general overview of code of regulations 21 part 58 good laboratory practices
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General Overview of Code of Regulations
21 Part 58
Good Laboratory Practices
Why GLP regulations ?
SAFETY• Non-clinical safety studies are to protect the safety of the participants in clinical studies
• By assuring that non-clinical data is in a accordance with the GLP regulations 21 CFR 58
Chapter 1, Title 21 CFR 58
Subpart A: General Provisions
Subpart B: Organization/Personnel
Subpart C: Facilities
Subpart D: Equipment
Subpart E: Testing Facilities Operation
Subpart F: Test and Control Articles
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
Subpart J: Records and Reports
Subpart K: Disqualification of Testing Facilities
Summary of Regulations 21 CFR 58
Subpart A: General Provisions
58. 1 Scope
[a] This part prescribes good laboratory practices for conducting nonclinical laboratory [in vivo or in vitro] studies that support, or are intended to support, applications for research or marketing permits for products regulated by FDA including:
Subpart A: General Provisions
58. 1 Scope…. Continuation . . .
• food and color additives
• animal food additives
• human and animal drugs
• medical devices for human use
• biological products
Subpart A: General Provisions
58.3 GLP Definitions
Sponsor: The entity that pays the bills and holds registration.
Management [UA Office of the Vice President for
Research]: Appoints Study Director and assures that the testing facility is in compliance.
Study Director: Legally responsible for the conduct of the study.
Quality Assurance: Designated by management to perform the duties relating to quality assurance of the study.
Subpart A: General Provisions
58.3 Study:
• Any experiment at one or more test sites, in which a test substance is studied in a test system under laboratory conditions or in the environment to determine or help predict its effects:
metabolism
product performance
environmental and chemical fate
persistence and residue
or other characteristics in humans, other living organisms or media.
Subpart A: General Provisions
58.3 Protocol: Approved, written document that clearly indicates objectives, study design and all methods to be used in conducting the study
Standard operating procedures: Written, approved procedures that describe in detail standard and repetitive actions including policies
Test system: the entity that the test substance is tested in or added to
Subpart A: General Provisions
58.3 Test Article: Any material or device administered to a test system
Control Article: Any chemical substance or mixture, analytical standard, or material, other than a test substance, feed, or water, administered to or used in analyzing the test system to establish bases for comparison…commonly referred to as positive control or an analytical standard
Subpart A: General Provisions
58.3 Study Dates
Study Initiation Date: date protocol is signed by the Study Director
Study Completion Date: date final report is signed by the Study Director
Experimental Start Date: first date the test substance is administered/ applied to the test system
Experimental Completion Date: last day data are collected for the study
Subpart A: General Provisions
58.3 Specimen: any material derived from a test system for examination or analysis
Sample: a portion of the test, control or reference material
Batch: a specific quantity or lot of a test, control or reference material
Vehicle: an agent which facilitates the mixture, dispersion or solubilization of a test substance with a carrier
Carrier: the material with which the test substance is combined for administration to the test system
Subpart A: General Provisions
58.3
Archives: Area used for the orderly storage and expedient removal of all raw data, documentation, protocols, specimens, and interim and final reports.
Subpart A: General Provisions
58.3 Raw Data: Any laboratory worksheets, records, memoranda, notes, or exact copies, that are the result of original observations and activities of a study and are necessary for the reconstruction and evaluation of the report of study
Subpart A: General Provisions
58.10 Applicability to studies performed under grants and contracts:
When a sponsor conducting a nonclinical laboratory study intended to be submitted to or reviewed by the FDA……it shall notify the consulting laboratory, contractor or grantee that the service is part of a nonclinical laboratory study that must be conducted in compliance with section 58.15….
Subpart A: General Provisions
58.15 Applicability to studies performed under grants and contracts:
(a) A testing facility shall permit an authorized employee of the FDA,
at reasonable times
in a reasonable manner to inspect
to copy records
…..regarding the studies with in the scope of part 58
Subpart A: General Provisions
58.15 Applicability to studies performed under grants and contracts:
(b) The FDA will not consider a non-clinical laboratory study in support of an application for research or marketing permit if the testing facility refuses to permit inspection.
Subpart B Organization/Personnel 58.29 Personnel
(a)Each individual engaged in the conduct of or responsible for the supervision of a nonclinical laboratory study shall have education, training, and experience, or combination thereof, to enable that individual to perform the assigned functions.
