Life Sciences

21 CFR Part 11 Decoded: Controls For Open Systems

fda-open-systems

 

This post is the second in the 21 CFR Part 11 “mini-series” focused on Subpart B – Electronic Records. Pull out your decoder rings and let’s look at Section 11.30 – Controls for Open 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. 

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11.30 – Controls for Open Systems

Mailbox LocationLync/Skype account locationPreparation Required
OnlineOnlineYes
On-premises

OnlineYes
OnlineOn-premises

Yes
On-premises

On-premises

No*

Well, 11.30 is nice and short, but the “additional measures” that you need to take are basically up for grabs, which can be overwhelming. Also, figuring out whether your system is “open” or “closed” can be confusing – we have had several internal discussions about this, here in the life sciences practice. The way “open” and “closed” are defined in the broader IT world is different from the definitions provided by the FDA in 21 CFR Part 11. When in doubt, stick to the regs. Or, just give us a call and we’ll help you through it.

Check back soon for the next post in this Subpart B mini-series: Section 11.50 – Signature Manifestations.

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.

About the Author

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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