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Clock-back + Shared Login + Audit Trail Disabled

Chromatography Data Integrity Issue

Data IntegrityAudit TrailFDA Compliance

Analysts changed HPLC computer date/time, re-ran analyses, and reported only passing repeats. Initial results were overwritten/deleted with no user traceability.

Where This Issue Shows Up

QC labs (API / DP testing), CRO analytical labs, bioanalytical labs using CDS/Chrom systems.

What Had Happened

  • 1

    Analysts changed the HPLC computer date/time ("clock-back"), re-ran analyses, and reported only passing repeats.

  • 2

    Initial results were overwritten/deleted and not available for FDA review.

  • 3

    Shared login was used (no user traceability).

  • 4

    Multiple instruments had audit trail feature disabled even though the software supported it.

Bad Consequences

Data integrity is questioned across products/batches; regulators often require broad retrospective impact assessments and may block approvals/supply until remediated.

Our Mitigation Strategy

What "audit-ready software" must enable:

1Technical Controls

  • Lock OS time changes (GPO/MDM), enforce NTP time sync, log any time drift attempts.

  • Enforce unique user IDs, prohibit shared accounts, implement role-based access and MFA for admins.

  • Audit trail always-on, tamper-evident, and independent (users cannot edit or disable it).

2Procedural Controls

  • SOP: repeat testing, invalidations, integration changes require documented justification + e-signature.

  • Routine audit trail review by QA (risk-based frequency).

3Validation

  • Validate the CDS configuration (not just the vendor product): audit trail, security, signatures, record retention.

Category

QC Labs

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