Document Management System

Comprehending Good Documentation Practices (GDocP) for Pharma & Medical Device Manufacturing

Comprehending Good Documentation Practices (GDocP) for Pharma & Medical Device Manufacturing

Arundhathy Shabu

July 26, 2024

Document Management System

Comprehending Good Documentation Practices (GDocP) for Pharma & Medical Device Manufacturing

Arundhathy Shabu

July 26, 2024

Comprehending Good Documentation Practices (GDocP) for Pharma & Medical Device Manufacturing

Document Management System

Arundhathy Shabu

.

July 26, 2024

You must be familiar with GxP referring to the ‘good practice’ guidelines and regulations ensuring that food, medical devices, drugs, and other life science products are safe, and of high quality. Good Documentation Practices (GDocP) is one such GxP applicable to the pharmaceutical and medical device industries. 

Thoroughly grasping GDocP is paramount for relevant enterprises as it describes a globally recognized standard for the creation, management, and maintenance of reliable and accurate documents. Thus, GDocP emerges as a non-negotiable element of any pharmaceutical quality system (PQS) and quality risk management (QRM).

What are Good Documentation Practices (GDocP)?

GDocP, also known as Good Recordkeeping Practice (GRK), is a set of protocols to ascertain informational validity and compliance with regulatory requirements in the pharmaceutical and medical device industries. GDocP welcomes a robust quality assurance system which is mandatory for organizations operating in these highly regulated sectors. 

Different regional regulatory bodies, such as the FDA in the United States, the EMA in Europe, the WHO, Health Canada, and the TGA in Australia, have established comprehensive documentation requirements to adhere to Good Documentation Practices (GDocP). While some GDocP standards are codified by authorities, others are not but are considered part of cGMP, with an emphasis on “current.” They ensure that all records are precise, complete, timely, legible, traceable, and properly controlled. 

Non-compliance with these mandates can lead to severe consequences, including regulatory penalties and fines, product recalls, and patient safety risks. Regulatory bodies can issue warning letters, suspend operations, or impose hefty fines. Furthermore, poor documentation can compromise product quality, leading to recalls and patient harm, while non-compliance to damage a company’s reputation, loss of licenses, and fraud charges. This underscores the critical importance of complying with GDocP to ensure patient safety and maintain the integrity of pharmaceutical products as well as medical devices.

Knowing the Key Principles of GDocP

Food Safety Management Software

Boost your food business’s hygiene standards with Smart Food Safe’s tech-driven solutions—streamline 4C processes to yield optimal results, and ensure compliance effortlessly.

Food Safety Management Software

Boost your food business’s hygiene standards with Smart Food Safe’s tech-driven solutions—streamline 4C processes to yield optimal results, and ensure compliance effortlessly.

The core principles of GDocP, known as the ALCOA+ principles, state that all documentation should be:

  • Attributable –  Each recorded task must be traceable to the individual or computerized system that performed it, including the time of the task. This requirement extends to any modifications to records, such as corrections, deletions, and changes, where it is crucial to know who made the change, when it was made, and why.
  • Legible – All records must be clear and readable to ensure they are understandable and useful. This applies to all information needed to be considered complete, including all original records or entries. 
  • Contemporaneous – Documentation of actions, events, or decisions should be made at the time they occur. This ensures that the documentation accurately reflects what was done, or decided, and why, capturing the influences on decisions at that time.
  • Original – The original record is the first capture of information, whether on paper (static) or electronically (dynamic, depending on system complexity). Information initially captured in a dynamic state should remain available in that state.
  • Accurate – Records must truthfully represent facts. Ensuring accuracy involves several elements of a PQS, including: 
     1. Equipment-related factors like qualification, calibration, maintenance, and computer validation.
     2. Policies and procedures that control actions and behaviors.
     3.
    Deviation management, including root cause analysis, impact assessments, and CAPA.
     4.
    Trained and qualified personnel who understand the importance of following established procedures and documenting their actions and decisions.
  • Complete – To understand an event fully, all critical information must be retained and not lost or deleted. The required detail level for completeness depends on the information’s criticality. 
  • Consistent – Information must be created, processed, and stored consistently. This involves policies or procedures that help standardize data (e.g., chronological sequencing, date formats, units of measurement, etc.).
  • Enduring – Records must be maintained in a way that ensures their integrity and accessibility for the entire retention period. They need to remain intact and accessible as durable records throughout this period.
  • Available – Records must be available for review at any time during the required retention period, accessible in a readable format to all applicable personnel responsible for their review, whether for routine release decisions, investigations, trending, annual reports, audits, or inspections.

