21 CFS Part 11 Compliance

Discussion about potential improvements to the hardware used for the Retro-Printer Module
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RWAP
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21 CFS Part 11 Compliance

Post by RWAP »

Following some feedback from our industrial customer base, we are currently looking at a new version of the Retro-Printer which will be compliant with the FDA 21 CFR Part 11, established by the US Food and Drug Administration (FDA) to ensure the authenticity, integrity, and confidentiality of electronic records and electronic signatures.

The problem is that the current versions of the Retro-Printer use an in-built Raspberry Pi to take the captured data and process it, storing it on the mico SD card and then emulating the original printer.

Unfortunately, this does not meet the requirements of the FDA CFR, which insists that both closed and open systems must have controls and procedures to ensure electronic records’ authenticity, integrity, and, when appropriate, confidentiality.

These procedures and controls must include the following:
  • Validate systems to ensure accuracy, reliability, and consistent performance.
  • Produce complete and accurate copies of records for review and copying by the FDA.
  • Retrieve records accurately and easily throughout the retention period.
  • Limit system access to authorized personnel.
  • Secure, computer-generated, and time-stamped audit trails.
  • Operational system checks to enforce the correct sequence of steps and events.
  • Authority checks to ensure only authorized individuals have access to the system, can electronically sign records, alter records, or perform the operation at hand.
  • Device checks to verify the source of data input or operational instruction.
  • Controls over systems documentation, including adequate distribution, access, and use of system operation and maintenance documents.
  • Documents need to contain Electronic signatures must include an individual’s name, date, time, and meaning of the signature.

Unfortunately, the Raspberry Pi does not meet these requirements - particularly the limitations on access to the system and logging access.

We are therefore looking at a complete redesign in conjunction with our long-term controls partner (MJ Controls Limited) which will meet these industry requirements and be part of their Blu Pop range of IOT devices, with the printer emulation running on the customer's secured PC
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Re: 21 CFS Part 11 Compliance

Post by RWAP »

First Glimpse...

It uses a DB25 connector instead of a centronics - but we are currently investigating why the last byte captured turns into a character 255 !!
PXL_20231205_152228834.jpg
PXL_20231205_152228834.jpg (109.63 KiB) Viewed 2185 times
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Re: 21 CFS Part 11 Compliance

Post by RWAP »

We have now completed the first version of the software to run on this device, and are capturing it in a Windows program.

The Retro-Printer-C stores no data and performs no data processing at all - it simple deals with the transmission and acknowledgement of the data coming from a centronics / parallel port and then sends each captured byte by USB lead to a Windows PC.

Now we can start the slightly harder task, of porting our printer emulators across to run on Windows.
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