INTEGRITAS DATA

(DATA INTEGRITY)
Pertemuan Ilmiah Tahunan IAI
Jogjakarta, 29 September 2016
OUTLINE
 Definition
 Regulatory Basis
 Why become a trending topic ?
 Warning Letters about Data Integrity
 Challenges, Examples of General Data Integrity Issues
 Requirements of Data Integrity (ALCOA ++++)
 DATA INTEGRITY : REGULATOR’S EXPECTATION
 DATA INTEGRITY : AN INDUSTRY PERSPECTIVE
 WHAT IS DATA INTEGRITY?

Definition :

MHRA - “The extent to which all data are complete,

consistent and accurate throughout the data
lifecycle.”
FDA - “assurance that data records are accurate,
complete, intact and maintained within their original
context, including their relationship to other data
records”
 WHAT IS DATA INTEGRITY?

Definition :

PDA - “Data integrity is the accuracy and consistency of

stored data, indicated by an absence of any alteration
in data between two updates of a data record. Data
integrity is imposed within a system at its design stage
through the use of standard rules and procedures, and is
maintained through the use of error checking and
validation routines.”
 WHAT IS DATA INTEGRITY?

Definition :

IVT - “Data integrity is a prerequisite for the regulated

healthcare industry as decisions and assumptions on
product quality and compliance with the applicable
regulatory requirements are made based on data.”
 WHAT IS DATA INTEGRITY?

Definition :

Refers to maintaining and assuring the accuracy and

consistency of data over its entire life-cycle and is a
critical aspect to the design, implementation and usage
of any system which stores, processes or retrieves data.
Data is recorded exactly as intended, and upon later
retrieval, the data is the same as it was when it was
originally recorded.
 Regulatory Basis- Key docs
• MHRA GMP Data Integrity Definitions and Guidance for Industry --- Published March 2015
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/412735/Dat
a_integrity_definitions_and_guidance_v2.pdf
• FDA Guidance for Industry Part 11, Electronic Records; Electronic Signatures — Scope and
Application, 2003
http://www.fda.gov/downloads/RegulatoryInformation/Guidances/ucm125125.pdf
• Upcoming guidance for Industry - Data Integrity and Compliance With CGMP Guidance for
Industry – draft available since April 2016
http://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidance
s/ucm495891.pdf
• Eudralex – Volume 4 Good manufacturing practice (GMP) Guidelines
http://ec.europa.eu/health/documents/eudralex/vol-4/index_en.htm
• Pedoman CPOB 2012 : Dokumentasi butir 10.8
• Pedoman CPBAOB 2009 : Dokumentasi dan Catatan bab 6
Data integrity – Why become a
trending topics now ?
•Agencies expects that pharmaceutical companies
should retain complete and accurate records and all raw
data and to make that available to inspectors

•The integrity of data generated by a regulated

pharmaceutical companies and laboratories matters
most, because properly recorded information is the basis
for manufacturers to assure product identity, strength,
purity, and safety and non-compliances found in the
integrity of data leads warning letters and a regulatory
action from the agencies
Warning letters issued by FDA in year
2014-15
• Micro Labs Limited 1/9/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm431456.htm
• Apotex Research Private Limited 1/30/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm432709.htm
• Cadila Pharmaceuticals Limited 10/15/14
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2014/ucm421544.htm
• Tianjin Zhongan Pharmaceutical Co., Ltd. 6/10/14
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2014/ucm400853.htm
• Sun Pharmaceutical Industries Limited – Karkhadi 5/7/14
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2014/ucm397054.htm
• Canton Laboratories Pvt. Ltd. 2/27/14
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm387960.htm
• Usv Limited 2/6/14
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm386678.htm
 Excerpt from FDA Warning Letters

January 2008:
“It was observed that the data stored on the computer can be
deleted, removed, transferred, renamed or altered [without
control].”

April 2008:
“There is no audit trail or log of data changes that are made to the
information in the database. Data cannot be verified against
source records, since such records are not maintained.”
 Excerpt from FDA Warning Letters

May 2010:
“Your firm failed to check the accuracy of the input to and output
from the computer or related systems of formulas or other records
or data and establish the degree and frequency of input/output
verifications.”