Applying these aspects appropriately across all applicable areas of GMP and GDP activities, along with other supporting elements of a PQS, ensures the reliability of the information used to make critical decisions regarding medicinal products.

Types of Documents Requiring GDocP Compliance in Pharma & Medical Device Industries

The manufacturing processes of pharmaceutical products and medical devices involve distinct procedures and respective documents documenting them.

  • Standard Operating Procedures (SOPs)

SOP documents outline the essential processes and protocols that must be followed to ensure product quality and regulatory compliance.

  • Quality Management System (QMS) Documentation

QMS documentation provides a structured framework for managing quality policies, procedures, and processes within the organization.

  • Batch Records & Production Logs

These records necessitate GDocP compliance to maintain traceability and control of manufacturing processes and product history.

  • Laboratory Notebooks & Testing Records

These documents capture the data and observations from laboratory experiments and testing, ensuring authenticity and reproducibility of results. 

  • Deviation & CAPA Reports

These reports document any deviations from standard processes and the corrective and preventive actions taken to address them.

  • Training Records

Training records track the qualifications and training history of employees to ensure they are competent to perform their assigned tasks, within the regulated environments.

How to Ideally Implement a GDocP System

Like every other GxP, establishing a GDocP system should comprise well-defined steps covering document lifecycle management. 

1. Establish a Documentation Policy

Develop a clear GDocP policy outlining objectives, scope, and applicability to ensure consistent documentation across all processes.

2. Develop Standard Operating Procedures (SOPs)

Create and standardize SOPs for document creation, review, approval, distribution, and archiving using approved templates.

3. Document Creation and Review

Ensure all documents are accurate, complete, legible, and traceable, with proper recording of data and details like dates and signatures.

4. Document Approval and Distribution

Set up a thorough review and approval process involving authorized personnel, and control the distribution of documents to maintain current versions.

5. Record Keeping and Archiving

Store records securely, define retention periods in compliance with regulations, and ensure easy accessibility for authorized personnel.

6. Regular Audits and Reviews

Conduct regular internal audits to verify GDocP compliance, identify areas for improvement, and implement continuous enhancements.

7. Handling Deviations and Corrections

Document, investigate, and correct any deviations from procedures, preserving original entries and preventing recurrence.

8. Documentation Culture

Foster a culture that values proper documentation as critical to manufacturing excellence, with strong leadership support for GDocP.

9. Electronic Documentation Systems

Utilize electronic documentation systems to streamline document control, improve accessibility, and ensure data integrity and regulatory compliance.

10. Training and Awareness

Provide comprehensive training to all employees on GDocP principles, with regular updates to maintain awareness and compliance.

Looking ahead, the future trends in GDocP are increasingly leaning towards digital documentation and electronic records, driven by the need to enhance efficiency in record-keeping. The transition from paper to electronic documentation represents a pivotal shift, as organizations aim to revamp operations and boost regulatory compliance. 

However, implementing GDocP faces several challenges, including but not limited to data security concerns, the need for validation processes, and the integration of new systems with legacy infrastructure. Overcoming these hurdles is a front-runner for harnessing the full potential of a seamless and compliant GDocP system.

Major Challenges Faced in GDocP Implementation & How Can Smart Food Safe’s Smart Docs Help?

