1 Z.A.S. Archive- and informationsmanagement Presentation at SAG Scientific Archivists Group Spring Conference in Basel 11 June 2010 Electronic Archiving in a GXP-regulated environment Author: Bernd Mohnsame
2 Greeting Good morning ladies and gentlemen, My name is Bernd Mohnsame. I am CEO of Z.A.S. Zentral Archiv Service GmbH located near to Berlin in Neubrandenburg, Germany. Since 1994 we have been providing archiving services in the field of record and information management, in particular for the pharmaceutical industry. Our clients are from Germany for the most part, though we do also have more and more clients from neighboring European countries.
3 What is Z.A.S. doing? Our scopes of business Konservierung
4 Introduction When I was asked in fall of last year whether I would be willing to give a presentation at this year s SAG Spring Conference on the topic of electronic archiving in a GXPregulated environment" in English, I did not know what I was getting myself into. For one my English is a bit rusty so please bear with me. -If you don t understand what I am saying, please do me a favor and DO NOT let me know- On the other hand, this topic is so complex that anyone trying to cover it in a 30-minute presentation is doomed to failure. Thus today I will concentrate on a small area that I assume will be of interest to you.
5 Structure My presentation is structured as follows: 1. Report on the stage of work of the working group on Digitization of documents in a GXP-regulated environment 2. Digitization processes three real-life examples 3. Scan on demand as an alternative to the complete digitization of archives? 4. Presentation film of the record- and informationmanagement service provider
6 Report Members DGGF, the German Society for Good Research Practice, and more specifically its division on archiving, set up a working group consisting of 6 members about one year ago. Its task was to draft a position paper entitled: Digitization of documents in a GXP-regulated environment. The working group consists of six members: Name Company 1 Torsten Dunker Biomedion 2 Klaus Lindow Bayer Healthcare 3 Bettina Quernheim sanofi-aventis 4 Bernd Mohnsame Z.A.S. Zentral Archiv Service 5 Britta Krusemeyer Covance 6 Michael Bursian Grünenthal
7 Report Tasks This working group defined the following tasks for its work: 1. Summary and analysis of existing regulatory framework conditions, based on GLP, GCP and GMP 2. Conclusion of recommendations for electronic archiving based on this existing regulatory framework 3. Design of a GXP-compliant digitization process 4. Description of prerequisites required for eliminating the need to keep originals (destruction of originals).
8 Report Facts Even though this working group has met fairly regularly every 4 to 8 weeks, this position paper has not been finalized yet which is why, at this point in time, I can only give you a quick snapshot of the current stage of work. Putting together all facts on the regulatory framework has been completed in the meantime.
9 Report For that we collected source texts from various pieces of legislation, organizations and authorities, such as: Sources Bund-Länder-Arbeitsgruppe GLP, a German working group that brings together representatives from the federal and the state level FDA (Food and Drug Administration) EMEA (European Medicines Agency) OECD (Organization for Economic Co-operation & Development) ICH (International Conference on Harmonization) 21 CFR Part 11, 58, 210&211, 820 German Ordinance on the Production of Pharmaceuticals and Active Substances (AMWHV) Chemicals Act
10 Report Analyze The next step was to allocate these sources texts to GLP, GCP and GMP and to summarize and analyze their material statements on "electronic archiving". By now and based on this analysis of source texts we have concluded recommendations on a GXP-compliant digitization process.
11 Report Requirements These recommendations relate to the following areas: Filing and the handing over of records from the competent department to the archiver Compliance Management Conservational preparation of files Completeness and totality Integrity and authenticity Indexing Pagination Preparation of documents Digitalization- technology, hardware and software Requirements on personnel used Requirements on procedure Validation and change control Access control Back-up and disaster recovery procedures Training of administrators and users Audit trial Analysis of the economic efficiency of electronic archiving versus archiving originals File format Electronic archiving system Archiving media
12 Report Controversials Based on the defined requirements the working group drafted a proposal for a GXP-compliant digitization process that I will talk about in greater detail in part 3 of my presentation. As part of the process of coming up with a GXP-compliant digitization process we realized that the various regulatory conditions that need to be taken into account, seem to leave a lot of room for interpretation at first glance. This led to many (and) controversial discussions during the meetings of this working group. Up until today the following aspects are subject to controversial discussion: Quality assurance in the digitization process Requirements on a digital certified /true copy Approach to and scope of an audit trial Under which requirements is it permissible to dispose originals, and if so, at what point?
13 Report Conclusion Of crucial importance is clearly the ability to dispose of originals. It has in principle been laid down by law and is permissible if And it is exactly this if that we are concerned about. For example: Non of the analyzed regulations mentioned above requires the liability to submit documents by original. Contra wise, it is explicit mentioned that it is legal to use certified copy s. But there is nowhere a link to find who say s how an electronic certified copy has to be arranged and what kind of process therefore is needed. Until these issues of the ifs and when's, and buts have not been defined and become legally binding, there will be some risk left for companies that, already at this stage, decide to archive documents only digitally.
14 Report Advantages The advantages of electronic archiving versus the traditional archiving of originals are obvious and could be summarized as follows: Availability of information at any time and anywhere Speed of access Security of access Accuracy of access Simple versioning Back-up and disaster recovery Saving of space In the pharmaceutical industry stakeholders agree that the electronic imaging of business processes is desirable.
