GMP Basics of Good Documentation Practices (GDocP)

Good documentation practice (GDocP) is a crucial component of regulatory compliance, including data integrity assurances.

Referred to in the industry as Good Recordkeeping Practice (GRK), the term good documentation practice generally involves adhering to ALCOA+ principles.

GRK/GDocP is mandatory to ensure that your documentation — and your products — meet industry standards. Meeting good documentation practice requirements is also an important part of fulfilling other legal responsibilities in the pharmaceutical & medical devices sectors.

Good Documentation Practice (GDocP) = Good Recordkeeping Practice (GRK = an essential component of your overall pharmaceutical quality system (PQS) and quality risk management strategies (QRM).

It’s important to understand the REASONS for complying with ALCOA+ and other good recordkeeping principles.

GDP/GRK requirements are particularly important for batch release procedures and batch tracing recordkeeping, self-inspections/GMP audits, data entry, non-conformance issues or deviation events, root cause investigations and CAPAs, and product recalls of medicines and other therapeutic goods. (For online courses covering these topics, click here).

Good documentation practice is good business practice no matter what your organisation services, produces, or sells.

Good documentation practices includes but is not limited to ensuring the following requirements are met.

These requirements include controls and checks that all GMP activity data meets expectations for:

Accuracy
Data Integrity (protected, secure and backed-up data systems)
Contemporaneous recordkeeping (timely, immediately/real-time)
Legible/legibility
Identify of the person recording the information (readily identifiable as to who recorded the information, including never sharing login passwords or data system log-ins, no forging of signatures (even if requested), and other data integrity measures
Readily accessible when required
Signature record log and register
- Initials and signatures of all employees, contractors and suppliers who fill in documentation
- A secure database to match initials and signatures with the actual identity of the person who recorded the data
Security / Backups and Data Integrity
- Data must not be able to be altered or erased once entered or recorded
- No white-out is permitted in GMP facilities and no gel pens (specific writing instruments are designated in your SOPs and working instructions)
- Specific rules must be followed when altering a record, such as a legible cross through of the data and the correction listed with your registered initials and the time/date (and reason for the change, depending on the recordkeeping requirements)

For GMP consultancy or GMP audit assistance, including quality management systems and data integrity consultancy, contact PharmOut’s leading consultants (international expertise in GMP industries and PICS compliance including QMS and audit failure recovery.

Benefits of Good recordkeeping/good documentation practice SOPs and training for employees

Recordkeeping procedures (SOPs) help organisations meet their PIC/S GMP/EU cGMP requirements.
These requirements include adhering to internationally accepted quality standards and regional laws, applying risk management principles and controls as appropriate to product type and patient safety, and gaining ISO certifications.

Reliable, accurate, consistently recorded information helps ensure product safety, quality and efficacy.

While recordkeeping procedures are an important part of ANY business — they are particularly crucial in pharmaceutical, veterinary medicine and medical device manufacturing industries in view of the potential risks to end-users of their products (i.e. consumers/patients, pets, or livestock).

Good documentation practices are also essential for attaining and sustaining ISO-9001 certification — or other ISO certifications specific to your industry, such as ISO/IEC 17025 (for laboratory testing and calibration standards); ISO/IEC 27001 (for information security management system / ISMS), or ISO 13485:2016 (for medical device manufacturing).

Recordkeeping Gaps and FDA Audit Findings & TGA Audit Findings

Recordkeeping/Documentation Citations

You can nearly guarantee your documentation procedures, recordkeeping systems, and data integrity assurance measures will be targeted in your next GMP inspection/Regulatory compliance audit.

Breaches of GMP regulations in relation to documentation practices and data systems are frequently cited in audits by the FDA, TGA, EMA, MHRA, and other Regulatory Authorities. To avoid audit findings and citations — and the potential for having to implement a recall due to poor documentation practices — good recordkeeping is essential.

Good recordkeeping, the foundation of data integrity, requires managerial-level prioritisation of data governance measures.

Your entire organisation must stay up to date with their Good Documentation Practice training courses to ensure they are complying with regulatory expectations.

Keeping good records is the foundational activity of good manufacturing practice (GMP), starting at the product conception and design stage, and continuing through clinical trials or prototype testing, production, distribution, and post-marketing surveillance.

Good documentation practices are required throughout the product’s entire life cycle, including design stages, manufacturing and testing, batch release, warehousing and distribution, and post-marketing surveillance — even disposal.

Good documentation practice throughout your organisation can reduce your chances of releasing a substandard batch of medicines, or medical device product, into the pharmaceutical supply chain (and help you avoid a product recall).

Do you need to learn the GMP requirements for managing deviations & non-conformances, managing therapeutic goods product complaints, preparing for a product recall, or implementing an effective CAPA system? Click here for online training for popular GMP industry education topics.