Training Records
Subpart B Organization/Personnel 58.29 Personnel
(b) Each testing facility shall maintain a current summary of training and experience and job descriptions for each individual engaged in or supervising the conduct of a nonclincal laboratory study.
Maintain Training Records and Job Descriptions
Training RecordsCV/Education summary
GLP training certificates
Professional meetings attended
Campus/industry certificates
Chemical safely
Animal Care
Radiation Safety
Proficiency on methods required by protocol and SOPs
Subpart B Organization/Personnel 58.29 Personnel
(c) There shall be a sufficient number of personnel for the timely and proper conduct of the study according to the protocol.
(d) Personnel shall take necessary personal sanitation and health precautions designed to avoid contamination of test and control articles and test systems.
(e) Personnel engaged in a nonclinical laboratory study shall wear clothing appropriate for the duties they perform. Such clothing shall be changed as often as necessary to prevent microbiological, radiological, or chemical contamination of test systems and test and control articles.
Subpart B Organization/Personnel 58.29 Personnel
(f) Any individual found at any time to have an illness that may adversely affect the quality and integrity of the nonclinical laboratory study shall be excluded from direct contact with the test systems, test and control articles and other operations or function that may adversely affect the study until the condition is corrected. All personnel shall be instructed to report to their immediate supervisors any health or medical conditions that may reasonably be considered to have an adverse effect on a nonclinical laboratory study.
Subpart B: Organization and Personnel
58. 31 Testing Facility Management
For each nonclinical laboratory study management [OVPR] shall:
(a) Designate a study director before the study is initiated
(b) Replace the study director promptly if it becomes necessary to do so during the study
(c) Assure that there is a quality assurance unit
(d) Assure that personnel, resources, facilities, equipment, materials and methods are available
Subpart B: Organization and Personnel
58. 31 ….Continuation…
(f) Assure that personnel clearly understand the functions they are to perform
(g) Assure that any deviations from these regulation reported by the quality assurance unit are communicated to the study director and corrective actions are taken and documented
Vice President for ResearchDr. Leslie Tolbert
Director of ComplianceAlice Langen
Quality Assurance OfficerMarilyn M. Marshall
GLP Laboratories
IACUC GLP Protocols
Management Organizational Chart, University of Arizona
21 CFR 58 Compliance
Subpart B Organization/Personnel 58.33 Study director
For each nonclincal laboratoty study, a scientist or other professional of appropriate education, training, and experience, or combination thereof, shall be identified as the study director. The study director has overall responsibility for:
• the technical conduct of the study
• interpretation
• analysis
• documentation
• reporting of results ……
Subpart B Organization/Personnel 58.33 Study director
…….represents the single point of study control
The study director shall assure that:
(a) The protocol, including any change, is approved
(b) All experimental data, including observations of unanticipated responses of the test system are accurately recorded and verified.
Subpart B Organization/Personnel 58.33 Study director
(c) Unforeseen circumstances that may affect the quality and integrity of the nonclinical laboratory study are noted when they occur, and corrective action is taken and documented.
(d) Test systems are as specified in the protocol.
(e) All raw data, documentation, protocols, specimens, and final reports are transferred to the archives during or at the close of the study
Subpart B Organization/Personnel 58.35 Quality Assurance Unit
Responsible for monitoring each GLP study to assure management that the following:
• facilities
• equipment
• personnel
• methods
• practices
• records
• controls
are in conformance with the regulation in 21 CFR 58 and 40 CFR 160.
Subpart B Organization/Personnel 58.35 Quality Assurance Unit
Quality Assurance Officer is responsible to:
• Maintain a copy of the Master Schedule of all studies
conducted at the testing facility
• Maintain copies of all protocols
• Inspect each study at intervals to assure the integrity of the study
• Immediately report any problems likely to affect study integrity to management and study director
Subpart B Organization/Personnel 58.35 Quality Assurance Unit
Quality Assurance Officer is responsible to:
• Maintain written and properly signed records of each periodic Inspection
• Date of Inspection
• Study inspected
• Phase or segment inspected
• Findings and problems
• Action recommended and taken to resolve existing problems
•Scheduled date for re-inspection
Subpart B Organization/Personnel 58.35 Quality Assurance Unit
Quality Assurance Officer is responsible to:
• Review the final study report to assure that such report accurately:
describes the methods and SOPs
and that the reported results accurately reflect the raw data
• Prepare and sign a statement to be included with the final study report which shall specify the dates inspections were made
Examples of Quality Assurance
• Assuring protocols are followed
• Assuring SOPs are followed
• Assuring deviations are documented and reported
• Assuring personnel are properly trained
• Assuring equipment calibration meets SOP requirements and documented
• Assuring that equipment is as specified in the protocol.
