Regulatory Compliance Guide

GLP, GMP & GXP:
The Record Keeping Rules Every Lab Must Know

Good Laboratory Practice, Good Manufacturing Practice, and the broader GXP family of regulations share one non-negotiable demand: that your data is trustworthy, your records are complete, and your processes are documented and defensible. This guide explains what each standard requires — and how CERF ELN helps your organization meet every one.

GLP · 21 CFR Part 58 GMP · 21 CFR Parts 210/211 OECD GLP Principles ALCOA-PLUS Data Integrity PKI Digital Signatures

GLP, GMP, GCP and GXP: What Each One Covers

The "Good Practice" regulations are a family of quality standards enforced by the FDA, OECD, EMA, and other global agencies. They share a common philosophy — that the quality of science can only be judged by the quality of its records — but apply to different activities along the drug and product development pipeline.

GLP Good Laboratory Practice

Governs non-clinical safety studies — how they are planned, performed, monitored, recorded, reported, and archived. Applies to studies submitted in support of regulatory marketing permits.

21 CFR Part 58 · OECD GLP Principles
CROs · Pharma pre-clinical · Agrochemical · Environmental

GMP Good Manufacturing Practice

Provides the framework for consistent production of pharmaceutical, food, and medical device products. Covers manufacturing premises, equipment, batch records, and quality control.

21 CFR Parts 210 & 211 · EU GMP · ICH Q7
Drug manufacturers · API producers · CMOs · Food & cosmetics

GCP Good Clinical Practice

International standard for design, conduct, recording, and reporting of clinical trials. Ensures participant rights are protected and clinical data is credible and accurate.

21 CFR Parts 50, 54, 56, 312 · ICH E6(R2)
Sponsors · CROs · Investigators · Site management

GXP The Umbrella Term

Collective shorthand for all "Good Practice" quality guidelines across pharma, biotech, medical device, and food industries. All GXP frameworks share common principles around documentation, traceability, and data integrity.

Underpinned by 21 CFR Part 11
Any organization across the product development lifecycle

The Key Requirements Your Organization Must Meet

While each GXP standard has its own specific regulations, they all converge on the same core principles for data management and record keeping. Here is what they require — and what CERF ELN provides to address each one.

1. Raw Data Integrity — Records Must Be Original, Accurate, and Unaltered

GLP (21 CFR 58.130) and GMP (21 CFR 211.68) both require that raw data be recorded directly, promptly, and legibly at the time of observation. Any correction must be made by drawing a single line through the original entry so that it remains legible, dated, signed, and accompanied by a reason for the change. Electronic systems must enforce equivalent controls — preventing backdating and ensuring no original entry can be obscured.

How CERF helps: In CERF, notebook entries use a compliant "strike out" function for corrections — the original text is visually crossed out and remains permanently visible, including on PDF copies. All edits are recorded in the immutable audit trail with the user's identity and a computer-generated timestamp. No backdating is possible. Documents must be checked out before editing, preventing simultaneous modification.
2. Audit Trail — Who Did What, When, and Why

21 CFR Part 11 §11.10(e) mandates secure, computer-generated, time-stamped audit trails that independently record all operator entries and actions that create, modify, or delete electronic records. The audit trail itself must be impossible to alter from within the system. Supervisors must be able to review audit trails readily, and they must be exportable for inspection.

How CERF helps: CERF maintains a complete, secure audit trail for all user actions. The trail is computer-generated, time-stamped, and cannot be modified or deleted from within CERF — even by a system administrator. Captured fields include: date and time, username, the resource modified (by name and type), the action taken, the reason where appropriate, and a full copy of the previous record content. The audit trail is exportable for regulatory inspection.
3. Version Control — All Versions Retained Permanently

GLP and GMP both require that all previous versions of records remain accessible. A regulatory inspector must be able to see the full evolution of a document — not just its current state. This is incompatible with file management systems that allow version histories to be purged, or word processors where files are simply overwritten.