April 2010:
“Your firm's laboratory analysts have the ability to access and
delete raw chromatographic data . . . Due to this unrestrictive
access, there is no assurance that laboratory records and raw
data are accurate and valid”
 Challenges noted by the agencies---
 Non contemporaneous Recording: Failure to record activities at the time when
activity was performed. There is evidence that the records were signed by company
personnel when the person was actually absent on that day.
 Document back-dating: Backdating stability test results to meet the required
commitments.
 Copy of existing data as new information: Test results from previous batches were
used to substitute testing for another batch or acceptable test results were created
without performing the test.
 Re-running samples to obtain better results: Multiple analyses of assay were done with
the same sample without adequate justification and in some cases samples were
tested unofficially or as a trial analysis until desired test results obtained.
 Data fabrication and data discarding: Original raw data and records were altered for
e.g., by using of correction fluid or Manipulation of a poorly defined analytical
procedure and associated data analysis in order to obtain passing results.
General issues of data integrity
• Back-dating
• Omission of data
• Editing of data
• Processing/testing into compliance
• Improper recording practices
• Improper computerized systems practices
• No audit trail, audit trail switched off, not used
• No periodic review of audit trails and user access
• User accounts not personalized
• Equipment not part 11 compliant, qualification gaps
• No backup of data, handling of e-records
• No logbooks in place
• No incident management
Examples of Data Integrity Issues experienced
during Product Reviews
 Undocumented Deviations:
 Product and/or test specs amended during verification and validation testing
 Out of spec result ignored
 Protocol sample size not adhered to and sample size justification
 Re-use of test specimens – validity of data generated
 Inconsistent protocol and test report rev number
 Test report summary inconsistent with raw data including altered results
 Testing duration cut short
 Reports not signed off at appropriate level or missing signatures
 Expertise of authors (biocomp and clinical)
 Scope of documentation not consistent with device models
 At recertification undeclared changes to specifications
 Tech file not kept up-to-date with regulatory environment (e.g. standards)
 Data should be:

 A – attributable to the person generating the data

 L – legible and permanent
 C – contemporaneous
 O – original record or true copy
 A – accurate
+++
 ‘Metadata’ is the data about data and provides context and
relationship to the primary data thus preserving the accuracy,
completeness, content, and meaning.
Data :
Information derived or obtained from raw data (e.g. a
reported analytical result)

Raw Data (primary data or source data) :

Manual Raw Data
Recorded data that is generated as a result of an action (e.g. pH,
temperature)
 Electronic Raw Data
1. Unprocessed
2. Processed Raw Data
3. Re-Processed Raw Data (manual/electronic)
APPLIES TO DATA RECORDED IN :
electronic and
paper formats or
a hybrid of both (paper and electronic)

DATA SHOULD BE PROTECTED TOWARDS :

Accidental modification
Intentional modification
Falsification
Deletion
Electronic Raw Data
1. Unprocessed
Data generated that is not controlled by user identified parameters such as
integration parameters (chromatographic/spectral analyses)
2. Processed Raw Data
Data generated that is controlled by user identified parameters such as
integration parameters (chromatographic/spectral analyses)
3. Re-Processed Raw Data (manual/electronic)
Data generated that is controlled by user intentionally adjusted identified
parameters, i.e., enhanced chromatogram
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
A Attributable This term refers to the -Failure to have audit trails for the system
need to be able to and to ensure that they are working all the
determine who time.
performed each -For manual systems, it is the failure to have
action. If there were traceability throughout the documents to
changes made, who show who performed tasks, changed
made the change information and the rationale for changes,
and why. e.g., cross-outs that are not showing the
reason for change and/or who made the
In all cases, there change.
needs to be a strong -Using other people’s passwords or a single
link to the original password for a group as this limits the ability
source data. to determine who exactly did the work and
who made the changes. Another variation
is the posting of passwords, so that anyone
can use them.
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
L Legible The data must be -Handwriting cannot be identified as
documented using to meaning upon review.
permanent ink and should -Failure to make corrections in a way
allow for the reader to that allows the original information to
identify all entries. (Manualbe read, e.g., not crossing out with a
systems) single line through the entry.
-Use of thermal printouts and not
Printouts should be legible, making copies so that the print will not
e.g., not fade over time. fade out over time.