Who in an organisation must comply with Good Documentation Practice (GDP)/Good Recordkeeping Practice?

The requirement for Good Documentation Practice (GDP/GDocP) — also referred to as Good Recordkeeping (GRK) — applies throughout your organisation.
Adhering to ALCOA+ principles is mandatory during manufacturing and post-marketing activities.
Keeping good records, and ensuring data integrity requirements are met in the process, is particularly applicable to any activities involving receiving raw materials/incoming goods, quarantine, production, testing, packaging & labelling (serialisation), and warehousing and distribution.

Not only must your employees and contractors comply with ALCOA+ principles and Good Documentation Practice (GDP) guideline — so must your contractors, suppliers/vendors, and distribution personnel (e.g. warehouse workers, product transport companies, and other individuals and businesses involved in manufacturing, packaging, storage, transportation, logistics, and delivery).

Good recordkeeping is also mandatory for Complaints Management Systems, CAPA systems, and post-marketing surveillance activities (pharmacovigilance/adverse event reporting). Click here to learn about PQS & QMS system requirements for GMP sectors.

GMP Inspection findings & Audit Citations (Documentation)

How many audit citations are related to poor recordkeeping and GMP documentation practices?

Inadequate documentation practices and recordkeeping weaknesses are key targets for FDA inspections, TGA inspections and QMS audits.

For Beginners | GMP Basics for Good Documentation Practices

GMP Industry Terminology for Good Recordkeeping

GDocP vs GDP (Good Documentation Practice vs Good Distribution Practice)

Before we discuss the basics of good documentation practices for beginners, good documentation practices should not be confused with good distribution practices (for which the acronym is GDP).

To avoid confusion, Good Documentation Practice should be referred to as GDocP — not GDP (or Good Recordkeeping/GRK is also acceptable).
However, some industry publishers still use the same acronym (GDP) for documentation practices as well as for distribution practices (an error).
Data Integrity is a measure on its own and is a separate yet related education topic for data collection, data analysis, data storage and retrieval for the documentation retainment duration expected according to Regulations.

A brief note about GxP Acronyms

GxP stands for various GMP guidelines or regulations, such as GWP (Good Warehouse Practice), GRK (Good Recordkeeping Practice), etc.
Double meanings for the acronym ‘GDP’ (GDP = GDocP vs GDP = Good Distribution Practice) could impact your quality management systems and guidelines.
Be sure to specify GDocP for good documentation practices — or refer to Good Recordkeeping Practice (GRK) instead, per PIC/S publication terminology and common uses.

ISO certification — as well as GMP compliance — depend upon an organisation-wide commitment to good documentation practice (GDocP)/Good Recordkeeping Practice (GRK) and other relevant GxP requirements.

Data Governance measures must be adequate to ensure good recordkeeping practice & data integrity.

Regulatory Authorities/Competent Authorities around the world expect high-level commitment to data governance measures (i.e. Management commitment, evidenced by actions and company-wide communications). These measures generally include ensuring data integrity is maintained, such as by training personnel in GDocP, validating computer systems and electronic record storage equipment and systems over time, timely monitoring of data entries, and continuous improvement initiatives in regard to recordkeeping and data storage and retreival systems.

Aim and purpose of good documentation practices (GDocP)

GDocP/GRK in pharmaceutical and medical device manufacturing

If you’re new to GMP (or new to working in a regulated sector/manufacturing sector), you can learn more about GMP through PharmOut’s PIC/S Annexes/GMP compliance training store.
Visit the short online course for Good Documentation Practice/Good Recordkeeping Practice (GRK) compliance training/presentation.

Online GMP courses are typically available immediately upon completion of the online order. These courses will help you (and/or your new employees or contractors) better understand GMP compliance guidelines and industry expectations.

General Documentation Requirements/Good Documentation Practices

In brief, Good Documentation Practice (GDocP) guidelines from organisations such as PIC/S aim to ensure globally-expected standards are met during ALL stages of manufacture and distribution of medicinal products (pharmaceuticals, medical devices, veterinary medicines, etc).

Summary of GMP, PIC/S and ISO 9001 documentation standards

Accepted standards for the ALCOA+ standards (repeated below), are used to assess recordkeeping and data storage/retrieval practices at an organisation. They are assessed during GMP and GxP Audits to ensure they meet expectations.

Complete the GMP Data Integrity training course & the Good Recordkeeping course by clicking here.

What’s generally required for good documentation practices and data integrity assurances?