Examples of Quality Assurance
• Assuring dosing/application rates as specified
• Assuring problems are reported to management and study director immediately
• Assuring study events are adequately documented
•Assuring management that systems are functioning as intended
Everyone bears responsibility for compliance
• Management
• Study Director
• Study Facilitates
• Quality Assurance
Subpart C: Facilities
58.43 Animal Care Facilities
(a) A testing facility shall have a sufficient number of animal rooms or areas, as needed, to assure proper:
• isolation of individual projects
• quarantine of animals and
• routine or specialized housing of animals
• separation of species or test systems
Subpart C: Facilities
58.43 Animal Care Facilities
(b) A testing facility shall have a number of animal rooms or areas or areas separate to ensure isolation of studies being done with test systems or test and control articles known to be bio-hazardous, including volatile substances, aerosols, radioactive materials, and infectious agents.
Subpart C: Facilities
58.43 Animal Care Facilities
(c) Separate areas shall be provided, as appropriate for the diagnosis, treatment, and control of laboratory animal diseases.
These areas shall provide effective isolation for the housing of animals either known or suspected of being diseased, or of being carriers of disease, from other animals.
Subpart C: Facilities
58.43 Animal Care Facilities
(d) When animals are housed, facilities shall exist for the collection and disposal of all animal waste and refuse or for safe sanitary storage of waste before removal from the testing facility.
Disposal facilities shall be so provided and operated as to minimize vermin infestation, odors, disease hazards, and environmental contamination.
Subpart C: Facilities
58.47 Facilities for handling test and control articles
(a) Separate areas for:
1. Receipt and storage of the test and control articles
2. Mixing of the test and control articles with a carrier
3. Storage of the test and control article mixtures
Subpart C: Facilities
58.47 Facilities for handling test and control articles
(b) Storage areas for the test and/or control articles and test and control mixtures shall be separate from housing the test systems and shall be adequate to preserve the identity, strength, purity, and stability of the articles and mixtures
Subpart C: Facilities
58.49 Laboratory Operation Areas
Separate laboratory space shall be provided for the performance of the routine and specialized procedures required by nonclincal laboratory studies
Subpart C: Facilities
58.51 Specimen and Data Storage
Space shall be provided for archives, limited access by authorized personnel, for the storage and retrieval of all raw data and specimens from completed studies
Subpart D: Equipment
58.61 Equipment design
Equipment used in the generation, measurement, or assessment of data and equipment used for facility environmental control shall be of appropriate design and adequate capacity to function according to the protocol and shall be suitably located for operation, inspection, cleaning and maintenance.
Subpart D:Equipment
58.63 Maintenance and calibration of equipment
(a) Equipment shall be adequately inspected, cleaned and maintained. Equipment used for the generation, measurement, or assessment of data shall be adequately tested, calibrated and or standardized.
(b) SOPs shall describe methods, materials and schedules to be used in the routine inspection, cleaning, maintenance, testing, calibration …and designate the person responsible for the performance of each operation
Subpart D:Equipment
58.63 Maintenance and calibration of equipment
(c) Written records shall be maintained of all inspection, maintenance, testing, calibration, and/or standardizing operations.
Subpart E: Testing Facilities
Section 58.81
Standard Operating Procedures [SOPs]
Subpart E: Testing Facilities
Section 58.81
Standard Operating Procedures [SOPs]
(a) A testing facility shall have standard operating procedures in writing setting forth nonclinical laboratory study methods that management is satisfied are adequate to insure the quality and integrity of the data generated in the course of study.
• All deviations in a study from the SOPs shall be authorized by the study director and shall be documented in the raw data.
• Significant changes in established SOPs shall be properly authorized in writing by the management.
Subpart E: Testing Facilities
58.81 SOPs….
(c) Each laboratory area shall have immediately available laboratory manuals and SOPs relative to the laboratory procedures being performed. Published literature may be used as a supplement to SOPs.
(d) A historical file of SOPs and all revisions thereof, including the dates of such revisions, shall be maintained.
