Letter" UCM066113
  16. 1 2 3 US FDA. "Warning Letter" UCM069041
  17. US FDA. Form FDA 483 issued to L. Perrigo Co., dated 11/07/2008. Observation #9A