Approval of GxP documents when working from home during the coronavirus (COVID-19) outbreak
Guidance for organisations involved in any aspect of the pharmaceutical lifecycle or GLP studies regulated by MHRA, covering the approval of paper documents when working from home
Latest change: First published.
AI Summary
The UK Medicines and Healthcare products Regulatory Agency (MHRA) issued this guidance to address challenges in approving paper documents during the COVID-19 pandemic. As remote work became standard, traditional wet-ink signatures for documents like validation protocols, risk assessments, and standard operating procedures (SOPs) became impractical. This guidance applies to all organizations within the pharmaceutical lifecycle, including those governed by Good Manufacturing, Distribution, Laboratory, Clinical, and Pharmacovigilance Practices (GxP). While existing validated electronic systems are preferred, the MHRA allows alternative methods—such as secure email or third-party software—provided they maintain document control. Key requirements include ensuring that remote signatures are equivalent to handwritten ones and are strictly attributable to the individual owner to prevent unauthorized use. Organizations must define their document distribution and approval processes clearly to minimize errors and ensure that remote reviewers have access to all necessary supporting data. A risk-based approach is mandatory, following regulatory frameworks like EU GMP Chapter 4 and Annex 11. Critical actions include ensuring documents cannot be altered after signing and maintaining a robust audit trail. While this is general guidance rather than a specific company inspection report, failure to implement these controls could lead to data integrity issues and regulatory non-compliance during future inspections.
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