Smart Food Safe’s Smart Docs is a document compliance software solution instrumental for businesses seeking to digitally strategize and enforce good documentation practices (GDocP). We present a centralized document management system to bring efficient document control and transparency by tackling the multiple challenges hindering GDocP implementation. Let’s dive into how Smart Docs make this possible.

Challenges

  • Inconsistent Documentation

    Different personnel may document information in varied formats, leading to inconsistencies

How Smart Docs’ Features Assist

  • Configuration of Custom Folders and Global Standards

    Properly categorize the documentation under uniform standards and folders.
  • Human Error

    Mistakes in documentation, such as incorrect entries or miscalculations, are common and can affect data accuracy.
  • Systematic Review and Approval Checks

    Well-defined workflow and reviewer notes to refer for respective users while approving the document, before submission for approval, and before publishing.
  • Version Control Issues

    Maintaining the correct version of documents and ensuring that all personnel are using the most up-to-date version can be challenging.
  • Version and Change Log

    Maintain the version and change log logic for each published document edit in order to track all changes and maintain a history of document versions.
  • Retrieval and Accessibility of Documents

    Efficiently storing and retrieving documents, especially in large volumes, can be challenging.
  • Document Numbering System

    Implement digital document numbering that allows for organized indexing, and retrieval of documents.
  • Collaboration and Review Processes

    Facilitating collaboration and review processes among multiple stakeholders.
  • Real-Time Document Collaboration

    Enable coauthoring of documents for editing, viewing, commenting, and creating notes in real-time, while streamlining the review and approval processes.
  • Audit Readiness

    Being prepared for audits and inspections with accurate and easily accessible documentation.
  • Audit Log Maintenance

    Comprehensive audit trails and reporting capabilities for each level of document version, enabling organizations to quickly compile and present documentation for audits, thereby improving audit readiness.
  • Storage and Backup

    Managing the storage and backup of large volumes of documentation.
  • Cloud-based Document Management

    Offer scalable storage solutions and automatic backup features, ensuring that documents are securely stored and backed up without requiring extensive physical storage space.
  • Document Integrity and Security

    Maintaining the integrity and security of documents to prevent unauthorized access or tampering.
  • Access Controls and Encryption

    Ensure that only authorized personnel can access and modify documents, thereby maintaining document integrity and security.

Document Management Software

You must be familiar with GxP referring to the ‘good practice’ guidelines and regulations ensuring that food, medical devices, drugs, and other life science products are safe, and of high quality. Good Documentation Practices (GDocP) is one such GxP applicable to the pharmaceutical and medical device industries. 

Thoroughly grasping GDocP is paramount for relevant enterprises as it describes a globally recognized standard for the creation, management, and maintenance of reliable and accurate documents. Thus, GDocP emerges as a non-negotiable element of any pharmaceutical quality system (PQS) and quality risk management (QRM).

What are Good Documentation Practices (GDocP)?

GDocP, also known as Good Recordkeeping Practice (GRK), is a set of protocols to ascertain informational validity and compliance with regulatory requirements in the pharmaceutical and medical device industries. GDocP welcomes a robust quality assurance system which is mandatory for organizations operating in these highly regulated sectors. 

Different regional regulatory bodies, such as the FDA in the United States, the EMA in Europe, the WHO, Health Canada, and the TGA in Australia, have established comprehensive documentation requirements to adhere to Good Documentation Practices (GDocP). While some GDocP standards are codified by authorities, others are not but are considered part of cGMP, with an emphasis on “current.” They ensure that all records are precise, complete, timely, legible, traceable, and properly controlled. 

Non-compliance with these mandates can lead to severe consequences, including regulatory penalties and fines, product recalls, and patient safety risks. Regulatory bodies can issue warning letters, suspend operations, or impose hefty fines. Furthermore, poor documentation can compromise product quality, leading to recalls and patient harm, while non-compliance to damage a company’s reputation, loss of licenses, and fraud charges. This underscores the critical importance of complying with GDocP to ensure patient safety and maintain the integrity of pharmaceutical products as well as medical devices.

