Device Master Record - Location of Records

Device master records shall be stored at the manufacturing establishment or at other locations that are reasonably accessible to company employees responsible for the manufacturing activities and accessible to FDA investigators. Appropriate records may be maintained in computer data banks if the records are protected, change controlled, and readily accessible for use by responsible employees at all relevant facilities. It is acceptable for a manufacturer to maintain records on microfilm and discard the original hard copies. Microfiche and/or microfilm reductions may be used in lieu of original record retention if the following conditions are met.

• All reductions shall be readily available for review and copying by FDA investigators and designated company personnel at any reasonable time.
• All necessary equipment shall be provided for viewing and copying the records.
• Reproductions shall be true and accurate copies of the original record.

The device master record is a single source document or file. Portions of this file may be kept in various locations. A device master record may exist as:

• one or more files or volumes of the actual records containing the information required by the QS regulation;
• a reference list of such documents and their location; or
• any combination of actual documents and/or reference lists.

The QS regulation allows use of reference lists as a means to reduce the duplication of records, particularly duplication of general documents such as standard operating procedures (SOP's). General SOP's (not directly related to a product or process) however should be made a part of the quality system record (QSR).

Use of a reference list also allows filing of device master record documents at several convenient locations. If the device master record contains a list of documentation, the actual documents shall be available for employee use and FDA inspection at the manufacturing site or other reasonably accessible locations. As noted above, this is a key and important GMP requirement.

When performing an inspection of a company, FDA investigators shall have access to actual records for review and copying during reasonable business hours. FDA investigators review these records to determine if a manufacturer is complying with the QS regulation and with the Food, Drug, and Cosmetic Act.

Records deemed confidential by a manufacturer should be marked to aid FDA in determining whether or not specific information may be disclosed under the Freedom of Information Act.

Records deemed confidential by a manufacturer should be marked to aid FDA in determining whether or not specific information may be disclosed under the Freedom of Information Act.