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FDA的数据完整性指南中为什么要说明到具体的处罚要求??并且individuals responsible是指具体的谁??
Finally, FDA recommends that data integrity problems be addressed by hiring a third party auditor, determining the scope of the problem, implementing a corrective action plan (globally), and removing at all levels individual responsible for problems from cGMP positions. Regarding this last point, one has to wonder how the agency defines the term “individual responsible”. For instance, if a quality assurance manager at a plant is within the chain of command of someone on the shop floor who manipulated data, but there is no evidence that he knew or participated in any of the data manipulation, is he an “individual responsible”? In addition, is it really appropriate to require a laboratory technician to be removed from a cGMP position when he or she was pressured – at risk of loss of employment in an autocratic facility – because he complied with orders to run an “unofficial” test?
选自:
FDA’s Draft Guidance on Data Integrity: The Cupola on a Tower of Guidances |
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