FDA CFR 21 PART 11 COMPLIANCE

Tool Management II provides a complete system to help you achieve Part 11 compliance including:

* Validation PackageA complete set of documentation provides an IQ/OQ protocol for efficient and timely system validation.

* Database Security – Support for Pervasive SQL database provides state of the art security for your data. For more information visit the Pervasive Web Site at www.pervasive.com/psql/

* Electronic Audits – Provides a record of the previous value for entries that have been modified or deleted.

* Date & Time Stamps – Displays the User, Date and Time of the last modification to the database record.

* User Login & Password Security - Ensure that only authorized individuals can use the system.

* Simplified Tool Inspections – minimize your cGMP responsibility by only inspecting critical dimensions.

VALIDATION PACKAGE – The optional TM2 Validation Package provides a complete set of documents including executable IQ and OQ protocols as well as a Summary Report and a CFR 21 Part 11 Compliance Statement. The Tool Management II (TM2) Validation Package includes the following electronic documents:

IQ Protocol - Developed by our validation specialist, the 203 page document contains:

- Purpose

- System Description

- References

- IQ Test Functions

 

- Scope

- Responsibilities

- Requirements

- OQ Test Functions

OQ Report - Compiled by independent validation specialist to provide a summary of the results from OQ Execution.  The eleven (11) page document includes:

- Overall Conclusion

- Deviations

- Results / Discussion

- Conclusion

 

21 CFR Part 11 – Checklist identifies procedures and controls used to establish compliance with 21 CFR Part 11 Requirements.

DATABASE SECURITYAs an essential component of CFR 21 Part 11 compliance, database security is necessary from both within the application and external to the application. Utilization of the Pervasive SQL database engine will provide complete data security across all access methods. In addition to the powerful Database Login, Pervasive SQL features strong, 128-bit encryption between the workstation and server, along with on-disk encryption.  “PervasiveSQL_Product_Sheet.pdf” or visit the Pervasive website at www.pervasive.com/psql/

 

ELECTRONIC AUDIT TM2 provides audit trail capability at the application level with secure, computer generated, time-stamped audit trails that record the date and time of operator entries and actions that modify or delete entries.   “AuditMaster_Product_Sheet.pdf”.    

DATE & TIME STAMPSApplication level, password protected access to date and time stamp information is viewable on-screen for most tables.  Determine immediately, the most recent date, time and user to modify every record in a table.  Electronic Audit functions provide additional capability as described above.

USER LOGIN & PASSWORD SECURITYBoth application and database password protection ensure that only authorized individuals can use the system, access the operation, alter a record, or perform the operation at hand.  The TM2 application includes twenty-six (26) different “rights” that can be assigned to or removed from each user ID.  TM2 provides an option for Windows Authentication that allows a network administrator to have complete control over the TM2 Login ID and password. For more information see the product sheet document “Security_Solution_Sheet.pdf.”

SIMPLIFIED TOOL INSPECTIONSWith every measurement you include in your inspection SOP, the FDA may want see evidence of: training; validation; calibration; etc.  In other words, why open a can of worms?  The TM2 system recommends that you ONLY INSPECT CRITICAL DIMENSIONS!

The following represents the recommendations of Natoli Engineering Company, Inc. for the proper approach to dimensional inspections of upper and lower punches in order to assure tablet quality.  The recommendations are based on dimensions that provide consistency with regard to tablet hardness, weight and thickness.

Punch Inspection Critical Dimensions – We believe there are three (3) critical dimensions that should be included in a dimensional inspection of an upper or lower punch.  Measuring any other dimension is either A) unnecessary because it rarely, if ever changes and therefore is not worthy of the time and expense of measuring or B) cannot be properly measured with current equipment and is better served by a visual inspection.

The three (3) critical dimensions include the following:

1.) Working Length – The working length is the most critical punch dimension because it determines tablet thickness and hardness.  Tolerances should be based on the measurement of a punch in relation to other punches as opposed to being based on a specific length.  Uniformity of punch working lengths is the key.  In other words, as long as the punches are the same length (or within the specified tolerance) it doesn’t matter how they compare in relation to a specific pre-defined length.

2.) Cup Depth – To find the cup depth, subtract the measured working length from the measured overall length.  Cup depth is not a critical dimension with regard to controlling tablet weight.

3.) Overall Length – The overall length is not critical except that it is necessary to accurately calculate Working Length and Cup Depth.  In other words, you should not always assume a 5.250” overall length measurement.

For additional reference, please see the “Encyclopedia of Pharmaceutical Technology” Volume 15 pp. 168 –169 and “Tableting Specification Manual” Sixth Edition pp. 13, 14  & 15.

We hope this will be of help to you in understanding our recommendations with regard to dimensional inspections of upper and lower punches.  Please feel free to call us if you have any questions.