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2014 · 09DataRegulatory Notices

Audit-trail review added to batch release

Ergopharm has added routine audit-trail review to its batch release process, so that the electronic record is examined as part of every release rather than only when an auditor asks for it.

Computerised systems that generate GMP data record who did what and when. That record is only a control if somebody reads it. Reviewing audit trails at release means that a changed result, a re-integrated chromatogram or a deleted injection is seen by the person deciding whether the batch ships, at the moment the decision is made.

An audit trail nobody reads is not a control. It is a log file.

The review is proportionate and defined: which systems, which events, and what constitutes an exception requiring investigation. Chromatographic data systems, the environmental monitoring system and the serialisation records are all in scope.

The practice sits within the ALCOA+ expectations for data integrity and the requirements for computerised systems in EU GMP Annex 11, and it applies equally to paper records, where original entries are never obliterated.

Key facts

When
At batch release, not only at audit
Systems in scope
Chromatography, environmental monitoring, serialisation
Defined
Which events reviewed, what counts as an exception
Framework
ALCOA+; EU GMP Annex 11

This notice describes Ergopharm’s own packaging and processes and how they follow published standards; it does not assert a specific national marketing approval.