Industries > FDA 21 CFR Part 11

MeasurLink® version 6 offers support of the FDA 21 CFR Part 11 specification for Electronic Data Storage and Signatures with enhanced logon security, profiles and audit trails as follows:
Function No. Function Description Mandatory/Desirable Requirement Location/Explanation of Function Documentation
F1 Operational Requirements    
F1-1 Require that a program be provided for the evaluation of measured values and the statistical process control, using different measuring devices to obtain the measured values. Mandatory This is basic functionality in the MeasurLink Real-Time/Real-Time Plus SPC data collection software. Detailed information is available in the Set-up and Operation Guides for these products
F1-2 Evaluations require to be immediately updated after change in the set data. Mandatory This is basic functionality in the MeasurLink Real-Time/Real-Time Plus SPC data collection software. Detailed information is available in the Set-up and Operation Guides for these products
F1-3 The program should be based on a special data structure, which guarantees a high degree of data security. Mandatory The relational database used for MeasurLink® applications is developed using Sybase® SQL Client/Server database tools and is base on a unique data structure. Data integrity is ensured through SQL transaction processing. Further documentation for the MeasurLink® relational database is available in the Appendix section of the Set-up and Operation Guides for MeasurLink® products.
F1-4 Produce various types of definitive reports. Mandatory MeasurLink Real-Time/Real-Time Plus SPC data collection software provides various reporting options with customable features. Detailed information for all reporting options is available in the Data Collection Chapter of the Set-up and Operation Guides for these products
F2 Security & Password Confidentiality    
F2-1 Add/modify/delete User profiles Mandatory The MeasurLink Security Center, provided with all MeasurLink versions 5.0 and above applications, has been recently redesigned to comply with the 21 CFR Part 11 ruling of the FDA. Functional documentation for these changes is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance.
F2-2 Assign Users to User profiles Mandatory The MeasurLink Security Center, provided with all MeasurLink versions 5.0 and above applications, has been recently redesigned to comply with the 21 CFR Part 11 ruling of the FDA. Functional documentation for these changes is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Adding/Moving Users to a Profile section
F2-3 Add/modify/delete Users Mandatory The MeasurLink Security Center, provided with all MeasurLink versions 5.0 and above applications, has been recently redesigned to comply with the 21 CFR Part 11 ruling of the FDA. Functional documentation for these changes is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance.
F2-4 Unique User ID & password combination to gain access. Mandatory A user must have an assigned, unique User ID, a valid passwords, and proper authority to gain access to any MeasurLink application. Functional documentation for these requirements is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance.
F2-5 Auto-logoff after a period of 10 mins. Mandatory A session time-out period may be set for each user individually. This period can be set from 1 minute to several hours. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-6 Passwords must not be displayed on the screen as they are entered. Mandatory Passwords are never displayed on the screen and encrypted when held in storage. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-7 Passwords must always be encrypted when held in storage for any significant period of time or when transmitted across the network. One-time passwords are accepted. Mandatory Passwords are never displayed on the screen and encrypted when held in storage. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-8 Passwords must never be embedded in sign-on utilities. For example, an unauthorized user must never be able to authenticate at sign-on merely by using a function key or by running an available program. Mandatory No embedded sign-on functionality has been introduced to any of the MeasurLink applications. User passwords must be successfully entered manually at the Log In prompt to gain access to a MeasurLink application.
F2-9 Passwords must never be hard-coded in source code, command files, scripts or installation kits. Mandatory The initial password for the administrative User ID is contained in the MeasurLink database upon installation. A user will be required to change this password the first time a login with this User ID is attempted. This password cannot be used to access any of the MeasurLink applications. No other User IDs or passwords exist in the MeasurLink database and none can be created until this initial administrative log on and password change takes place. Functional documentation for this is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Logging in for the First Time section
F2-10 Passwords must have a minimum length of six (6) characters. Mandatory Passwords must have length of 6 to 12 characters and are case sensitive. A user’s previous 5 passwords cannot be repeated. Functional documentation for these features is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-11 Passwords must be changed at least every ninety (90) days. System should prompt the User to change the password. Mandatory A password expiration period can be set for each user individually. The default password expiration period will require users to renew their passwords every 90 days. This period can be modified to require users to renew passwords from 1 to 365 days. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-12 Temporary and initial passwords must be marked as expired, and the user must be required to change the password at the first use. Mandatory MeasurLink Security requires all initial and temporary passwords to be changed by a user the first time a log on is attempted. Initial and temporary passwords cannot be used to access a MeasurLink Application. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-13 User-chosen passwords must not be reused for five (5) iterations. Mandatory Passwords must have length of 6 to 12 characters and are case sensitive. A users previous 5 passwords cannot be repeated. Functional documentation for these features is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-14 Proper proof of identification must be provided before changing a password. Mandatory Proper proof of identification must be provided in the form of the unique User ID and a password before a Login or password change is allowed. Functional documentation for this feature is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F2-15 If a resigning or terminated staff member was responsible for system administration, all relevant passwords must be changed immediately. Mandatory Someone with proper authority can change a password for any user at any time. Functional documentation for this is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Password Setup section
F3 Audit Trails    
F3-1 Person Responsible Mandatory MeasurLink supports audit trails for login/logout, data entry, data modification, and data deletion. These audit trails are generated for users through use of Security Center and Process Traceability functions. Documentation for Security Center is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Detailed information for setting up Process Traceability is available in the Traceability Lists Chapter of the Set-up and Operation Guides for these products.
