21 CFR Part 11 Compliance

 

 

GemStone can be part of your lab's compliance strategy for 21 CFR Part 11 when it is setup and operated in Compliance mode.  It has been developed under a quality management system and validated with a suite of quality assurance tests. The table below summarizes how the key elements of Part 11 relate to GemStone and its use in Compliance mode settings.

 

Section Summary of Rule Compliance Strategy
11.10 Controls for closed systems GemStone can be accessed only through the user interface; it is a closed system.
11.10 (a) Validation and accuracy. GemStone uses externally-generated data to validate its results and employs proprietary binary format, static PDF, and/or CRC methods to ensure valid files.
11.10 (b) Record generation and readability GemStone generates CRC-checked log files and static PDF reports that are human-readable and machine-readable.
11.10 (c) Record protection and retrieval Record retention and retrieval plan is managed by the laboratory’s file management practices.
11.10 (d) Authorized access GemStone uses the operating system’s user login validation, and user group membership determines permissions within the software.
11.10 (e) Audit trails GemStone employs a CRC-checked logging system with time stamps, and log files are preserved. Log files cannot be deleted by ordinary means.
11.10 (f) Operational system checks GemStone enables and disables portions of the UI to enforce permitted sequencing of steps and events.
11.10 (g) Authority checks GemStone uses the operating system user groups and login validation to assure authorized access.
11.10 (h) Device checks and validity GemStone performs validation checks on the FCS data files.
11.10 (i) Education, training and experience GemStone provides a User Guide, technical support, and tutorial videos to assist with the proper, intended use of the program. Specific on-site training may be arranged.
11.10 (j) Electronic signatures This is an individual laboratory requirement beyond the scope of use of GemStone.
11.10 (k) Systems documentation GemStone version releases are accompanied by an updated User Guide. Verity employs document control procedures.
11.30 Controls for open systems GemStone is designed as a closed system.
11.50 Signature manifestations GemStone does not require or offer electronic signatures.
11.70 Signature linking GemStone does not require or offer electronic signatures.
11.100 (a) Unique electronic signatures Your laboratory must ensure that electronic signatures are unique to each user on the network.
11.100 (b) Identity verification Each laboratory must verify its own employment records and IDs.
11.100 (c) Signature verification Each laboratory must verify electronic signature eligibility with the FDA.
11.200 (a)(1) Two-component signing GemStone does not require or offer electronic signatures.
11.200 (a)(2,3) Authenticity and falsification GemStone does not require or offer electronic signatures.
11.200 (b) Biometric signatures GemStone does not utilize biometric IDs.
11.300 (a) Controls for identification GemStone uses the operating system user groups and login validation to assure unique user identities.
11.300 (b) Identification aging The individual laboratory IT structure must control password checks and aging requirements.
11.300 (c) External ID validation Not applicable. GemStone does not utilize external tokens, cards, RFID, or other physical identity-confirming devices.
11.300 (d) Unauthorized use The individual laboratory IT structure must control login authenticity and manage safeguards to prevent unauthorized use.
11.300 (e) External device testing Not applicable. GemStone does not utilize external tokens, cards, RFID, or other physical identity-confirming devices.