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  • 1.  Electronic signature

    Posted 01-Aug-2018 00:11

    Hi ,

    Can anybody clarify the requirements under 21 CFR Sec C Part 11.100 , what does this requirement pertain to and what is required?

     

    (c) Persons using electronic signatures shall, prior to or at the time of such use, certify to the agency that the electronic signatures in their system, used on or after August 20, 1997, are intended to be the legally binding equivalent of traditional handwritten signatures.

    (1) The certification shall be submitted in paper form and signed with a traditional handwritten signature, to the Office of Regional Operations (HFC-100), 5600 Fishers Lane, Rockville, MD 20857.

    (2) Persons using electronic signatures shall, upon agency request, provide additional certification or testimony that a specific electronic signature is the legally binding equivalent of the signer's handwritten signature.

     

    Thanks & Regards,

     

    Rashmi Pillay
    Regulatory Affairs Associate


    Ellex 

    3-4 Second Avenue

    Mawson Lakes SA, 5095

     

    T + 61 8 7074 8105
    rpillay@ellex.com

    W ellex.com

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  • 2.  RE: Electronic signature

    Posted 02-Aug-2018 07:47
    ​Hi Rashmi,

    I'm not sure for what purpose you are intending to use electronic signatures, but you may find this link helpful.  This is specific to the FDA ESG system, it is samples of  Non-Repudiation Agreement letters.

    Appendix G: Letters of Non-Repudiation Agreement
    Fda remove preview
    Appendix G: Letters of Non-Repudiation Agreement
    FDA Industry Systems (FIS) was created to facilitate making submissions to the U.S. Food and Drug Administration (FDA), including registrations, listings, and other notifications; FIS includes Food Facility Registration, Prior Notice of Imported Foods, Low Acid Canned Foods, Electronic Submissions Gateway, and other industry information.
    View this on Fda >


    Regards,
    Melissa

    ------------------------------
    Melissa Torpey
    Global Regulatory Compliance Specialist
    Victor NY
    United States
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  • 3.  RE: Electronic signature

    Posted 02-Aug-2018 08:33
    Melissa has directed you to the correct FDA information on Letter of Repudiation.  While that information is specific to the ESG, the certification requested is for any electronic signature on a document or record that is considered required under the Predicate Rule - that is any document or record required by regulation to be signed.

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    Glen Park
    Jersey City NJ
    United States
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  • 4.  RE: Electronic signature

    Posted 02-Aug-2018 10:15
    Hi Rashmi, 

    21CFRPart11 should be applied any time an electronic signature is used in place of a wet-ink signature. Here is an example. We use electronic signatures in MasterControl; the user enters their username and an "electronic signature" (like a password) to electronically approve standard operating procedures and other quality events. 

    Before a user's account is set up in this system, they provide a wet-ink signature on a following document with the following statement:

    "By signing this form, the Employee listed below is certifying that they understand that His or Her Electronic Signature (i.e. Unique User ID and Approval Password) is to be considered as a legally acceptable and functionally binding equivalent of their paper-based signature.

     They are also certifying that they shall:

    •  Protect their passwords at all times. They shall not:
      • Share, post, circulate passwords or access security credentials
      • Cut, paste, modify or alter e-signatures
    • Report compromised electronic signatures and/or lost laptops to their managers and IT as soon as possible.
    • Report any suspected misuse of their password.
    • Be accountable for any actions to which their electronic signature is applied.
    • Answer any questions about their application of an electronic signature when asked by a regulatory authority."
    We scan and store these completed forms electronically for review by regulatory agencies upon request. Hope this helps clarify the requirement a bit.

    Best, 



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    Kelly Dolezal
    Savoy IL
    United States
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  • 5.  RE: Electronic signature

    Posted 02-Aug-2018 11:00
    ​Hi Rahmi,

    The letter of certification alluded to is a one-time obligation of each company that intends to utilize electronic signatures on records regulated by the USFDA. Here are the instructions (better than the reg) provided by the FDA:  Electronic Records: Electronic Signature Certification.

    Note that the address to send the letter of certification to has changes from what is in the regulation.

    Best regards,
    Kevin

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    Kevin Hawkins, RAC
    Director, Quality & Regulatory Affairs
    Portland OR
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