Subpart E: Testing Facilities
58.83 Reagents and Solutions
All reagents and shall be labeled to indicate:
identity
titer/concentration
storage requirements
expiration date
Subpart E: Testing Facilities
58.83 Reagents and Solutions
Deteriorated or outdated reagents and solutions shall not be used
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
58.120 Protocol….
(a) Each study shall have an approved written protocol
Descriptive title and statement of the purpose of the study
Identification of the test and control articles by name, chemical abstract number, or code number
Name of the sponsor and the name and address of the testing facility at which the study is being conducted
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
58.120 Protocol
Number, body weight range, sex, source of supply, species, strain, substrain, and age of the test system…….cell line, original source, passage number
Procedure for identification of the test system
A description of the experimental design
A description and/or identification of the diet used in the study as well as solvents, emulsifiers, and/or other materials used to solubilize or suspend the test or control articles before mixing with the carrier.
Subpart G: Protocol for and Conduct of a
nonclinical Laboratory Study
58.120 Protocol
Each dosage level expressed in milligrams per kilogram of body weight, or other appropriate units of the test control article to be administered and the method of administration
The type and frequency of tests, analyses, and measurements to be made
The date of approval of the protocol by the sponsor and dated signature of the study director
A statement of the proposed statistical methods
All changes to the approved protocol shall be documented, signed by study director and dated maintained with the protocol
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
58.130 Conduct
( a) study shall be conducted in accordance with the protocol.
(b) test systems shall be monitored in conformity with protocol
(c) specimens shall be identified by test system, study, nature, and date of collection. This information must be located on the specimen container or accompany the specimen in a manner that precludes error in the recording and storage of data.
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
58.130 Conduct
(d) records of gross findings for a specimen from postmortem observations should be available to a pathologist when examining that specimen histopathologically.
• (e) All data generated during the conduct of a study except those that are generated by automated data collection systems, shall be:
> recorded directly
> promptly
> and legibly in ink
58.130 Conduct
All data entries shall be dated on the date of entry and signed or initialed by the person entering the data
Any change in entries shall be made so as not to obscure the original entry and shall indicate the reason for such a change and shall be dated and signed or identified at the time of change.
Subpart G: Protocol for and Conduct of a nonclinical Laboratory Study
Laboratory/Study Documentation :
• Write neatly
• Use a pen with ink that does not smear
• Make sure all boxes, and lines are completed on checklists….if there is no information, enter n/a for “not applicable” or draw a line through empty line/box.
• Always sign and/or initial and date entries
• For documenting dates…be sure to include the year
• For clarity use military time or AM/PM
Raw Data/Documentation
Promptly
Recorded as generated
Take forms to the field/lab
No keeping several measurements “in your head”
No filling out data sheets at the end of the day or “when time allows”
….real time data!!
Raw Data/Documentation
Directly (original)
Onto appropriate forms
Into appropriate logs
First entry is the RAW data
Raw Data/Documentation
Legibly
Understandable – can a third party figure it out?
If it can’t be read, it is not legible
If you are sloppy, slow down and print
Do not “scrunch” data
Don’t write on backs of pages
Don’t write in borders or margins, use additional paper
Raw Data/Documentation
Other considerations
In permanent medium (INK)
Color not specific; must be indelible
Entries signed/dated at the time of entry
Data corrections in compliance with GLP
Must not obscure original (one line through)
Reason given (error code)
Signed and dated by person making correction
Raw Data/Documentation
Maintained in an organized manner
- Data collection forms
All data points required by the protocol collected
Values of lab analyses recorded on a record sheet or attached
Normal reference values included
Laboratory/Study Documentation :
Corrections/updates to documentation (other than SOPs) may be made at any time as long as each…..
> is initialed > is dated
> includes a short explanation as to why the information was not included before
Laboratory/Study Documentation :
• Legibility ….must be able to read
• Identifiably….who did the work
• Retrievability ….can find the raw data
Documentation should allow you to be able to reconstruct the study for legal and regulatory purposes if needed
58.185 Reporting of nonclinical laboratory study results
(a) Final report
Name and address of the facility performing the study and the dates on which the study was initiated and completed
Objectives and procedures stated in the approved protocol, including any changes in the original protocol
Statistical methods employed
Subpart J: Records and Reports
58.185 Reporting of nonclinical laboratory study results
(a) Final report
The test and control articles identified by name, chemical code number, strength, purity, and composition or other appropriate characteristics
Stability of the test and control articles under the conditions of administration
A description of the method used
Subpart J: Records and Reports
58.185 Reporting of nonclinical laboratory study results
(a) Final report
A description of the test system used including the number of animals used, sex, body weight range, source of supply, species, strain, age and procedure used for identification
A description of the dosage, dosage regimen, route of administration, and duration.
