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21 CFR Part 11 Decoded: Controls For Closed Systems

This post marks the first in the 21 CFR Part 11 series that is focused on Subpart B – Electronic Records. Since Subpart B contains four sections, its 21-cfr-part-11-Controls-Closed-Systems“mini-series” will contain four posts. Do you have your decoder rings handy? It’s time to decode Section 11.10 – Controls for Closed Systems.

In the table below, the actual language from each regulation is on the left, and my personal interpretation of what that language means is on the right. Keep in mind that I do not represent the FDA and nothing in the “Interpretation” column should be taken as fact.

11.10 – Controls for Closed Systems

Mailbox LocationLync/Skype account locationPreparation Required





Whew! That was a big one. Eleven Subsections! Are your decoder rings smoking?? When all of the dust settles, the most important takeaway here is that you MUST have procedures and controls for the above topics clearly documented and available for inspection. In the life sciences industry, documentation is paramount, so be sure to tell your QA department that you appreciate what they do.

Up next? Subpart B, Section 11.30 – Controls for Open Systems. Don’t worry – it’s short. 😉

If you have questions between now and the next post, feel free to contact us. To read past posts in the 21 CFR Part 11 Decoded series, click here.

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Marin Richeson

Marin joined the life sciences industry in 2001. Over the course of her tenure, she has held roles in clinical finance, IT, quality assurance, and validation. The diversity of her experience provides her with a unique perspective on the interconnectedness of this complex, multi-faceted industry. Marin Richeson is a lead business consultant in Perficient's life sciences practice.

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