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Compliance FrameworksAmericas

FDA 21 CFR Part 11

FDA Electronic Records and Electronic Signatures - audit trail, validation, access control, integrity.

FDA Electronic Records and Electronic Signatures - audit trail, validation, access control, integrity.

Short name21 CFR 11
RegionAmericas
Country or scopeUnited States
SectorHealthcare
In your workspaceOn unless you switch it off in Compliance › Manage.

How Safeguard covers 21 CFR 11

  • Scan requirements: 6, all decided by a scan.
  • Controls: the scan requirements below, plus 14 controls from Safeguard's control catalog for 21 CFR 11.
  • Automated tests: none map to it directly. You can link any automated test to its controls yourself (how).
  • Policy templates: 26: 4 written for 21 CFR 11 and 22 from the standard set.

How each kind of coverage works, and what the readiness score counts: Compliance frameworks.

What a scan checks

Each scan of a product checks these 6 requirements against what the scan found, including the product's software inventory (SBOM).

RequirementWhat Safeguard checksDecided by
FDA-P11-10A System Validation BaselineSystems must be validated to ensure accuracy, reliability and consistent intended performance; validation is only meaningful against a fully enumerated system where every software component is named and versioned (21 CFR § 11.10(a))Scan
FDA-P11-10B Accurate Machine-Readable CopiesSystems must be able to generate accurate and complete copies of records in both human-readable and electronic form suitable for FDA inspection; standardised machine-readable system documentation (SPDX/CycloneDX) satisfies the electronic-copy expectation for the software record (21 CFR § 11.10(b))Scan
FDA-P11-10C Record Protection and IntegrityRecords must be protected so they remain accurate and readily retrievable throughout the retention period; cryptographic integrity evidence (hashes) for the software handling those records demonstrates protection against undetected alteration (21 CFR § 11.10(c))Scan
FDA-P11-10E Audit Trail FoundationsSecure, computer-generated, time-stamped audit trails must independently record operator entries and actions; the system documentation itself must carry document identity and creation timestamps to anchor that audit chain (21 CFR § 11.10(e))Scan
FDA-P11-10K Documentation and Change ControlThere must be controls over systems documentation, including revision and change-control procedures that maintain an audit trail of modifications; vague or floating component versions (latest, wildcards, ranges) are incompatible with controlled change management (21 CFR § 11.10(k))Scan
FDA-P11-50 Signature and Authorship ManifestationSigned electronic records must show the printed name of the signer and the date, time and meaning of the signing; analogously, the system record must identify who or what tool created it (21 CFR § 11.50)Scan

More controls in the catalog

The framework's Controls tab lists its scan requirements and these controls from Safeguard's control catalog. Evidence them with automated tests, uploaded evidence, policies or an attestation.

ControlName
11.10(a)System Validation
11.10(b)Record Legibility & Retention
11.10(c)Record Protection & Archival
11.10(d)System Access Limitation
11.10(e)Secure Audit Trails
11.10(f)Operational System Checks
11.10(g)Authority Checks
11.10(k)Personnel Training Controls
11.30Open Systems Additional Controls
11.50Signature Manifestations
11.70Signature/Record Linking
11.100Electronic Signature Uniqueness
11.200Electronic Signature Components
11.300ID Code & Password Controls

Policy templates

Written for 21 CFR 11:

  • Computer System Validation (CSV) Policy: 21 CFR Part 11
  • Electronic Signature Controls Procedure: 21 CFR Part 11
  • Audit Trail Review Procedure: 21 CFR Part 11
  • Open Systems Security Policy: 21 CFR Part 11

And 22 from the standard set, adapted to 21 CFR 11.

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