C Contempor All data should be -Writing notes on post-its to enter into

aneous recorded at the time the the log book or data form at a later
work is performed. All date date.
and time stamps should be
in order (based upon date
and time).
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
O Original Is the document the -Fabricating of data for which there is
original (raw) data? no original data
This should be the first time -Copying data and claiming it to be
the information is new and original data
recorded. -Unauthorized access to computer
In some cases, the original system to modify, delete, or not save
may not be available but electronic files is not prevented
a “certified true copy” is
available e.g., a copy may
be from a thermal printer
and photocopied to
preserve the printing.
It should be signed and
dated with wording that
this is a certified copy.
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
A Accurate This refers to the data -Data which has been falsified, e.g.,
being entered without failure to run experiments to generate
errors or editing. If editing the data.
occurred, it must be -Backdating the dates on the data as
properly documented, if it occurred earlier
e.g., audit trail, traceable -Coping existing data as if it occurred
to original data. this time
-Turning audit trails off to hide data
changes
-Unauthorized access to computer
system to modify, delete, or not save
electronic files is not prevented
-Releasing product that does not
meet the product specifications (i.e.,
failing product)
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
+ Complete All of the data generated -Failure to maintain all of the data
is included in the analysis. generated for a test, e.g., eliminating
This includes all runs, bad testing data and only keeping
whether good or bad. In part of the data
some cases data may not -All of the analysis (good or bad) for
be used in an analysis, but the sample was maintained
it is addressed in a -For chromatographs, not including
deviation or investigation data for all injections
and shown to be invalid. -Testing samples into compliance
-Unauthorized access to computer
See 21 CFR 211.194 system to modify, delete, or not save
electronic files is not prevented
-Re-running samples to get desired
results
 ALCOA Element Description Examples of Data Integrity Issues
Acronym
+ Consistent This refers to the consistent -Evidence that data is backdated
use of date and time -Date and/or time markings are out of
stamps and that the data order
is collected/reported in
the proper sequence (as
expected).
+ Enduring The original data is -Use of post-its or scrap paper to
recorded in controlled record data and later transfer the
records, e.g., controlled data without identifying it as
(numbered) worksheets, transcripted data
laboratory notebooks -Failure to save electronic or manual
(bound) or electronic records
media.
+ Available One can access the data -Failure to maintain the records for the
throughout the lifetime of product lifecycle (and any other
the record (and the applicable retention periods)
associated retention -Failure to save electronic or manual
period required). records
DATA INTEGRITY
FROM REGULATOR’S PERSPECTIVE /
EXPECTATIONS
INSPECTION FOCUS
Data integrity requirements applicable to:

API and FP manufacturers, including contract

manufacturing
Testing units, including contract laboratories
Outsourced GMP activities such as equipment
qualification and calibration
INSPECTION FOCUS – general
Company understanding of computerized system
capabilities and transfer of data between systems
Up to date listing of all relevant systems and GMP
functionality
Control of networked & standalone instruments
Policies and procedures detailing processing and
control of data
INSPECTION FOCUS – qualification
User Requirement Specification - should describe
the required functions of the computerized system
and be based on documented risk assessment and
GMP impact.
•Evidence of appropriate test methods and test
scenarios for parameter limits, data limits and error
handling
•Justification on the extent of validation and data
integrity controls documented through risk
assessment of the computerized system.
INSPECTION FOCUS – system administration
Configuration of systems – GxP functions
 Security of the system and user access levels –
appropriate segregation of duties
 Electronic signatures – use of individual and
generic passwords
INSPECTION FOCUS – data
Data processing and review
Accuracy checks
Potential for data manipulation and deletion
Repeat testing / replicate data
Date / time stamp manipulation
Criteria used to invalidate data
Data transfer to systems - Checks that data are not
altered in value and/or meaning (primary and
meta data). Level of checking should be
statistically sound
INSPECTION FOCUS – storage of data
Regular back-ups of all relevant data should be
done. Integrity and accuracy of backup data and
the ability to restore the data should be checked
during validation and monitored periodically.
Archived data should be checked for accessibility,
readability and integrity. If changes are to be
made to the system, then the ability to retrieve the
data should be ensured and tested
INSPECTION FOCUS
Audit trails - Consideration should be given, based
on a risk assessment, to building into the system the
creation of a record of all GMP-relevant changes
and deletions
Vendors - Subject to requirements for assessment of
contractor competency to deliver expectations.
Change management - Changes to a part of the
system may pose a risk due to interdependencies.
INSPECTION FOCUS
Data Integrity included in risk assessments
Data Integrity included in training program
Data Integrity included in self inspection program -
justify frequency of periodic evaluation based on
system criticality and complexity
Deficiencies - Computerized Systems
 A listing of GMP computerized systems was not maintained.
 The software utilized to control [equipment] had not been
categorized.
 Not all critical GxP systems were present. For example the
[Equipment] Program and Review software.
 While a statement of GxP or non-GxP was documented for
Global Systems, there was no associated documentation
justifying the statement.
 Computerized System Risk Assessments for critical systems
were not in place.
 There was no system description/boundary despite the
critical system being ‘live’.
Deficiencies – user accounts
 It was possible for administrators to verify their own test result
recording in ERP. There were no procedural restrictions
around this and was hence considered to increase the
overall risk of the associated testing processes.
 The ‘system owner access level’ was not described.
 The removal of test accounts had not been considered by
the company prior to the system going ‘live’.
 ERP] access configurations for the job roles within the site
was not adequately defined in that there was no
documented correlation of roles to the user access
elements defined by the Global [ERP] group.
 System authorization concepts were not always considered
in that Users could be administrators with full system access
and also have batch manufacturing responsibilities.
Deficiencies – audit trails

 Audit trail comments on [the CDS] were not always

sufficiently detailed. For example, a number of changes
were observed to have been made to the integration
method utilized on [a test] on [a date] and these had a
comment of ‘save’ documented.
 Operating System User Accounts were utilized to access the
<system>. There was no periodic review of Operating
system audit trails (logs) as appropriate and this was not
justified.
Deficiencies – qualification
 The qualification of the ERP system was considered deficient
in that:
 The independent code review was not available for review
during the inspection.
 The actual observed results were not always documented
within the qualification records
 The procedure for electronic signatures data transfer to the
ERP system was not described in a procedure and was not
qualified.
 There was no assessment of ERP database integrity.
 The decision not to test requirement [Electronic Signatures]
documented in [Rationale] was not considered to be
justified in that the referenced documents disclaimer stated
that the information should not be relied upon.
Deficiencies – qualification
 The Virtual Private Network software had not been subject
to GxP assessment or qualification as appropriate.
 In relation to the back up and restoration of data
 There was no process for logging of media used to back up
the server systems.
 The maximum number of uses for the magnetic tapes was not
defined or the number of uses controlled.
 All backup activities on the site were not procedurised. For
example back up of the [Program] data from [Equipment]
and back up of certain [Equipment] PLC code was performed
on an ad-hoc basis using HDDs which were not stored in an
appropriate location.
Deficiencies – periodic review/evaluation
 The periodic assessment of computerized systems had not
been completed for all equipment. For example,
[computerized system] was installed [a long time ago] and
at the time of the inspection had not been reassessed.
 Periodic review of global applications was not performed
and there was no procedure in place for periodic review.
 The periodic system review of the <system> was
<documented>. The review stated that there was no
requirement for audit trail review as they were “displayed
on the screen”. This was not considered to justified. Further
to this, there was no procedure in place for periodic audit
trail review.
Deficiencies – change management
 In relation to the testing associated with <IT Change Control
System>, the evidence for the appropriate test scenario
was not available for review. The system permitted only the
most recent test scenario for the process to be viewed.
There was no evidence that the system level risk assessment
had been critically assessed prior to this change in order to
determine the appropriate test scenarios. Further to this, the
change to this production parameter had been assigned as
a non regulatory change i.e. not subject to GxPs.
 Change logs for <ERP> user access sub-role profiles were
maintained in an uncontrolled manner. E.g
Z_XXX_XXX_XX_DATA, the associated text box change log
had three entries post implementation of <IT Change
Control System> whereas <IT Change Control System> listed
four valid changes for this profile
Deficiencies – production
 The following deficiencies were noted with regards to the blister
packaging machine :
 There was no controlled recipe in place to confirm that parameter
settings on the machine were those approved.
 The time on the HMI was incorrect – the actual time (taken from
the wall clock in the packaging area was recorded at 12:15, the
machine time was displayed as 11:08.
 A generic operator password was in use
 Audit trails were not reviewed.
 The print out function was not enabled and there was no
assessment to determine if stored data could be securely
transferred or downloaded to storage media in an intelligible
format for review
 Manufacturing data since 2003 from a previous manufacturer /
owner was retained on machine.
Deficiencies – production