The list below is an overview, in brief, of what Regulatory Authorities expect (this equates to the requirements of ALCOA and ALCOA+).

data accuracy (the A in ALCOA+)
- recorded accurately
- cross-checked for errors
- not intentionally misleading (prevents fraudulent entries, editable entries)
attributable data (the second A in ALCOA +)
- identity of the person recording the data is known/readily understood
- the identify of the individual keeping any record or performing data entry must be identifiable at all times, on all GMP documentation
- there must be no ambiguity, whatsoever, as to who recorded the data
legibility (the L in ALCOA+)
- clarity of content (easily understood/accepted notations/formats/etc)
- legible (readable by anyone, removing guesswork)
- readily accessible
contemporaneous recording (the C in ALCOA+)
- recorded at the time of the event (as close as practicable)
- not recorded or edited after the event
original (the O in ALCOA+)
- the record must be an original (not a copy)
- edited records must not be erased or changed without specific notations and leaving the original data intact (learn how to cross through errors in a GMP environment)

Regulatory expectations also include the following in terms of recordkeeping and data collection/storage and retrieval, for both paper-based systems and electronic systems (which must be validated):

identifiable
- clear records that can identify the person who actually records the data
  - Blockchain is increasingly being discussed as part of Pharma 4.0 innovations
  - watch for other new technology adaptations for GDocP as systems evolve
- Especially given growing global concerns about counterfeit pharmaceuticals and cosmetic medicines and substandard medicines and fake antibiotics entering global pharmaceutical chains
- GMP and GDocP requires no shared passwords (and high-tech digital security for data integrity purposes and data entry tracking/logging identification)
data integrity/validation
- genuine, true data
- validated and supported/witnessed; vs intentionally falsified
- relevant to the reporting requirement
- not changeable after original recordkeeping entry (extensively tracked changes)
reporting/recordkeeping timeliness
- information is recorded contemporaneously
- real-time record keeping including date stamps (e.g., automated time-stamping)
  - prevents errors from human memory-reliance issues and prevents editing of original data

Documentation/manufacturing records must meet ALCOA+ standards.

What does the “+” represent in ALCOA+?
Learn more about ALCOA+.

Tips for beginners: additional information on the basics of Good Documentation Practice (GDocP)/GRK.

All personnel, including contractors, are responsible for following regulatory guidelines.

Expectations for GDocP/GRK compliance go well beyond being an organisation-wide requirement.
These expectations also apply to contractors, service vendors/maintenance workers, equipment installation engineers, raw material suppliers, and any other individuals or companies involved in your manufacturing, production, labelling/packaging operations (and supply chains).

It’s important to be aware of the compliance gaps that lead to GMP audit citations and/or audit failures (audit findings/citations/production line shutdowns and/or facility closures).

Documentation AND distribution practices are two key areas where companies often end up inadvertently breaching GMP requirements/PIC/S guidelines for documentation practices.

As the manufacturer (product sponsor), your organisation is ultimately responsible for ensuring EVERY person involved in the production and distribution of your products has attained appropriate GDocP compliance training (with proof, e.g. assessments/training certificates).

Documentation Audits & Inspection Findings

Averting GMP audit findings (GMP compliance breaches, e.g. to avert failing an ISO certification audit, or being subjected to a TGA warning letter/citation or an FDA warning letter/audit citation/fine):

GDocP compliance investigations need to be performed regularly
Management must provide/ensure adequate training and monitoring of documentation practices and quality systems, including those used by contractors, key suppliers, and transportation personnel
Data governance measures must be appropriate to risks
Computer systems / electronic data systems must be validated

Self-Inspections for GDocP compliance are recommended to be performed more frequently than your annual self-inspection requirement.

It may be beneficial to perform self-inspections of recordkeeping/documentation practices more frequently than your annual requirement.
Frequent self-inspections (internal GMP/GDP compliance audits) can help improve compliance, reduce risks, and provide ideas for continuous improvements — as well as ensuring your Pharmaceutical Quality System (PQS) is functioning as intended.

Applicability of Good Documentation Practice (GDP) Guidance by PIC/S

Good documentation practices (requirements) apply to nearly all delivery regions and countries.
While PIC/S guidelines aim to ensure global consistency in terms of manufacturing standards, some regions may have slightly different documentation requirements — DO check before you ship.

Digital recordkeeping systems

If you’re relying on any type of digital recordkeeping system, you must ensure your computerised systems and data collection/data analysis processes are validated according to GMP guidelines/regulatory expectations.

Ensure you comply with data integrity requirements.

Documentation Types | Good Documentation Practices

What types of documents or recordkeeping is required in the pharmaceutical industry or in the production of medicinal cannabis, medical devices, blood and tissue products and veterinary medicine production?

