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생명과학 eQMS 12개 항목

Electronic Batch Record Review-by-Exception Checklist

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Confirms that electronic batch records and a review-by-exception model are configured, validated, and governed so that batch release remains compliant and data-integrity sound. Use to establish or audit an EBR/MES review process.

21 CFR 211.18821 CFR 211.192EU GMP Annex 1121 CFR Part 11

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EBR Configuration and Validation

Establish the electronic record foundation.

  • Is the electronic master batch record configured to reflect the approved master production and control record? *
  • Are automated in-process checks, limits, and interlocks validated in the MES? *
  • Are enforced sequencing and mandatory data entries configured to prevent skipped steps? *

Review by Exception Design

  • Is the review-by-exception model defined so that automatically captured, in-limit data need not be re-reviewed manually? *
  • Are exceptions, deviations, and out-of-limit events automatically flagged for mandatory review? *
  • Is the risk-based rationale for the scope of exception review documented and approved? *

Exception Handling and Data Integrity

  • Are all flagged exceptions resolved and dispositioned before batch release? *
  • Are audit trails for the batch record reviewed for critical data as part of disposition? *
  • Are corrections made with attributable, time-stamped, reason-documented entries? *

Release and Governance

  • Does the quality unit perform the final review and approval of the electronic batch record before release? *
  • Are role-based permissions and electronic signatures enforced for review and approval steps? *
  • Is the EBR system maintained under change control and periodic review? *

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