Procedure for Ensuring Compliance with Data Archiving Policies
Department | Quality Assurance (QA)/Information Technology (IT)/Regulatory Affairs |
---|---|
SOP No. | SOP/Ointment/170 |
Supersedes | V 1.0 |
Page No. | Page X of Y |
Issue Date | [Insert Issue Date] |
Effective Date | [Insert Effective Date] |
Review Date | [Insert Review Date] |
1. Purpose
The purpose of this Standard Operating Procedure (SOP) is to establish a structured approach for data archiving, ensuring compliance with Good Manufacturing Practices (GMP), regulatory guidelines, and internal data retention policies. Proper data archiving safeguards critical records and maintains data integrity for audits and inspections.
2. Scope
This SOP applies to personnel in the Quality Assurance (QA), Information Technology (IT), and Regulatory Affairs departments responsible for the storage, retrieval, and management of archived data in pharmaceutical manufacturing.
3. Responsibilities
- QA Officer: Ensures adherence to archiving procedures.
- IT Administrator: Maintains electronic archiving systems and data security.
- Regulatory Affairs Officer: Verifies compliance with regulatory data retention policies.
- QA Manager: Approves archiving policies and reviews data access logs.
4. Accountability
The QA and IT Managers are accountable for ensuring that all archived data is securely stored, retrievable, and maintained in compliance with GMP, FDA, ICH, and WHO regulations.
5. Procedure
5.1 Types of Data to be Archived
The following categories of data must be archived:
- Batch Manufacturing Records (BMR): Includes production details and quality checks.
- Quality Control (QC) Test
5.2 Data Archiving Methods
Archiving may be done in either physical (paper-based) or electronic formats, based on company policy.
- Physical Archiving:
- Paper documents must be stored in fireproof, locked cabinets.
- Archived documents must be labeled with unique identification numbers.
- Storage areas must be climate-controlled and protected from moisture.
- Electronic Archiving:
- Data must be stored in a **validated Document Management System (DMS).**
- Backups must be performed on **secure servers with restricted access.**
- Electronic signatures must comply with **21 CFR Part 11** for regulatory acceptance.
5.3 Data Retention Period
- All data must be archived for the following minimum durations:
- Batch Manufacturing Records: **At least 5 years after product expiration.**
- QC Analytical Data: **At least 7 years.**
- Regulatory Documents: **At least 10 years.**
- Equipment Calibration Logs: **At least 5 years.**
- Training Records: **At least 3 years post-employment.**
- Records must be accessible for regulatory inspections at all times.
5.4 Security and Access Control
- Archived data must have **restricted access** based on role-based permissions.
- QA and Regulatory Affairs personnel must approve any **data retrieval requests.**
- Access to electronic archives must require **password authentication and audit logging.**
- Physical archives must be protected with **authorized key or badge entry.**
5.5 Data Backup and Disaster Recovery
- Electronic archives must have:
- Daily incremental backups.
- Weekly full backups stored on secure cloud or off-site locations.
- Data recovery testing performed **annually.**
- Paper-based archives must have **duplicate copies stored off-site** for critical records.
- Emergency recovery plans must be documented and reviewed **every six months.**
5.6 Periodic Review and Audit of Archived Data
- QA and IT must conduct **quarterly audits** of archived records.
- All archived data must be verified for completeness and compliance.
- Non-compliant records must be corrected within **15 days** of identification.
6. Abbreviations
- GMP – Good Manufacturing Practices
- QA – Quality Assurance
- QC – Quality Control
- DMS – Document Management System
- FDA – Food and Drug Administration
- ICH – International Council for Harmonisation
7. Documents
- Data Archiving Log (Annexure-1)
- Data Retrieval Request Form (Annexure-2)
8. References
- ICH Q7 – GMP for Active Pharmaceutical Ingredients
- WHO Guidelines on Data Integrity and Archiving
- US FDA 21 CFR Part 11 – Electronic Records and Signatures
9. SOP Version
Version 2.0
10. Approval Section
Prepared By | Checked By | Approved By | |
---|---|---|---|
Signature | |||
Date | |||
Name | |||
Designation | |||
Department |
11. Annexures
Annexure-1: Data Archiving Log
Date | Document Type | Retention Period | Storage Location | QA Approval |
---|---|---|---|---|
02/02/2025 | Batch Record | 5 Years | Secured Archive | Approved |
Annexure-2: Data Retrieval Request Form
Date | Requester Name | Document Type | Purpose | Approval Status |
---|---|---|---|---|
02/02/2025 | Jane Smith | QC Test Report | Regulatory Audit | Approved |
12. Revision History
Revision Date | Revision No. | Details | Reason | Approved By |
---|---|---|---|---|
02/02/2025 | 2.0 | Expanded Archiving Security Measures | Improved Compliance | QA Head |