Presentation on theme: "Electronic Records, 21 CFR Part 11 and Oracle 9i Shon Naeymirad Principal Analyst/DBA Abbott Laboratories."— Presentation transcript:
Electronic Records, 21 CFR Part 11 and Oracle 9i Shon Naeymirad Principal Analyst/DBA Abbott Laboratories
Agenda 21 CFR Part 11 Electronic Record Electronic Signature How to build the final rule of 21 CFR Part 11 J2EE Platform Overview Oracle Application Development Framework (ADF)
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration 21 CFR Part 11 [Docket No. 92N – 0251] RIN 0910 – AA29 Electronic Records; Electronic Signatures 1991, members of the pharmaceutical industry met with the agency to determine how they could accommodate paperless record systems under the current good manufacturing practice (CGMP) regulations in parts 210 and 211 (21 CFR parts 210 and 211). FDA created a Task Force on Electronic Identification/Signatures to develop a uniform approach by which the agency could accept electronic signatures and records in all program areas. 1992, report, a task force subgroup, the Electronic Identification/Signature Working Group, recommended publication of an advance notice of proposed rulemaking (ANPRM) to obtain public comment on the issues involved A complete discussion of the options considered by FDA and other background information on the agency’s policy on electronic records and electronic signatures can be found in the ANPRM and the proposed rule. 1997, The final rule provides criteria under which FDA will consider electronic records to be equivalent to paper records, and electronic signatures equivalent to traditional handwritten signatures. Part 11 (21 CFR part 11) applies to any paper records required by statute or agency regulations and supersedes any existing paper record requirements by providing that electronic records may be used in lieu of paper records. Electronic signatures which meet the requirements of the rule will be considered to be equivalent to full handwritten signatures, initials, and other general signings required by agency regulations. 21 CFR Part 11 : Electronic Records; Electronic Signatures
Complaint Form Reporter Name: Event Description: Event Date: Blank Form = context Data = content Form + Data = record Reporter Name: Jim Smith Event Description: Patient Infection Event Date: January 10, 2001 Paper Record
Database Record Data Definition Complaint Table Complaint IDNumber(10)Unique ID for complaint table Reporter ID Number(10)Foreign Key to Reporter Table Complaint DescVarchar2(4000)Description Complaint DateDateDate of Call Days OpenNumber(6)Calculated Field
Electronic Record - Context
Electronic Record - Content
Electronic Records Electronic Record Context = Reporter.Name Complaint.Complaint Description Complaint.Date Electronic Record Content = Jim Smith Patient Infection January 10, 2001 Electronic Record: Context + Content = Reporter.Name: Jim Smith Complaint.Complaint Description: Patient Infection Complaint.Date: January 10, 2001
Paper vs. Electronic Records Complaint Form Reporter Name: Jim Smith Event Description: Patient Infection Event Date: January 10, 2001 Electronic Record Context = Reporter.Name Complaint.Complaint Desc Complaint.Date *Record definition includes 2 tables and 3 fields but excludes 8 fields in those tables plus all fields in the address table. Electronic Record = Paper Record Reporter.Name: Jim Smith Complaint.Complaint Desc: Patient Infection Complaint.Date: January 10, 2001
You must define the context of the electronic record (i.e., the collection of fields and tables that comprise the record) independent of the underlying database structures. Otherwise, you risk the interpretation that all information in the database is part of the “electronic record.” Key Point As with any definition we need to store that definition so it can be applied consistently and referred to when is needed.
Attestation, simply stated, is attesting to the fact that a person changed a record, and links the record to the person who changed it, and when the change occurred. A signature, on the other hand, implies approval, acceptance, or authorization (like signing a check, to authorize your bank to release funds). Attestation vs. Signature Key Point: Your software should differentiate between attestation and signature since you need attestation on all required records but signatures only on certain records as defined by predicate rule. “Don’t allow IT to define what records to apply signatures.”
UTC Establish a procedure for determining the local date and time from a time stamp based on UTC, Coordinated Universal Time. Coordinated Universal Time replaces Greenwich Mean Time to represent the Earth's prime meridian (0 degrees longitude). UTC is based upon the atomic time scale that is commonly referred to as GMT. In 1970 the International Telecommunication Union agreed upon a single acronym for use in all languages to be UTC. Oracle server date and time must be set to UTC.
How to build the final rule of 21 CFR Part 11 System Understand system requirements Design good data model Define security roles Enforce password change Build Audit Trail for all tables Select your framework Automate your development Performance tuning
Build Audit Trail Create history table for all tables Use database insert, update, delete triggers to build history records Record user, server date and time Define your Electronic Record Define approval process of Electronic Record Build a mechanism to record versioning for your Electronic Records
Oracle Security From the authentication standpoint, Oracle’s Single Sign-On (SSO) Server provides a scalable and extensible solution to address Web-based SSO. Oracle ID and password can be used as Electronic Signature. Use Oracle Profile to enforce password expiration, re-use control and complexity. Use Oracle Roles to control user access Oracle database instance login trigger can be used to monitor all logins. Time stamps must be stored with electronic signature.
Oracle9iAS Security Components Single Sign-On Oracle Internet Directory mod_ossl Client Oracle HTTP Server JAAS OC4J mod_osso
Oracle9iAS JAAS Provider Integration with OC4J and SSO/OID
Logon Trigger CREATE TRIGGER "SYSTEM"."LOGON_CHECK" AFTER LOGON ON DATABASE Begin -- Limit access -- Verify usage of tools that was used to logon -- Insert into appl_audit_tables end;
J2EE Platform Overview Open standard supported by a community process Backed by Big names like Oracle, IBM, Sun Architecture for Highly scaleable multi-tier enterprise applications Extends java promise for “Write Once, Run Anywhere" portability
J2EE Platform Roles Product Provider – supplier of container e.g. Oracle Tool Provider – supplier of tools for development and packaging Application Developer Application Assembler Application Deployer System Administrator
Oracle9 i Application Server Release 2 Productive Development – Complete J2EE, Web Services – Lightweight J2EE Footprint Most Reliable Deployment – Fast Application Server – High Availability and Clustering – Complete Management and Security 100% Standards Compliant – J2EE 1.3, Web Services, SOAP, WSDL, UDDI, ebXML, RosettaNet, LDAP, SSL, XML...
Summary Your software should differentiate between attestation and signature. You should define the context of the electronic record independent of the underlying database structures. You must link the attestation, or person who created, modified or deleted the record, to the correct revision of the record. This audit trail functionality is required. Design your electronic record around approval process Select your framework for J2EE Use existing tools to integrate and automate