21 CFR Part 11 Compliance

 

ModFit LT 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 ModFit LT and its use in Compliance mode settings.

 

Section Summary of Rule Compliance Strategy
11.10 Controls for closed systems ModFit LT can be accessed only through the user interface; it is a closed system.
11.10 (a) Validation and accuracy. ModFit LT 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 ModFit LT generates Xml-format model files, CRC-checked log files, and static PDF 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 ModFit LT uses the operating system’s user login validation, and user group membership determines permissions within the software.
11.10 (e) Audit trails ModFit LT 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 ModFit LT enables and disables portions of the UI to enforce permitted sequencing of steps and events.
11.10 (g) Authority checks ModFit LT uses the operating system user groups and login validation to assure authorized access.
11.10 (h) Device checks and validity ModFit LT performs validation checks on the FCS data files.
11.10 (i) Education, training and experience ModFit LT provides a User Guide, technical support, and tutorial videos to assist with the proper, intended use of ModFit. Specific on-site training may be arranged.
11.10 (j) Electronic signatures This is an individual laboratory requirement beyond the scope of use of ModFit LT.
11.10 (k) Systems documentation ModFit LT version releases are accompanied by an updated User Guide. Verity employs document control procedures.
11.30 Controls for open systems ModFit LT is designed as a closed system.
11.50 Signature manifestations ModFit does not require or offer electronic signatures.
11.70 Signature linking ModFit LT 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 ModFit LT does not require or offer electronic signatures.
11.200 (a)(2,3) Authenticity and falsification ModFit LT does not require or offer electronic signatures.
11.200 (b) Biometric signatures ModFit LT does not utilize biometric IDs.
11.300 (a) Controls for identification ModFit LT 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. ModFit LT 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. ModFit LT does not utilize external tokens, cards, RFID, or other physical identity-confirming devices.