 The qualification and data integrity controls for the filling

machine were considered inadequate in that:
 There was no technical agreement with the vendor
 A single generic user name and password was used to access
and operate the equipment.
 The time setting on the software control was inaccurate.
 The audit trail could not be generated at the time of inspection.
 The system and security for archiving of data was not known
 The User Requirement Specification did not specifically state all
the requirements for the machine and was not linked to any
critical process parameters / variables
Deficiencies – production

 The company is advised that manufacturing controls should be

updated in line with technical progress (ref. Directive
2003/94/EC, Article 5 (2)). In particular fluid bed dryers should
be equipped with chart recorders to facilitate monitoring and
recording of the granulate drying process.
 •The qualification / revalidation was deficient in that there was
no consideration of the impact of updated requirements since
the initial IOQ, specifically Annex 11.
Deficiencies – QC data

 There was no justification for the test injections of samples

including stability samples being run prior to system suitability.
 There was no explanation for why areas changed for test
injections from test, test 1 and test 2, prior to running the sample
set. It was noted that when the assay for test was calculated
that this resulted in an OOS result, whereas the result for test 2
was within specification.
 The Empower list of users and user types did not reflect the
highest level of access a user had.
 Analysts with System Administrator access had the ability to
change custom fields including calculations and sample
names.
Deficiencies – QC data

 The company stated that sample injections were being run as

there were problems with the systems, however; no evidence
of this was presented.
 The results of a processed test injection had been deleted by
an analyst with administrator access.
 There was no requirement to review raw data on electronic
systems.
 There was no requirement to review audit trails.
 Projects were not locked and it was possible to reprocess results
Deficiencies – QC data

 There was no date / time stamp of printing on analytical reports

from ‘system’ (chromatograms, methods and sample set data)
to facilitate traceability and ensure integrity of the data
 The procedure for test performance and review of documents
did not make reference to review of the audit trail or review of
soft copies of the chromatograms on the ‘system’ network
 A number of sample sets and their associated injections on the
‘X system’ in the stability laboratory, were not all appropriately
identified and carried non descriptive titles, such as “trial”
 No deviations or explanations had been documented for a
number of ‘altered sample’ incidences which were evident
from ‘X system’ project audit trails
Deficiencies – QC data

 There was no date / time stamp of printing on analytical reports

from ‘X system’ (chromatograms, methods and sample set
data) to facilitate traceability and ensure integrity of the data
 The procedure for test performance and review of documents
did not make reference to review of the audit trail or review of
soft copies of the chromatograms on the ‘X system’ network
 Alterations to runs were frequently performed to add an extra
test or blank sample but there was no procedure in place for
this and the reason for the changes was generally not
recorded to a level of detail enabling the true reason for the
change to be determined
Deficiencies – QC data

 A number of sample sets and their associated injections on the

‘X system’ in the stability laboratory, were not all appropriately
identified and carried non descriptive titles, such as “trial”
 •Management of the ‘X system’ was considered deficient as a
number of GxP functions were observed as not switched on
(e.g. Allow lock channels after sign off, Disallow use of
Annotation Tools etc). In addition, it was observed that a
statement by ‘X company’ reflected below the GxP function
window indicated that they recommended all GxP functions to
be switched on
 •The LC Solution system (version ‘y.yyy’) for the ‘X’ HPLC system
was considered deficient in that all users could gain
‘Administrator’ access to the application system by using a
common username ‘Admin’ and no password
Deficiencies – QC data
 Raw data for HPLC/GC runs which had been invalidated due
to failed system suitability criteria were stored separately to the
QC raw data packages and were not included in the review
process. The ‘log for record of invalidated runs’ was not
incorporated under the quality management system and
invalidated runs were not always evaluated and documented
 Original run sequences which had been amended during
HPLC/GC runs were not printed and retained with the QC raw
data packages
 Full Audit Trail did not appear to be available for the ‘X’ data
acquisition system in that the different version numbers of the
processing methods were not all visible in the audit trail (e.g.
the current version of ‘Y’ method was 18 and only 7 lines were
visible on the audit trail). In addition, there were no data audit
trails available on this system
 Deficiencies - stability
Stability data had discrepancies including:
 Initial records of secondary spots for TLC related substance
tests were later re-annotated to indicate that no secondary
spot had been identified
 Data recorded in summary reports were not reflective of the
raw data
 Summary reports were presented to the inspector for which
the supporting raw data could not be provided
 Deficiencies - stability
Stability data had discrepancies including (cont’d):

