White Paper

How to Implement Good

Documentation Practices

This white paper describes the fundamental requirements of Good Documentation Practice
(GDP) routinely used within the pharmaceutical industry – as best practice standards or as a
direct requirement of the Code of Good Manufacturing Practice (GMP).

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Why are document standards important?

In a GMP environment documentation needs to meet certain requirements to ensure product
quality and product safety. If an instruction or record is poorly documented, then the
manufacture or Quality assurance/control of a product can be negatively impacted, potentially
reducing patient safety.
The GMP regulations from PIC/S, FDA and EU all include mandatory sections on documentation.
Documentation provides both:
 Information on when, where, who, why and how to complete tasks, and
 Evidence proving that the tasks have been completed as they should be.
Consequently, the standard of documentation within a company can directly impact the level of
success in manufacturing quality products that are safe as well as success during audit
situations.

“If it isn’t written down, then it didn’t happen” TGA & FDA

The basics of GDP

To meet industry standards, it is critical that all documentation follows GDP when it affects:
 GMP processes
 material or product identity, quality, purity, strength and safety
 the validated state of GMP product manufacture, facilities, equipment, computer systems
and testing methods.
It is recommended that your company has a policy or procedure outlining the expected GDP
standards, particularly for those requirements that may be unique to your company – for
example, using a specific pen colour or when and how to use scanned documents/records as
original data.

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Documentation is a valuable resource

Documentation may be divided into:
 documents – procedural or instructional documentation, and
 records – evidence of compliance.
Refer to EU GMP Chapter 4 for further information on different types of documents.
Both documents and records are an invaluable communication tool for any business.
Benefit Description Form of documentation
Provide background Information storage point for anyone to access. Record
history Information can be added at any time, providing a
full history.

Preserves learning and Reference for future use or a means to Document

knowledge communicate information to others. Particularly
important to ensure that knowledge is not lost
when an employee leaves.

Protects intellectual Evidence of an idea or a finding including the date Record

property and the responsible person.

Provides legally valid Documents events, processes, ideas, Record

evidence communications etc. which can show that
something did or did not happen.

Ensure the quality and Provides the same critical information and Document
consistency of processes training to all relevant employees, to ensure the
/activities/manufacturing quality and safety of the product.

Different types of documents and records

Documentation and records used throughout the manufacturing process, as well as supporting
processes (e.g. Quality Control or Quality Assurance), must meet the basic requirements of
GDP. These include (but are not limited to):
 Batch Record Forms
 Bills of Materials (BOMs)
 Specifications
 Policies
 Protocols
 Standard Operating Procedures (SOPs)
 Work Instructions (WIs)
 Test Methods
 Checklists
 Forms/Log sheets
 Training Assessments
 Electronic and hardcopy Quality records (e.g. non-conformance, corrective and preventative
actions, internal inspection, change control, training records etc.)
 Certificate of Analyses (CoA) or Certificate of Compliance (CoC)
 Technical transfer reports
 Validation documentation

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General requirements
The following requirements should be applied to all documentation within the GMP
environment.
General elements GDP requirements
Clearly written All documents must be accurate and written in a manner that prevents errors
documentation and ensures consistency. If documents are to be used together, e.g. an SOP and
a form, then each should reference the other.
Ensure there is traceability between two or more documents/records using
formal document numbers or record identification.

Using indelible ink All records must be filled out in indelible ink for long term legibility. Do not use
pencil or ink that can be erased.
Colour should be specified by the company GDP procedure; often this is limited
to blue or black because historically copy/scanning technology was limited in
reproduction quality. However, this is less of a factor with the advent of high
resolution scanners and colour copiers.
Consistent use of blue and black ink on GMP documentation provides a more
professional perception of your organisation.

Legible handwritten A document is unusable if it cannot be read, so care must be taken to ensure
entries that handwriting is legible. All entries must be made at the time the tasks are
performed and should be legibly signed and dated.
The same is true of electronic documents and records – language should be
clear and unambiguous.

Reviewing and Documents and records should be reviewed by someone who did not perform
approving the task to ensure that the information is correct and accurate. A signature and
date by the reviewer/approver confirms that a review has taken place.
Unsigned documents or records are incomplete and should not be used to
perform any task or considered as evidence of a completed task.

Staff signatures Handwritten signatures must be unique to the individual and listed within the
site signature register to ensure that the signature is traceable to a member of
staff (or contractor). Staff are not permitted to sign for another member of staff
unless delegated. Signatures must never be forged.
The management of the signature record should be governed by a procedure
and routinely reviewed so that it remains current – new staff should sign the
signature register during induction, the signature register must indicate the
date staff exit the company.
Electronic signatures must meet the same general documentation
requirements – refer to EU Annex 11: Computerised Systems or PIC/S Annex
11: Computerized Systems for additional regulatory requirements.

