OSHA
US federal regulation assuring workplace safety standards
FDA 21 CFR Part 11
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.
OSHA
Occupational Safety and Health Act of 1970
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
FDA 21 CFR Part 11
21 CFR Part 11 Electronic Records; Electronic Signatures
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
| Aspect | OSHA | FDA 21 CFR Part 11 |
|---|---|---|
| Scope | Workplace safety, health hazards, recordkeeping | Electronic records, signatures trustworthiness |
| Industry | All general industry, construction, agriculture US | Pharma, devices, biologics, food safety US |
| Nature | Mandatory federal regulations, enforced inspections | Mandatory for electronic records, enforcement discretion |
| Testing | No system validation, compliance inspections | Risk-based system validation, IQ/OQ/PQ |
| Penalties | Civil fines up to $165k willful, daily abatement | Warning letters, product holds, injunctions |
Scope
Industry
Nature
Testing
Penalties
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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