thebench.bio #1 Ecosystem for the Bio-Tech Industry
All Quality Control questions

Question 10 of 20 Fundamentals Practical

What must a GMP laboratory record contain for each test?

Short answer

It must identify the sample and its source, state the method and the weight or volume used, hold all raw data including chromatograms and spectra, show every calculation with units, compare the result with the specification, and carry the analyst's and an independent reviewer's signatures and dates.

Why

21 CFR 211.194 lists what a laboratory record must hold so that someone else could reconstruct the test. It starts with the sample: where it came from, quantity, lot, date sampled and date received. Then the method, with a reference to the data showing it is accurate and reliable, and for compendial methods a verification that it works under actual conditions of use.

Then the amount of sample, the complete record of all data including graphs, charts and spectra, all calculations with units, conversion and equivalency factors, and the result compared with the standard. The analyst initials or signs and dates it, and a second person signs to show the original records were reviewed for accuracy, completeness and compliance. Modifications of a method, and testing of reference standards, reagents and standard solutions, also need complete records.

In practice the most common gaps are calculations done in an unlocked spreadsheet with no record of the formula, chromatograms that were reintegrated without the earlier version kept, and standards prepared without recording the balance used. The FDA's data integrity guidance treats the full audit trail as part of the record for electronic systems, so a printed final report alone is not the complete data. Records are only useful if they are made at the time, so writing results on a glove and copying them later breaks the rule even if every number is right.

How to work it through

  1. Record sample identity, source, lot and dates on receipt.
  2. Reference the approved method and version and record any permitted deviation.
  3. Record weights, volumes, instrument IDs and reagent and standard lots as you work.
  4. Keep all raw data and the processing history, including audit trails for electronic systems.
  5. Show calculations with units or use a validated, locked calculation tool.
  6. Compare the result with the specification, sign and date, then pass the full package to an independent reviewer.

An example

An analyst runs an HPLC assay on lot 24-117. The record shows the sample received on 3 March from the blender discharge, 50.12 mg weighed on balance B-07, standard lot WS-22 with assigned purity 99.6 percent, and the chromatography data system sequence name. Result: 99.1 percent against 95.0 to 105.0 percent.

The reviewer opens the audit trail, sees one manual integration with a recorded reason, checks the calculation from peak areas, and signs. Without the audit trail check, the review would have missed whether earlier integrations existed.

Where the answer stops holding

The regulation lists content, not how to achieve it, so electronic systems need validation and configuration to capture it reliably. A complete record can still be wrong if the underlying measurement is wrong. Review quality depends on the reviewer looking at raw data rather than only the summary.

A strong answer covers

  • Sample identity, source and dates
  • Method reference and verification of suitability
  • All raw data including spectra and chromatograms
  • Calculations with units and factors
  • Analyst and independent reviewer signatures

Common mistakes

  • Keeping only the final printed report and not the raw data or audit trail.
  • Doing calculations in an uncontrolled spreadsheet with no record of formulas.
  • Recording results on scrap paper and transcribing them later.