Signed delegation of In the event that a critical member of staff is absent for a time, they must
responsibility delegate responsibility to another qualified person. The delegation must be
either:
 proceduralised in a document (SOP, WI etc.), or
 documented with names of all people involved and signed by the person
that is delegating their responsibility. The delegation should also be
approved with the signature of a more senior member of staff.

Page numbering GMP documents should have page numbers using the following standard ‘X of
Y’ to indicate the total number of pages in a document.

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Records must be permanent

Traceability of records in the GMP environment is of critical importance so that:
 the company can prove they are compliant to the Code of GMP and to their own processes
and procedures
 the root cause of a non-conformance or a justified customer complaint can be identified
 corrective or preventative actions can be implemented and their effectiveness checked over
time.
It is imperative that records are accurate and any changes or amendments are made in a
complaint manner.
General requirements
No Requirement
1 Deliberately amending or destroying GMP records to hide or falsify data is fraud.

2 Do not discard a GMP record just because you might have made a mistake, it is still required for
traceability.

3 It is not acceptable to discard GMP records for any reason unless the retention period expiry is
reached.

4 Loose unofficial papers, notes and uncontrolled documents that can easily be lost or changed
without appropriate approval do not meet GDP requirements.

5 Do not use notebooks/legal pads with easily removed pages, scrap paper or post-it-notes to
record GMP information.

Record control
Your site GDP procedure should describe the types of workbooks/notebooks that may be used –
typically these are hard-covered with sown/sturdy binding; avoid spiral bound workbooks or
logbooks as pages may be removed.
In an emergency, if no official means to record an observation is available, then:
 Initial, date and provide a comment on the paper record of the observation and attach to the
official hardcopy record as soon as possible.
 Transcribe and attach the data to the official record and annotate ‘Transcribed, see attached
original’. The transcription must be signed and dated by the Preparer and filed/stored
together with the original record.
 The data must be checked for accuracy by a second staff member.
 Investigate why an official record was not available at the time. Implement corrective
actions so that the same situation may not arise again, e.g. create a form for the record,
amend the procedure, change the process so that the record is captured electronically etc..

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Using true copies

Sometimes there is a need to use a copy of an original document or record, e.g. attaching a copy
of a report to a non-conformance record. So that it is apparent that the record is not the
original:
 Stamp or write on the front of the copied documentation, ‘True Copy’.

 Sign and date the ‘True Copy’ amendment.

Modifying records in a compliant manner

The company GDP procedure should stipulate how data or entries may be amended. This should
include details on:
 Any standard abbreviations used, e.g. ‘not applicable’ (NA or N/A) etc.
 Unacceptable practices, e.g. using ‘ditto’ marks (“) to indicate the same entry as above,
leaving empty fields in a form, etc.
 Who is responsible for checking documentation amendments or general GMP compliance of
logbook pages over time.

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The following requirements outline the ways in which handwritten entries may be amended.
Handwritten GDP requirements Example
Corrections
Making a legible If a correction needs to be made, the original record must still be legible:
correction 1. Make a single line through the error – never use correction fluid,
multiple cross-outs or marker pen to obscure the original record.
Original information must still be legible after correction.
2. Record the correction close by – numbering corrections is acceptable
when space is limited. If the record becomes too congested with
corrections, an attachment may be used, however the original record
must indicate the number of pages attached and the attachment
reference the record it is related to.
3. Provide a brief comment why the change is required (as appropriate).
4. Initial the change so that it is clear that the correction is deliberate.
5. Record the date of the correction next to the initials so that there is a This is a very poor example of a correction.
record of when the change was made.

Handling omitted If an entry was omitted and must be made at a time later than the activity Standards UV Absorbance 1. Data collected 12/12/12 but not
data was performed then: recorded due to fire evacuation.
Std 1 1.022
1. Clearly indicate the date the activity was performed and the date the Data retrieved from instrument on
activity is recorded on the documentation. Std 2 0.958 13/12/12 .
2. Document an explanation to substantiate the entry and the reason for the 2. Completed by C. Kent 13/12/12
Std 3 0.994 (1)
delay in recording. Checked by L. Lane
3. Sign and date the change. 21/05/12
Important: Back dating of entries is not permitted.

