Regulatory Open Forum

 View Only
  • 1.  21 CFR Part 11

    Posted 02-Dec-2014 09:34
    Dear all,

    We are a manufacturer of dietary suppléments. Do we have to be compliant with 21 CFR Part 11 for the management of our electronic data?

    Thank you for your assistance.

    -------------------------------------------
    Kerry


  • 2.  RE: 21 CFR Part 11

    Posted 03-Dec-2014 08:33
    Hi Kerry.

    From my understanding, 21 CFR 11 is a "general" requirement in the regulations in terms of applicability.  So if you are using electronic data as your system of record, the data really should conform to 21 CFR 11 requirements.  That said, there might be ways to get around the requirement to meet 21 CFR 11 if your system is not capable or does not validate as conforming to the requirements...but that requires a lot more process than most companies want to involve in my experience.  So my suggestion is to either obtain a 21 CFR 11 capable system or to remain on paper in general.

    -------------------------------------------
    Victor Mencarelli
    Sr. Manager - Regulatory Affairs
    United States
    -------------------------------------------




  • 3.  RE: 21 CFR Part 11

    Posted 04-Dec-2014 06:27
    Dear both

    Part 11 can only ever come into force in conjunction with a predicate rule (e.g. 21 CFR Part 210 is a predicate rule). You need to establish if there is a predicate rule for dietary supplements (I just don't know if there is one). If not, Part 11 will not apply.

    If there is, the question remains whether you create electronic records within the meaning of Part 11 - it is best to consult the Scope and Application guidance issued by FDA.

    If you are still stuck after that maybe you need to consult with an expert who looks at your specific circumstances

    Regards
    Siegfried

    -------------------------------------------
    Siegfried Schmitt
    Principal Consultant
    PAREXEL
    Braintree, Essex
    United Kingdom
    -------------------------------------------




  • 4.  RE: 21 CFR Part 11

    Posted 04-Dec-2014 07:52
    Kerry,

    21 CFR 111.605 states the requirements for records for dietary supplements. Paragraph (c) specifically states..."All electronic records must comply with part 11 of this chapter."

    Best wishes,

    -------------------------------------------
    Mark Loewen
    Director, QA/RA
    First Quality Hygienic, Inc.
    McElhattan PA
    United States
    -------------------------------------------




  • 5.  RE: 21 CFR Part 11

    Posted 04-Dec-2014 09:53

    Thank you all for your advice.

    Kerry
    -------------------------------------------
    Kerry Diaz
    Regulatory Affairs Manager
    Bio-K Plus International Inc.
    Laval QC
    Canada
    -------------------------------------------