Subpart J: Records and Reports
58.185 Reporting of nonclinical laboratory study results
(a) Final report
A description of all circumstances that may have effected the quality or integrity of the data
The name of the study director, the names of other scientists or professionals, and the names of all supervisory personnel, involved in the study
Subpart J: Records and Reports
58.185 Reporting of nonclinical laboratory study results
(a) Final report
A description of the transformations, calculations or operations performed on the data, a summary and analysis of the data, and a statement of the conclusions drawn from the analysis
Locations where all specimens, raw data, and the final report are to be stored
The statement prepared and signed by the quality assurance unit
Subpart J: Records and Reports
58.185 Reporting of nonclinical laboratory study results
(b) Final report shall be signed and dated by the study director
(c) Corrections or additions to a final report shall be in the form of an amendment by the study director
Subpart J: Records and Reports
58.190 Storage and retrieval of records and data
(b) There shall be archives for orderly storage and expedient retrieval of all raw data, documentation, protocols, specimens, and interim and final reports…Conditions of storage shall minimize deterioration of the documents or specimens
(c) An individual shall be identified as responsible for archives
Subpart J: Records and Reports
58.190 Storage and retrieval of records and data
(a) All raw data, documentation, protocols, final reports and specimens….
(except wet specimens of blood, urine, feces and biological fluids….)
generated as a result of a nonclinical laboratory study shall be retained..
Subpart J: Records and Reports
58.190 Storage and retrieval of records and data
(d) Only authorized personnel shall enter the archives
(e) Material retained or referred to in the archives shall be indexed to permit expedient retrieval
Subpart J: Records and Reports
58.195 Retention of records
Different interpretations as to time period….
(1) A period of a least 2 years following the date on which an application for a research or marketing permit, in support of which the results of the nonclinical laboratory study were submitted, is approved by the FDA
(2) A period of at least 5 years for
IND’s (Investigational New Drug)
IDE’s (Investigational Device Exemptions
Subpart J: Records and Reports
58.195 Retention of records
(3) In other situations where the study does not result in submission of the study…. at least 2 years following the date on which the study was completed, terminated or discontinued
Subpart J: Records and Reports
58.195 Retention of records
(c) Wet specimens …. samples of test or control articles shall be retained only as long as the quality of the preparation affords evaluation.
(d) Master schedule sheet, copies of protocols and records of QA inspections shall be maintained by the QAU
(e) Summaries of training and experience and job descriptions shall be retained….
(f) Records of maintenance, and calibration
Subpart J: Records and Reports
58.195 Retention of records
(g) Records required by this part may be retained either as original records or as true copies such as photocopies, microfilm, microfiche, or other accurate reproductions of the original records
(h) If a facility conducting testing goes out of business, all raw data, documentation, and other material shall be transferred to the archives of the sponsor of the study. FDA should be notified of transfer.
Subpart J: Records and Reports
Benefits of GLP…
• SOPs as training tools
• SOPs for reproducible methodologies
• Record of equipment maintenance and use
• Record of reagent lot #s or instrument operating parameters that provide traceability, and verification of study results
•Easier preparation of final reports
Life after GLPs
• WCAC– All procedures are now written down and in
notebooks.– The procedures are done consistently and records
are uniformly kept by everyone.– All procedures done with known standardized and
current chemicals.– It is much easier to train new students and
personnel with written procedures.– Equipment is maintained on a yearly basis.– Facility has maintained GLPs, throughout, even
though only one room is used for the FDA project.
Life after GLPs
• Main Campus– We survived.
– All procedures are now written in a consistent form and easily found in notebooks.
– Inconsistencies of procedures have been corrected and everyone is doing procedures uniformly.
– Maintenance records of equipment and chemical/ stain inventories are readily available.
– Everyone is more aware of procedures, keeping records, etc., even in the areas not brought up to GLP standards.
Overall Advantages
As the decline in research funding continues, it is assumed being a GLP laboratory will give us an edge over other non-GLP research facilities.
Personnel CVs are always current. Equipment is better maintained. Procedures are known to be done the
same by everyone and procedural questions are fewer.
Everyone bears responsibility for compliance
• Management
• Study Director
• Study Facilitates
• Quality Assurance
• Plan What You Do
• Do What You Plan
• Document That You Did It
If it is not written down…..
It did not Happen!!!
Good Practices = Good Science
Quality…….
“ Quality is never an accident; it is always the result of high intention, sincere effort, intelligent direction, and skillful execution
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