Life sciences manufacturers are required to comply with strict guidelines outlined by regulatory bodies including the US Food and Drug Administration (FDA). After all, pharmaceutical products and medical devices have a direct impact on the health and safety of the end consumer.
As part of a broader code of regulations to govern the life sciences industry, the FDA instituted 21 CFR Part 11. This regulation applies to both medical device and pharmaceutical manufacturers with the primary objective of governing the handling of electronic records and electronic signatures.
In this post, we’ll review the regulations outlined in 21 CFR Part 11 and how manufacturers in the life sciences industry can simplify compliance as they undergo their digital transformation.
What is 21 CFR Part 11?
21 CFR Part 11 refers to part 11 of Title 21 of the Code of Federal Regulations as stipulated by the US Food and Drug Administration. These regulations focus on electronic records (including electronic batch records and device history records) as well as electronic signatures, providing conditions under which these particular compliance activities can be trusted to the same degree as signatures on paper documents.
Part 11 of this code of regulations guides manufacturers on the integrity and confidentiality of electronic data and documents and provides an environment where the parties involved can’t contest approval and review of electronic signatures.
Apart from electronic documents, this code also encompasses images, sound files, source code, and videos. Ultimately, 21 CFR Part 11 enables manufacturers in the life sciences industry to sidestep most of the more complex paper document management.
Notably, the comprehensive nature of this code lends itself well to a manufacturer’s quality management system. It ensures that all electronic material stemming from manufacturing practices meets the standards and regulations required by the FDA.
Automate data collection and streamline compliance activities
The Digital History Record app allows you to view all digital logbook records, electronic batch records and equipment activity in one centralized location.
Why Compliance Matters in Modern Manufacturing
For manufacturers in regulated industries, compliance isn’t negotiable, it’s fundamental to staying in business. Missing FDA expectations goes well beyond a warning letter. It can mean production shutdowns, product recalls, and long, expensive remediation cycles that pull resources from real work.
21 CFR Part 11 defines how electronic records and signatures must be managed. If your systems fall short of that standard, the data they produce can’t be trusted in an audit. For any company operating under GxP principles, that risk alone can stop operations cold.
Regulators have been direct about what they expect: validated systems, restricted access, and audit trails that can’t be altered. Over the past several years, the FDA has focused more attention on software-driven quality systems, and findings tied to Part 11 are among the most frequent. ISPE data shows that missing or incomplete validation is consistently one of the top issues flagged during inspections.
Compliance isn’t just a checkbox, it’s what protects your operation from disruption. A properly validated and maintained system gives you certainty that your records are accurate, your electronic signatures are defensible, and your data will hold up under inspection at any site, any time.
Requirements of 21 CFR Part 11
Life sciences manufacturers have a set of requirements from the FDA detailing essential quality management considerations when implementing digital document management systems. These include:
| Requirement | What It Really Means | What to Include or Implement |
|---|---|---|
| Software Validation | Any digital system involved in GxP processes must consistently perform as intended. You need documented proof that your system works, and keeps working. | Document how the system functions, run validation tests, and retain results that show accuracy, reliability, and consistency. Validation should be repeatable, reviewable, and traceable. |
| Access Controls | Only authorized individuals should access systems. Roles, permissions, and secure login credentials are essential. | Use role-based access control, unique login credentials, and password policies. Define what each user can see or do in the system. Include session timeouts and change logs. |
| Electronic Signatures | A digital signature must be uniquely tied to one person and one record. It must include the name, date, and signing reason. | Require authenticated signatures with a clear purpose field and timestamp. Ensure the signature cannot be reassigned or duplicated. |
| Audit Trails | Keep a complete, time-stamped history of edits, approvals, and logins. No silent changes. | Automatically track who made changes, what was changed, when it happened, and why. Version history should be preserved and searchable. |
| Record Retention | Store records securely and in full for the required duration. All versions must be accessible. | Archive documents in a way that preserves their integrity and makes prior versions easy to retrieve during audits. Follow retention rules for your region and product class. |
| Data Integrity | The data must remain whole, unaltered, and traceable throughout its lifecycle. | Implement controls to prevent unauthorized edits. Ensure traceability from the original entry to the final approved record. System logs should reflect any changes to the data or structure. |
| Retrieval & Indexing | Data must be easy to access, index, and retrieve, especially during audits. | Use indexing, archiving, and searchable formats to make data retrieval fast and auditable. Ensure records are logically organized and accessible on demand. |
| Operational Controls | Systems must guide users through approved workflows in the correct order. | Use system logic or checks to enforce sequencing (e.g., don’t approve before review). Document flows should follow a phase-gate process: authoring → review → approval. |
| Training & SOP Compliance | People using the system must be trained and show documented proof of that training. | Maintain up-to-date SOPs. Track training records and require acknowledgement or certification before granting users access to critical workflows. |
| Digital Document Management | All digital records must comply with integrity, security, and traceability expectations and not just be digitized versions of paper. | Ensure your document system goes beyond “paper on glass.” Use interactive tools that enforce proper documentation, track edits, and ensure audit readiness. Digitization must add controls, not reduce them. |
Tips for digitizing compliance procedures
With the earlier discussed requirements, medical manufacturers can create CFR part 11 compliance checklists to maintain the security and integrity of their digital documents. However, this can be challenging, especially when the company moves from paper to digital.