Knowing the Key Principles of GDocP

Food Safety Management Software

Boost your food business’s hygiene standards with Smart Food Safe’s tech-driven solutions—streamline 4C processes to yield optimal results, and ensure compliance effortlessly.

The core principles of GDocP, known as the ALCOA+ principles, state that all documentation should be:

  • Attributable –  Each recorded task must be traceable to the individual or computerized system that performed it, including the time of the task. This requirement extends to any modifications to records, such as corrections, deletions, and changes, where it is crucial to know who made the change, when it was made, and why.
  • Legible – All records must be clear and readable to ensure they are understandable and useful. This applies to all information needed to be considered complete, including all original records or entries. 
  • Contemporaneous – Documentation of actions, events, or decisions should be made at the time they occur. This ensures that the documentation accurately reflects what was done, or decided, and why, capturing the influences on decisions at that time.
  • Original – The original record is the first capture of information, whether on paper (static) or electronically (dynamic, depending on system complexity). Information initially captured in a dynamic state should remain available in that state.
  • Accurate – Records must truthfully represent facts. Ensuring accuracy involves several elements of a PQS, including: 
     1. Equipment-related factors like qualification, calibration, maintenance, and computer validation.
     2. Policies and procedures that control actions and behaviors.
     3.
    Deviation management, including root cause analysis, impact assessments, and CAPA.
     4.
    Trained and qualified personnel who understand the importance of following established procedures and documenting their actions and decisions.
  • Complete – To understand an event fully, all critical information must be retained and not lost or deleted. The required detail level for completeness depends on the information’s criticality. 
  • Consistent – Information must be created, processed, and stored consistently. This involves policies or procedures that help standardize data (e.g., chronological sequencing, date formats, units of measurement, etc.).
  • Enduring – Records must be maintained in a way that ensures their integrity and accessibility for the entire retention period. They need to remain intact and accessible as durable records throughout this period.
  • Available – Records must be available for review at any time during the required retention period, accessible in a readable format to all applicable personnel responsible for their review, whether for routine release decisions, investigations, trending, annual reports, audits, or inspections.

Applying these aspects appropriately across all applicable areas of GMP and GDP activities, along with other supporting elements of a PQS, ensures the reliability of the information used to make critical decisions regarding medicinal products.

Types of Documents Requiring GDocP Compliance in Pharma & Medical Device Industries

The manufacturing processes of pharmaceutical products and medical devices involve distinct procedures and respective documents documenting them.

  • Standard Operating Procedures (SOPs)

SOP documents outline the essential processes and protocols that must be followed to ensure product quality and regulatory compliance.

  • Quality Management System (QMS) Documentation

QMS documentation provides a structured framework for managing quality policies, procedures, and processes within the organization.

  • Batch Records & Production Logs

These records necessitate GDocP compliance to maintain traceability and control of manufacturing processes and product history.

  • Laboratory Notebooks & Testing Records

These documents capture the data and observations from laboratory experiments and testing, ensuring authenticity and reproducibility of results. 

  • Deviation & CAPA Reports

These reports document any deviations from standard processes and the corrective and preventive actions taken to address them.

  • Training Records

Training records track the qualifications and training history of employees to ensure they are competent to perform their assigned tasks, within the regulated environments.

How to Ideally Implement a GDocP System

Like every other GxP, establishing a GDocP system should comprise well-defined steps covering document lifecycle management. 

1. Establish a Documentation Policy

Develop a clear GDocP policy outlining objectives, scope, and applicability to ensure consistent documentation across all processes.

2. Develop Standard Operating Procedures (SOPs)

Create and standardize SOPs for document creation, review, approval, distribution, and archiving using approved templates.

3. Document Creation and Review

Ensure all documents are accurate, complete, legible, and traceable, with proper recording of data and details like dates and signatures.

