Standards Comparison

    OSHA

    Mandatory
    1970

    US federal regulation assuring workplace safety standards

    VS

    FDA 21 CFR Part 11

    Mandatory
    1997

    FDA regulation for trustworthy electronic records and signatures

    Quick Verdict

    OSHA ensures safe workplaces via hazard standards and inspections for all US industries, while FDA 21 CFR Part 11 validates electronic records/signatures for pharma/devices. Companies adopt OSHA for compliance, Part 11 for digital trust in regulated data.

    Occupational Safety

    OSHA

    Occupational Safety and Health Act of 1970

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • General Duty Clause enforces recognized hazard-free workplaces
    • Hierarchy of controls prioritizes engineering over PPE
    • Codified standards across 29 CFR 1910-1928 subparts
    • Risk-based inspections target high-hazard industries
    • Electronic injury reporting via Injury Tracking Application
    Electronic Records

    FDA 21 CFR Part 11

    21 CFR Part 11 Electronic Records; Electronic Signatures

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Secure, time-stamped audit trails for changes
    • Validation of systems for accuracy and reliability
    • Access controls for authorized users only
    • Electronic signatures with linking and manifestation
    • Risk-based controls for closed and open systems

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    OSHA Details

    What It Is

    Occupational Safety and Health Administration (OSHA), established by the Occupational Safety and Health Act of 1970 (OSH Act), is a US federal regulation enforcing workplace safety and health standards codified in 29 CFR Parts 1910-1928. Its primary purpose is assuring safe conditions nationwide via standards enforcement, inspections, and the General Duty Clause for recognized hazards. It uses a performance-based, hierarchy-of-controls approach prioritizing elimination, substitution, and engineering.

    Key Components

    • Subparts covering walking-working surfaces, PPE, hazardous materials, toxic substances (Subpart Z), emergency plans.
    • Over 1,000 standards with PELs, recordkeeping (Part 1904), reporting.
    • Core principles: hierarchy of controls, worker rights, state plans.
    • Enforcement model with citations, penalties up to $165K.

    Why Organizations Use It

    • Legal compliance avoids fines, shutdowns.
    • Reduces injuries, workers' comp costs; enhances productivity, reputation.
    • Builds stakeholder trust via data transparency.

    Implementation Overview

    • Phased: gap analysis, written programs (IIPP, HazCom), training, audits.
    • Applies to most private employers; scales by size/industry.
    • No certification; inspections verify compliance.

    FDA 21 CFR Part 11 Details

    What It Is

    FDA 21 CFR Part 11 is a U.S. federal regulation establishing criteria for electronic records and signatures to be considered trustworthy, reliable, and equivalent to paper records and handwritten signatures. It applies to FDA-regulated industries using electronic systems for predicate-rule-required records. The approach is risk-based, with narrowed scope per 2003 FDA guidance, focusing on reliance on electronic records.

    Key Components

    • Controls for closed systems (§11.10: validation, audit trails, access limits) and open systems (§11.30: encryption, digital signatures).
    • Electronic signature requirements (Subparts B/C: uniqueness, manifestation, linking, multi-component controls).
    • Core principles: authenticity, integrity, non-repudiation; enforcement on access, checks, training, policies.
    • Compliance via validation, SOPs; no formal certification but inspection readiness.

    Why Organizations Use It

    • Meets legal obligations for GxP records in pharma, devices, biotech.
    • Mitigates enforcement risks (warnings, holds); enables paperless operations.
    • Enhances data integrity, efficiency, inspection readiness; builds stakeholder trust.

    Implementation Overview

    • Phased: scoping, risk assessment, CSV (IQ/OQ/PQ), training, change control.
    • Targets life sciences; risk-based for any size; audited via FDA inspections.

    Key Differences

    Scope

    OSHA
    Workplace safety, health hazards, recordkeeping
    FDA 21 CFR Part 11
    Electronic records, signatures trustworthiness

    Industry

    OSHA
    All general industry, construction, agriculture US
    FDA 21 CFR Part 11
    Pharma, devices, biologics, food safety US

    Nature

    OSHA
    Mandatory federal regulations, enforced inspections
    FDA 21 CFR Part 11
    Mandatory for electronic records, enforcement discretion

    Testing

    OSHA
    No system validation, compliance inspections
    FDA 21 CFR Part 11
    Risk-based system validation, IQ/OQ/PQ

    Penalties

    OSHA
    Civil fines up to $165k willful, daily abatement
    FDA 21 CFR Part 11
    Warning letters, product holds, injunctions

    Frequently Asked Questions

    Common questions about OSHA and FDA 21 CFR Part 11

    OSHA FAQ

    FDA 21 CFR Part 11 FAQ

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