A self-check for people who work with GxP records and systems: QA, validation, MES and Salesforce Life Sciences teams. Step 1 asks whether FDA's 21 CFR Part 11 likely applies to a record or system. Step 2 is a checklist of 32 data-integrity points from Part 11, EU GMP Annex 11 and ALCOA+, each with the reason and where it comes from. Your answers stay in this browser; nothing is sent anywhere.
This is a self-check, not regulatory advice. It does not replace your own QA and regulatory review. See the disclaimer.
ALCOA+ in plain words
ALCOA is the five original terms; the '+' adds Complete, Consistent, Enduring and Available. FDA's 2018 Q&A uses ALCOA. MHRA (2018) says expectations are the same whichever acronym is used. The plain definitions below follow the PIC/S table (PI 041-1, 2021).
| Term | What it means |
|---|---|
| Attributable | You can see who (which person or computerised system) did each task or change. |
| Legible | The record can be read and understood. If the data is dynamic, you can still view and use it with a suitable application. |
| Contemporaneous | Actions, events and decisions are recorded at the time they happen. |
| Original | The first capture of the data (or a true copy) is kept. Data first captured in dynamic electronic form stays available in that form. |
| Accurate | The data is correct. Qualified equipment, validated systems, good procedures and trained people support this. |
| Complete | All information needed to rebuild the event is there, including relevant metadata. |
| Consistent | Good documentation practice is used every time, in every step, and all changes to data are captured. |
| Enduring | The record stays intact and durable for the whole retention period. |
| Available | The record can be found and read for review, audits or inspections at any time during the retention period. |
Related guides on vtfriday
- MES Data Integrity & Audit Trails Explained: ALCOA+, 21 CFR Part 11 & Cloud GxP Guide
- Pharma Data Integrity Explained: ALCOA+ & Audit Trails in MES
- What is ALCOA in Pharma? A Simple Guide to Data Integrity
- MES Validation & Computer System Validation (CSV): Complete Guide
- What is an Electronic Batch Record (EBR) in Pharma MES?
- 10 Daily Habits for GxP Inspection Readiness
Sources
The points above were written from these texts. Check the current official versions: a revised Annex 11 went to public consultation in 2025.
- eCFR: 21 CFR Part 11
- FDA: Part 11, Electronic Records; Electronic Signatures - Scope and Application
- FDA: Data Integrity and Compliance With Drug CGMP: Questions and Answers (December 2018)
- European Commission: EudraLex Volume 4, Annex 11 Computerised Systems
- MHRA: GXP Data Integrity Guidance and Definitions, Revision 1, March 2018
- PIC/S PI 041-1 Good Practices for Data Management and Integrity in Regulated GMP/GDP Environments (1 July 2021)