 Missing raw data and summary report for batch of ‘X’ Tablets
where stability data had been used to support the risk
assessment of product remaining on the market in the EU
 Missing raw data and incorrect entries that were reviewed and
authorised as correct
 Some stability data presented to the inspector was from product
packed in different packaging to that supplied to the market
and therefore not relevant
 Statements of Non-compliance
Issues identified which compromised the integrity of analytical
data :
Evidence seen of data falsification
Significant number of product stability data results
reported in the Product Quality Reviews had been
fabricated
Neither hard copy nor electronic records available
Issues seen with HPLC electronic data indicating
unauthorised manipulation of data and incidents of
unreported trial runs prior to reported analytical runs
Record integrity and veracity - some records made up or
altered
Lack of mechanisms to ensure integrity of analytical data
 Statements of Non-compliance

Critical deficiency cited with regards to testing of finished

product and stability testing related to data integrity :

Deleted electronic files with no explanation

The running of “trial testing” prior to performing system
suitability and the formal testing
Loss of control of reconciliation of samples - those used for
additional testing could not be traced
Manipulation and falsification of documents and data
observed in different departments
SUMMARY

You don’t need to be an IT expert, but you need

to know GMP requirements
Understand the capability of your equipment,
know if it stores electronic data, assess if
parameters are changed what impact it will
have.
Integrity of data is not a ‘new’ regulatory
requirement.
SUMMARY OF REGULATORS’ EXPECTATION

You don’t need to be an IT expert, but you need

to know GMP requirements
Understand the capability of your equipment,
know if it stores electronic data, assess if
parameters are changed what impact it will
have.
Integrity of data is not a ‘new’ regulatory
requirement.
DATA INTEGRITY
AN INDUSTRY PERSPECTIVE
What is Breach of Data Integrity (BDI) ??
 Breach of Data Integrity is , a violation of the integrity of
Data. Which means, the actions performed and the
documents/records written do not reflect the truth and
the reality which has taken place.
 It is not about Lab Data alone
 “Data Integrity is not only about the QC, it applies to
compliance with GMPs:
 Relates to:
- Research & Development
- Clinical Trials
- Manufacturing & Testing
- Inspection
- Post Inspection Activities
BDI – CONTRIBUTING FACTORS –
TECHNICAL ASPECTS
Product Development & Technology Transfer:
Unrealistic commitments, inadequate
development and associated documentation
Over commitment regularly contribute to data
integrity issues
Material attributes and Critical Process
Parameters – not defined through formal Risk
Assessment
The responsibilities of the technology Sending Unit
and Receiving Unit are not defined and / or
controlled
BDI – CONTRIBUTING FACTORS –
TECHNICAL ASPECTS
Product Development & Technology Transfer:
 Not following ICH Guidelines Q8, Q9 & Q10
 Quality should be built into the product from
development through to clinical and subsequent
regulatory approval. Testing alone cannot be relied
upon to ensure product quality.

In other words, even before commercial manufacture,

safety, efficacy and quality of the drug product must be
unambiguously established.
BDI – SOME CONTRIBUTING FACTORS –
BEHAVIOURAL
DATA INTEGRITY
DATA INTEGRITY
 DATA INTEGRITY
At highest level of learning ‘Unconscious
Competence’, one is incapable of
committing a deliberate error
Good Practice becomes second nature
A good habit is involuntary, needs no
supervision, is driven by character ethic
and in the face of challenging situation
does not change
THANK YOU