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Handwritten GDP requirements Example

Corrections
Completing all All fields on a record should have an entry, even if it is ‘N/A’. Alternatively,
fields on a record multiple blank spaces/rows/columns on a record must be marked out with a
single line across the whole field/space. This: Date Result
 ensures that the record cannot be added to at a later date without
appropriate checking or approval
 indicates that not completing a field/space is deliberate.
Marking out a larger space or whole page may be completed with a diagonal N/A
line.
Use ‘N/A’ above the line (or other standard response indicated in the site
B. Wayne 20/07/12
GDP procedure) and sign and date to shown that the field/space is not
applicable.
An explanation may be required why the field/space is ‘not applicable’.

Name: B Wayne Date: 15 August 2012

Important: A GMP record is incomplete when fields or spaces for entries
have not been filled. Do not discard a page of a record just because the fields Equipment No.: NA Calibration expiry: NA
are not applicable because the page could be mistaken as missing.
Solution expiry: 20 August 2012 Storage: 2-8C
Do not use ditto marks to indicate the field is the same as above.

Checking Corrections or amendments may be made after the content of the record has
corrections already been checked. Therefore, the correction must also be checked by the
Name: B. Wayne Date: 15 August 2012
same person who checked the rest of the document.
The checking analyst should: Equipment No.: NA Calibration expiry: NA
1. Review the change and ensure that it has been made in a complaint Solution expiry: 20 August 2012 Storage: 2-8C
manner – clear, legible, accurate, original entry is still visible etc.
21 Aug 2012 (incorrect expiry assigned)
2. Review the change with respect to the content of the rest of the
B. Wayne 16 Aug 2012.
document
Checked by P. Parker 16 Aug 2012.
3. Sign and date the correction.
Important: Correction dates occurring after the last date that the record was
checked are not compliant.

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Recording numbers
The following requirements outline the ways numbers should be recorded.
Recording numbers GDP requirements
Decimal numbers The company GDP procedure should stipulate any specific requirements for
recording data.
In general, if a decimal value is a fraction of 1 then a zero must be placed before
the decimal point.
Example: Record 0.98 rather than .98
The number of decimal places to be recorded should be outlined in a procedure.
Example: When a specification limit is 2.55 - 2.85 and the result is 2.7, then
record the result as 2.70 and not 2.7.

Rounding The company must indicate how any rounding is to be performed and the results
recorded.
Consider the number of significant figures of the specification and the error of
the instrument/equipment, rounding averages etc.

Dates format Record dates following common practice of the country, such as Day/Month/Year
(Australia) or Month/Day/Year (USA). Because of differences between countries,
it is recommended that the month is denoted by its first 3 letters for clarity.
Example: 11/03/12 or 11/03/2012 or 11 Mar 2012.
This is particularly relevant for multi-national companies where different date
formats are traditionally used. A corporate policy should cover multi-national
date formats so that there is consistency in records and prevents confusion
between different sites.

Time format Record time in 24 hour format (00.00 – 23.59) or denoting am or pm.
Example: 1 pm or 13.00
Record a period of time in hours and minutes. The site GDP procedure should
indicate when to use 24 hour increments.
Example: 1 hr 36 min or 1:36 hours or 96 min.

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Dealing with attachments and printouts

The following requirements must be met when attaching records and printouts to GMP
documents.
Handling GDP requirements
attachments
Attachments to forms Attach one record to another (for example if a report is to be attached to a form):
• Staple the attachment to the record; paperclips are not acceptable.
• Cross-reference the record and the form with each other, e.g. the record
references the report number and the report references the record number

Attachments to • Secure the attachment to the appropriate page of the workbook/logbook –

workbooks/logbooks use tape or staples, glue or paperclips are not acceptable
• Do not obscure any data on either the workbook page or attachment.
• Ensure sufficient identification on the attachment to ensure traceability in
the event it becomes separated (cross-referencing)
• Indicate on the original document that there is an attachment.
• Sign and date both the workbook and attachment.

Thermal printouts All printouts made on thermal paper must be copied before attaching to a report
or filing. Indicate ‘copy of original ’or ‘true copy,’ on the copy and initial and date.
Do not tape over information on thermal paper as the tape will cause the data to
rapidly fade. After making a copy, secure the original and the copy with the
report.

