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7-Documentation
• After completing this
lecture, the students ... 1. Know the concept of documentation. 2. Understand different guidelines for good documentation. 3. Differentiate between quality manual and policies. 4. Understand each step of GMP to achieve documentation. 5. Realize the elements to be covered in mistakes correction. A Famous Proverb says: “IF YOU HAVE NOT DOCUMENTED AN ACTIVITY, YOU HAVE NOT DONE IT” • “ Documentation is any communicable material that is used to describe, explain or instruct regarding some attributes of an object, system or procedure, such as its parts, assembly, installation, maintenance and use.” • Clearly written documentation prevents errors that may arise in oral or casually written communication. • It provides assurance that quality related activities are carried out exactly the way they have been planned and approved Purpose of documentation • To ensure that there are specifications for all materials and methods of manufacture • Employees know what to do • Responsibilities and authorities are identified • Ensure that authorized persons have all information necessary for release • Provide audit trail • Forms the basis for improvement. Principle of documentation • It shall be able to record executed activities for maintenance, storage, quality control, distribution and other specific matters. • For all manufacturing activities, a documentation system must be prepared. • The system consisting of manufacturing formulae and instructions, specifications, procedures and records must be free from errors and clearly established. • A document bearing original signatures should never be destroyed. • Never falsify information • Never you a White-out and cover-over-tapes Properties of documentation system • Able to record the complete history of batch. • Adequate to permit investigation. • Documents shall contain all information, to be kept up to date and any amendment shall be performed by following proper document change control procedure. • It shall include provision for periodic review. • Product related records shall be retained for at least one year after the expiry date of the finished product. Reasons for Documentation • If an instruction or record is poorly documented, then the manufacturer or Quality assurance/control of a product can be negatively impacted, potentially reducing patient safety. • Consequently, the standards 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. • Ensures documented evidence, traceability, provide records and audit trails for investigation • Ensures availability of data for validation, review and statistical analysis. Electronic Data • Data may be recorded by electronic systems, photographic or other reliable means. • There shall be detailed procedure (e.g. SOP) relating to the system in use. • Be checked and verified for accuracy of the records • Be authorized personnel to enter or modify data in the computer. • Be a record of changes and deletions • Be traceability to all raw data • Be restricted by passwords or other means for access • Be independently checked and verified for the result of entry of critical data. • Be protection and back-up for all batch records. Types of documents • Quality manual • Policies • Standard operating procedures (SOPs) • Batch records • Test methods • Specifications • Logbooks • Narrative • Flowchart • A global company document that describes, in paragraph form, regulations or that the company is required to follow. • Documents that describe in general terms, and not with step-by-step instructions, how specific GMP aspects (such as security, documentation, health, and responsibilities) will be implemented. Batch records • These documents are typically used and completed by the manufacturing department. • Batch records provide step-by-step instructions for production-related tasks and activities, besides including areas on the batch record itself for documenting such tasks. Test methods • These documents are typically used and completed by the quality control (QC) department. • Test methods provide step-by-step instructions for testing supplies, materials, products, and other production-related tasks and activities, e.g., environmental monitoring of the GMP facility. • Test methods typically contain forms that have to be filled in at the end of the procedure. Specifications • Documents that list the requirements that a supply, material, or product must meet before being released for use or sale. • The QC department will compare their test results to specifications to determine if they pass the test. • Bound collection of forms used to document activities. • Logbooks are used for documenting the operation, maintenance, and calibration of equipment and to record critical activities, e.g., monitoring of clean rooms, solution preparation, recording of deviation, change controls and its corrective action assignment. Narrative document • The most common format being used • The narrative document can be described as the following: Ø Policy reference Ø Objective : why and for what Ø Coverage area Ø Document reference Ø Responsible person Ø Detail procedure Ø Record if needed Flowchart document • Schematic representation which describe the flow of processes in certain target activity. • Very clear and easy to understand. • For complicated process, sometimes flowchart alone might not be able to capture detailed information, therefore it should be combined with a narrative. Requirements for Good documentation Approve, review & update documents Change & current revision status of document Relevant versions of applicable documents Document remain legible and readily identifiable Documents of external origin identified Prevent unintended use of obsolete documents. Constitutes of Documentation Clearly Written documentation All documents must be accurate & written in a manner that prevents errors and ensure consistency. Using indelible ink: Don’t use pencil or ink that can be erased Legible hand written entries Reviewing & approving Staff Signatures: Hand written Signature must be unique to the individual and listed within the site signature register to ensure that signature is traceable to a member of staff. Page Numbering Correction of mistakes • Make a single line through the error • never use correction fluid, multiple cross or marker pen to obscure the original record. • Provide a brief comment why the change is required. • Initial the change so that it is clear that the correction is deliberate. • Record the date of the correction next to the initials so that there is a record of when the change was made. Common Documentation Errors Missing signature and dates at the time of activity performed. The write-over Non-uniform date and signature entry Writing a note that activity was performed on one day and signed for on other day. Blank spaces Illegible writing Too many corrections