Here’s how such manufacturers can effectively venture into digital compliance:
The digital compliance tool should have security features for proper user identification, access, and system privileges. Simply, the digital solution should allow manufacturers to assign unique usernames and passwords. This promotes document integrity and system security.
The digital solution should have the ability to provide e-signatures for authorized personnel. Additionally, the owner should certify this signature, making it legally binding similar to hand-written paper signatures.
An ideal digital compliance solution should provide ordered historical data, making it easy to audit the system. The audit trail provides a comprehensive account of documents, their authors, date of authorship, and any amendments.
How Tulip Supports 21 CFR Part 11 Compliance
Tulip was built for manufacturers who need to digitize regulated work without losing control of compliance. The platform includes the elements auditors expect, already built into the core system.
Validation documentation that fits real use
Tulip’s Trust Center gives teams access to validation packages, test scripts, and change-control records made for regulated production. The materials line up with both GAMP 5 and risk-based approaches. They’re meant to be used as-is or adapted, no need to start the validation plan from zero.
Audit trails that record what matters
Any regulated app in Tulip keeps its own audit trail automatically. Every edit, signoff, or approval is logged with a timestamp and user record. It’s handled by the system itself, so engineers don’t have to build tracking features into every workflow.
Controls you can configure without coding
Engineers and quality teams can set permissions, manage access, and require e-signatures directly in Tulip. All of it can be done with the built-in tools, no custom development or IT tickets. This keeps updates simple and reduces the risk of small compliance gaps.
Electronic records built for traceability
Each record inside Tulip is tied back to the workflow that created it. Batch releases, deviations, inspections—everything is stored securely with version control and protection against unauthorized edits.
Made for regulated operations
Tulip is used in medical devices, biotech, and pharmaceutical production where validation isn’t optional. Teams often start with the Validation Template from the App Library to speed deployment and keep compliance consistent across lines and sites.
Conclusion
As manufacturers in regulated industries continue to shift away from traditional, paper-based solutions within their business, it’s imperative that they address rules and regulations outlined by regulatory agencies such as 21 CFR Part 11.
We’ve worked with a number of pharmaceutical and medical device manufacturers to help digitize compliance procedures with Tulip’s Frontline Operations Platform, ensuring that businesses are able to consistently and securely track and store critical production data, creating a digital audit trail that can stand up to scrutiny from regulators.
If you’re interested in learning how you can improve your operations with an integrated, digital solution while maintaining compliance as a core pillar of your business, we invite you to reach out to a member of our team to learn more about how Tulip's Frontline Operations Platform!
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It comes down to control and proof. If you use electronic records or signatures, you need to show that the data is complete, traceable, and secure. The systems must be validated, access must be restricted, and audit trails must exist for every change. Regulators want evidence that your digital records can be trusted the same way they’d trust paper ones.
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Each signature has to identify a single person, include a date and time, and show the reason for the action like “approved by” or “reviewed by.” The signature must link directly to the record and can’t be reused by anyone else. When those conditions are met, it carries the same weight as a handwritten signoff.
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Yes, as long as the system is validated and includes the required controls. The FDA doesn’t treat cloud and on-premise software differently. What matters is that access, audit trails, and data protection meet the same standard.
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You’ll need user requirements, a validation plan, risk assessments, and test protocols -usually IQ, OQ, and PQ. Change-control records should show how updates are managed over time. Together, those documents prove that the system works as intended in your specific process.
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Teams often overlook system validation or forget to maintain audit trails. Reused passwords for signatures are another red flag. Some plants still track changes manually, which leads to missing records or inconsistent compliance between sites.
Streamline compliance with Tulip's Frontline Operations Platform
See how a system of apps can help digitize operations and create a digital audit trail to simplify compliance activities.