F3-2 Date and time stamp Mandatory All data sets collected by MeasurLink® applications and stored to the MeasurLink® relational database are assigned a data Run ID. This mandatory field is used to identify the sets of data collected for a selected inspection routine. The default value is set to the current date and time with the format “yyyy/dd/mm hh:mm:ss” with hours based on a 24-hour clock. Further documentation for the MeasurLink® Run ID date and time stamp is available in the Data Collection section of the Set-up and Operation Guides for MeasurLink® data collection applications.
F3-3 User action/entry (e.g. logging in/out, creating, modifying and deleting records). Mandatory MeasurLink supports audit trails for login/logout, data entry, data modification, and data deletion. These audit trails are generated for users through use of Security Center and Process Traceability functions. Documentation for Security Center is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance. Detailed information for setting up Process Traceability is available in the Traceability Lists Chapter of the Set-up and Operation Guides for these products.
F4 Backup    
F4-1 System allows backup & restore of electronic data Mandatory The relational database used for MeasurLink® applications is developed using Sybase® SQL Client/Server database tools and can be maintained on a database server. This relational database can work directly with a multi-user Client/Server database system (purchased separately by the user) and can be archived and restored via the host database management system. Further documentation for the MeasurLink® relational database is available in the Appendix section of the Set-up and Operation Guides for MeasurLink® products.
F4-2 Backup can be setup to occur automatically Mandatory The relational database used for MeasurLink® applications is developed using Sybase® SQL Client/Server database tools and can be maintained on a database server. This relational database can work directly with a multi-user Client/Server database system (purchased separately by the user) and can be archived and restored via the host database management system. Further documentation for the MeasurLink® relational database is available in the Appendix section of the Set-up and Operation Guides for MeasurLink® products.
F5 Data Integrity    
F5-1 System has ability to detect/prevent alteration of electronic data. Mandatory MeasurLink® data collection applications maintain an audit trail of observation data that has been modified. This audit record can be retrieved in a summary report using the reports function. Further documentation for reporting functions and modifying observation data is available in the Data Collection section of the Set-up and Operation Guides for MeasurLink® data collection applications.The ability to edit data can be limited to authorized users via Security Center and prevented completely by assigning an e-signature to data sets via MeasurLink® Process Analyzer. For a description of the security access levels, see the Security chapter of the Set-up and Operation Guide. Functional documentation for using e-signature functions is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance, e-signature section.
F5-2 Complete copies of data can be produced. Mandatory Simple data export functions are available in all MeasurLink® data collection applications and MeasurLink® Process Analyzer. Process Analyzer also provides a spreadsheet function portable to Microsoft® Excel. All MeasurLink® applications have report functions capable of producing SPC charting and data analysis. Functional documentation for these features is provided in the Set-up and Operation Guides for these products.
F6 Electronic Signature    
F6-1 The User will be required to approve & sign-off on quality critical records electronically to prevent accidental or deliberate record and signature falsification. Mandatory Each authorized user will have a unique e-signature base on their User ID and password. Functional documentation for using e-signature functions is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance, e-signature section.
F6-2 The e-sign will be unique to one individual. Mandatory Each authorized user will have a unique e-signature base on their User ID and password. Functional documentation for using e-signature functions is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance, e-signature section.
F6-3 The e-sign will be based on 2 distinct components. Mandatory Each authorized user will have a unique e-signature base on their User ID and password. Functional documentation for using e-signature functions is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance, e-signature section.
F6-4 During a continuous session the password is executed at each signing. Mandatory Every application of an e-signature will require password verification. Functional documentation for using e-signature functions is provided in the MeasurLink supplemental document; Operation Guide Supplement For MeasurLink® Applications, Enhancements for FDA 21 CFR Part 11 Compliance, e-signature section.