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USFDA Warning Letter – Data Deletion & Audit Trails

Electronic Files Could Be Deleted

FDA WarningData DeletionAudit Trail

Electronic files from lab systems could be deleted with no adequate controls. HPLC/GC control software did not have appropriate audit trails enabled for significant changes.

Where This Issue Shows Up

QC labs + stability labs; also CRO labs running OTC/API testing.

What Had Happened

  • 1

    Electronic files from a lab system could be deleted (no adequate controls).

  • 2

    HPLC/GC control software did not have appropriate audit trails enabled for significant changes.

Why It Matters

Even if you think you're compliant, regulators focus on whether the system prevents/records deletion and modification of GxP data.

Bad Consequences

  • Regulators typically demand:

  • retrospective review of affected data,

  • re-testing / re-qualification,

  • and proof that electronic records are trustworthy.

Our Mitigation Strategy

What "audit-ready software" must enable:

1Technical Controls

  • Implement write-once / immutable storage for raw data + metadata.

  • Configure deletion = prohibited (or requires controlled workflow with reason + dual approval).

  • Audit trail must capture who/what/when/why, and be retained as long as the record.

  • Add a "data integrity monitor": alerts for deletions, method edits, reintegration, reprocessing, aborted runs.

Category

QC Labs

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