Examples of records for which employees/contractors and suppliers must adhere to good documentation practices (GDocP as part of GMP including GDP or distribution) include, but are not limited to:

Analytical Methods
Annual Self-Inspection (Procedures, Implementation and Findings/Actions)
Batch Records / Supply Sources
Bills of Materials (BOMs)
CAPA (Corrective Actions and Preventative Actions)
Clinical Study Records
Cold Chain reports and climate testing measurements/records
Complaints and complaint handling/monitoring
Continuous Improvements
Certificate of Analyses (CoA)
Certificate of Compliance (CoC)
Deviations
Distribution records including Routes, Storage and Delivery Records
Incident Reports
Laboratory Notebooks / Logbooks
Labels (Product Labels and sampling labels)
Non-conformances
Policies (documentation including approvals and distribution/employee training records)
Protocols and changes to protocols (change management system documentation including approvals)
Quality management records / QMS systems
Recalls and Recall Policies
Releases (QMS approvals by trained, competent and authorised personnel)
SAE reporting (serious adverse events reporting)
Source suppliers and source supply testing/monitoring
Standard Operating Procedures
Test Methods / Quality Testing methods including validation and recordkeeping
Training | GMP training for Employees, Contractors, Suppliers/Vendors including your distribution/warehouse and transportation personnel or contractor(s)
Work Instructions (Workflow, procedures, SOPs)
Workplace Safety reports/record keeping
Validation (methods, reports and related documentation including IQs, OQs and PQs)

GMP Recordkeeping Categories

Documents and records can fall into various classification systems, and in general, there are 4 key classifications for documentation.

Primary Records (examples: production formulas, supply source documents, contracts, packaging instructions)
Procedures or supporting procedures (instructions and guidebooks, SOPs)
Subsidiary records (help meet GMP, e.g. calibration readings reports, print outs, other supporting documents)
Quality Control records (testing results, testing methods, recall procedures, investigations, self-inspection reports, CAPA, more)

GDocP | What are the specific requirements for good documentation practices in pharmaceutical production including medicinal cannabis and other herbal medicines, veterinary medicines and medical device manufacturing?

Check your organisations SOPs (Standard Operating Procedures) and work instructions for details.

Basic requirements for good documentation practices will include, but not be limited to, the following components:

Accuracy
Data Integrity (protected, secure and backed-up data systems)
Contemporaneous recordkeeping (timely, immediately/real-time)
Legible
Readily identifiable as to who recorded it (no shared passwords or shared data system log-ins, no forging of signatures even if requested)
Readily accessible when required
Signature record log and register
- initials and signatures of all employees, contractors and suppliers who fill in documentation
- a secure database to match initials and signatures with the actual identity of the person who recorded the data
Security / Data Integrity
- Data must not be able to be altered or erased once entered or recorded
- No white-out is permitted in GMP facilities and no gel pens (specific writing instruments are designated in your SOPs and working instructions)
- Specific rules must be followed when altering a record, such as a legible cross through of the data and the correction listed with your registered initials and the time/date (and reason for the change, depending on the recordkeeping requirements)

We have online training for GDocP as well as custom onsite courses and upcoming GMP course training dates.

Good Documentation Practice (Summary)

GDocP/GRK training, and recordkeeping compliance monitoring, in conjunction with other data governance measures, can help reduce your risks of ‘failing’ a GMP compliance audit.

Just remember that good recordkeeping requirements apply to everyone in your distribution supply chain, not just manufacturing-site personnel.

It is applicable to your casual workers/contractors, contract service providers, source material/API suppliers, warehouse workers, and transport/delivery organisations.

All people who have contact with your product, at any stage of production or delivery:

require documented, ongoing training in GDocP/GRK compliance
are expected to be monitored for GMP/GxP compliance
should understand how to identify potential issues with records/data integrity

The FDA and TGA will likely investigate your employee records, and the documentation practices of your suppliers and service providers — including contractors — and they’ll do so in-depth!

That’s because good documentation practices are part of the 10 golden rules of GMP.

References, Sources and Further Reading

The Food and Drug Administration (FDA or Agency) – December 2018 (‘‘Data Integrity and Compliance With Drug CGMP: Questions and Answers’’ PDF)

Other Training Bundles

Or for individual or onsite training courses, review GMP training courses by PharmOut’s GMP Training, learning and development expert, Maria Mylonas and other GMP manufacturing and medicinal cannabis TGA industry experts.

References:

Warehouse, Distribution and GMP Training for Transportation employees and Outsourced contractors (Training)

FDA Good Documentation Practices (FDA GDP)

TGA Good Record Keeping / GDocP

For GMP consultancy and/or GMP audit assistance, validated quality management systems (QMS) and other data integrity or production engineering and distribution practice consultancy, visit PharmOut’s site.

You can also browse our top online GMP training courses for industry-specific training, available in bundles. Onsite custom courses by Maria Mylonas are also available at your facility anywhere in the world.

Page last updated: October 17, 2022.