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Using scanned documents

Scanned documents, converted to pdf files, are very useful for companies or department
operating across different locations. However, the company should indicate how to treat
scanned documentation and other compliance requirements associated with electronic media
(refer to PIC/S Annex 11: Computerized Systems).
Scanning GDP requirements
documents
Obtaining approval Obtaining approval signatures from staff located at different sites/locations/
signatures time-zones can be completed using scanning rather than hardcopy:
1. Print the document to be approved
2. Sign and date the hardcopy and then scan the hardcopy with the signature.
3. The pdf file of the scan is emailed to the appropriate signatories, who each
print out the pdf file, sign and date their signature field, and then re-scan
the document and email back to the preparer.
4. The preparer receives a pdf file from each signatory indicating their
approval.
5. Attach the signatory page from each approver to the original, hardcopy with
the preparer’s hardcopy signature.
6. Indicate on the front page the number of attached signature pages.
7. File all the pdf files in the same storage folder as per the company policy
for electronic versions.

Access to pdf and MS Generally, pdf versions of documentation can be accessed by staff because they
Word versions are not able to be changed (without specific software).
However, MS Word files (or equivalent software) can be changed and so should
have limited access for most staff (unless other security functions are enabled).

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Communication styles used in GDP

The following table contains suggestions for communication styles useful for GDP.
Actions How they help
Using words that everyone Unfamiliar words reduce the reader’s understanding of what is written.
can understand (reduce It can also interrupt their flow of learning if they need to search for the
jargon or abbreviations) meaning of a word. Therefore, jargon or abbreviations should be avoided
if possible, unless well known to the audience.
Definitions of jargon or abbreviations should always be included in the
document for reference. This is most effectively done by included the
definitions in a table format, at the start or end of the document.
There is often company-specific jargon that develops within a company
or on a site that may be very confusing to outsiders or new staff –
prepare a list of these terms that is easily accessible and include within
the induction procedure and for audit situations.

Using words with The English language is full of descriptive words which can have
unambiguous meaning different meanings depending on the context, the understanding of the
reader and even cultural differences. For this reason, words should be
chosen very carefully.

Using whitespace Ensure that the contents of the document are not squeezed into a
smaller area just to limit page numbers. Documents with small margins
and no spaces between paragraphs and headings can be difficult to look
at, hard and slower to read. Space the contents out so that the type/font
is easy to read for all users (consider the overall audience age, or
potential colour blindness or dyslexia).

Providing enough detail to When creating a document, consider the context in which the document
make sense of it in the future may be used in the future and whether the reader has enough
background information. However, too much non-critical information
can also detract from the document and make it too wordy.

Using pictorial or graphical Many people remember information best when there is a strong visual
aids (including tables) prompt, such as a diagram. When the document has to be wordy,
consider using tables to structure the information so it is less
overwhelming to the reader.

Previous experience and The level of detail, written style and type of document should all be ruled
expectations by the documents target audience.

Consistent wording to avoid Referring to something by two different names, even if only slightly
confusion different, can be confusing.

Consistent styles templates Consistency with styles will give any document a greater sense of
professionalism.

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About PharmOut
PharmOut is a professional consultancy offering product registration, engineering, validation
and regulatory compliance solutions to the Medical Device, Pharmaceutical and Veterinary drug
manufacturing industry from concept development, feasibility studies, scale up, engineering
design, project management to the final product regulatory approval and GMP compliance
certification.

How PharmOut can help

We offer the following range of services:
ISO, GMP & APVMA compliance consulting
Policies, SOP, and Forms. We can also help you obtain approval from the following
international regulatory authorities (APVMA, FDA, MHRA, and TGA).
Engineering
Our experienced industry engineers can develop concept and detailed designs, around your
production process ensuring full GMP compliance by careful project management and
verification (validation) to ensure that the exacting GEP standards are met.
GMP Compliance
We can visit your site before or after a FDA or TGA GMP audit to assess and improve your quality
management systems and/or validation documentation, business processes and physical
operations.
Quality Management Systems
We can help you create a Quality Management System from scratch, or bring your current
system into compliance.
Technical Document Writing
We can help you write procedures and work instructions that your staff will actually use and can
follow.
ISO & GMP consulting
We can provide practical recommendations and advice on the implementation of ISO 9001 for
Pharmaceuticals or ISO 13485 for Medical Device Quality Management Systems, Policies, SOP,
and Forms. We can also help you obtain approval from the following international regulatory
authorities (FDA, MHRA, and TGA). This includes Part 11 and Annex 11 compliance to FDA and
TGA requirements.
Training
We run on-site or in-the-city classroom training on GLP, GMP compliance, validation and
documentation writing. We also develop e-learning modules on topics such as Good Record
Keeping that you can use for your ongoing training needs.
Validation
Our validation engineers / specialists can write validation plans, specifications and qualification
protocols for i.e. cleaning validation, equipment validation, computers systems validation,
analytical method validation or process validation.

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