PIC/SRegulatory IntelligenceGuidanceHIGH INSPECTION RISK
PIC/S PI 041-1

Good Practices for Data Management and Integrity in Regulated GMP/GDP Environments

The PIC/S data integrity guidance (adopted 1 July 2021), written for inspectorates — which makes it the closest public view of how data integrity is actually inspected. Covers data governance, paper-based and computerised systems, hybrid situations, outsourced activities, and how deficiencies should be classified and remediated.

LAST REVISED
July 2021
PRODUCT AREAS
SterileSolid DoseBiotechApi
SCOPE & APPLICABILITY

GMP and GDP environments inspected by PIC/S participating authorities. Structured as inspection guidance, so each section pairs expectations with the way an inspector should probe them.

QUICK REFERENCE · ALCOA+ — THE DATA INTEGRITY TEST

The nine attributes PIC/S PI 041-1 expects of GMP/GDP data, whether paper or electronic.

  • Attributablewho recorded the data or performed the action, and when
  • Legiblereadable and permanent for the record’s entire lifecycle
  • Contemporaneousrecorded at the time the work is performed
  • Originalthe first capture, or a verified true copy of it
  • Accuratecorrect, truthful, complete, valid and reliable
  • Completeall data, including any repeats, reanalyses or reprocessing
  • Consistentsequenced and date/time-stamped in the expected order
  • Enduringrecorded on controlled, durable media — not scrap paper
  • Availableretrievable for review and inspection throughout the retention period

PI 041-1 is written for inspectors, so it also expects data-integrity risk to be governed proportionately to data criticality, and deficiencies to be classified and remediated.

Source: PIC/S PI 041-1, Good Practices for Data Management and Integrity. Verify against the current text before relying on it for a submission.

KEY REQUIREMENTS
  • 01Implement a documented data governance system with clear management ownership
  • 02Apply risk-based controls across paper, electronic, and hybrid records
  • 03Control user access, privileges, and audit trails in computerised systems
  • 04Extend data integrity expectations to outsourced activities and suppliers
  • 05Classify and remediate data integrity deficiencies with a risk-based methodology
IMPLEMENTATION TIPS
Self-inspect against PI 041 section by section — it is literally the inspection script
Use its deficiency-classification examples to calibrate your internal audit grading
Fold supplier data integrity questions into quality agreements and audit checklists
Treat the maturity ladder as a roadmap: procedural compliance first, then embedded behaviour
REVISION NOTES

PI 041-1 was adopted 1 July 2021 after several draft rounds. It consolidates the PIC/S position alongside the MHRA (2018) and WHO data integrity guidances and is referenced by many national inspectorates.

PIC/S PI 041-1: frequently asked questions

Quick answers to common questions about PIC/S PI 041-1.

What is PIC/S PI 041-1?

PIC/S PI 041-1 — Good Practices for Data Management and Integrity in Regulated GMP/GDP Environments — is a guidance issued by the Pharmaceutical Inspection Co-operation Scheme. The PIC/S data integrity guidance (adopted 1 July 2021), written for inspectorates — which makes it the closest public view of how data integrity is actually inspected. Covers data governance, paper-based and computerised systems, hybrid situations, outsourced activities, and how deficiencies should be classified and remediated.

Who does PIC/S PI 041-1 apply to?

GMP and GDP environments inspected by PIC/S participating authorities. Structured as inspection guidance, so each section pairs expectations with the way an inspector should probe them.

What are the key requirements of PIC/S PI 041-1?

PIC/S PI 041-1 requires, among other things: Implement a documented data governance system with clear management ownership; Apply risk-based controls across paper, electronic, and hybrid records; Control user access, privileges, and audit trails in computerised systems; Extend data integrity expectations to outsourced activities and suppliers.

When was PIC/S PI 041-1 last updated?

The current version of PIC/S PI 041-1 dates from July 2021. PI 041-1 was adopted 1 July 2021 after several draft rounds. It consolidates the PIC/S position alongside the MHRA (2018) and WHO data integrity guidances and is referenced by many national inspectorates.

RELATED STANDARDS
SPEQ TEMPLATES FOR THIS STANDARD

Ready-to-use templates designed to help you comply with PIC/S PI 041-1.

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Live openFDA recalls SPEQ maps to this standard’s topics — a SPEQ interpretation, not an FDA classification.

THIS STANDARD IN PRACTICE

Recall domain is a SPEQ mapping of this standard’s topics, not an FDA classification.

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