4. Document Approval and Distribution

Set up a thorough review and approval process involving authorized personnel, and control the distribution of documents to maintain current versions.

5. Record Keeping and Archiving

Store records securely, define retention periods in compliance with regulations, and ensure easy accessibility for authorized personnel.

6. Regular Audits and Reviews

Conduct regular internal audits to verify GDocP compliance, identify areas for improvement, and implement continuous enhancements.

7. Handling Deviations and Corrections

Document, investigate, and correct any deviations from procedures, preserving original entries and preventing recurrence.

8. Documentation Culture

Foster a culture that values proper documentation as critical to manufacturing excellence, with strong leadership support for GDocP.

9. Electronic Documentation Systems

Utilize electronic documentation systems to streamline document control, improve accessibility, and ensure data integrity and regulatory compliance.

10. Training and Awareness

Provide comprehensive training to all employees on GDocP principles, with regular updates to maintain awareness and compliance.

Looking ahead, the future trends in GDocP are increasingly leaning towards digital documentation and electronic records, driven by the need to enhance efficiency in record-keeping. The transition from paper to electronic documentation represents a pivotal shift, as organizations aim to revamp operations and boost regulatory compliance. 

However, implementing GDocP faces several challenges, including but not limited to data security concerns, the need for validation processes, and the integration of new systems with legacy infrastructure. Overcoming these hurdles is a front-runner for harnessing the full potential of a seamless and compliant GDocP system.

Major Challenges Faced in GDocP Implementation & How Can Smart Food Safe’s Smart Docs Help?

Smart Food Safe’s Smart Docs is a document compliance software solution instrumental for businesses seeking to digitally strategize and enforce good documentation practices (GDocP). We present a centralized document management system to bring efficient document control and transparency by tackling the multiple challenges hindering GDocP implementation. Let’s dive into how Smart Docs make this possible.

Challenges

  • Inconsistent Documentation

    Different personnel may document information in varied formats, leading to inconsistencies

How Smart Docs’ Features Assist

  • Configuration of Custom Folders and Global Standards

    Properly categorize the documentation under uniform standards and folders.
  • Human Error

    Mistakes in documentation, such as incorrect entries or miscalculations, are common and can affect data accuracy.
  • Systematic Review and Approval Checks

    Well-defined workflow and reviewer notes to refer for respective users while approving the document, before submission for approval, and before publishing.
  • Version Control Issues

    Maintaining the correct version of documents and ensuring that all personnel are using the most up-to-date version can be challenging.
  • Version and Change Log

    Maintain the version and change log logic for each published document edit in order to track all changes and maintain a history of document versions.
  • Retrieval and Accessibility of Documents

    Efficiently storing and retrieving documents, especially in large volumes, can be challenging.
  • Document Numbering System

    Implement digital document numbering that allows for organized indexing, and retrieval of documents.
  • Collaboration and Review Processes

    Facilitating collaboration and review processes among multiple stakeholders.
  • Real-Time Document Collaboration

    Enable coauthoring of documents for editing, viewing, commenting, and creating notes in real-time, while streamlining the review and approval processes.
  • Audit Readiness

    Being prepared for audits and inspections with accurate and easily accessible documentation.
  • Audit Log Maintenance

    Comprehensive audit trails and reporting capabilities for each level of document version, enabling organizations to quickly compile and present documentation for audits, thereby improving audit readiness.
  • Storage and Backup

    Managing the storage and backup of large volumes of documentation.
  • Cloud-based Document Management

    Offer scalable storage solutions and automatic backup features, ensuring that documents are securely stored and backed up without requiring extensive physical storage space.
  • Document Integrity and Security

    Maintaining the integrity and security of documents to prevent unauthorized access or tampering.
  • Access Controls and Encryption

    Ensure that only authorized personnel can access and modify documents, thereby maintaining document integrity and security.

Document Management Software