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FDA 21 CFR Part 11 - Electronic Signatures and Gait Files

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  • FDA 21 CFR Part 11 - Electronic Signatures and Gait Files

    Dear All

    I have an intriguing problem with which you may be able to help.

    I need to inlcude some of our gait files in a study to be submitted at
    sometime in the future to the FDA - and being a 'computerised system' the
    files need to have electronic signatures.

    The guidance is clear that I need to run a system that requests the
    signature BEFORE the data capture. But the system we run has no such
    facility.

    I was proposing to encrypt the files immediately AFTER capture -
    appropriately signed and time-stamped but our QA people say that is too
    late.

    Has anyone had to face this problem?

    If so, how have you added electronic signatures 'retrospectively'?

    Many thanks

    Edward

    Orthopaedic Research Fellow
    Imperial Collge, Royal Veterinary College
    London

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