15 Alternatives Thus please allow me to raise the question whether there are any alternatives that could be used in the meantime until we have such a regulation providing for a legally binding provision on electronic archiving as the only type of archive. The alternative we are looking for should still allow us to use the advantages of electronic archiving, without having to do with any reversal of the legal certainty. On this note I would like to show you three real-life examples that ZAS is currently implementing with various clients. But in all examples currently we still retain the originals.
16 Alternatives 3 Examples O u t h o u s e Three general ways for digitalization data documents files General I n h o u s e retrospective Hybridsystem Extern prospective electronic archive The following Examples are based on a retrospective digitalization process. But it should be the aim to come to a prospective way.
17 Alternatives Scanning documents to create a simple working copy Example 1 Simple working copy In a global work environment the goal of creating a simple working copy is to provide for the easiest possible handling of information, in particular the exchange of information. Original documents are still physically archived in line with the legal obligation to retain data. No original documents are taken from the archive. In case of a request for a document only the digital document is provided.
18 Alternatives Example 1 This procedure results in intended, positive side effects, such as the additional protection of the original documents in view of their totality, completeness, and integrity. In addition by retaining the originals, revision- and manipulation-safety is provided for as well. Simple working copy Having an electronic working copy also provides some protection in case the original accidentally got lost. From my point of view scanning documents to create a simple working copy can be realized by an quite easily configured process and is thus particularly suitable for archives of old files.
19 Alternatives Scanning documents to create a qualified working copy Example 2 Qualified working copy The intention when creating a qualified working copy is to provide a duplicate that mirrors the content of the original document 1:1. It can then be passed on as a working copy as I just described while the original documents remain physically stored. The qualified working copy is different from a simple working copy in that the completeness and integrity of the digitized document are provided for. This is also why all originals need to be checked for that before starting the digitization process.
20 Alternatives Example 2 A log file will afterwards provide information on what documents are contained in what folders and how many pages each of these documents have. Every page needs to be paginated. Qualified working copy As part of digitization the scanning operator confirms with his electronic signature that all pages have been digitized with the information mirroring 100% of the original. I believe scanning documents to create a qualified working copy is particularly suitable for completed studies or trials, in particular if these were completed by subcontractors.
21 Compliance Scanning documents to create a certified copy Example 3 Electronic certified copy When creating elektronic certified copies, the intention is to use digitization to be able to do without paper documents. The digitization process needs to be trustworthy and manipulation-safe to provide for this purpose. Every scanning process needs to be adapted to the needs and circumstances of the respective company Scanning documents to create a certified copy is thus particularly suitable for creating an electronic image of ongoing business processes.
22 Compliance Example 3 Apart from the requirements that have already been determined for simple and qualified copies, compliance with 21 CFR Part 11 needs to provide for at least the following aspects: Electronic certified copy Complete description of the entire process Validation of technology, hardware and software used, including change control Access control on the logical and physical level Proof of training for administrators and users Evidence of 4-eye-principle for checking individual pages and indexing using two separate advanced electronic signatures Scanning in PDF/A format including blank back pages SOP for operating an electronic archive Audit trial after converting every single document
23 Compliance Process Example 3 Electronic certified copy
24 Compliance Process Example 3 Electronic certified copy
25 Practice Scan on Demand In the end the question whether, from a legal and business perspective, electronic archiving is preferred over the paperbased archiving of originals is a decision that needs to be company-specific. The physical archiving of originals with a service provider that offers "scan on demand" is surely an alternative that, from a commercial perspective, is worth thinking about. The external archiving specialist stores your originals and archives them physically in accordance with GXP. Originals are indexed in consultation with the competent departments. In addition every original is allocated a barcode that identifies the position in the archive and an identification number. In this way every archived medium can be definitely identified by metadata's.
26 Practice Scan on Demand This metadata`s consisting of the index and the identification number is made accessible to you via a web-based archive database, a platform through which you can conveniently request digital copies of originals. After receiving a request for a document, the archiving service takes out the originals from the physical archive, scans them and provides you with the digitized version, ideally within about 60 minutes, via , FTP server or through a web archive. The scan on demand service of an external archiving company combines the desired advantages of electronic archiving with a high degree of economic efficiency while providing for legal security and is thus a valuable alternative. Such a solution can be installed within only three months!
27 Practice Service Provider External service providers generally look at your information management from the outside and can thus provide solutions on an as-need basis. Digitizing your originals, with archiving capacities that grow with that, and their certified security standards make external service providers the solution of choice for many pharmaceutical companies. Obviously these companies will first have to make their information management a priority and include it in their long-term corporate strategy.
28 Thank you for your attention Bernd Mohnsame mobil: +49 (0) 176/ Contact: Z.A.S. Zentral Archiv Service GmbH Justus-von-Liebig Str Neubrandenburg Tel.: 0395/ Fax: 0395/ Departments: Z.A.S. Neubrandenburg Z.A.S. Magdeburg Z.A.S. Berlin Z.A.S. Frankfurt a. M.
29 For those of you who are interested in the position paper of our working group, I will pass a sheet of paper around where you can put down your contact details. I hope to be able to send you the completed position paper by autumn If we still have time, let s watch the ZAS presentation film. Film on! Film eng..wmv Gez Bernd Mohnsame Z.A.S. Zentral Archiv Service GmbH Justus von Liebig Str Neubrandenburg Germany Mail:
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