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Does the FDA consider electronic signatures to be as trustworthy and
reliable as handwritten paper signatures? - 🧠ANSWER ✔✔Yes (although
permission to use such e-sigs has to be approved by the FDA)
Does the FDA consider electronic records that meet requirements to be
equivalent to handwritten records ? - 🧠ANSWER ✔✔Yes
,Open system (FDA term) - 🧠ANSWER ✔✔System access is NOT
controlled by people who are responsible for the content of the electronic
records in the system. (Like me putting data into CHOP - controlled
databases)
Closed system (FDA term) - 🧠ANSWER ✔✔Environment in which SYSTEM
ACCESS is controlled by the same people responsible for the content of
the system (I.E. I control the Robotic Database access AND its contents)
What are some FDA Standards to meet when operating a closed record
system? - 🧠ANSWER ✔✔1. Must be able to tell if records have been
altered or invalid
2. Must be able to copy records for agency review
3. Protect records throughout retention period
4. Limit system to authorized individuals only
5. Use time-stamped audit trails of modification etc
6. Use operational system checks and restrictions
7. Use authority checks to make sure only authorized individuals are using
the system
,8. Use device checks to validate data input
9. Make sure those authorized to use system have appropriate training,
education, experience
10. Have written policies that deter data falsification
11. Audit and control the maintenance of the actual system
What are some FDA standards to meet when using an Open System? -
🧠ANSWER ✔✔All those mentioned for the closed system.
1. Document encryption as appropriate
What information should a handwritten SIGNATURE block contain? -
🧠ANSWER ✔✔1. Printed name of signer
2. Date and Time when signature was executed
3. The MEANING associated with the signature (approval? responsibility?
authorship?)
Signature and record linking ? - 🧠ANSWER ✔✔Signatures must be linked
to their respective electronic records to make sure they cannot be copied,
falsified, transferred etc.
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, Do researchers need to request permission from the FDA to use electronic
signatures in place of regular signatures? - 🧠ANSWER ✔✔Yes
What controls should an E-SIGNATURE contain? - 🧠ANSWER ✔✔Employ
at least 2 identification components - such as an identification code AND a
password.
Name some CONTROLS for the identification components (i.e.
identification code and password) for e-signature? - 🧠ANSWER ✔✔1. no 2
people should have the same identification controls (password... code)
2. Identification codes and passwords should be periodically checked,
revised, etc.
3. Deauthorize lost, stolen, missing codes and passwords
4. Periodically test your devices that generate these codes
Can an informed consent contain exculpatory language? - 🧠ANSWER
✔✔NO! Cannot say things like "you are waiving your right to damages" etc
When may an experimental drug or device be used on a patient WITHOUT
informed consent? ((EMERGENCY USE)) - 🧠ANSWER ✔✔1. the