A (re)introduction to data integrity and validation for the pharmaceutical industry

The issue of data integrity may appear to be archaic in a highly connected, digital world. Yet, many within the pharmaceutical industry continue — be it intentional or not — to fall foul of regulators tasked with auditing business practices. Peter Cusworth at Yokogawa examines an age-old problem, its importance and why organisations continue to get it wrong

According to the Office for National Statistics, 610 organisations operated in the UK pharmaceutical sector in 2018. These companies generate approximately £21 billion in market value and employ 63,000 persons.1

Based on historical trends and an increase in manufacturing investment, these numbers are likely to grow.

Sector growth will drive the need for robust data integrity and validation processes. First, to ensure that pharmaceuticals are produced to the highest quality standards; and second, to satisfy regulators who have been issuing warning letters and fines for poor practice in recent years.

A sector analysis report from Deloitte, for example, states that the US Food and Drug Administration (FDA) issued 75 warning letters in 2016, of which 43% contained instances of data integrity violations.2

What is data integrity?

Regulatory bodies that issue guidelines for manufacturers define data integrity as the extent to which information is complete, consistent and accurate throughout the data lifecycle. This includes all original records and true copies, metadata and all subsequent transformations and reports.

Peter Cusworth

Auditors expect both paper and electronic records to be collected and maintained securely throughout the entire production process. This includes testing, licensing, manufacturing, packaging, distribution and monitoring.

Regulatory requirements are captured in the acronym ALCOA, which states that all data must be attributable, legible, contemporary, original and accurate. ALCOA also implies that data must be available at all times, restating the need for effective technology that can record, store and retrieve information when requested.

Why is data integrity important?

Data integrity is essential for most day-to-day business processes; but, its importance is critical when developing and producing pharmaceuticals. Drug developers and manufacturers need accurate, reliable data to maintain the efficacy and quality of a product.

Auditors cannot always be on-site to oversee every processing and production stage, so checks and balances are necessary to guarantee patient safety.

Good data integrity processes ultimately build trust between the industry and its regulatory bodies while also helping to limit the chances of product recalls, compliance issues and damage to a business’s reputation.

This idea is best seen in a lawsuit from 2018, which saw Fresenius SE cancelling its $4.3 billion acquisition of US drugmaker Akorn Inc.

Fresenius claims that Akorn did not have sufficient controls in place to guarantee the reliability and validity of data gathered during process development for one of its products. Once a judge ruled that Fresenius’s withdrawal was justified, Akorn’s shares dropped by 59%.3

Historical challenges

Fresenius versus Akorn is exceptional because it scuppered a significant acquisition, but the conditions that caused the deal to be called off are not unusual.

Indeed, data integrity and validation continue to be a problem for many organisations in the sector, not least because “hybrid” systems that exist half on paper and half digitally are still relatively common.

The World Health Organization’s guidelines say that these systems are discouraged … and migrating to a completely digital system should now be prioritised.4

Such moves, however, are perceived to be difficult and time-consuming. A typical facility will have many machines that generate data, usually developed by different companies using a variety of recording techniques.

Many machines will not come with software. Those that do will require validation — a systematic approach required to guarantee that any process in a pharmaceutical facility will operate within specific parameters when required.

This process can take months to complete depending on the experience of those doing the validation and whether they are following specific procedures.

Some organisations offer integration of all instruments, but this usually falls short of ALCOA requirements and can actually drag out the process as individual assessments of each connection need to be tested.

“Off the shelf” software solutions are seen to be the preferred way to digitise paper-based approaches as they are tested more rigorously and simplify the validation process, even when connecting multiple machines and instruments.5

Beyond these practical challenges, businesses also have to contend with a complex regulatory landscape that continues to shift. To combat the recent spike in compliance failings, the World Health Organization, UK Medicines and Healthcare Products Regulatory Agency (MHRA) and FDA have all issued draft guidance for maintaining data integrity.

For manufacturers, these updates will also run alongside other requirements, such as GAMP-5 issued by the International Society for Pharmaceutical Engineering, which defines good practice when using automated systems in the sector.

Emerging problems

Although the move away from hybrid systems is welcomed by regulators, businesses are still being flagged for data integrity shortcomings even when using newer digital systems.

One of the biggest challenges that has emerged during the last 20 years relates to audit trails, particularly among companies that use software with audit trail functionality. There is a tendency to fit and forget without revisiting the data and understanding what’s being collected and why. This can pose challenges when work is being submitted to a quality group for review.

The age of some automated systems is another critical concern, particularly for drug manufacturers.

As equipment reaches a certain age, hardware and software components inevitably fail or become obsolete; this not only jeopardises the validity of some data but also the required quality of a product.

However, major retrofitting projects come with their own risks, and business owners are advised to proactively manage their systems to identify when components need replacing. This approach limits plant downtime and ultimately protects data validity, even as processing changes are made.

Ultimately, even the most conservative organisations will agree that data integrity can never be fully assured. It’s an ongoing process that has to be appraised at regular intervals. However, technology now exists to simplify the task, even as the volume of data collected increases.

References

  1. https://globalambition.ie/wp-content/uploads/2020/03/Enterprise-Ireland-Report-UK-Pharmaceutical-Manufacturing-Sector-Overview.pdf.
  2. www2.deloitte.com/content/dam/Deloitte/uk/Documents/life-sciences-health-care/deloitte-uk-data-integrity-report.pdf.
  3. www.lifescienceleader.com/doc/how-to-avoid-data-integrity-woes-in-pharma-0001.
  4. www.who.int/medicines/areas/quality_safety/quality_assurance/QAS19_819_data_integrity.pdf?ua=1.
  5. www.news-medical.net/news/20190729/Data-Integrity-in-the-Pharmaceutical-Industry.aspx.

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