How CERF helps: CERF's version control system retains all previous versions of every resource indefinitely. Documents must be checked out before modification and checked back in to create a new version; the previous version is preserved and can be viewed or printed at any time. Records placed in "Finalized" status are locked against further change. Even "deleted" or "inactivated" items remain searchable by administrators.
4. Controlled Documents & SOPs — Enforced, Versioned, and Acknowledged

GLP (21 CFR 58.81) and GMP (21 CFR 211.68) require that all laboratory operations be described by written SOPs, that personnel follow approved SOPs, and that superseded SOPs be archived and retrievable. For GLP, the Study Director must ensure all personnel are familiar with applicable SOPs before beginning work.

How CERF helps: CERF includes a dedicated Controlled Documents system supporting SOPs, Protocols, Assays, Business Contracts, NDAs, and Purchase Orders. When a controlled document is assigned to a user, CERF enforces a required review period before the user can mark it as accepted. Users who have not accepted the current SOP can be automatically blocked from signing notebook pages. CERF sends automated notifications when controlled documents are nearing expiry.
5. Digital Signatures — Legally Binding, Non-Repudiable, and Linked to Records

21 CFR Part 11 Subpart C governs electronic signatures used in GXP contexts. Signatures must be unique to each individual, non-transferable, and cryptographically linked to the signed record so that the signature cannot be excised, copied, or transferred to falsify a record. GLP additionally requires that study directors sign the final study report and that peer reviewers co-sign raw data entries.

How CERF helps: CERF is the only commercially available ELN that uses true PKI hashing via the U.S. federal Digital Signature Algorithm (DSA). Every notebook entry carries its own MD5 hash digest; any subsequent modification invalidates the hash. Signing requires three factors: a valid user session plus a separate digital signature password. Multi-step signature workflows are fully configurable: signing initiator → co-contributors → manager → legal/regulatory.
6. Access Control — Authorized Users Only, Enforced at Every Level

21 CFR Part 11 §11.10(d) and GLP/GMP regulations require that system access be limited to authorized individuals. Access controls must prevent unauthorized users from viewing, creating, modifying, or deleting records — and these controls must apply at the data level, not just the folder level. Even in search results, users must not see records they are not authorized to access.

How CERF helps: CERF's Workgroup system provides exceptionally granular, hierarchically delegated access control. Users are assigned to workgroups with specific roles (Read Only, Annotator, Editor, Notebook Editor, Manager) that determine exactly what actions they can perform. All permissions are enforced at the object level — a user without read access cannot see a record even in search results. CERF prevents simultaneous sessions from multiple workstations.
7. Long-Term Archiving — Records Retained for the Life of the Study

GLP regulations (21 CFR 58.195) require that raw data, protocols, final reports, specimens, and all documentation related to a study be retained for specified periods — which for many pharmaceutical submissions effectively means indefinitely. The archiving system must protect records from deterioration, accidental loss, and unauthorized access, and must allow retrieval at any time.

How CERF helps: CERF was designed from the ground up for ultra-long-term storage. Data is stored as native files in a secure file system — not compressed into a proprietary database format — meaning it will remain readable even if CERF software is discontinued. Available perpetual licenses mean that an installed CERF system continues to operate independently of ongoing vendor relationships, even on a sealed LAN with no internet connectivity.
8. Training & Personnel Records — Documented Competence

GLP (21 CFR 58.29) requires that the test facility have sufficient personnel with education, training, and experience necessary to perform their assigned functions. These qualifications must be documented, and personnel must be trained in the specific SOPs they are expected to follow before performing regulated work.

How CERF helps: CERF's Controlled Documents system maintains a complete, time-stamped record of every user's acknowledgment of each SOP — including the specific version acknowledged and the date. SOP placeholders on notebook templates enforce that a user must have reviewed and accepted the relevant current controlled document before a notebook page can be signed — making it impossible to sign off on work without the required training documentation being in place.

ALCOA-PLUS: The Nine Principles Behind All GXP Data Integrity

ALCOA (and its extended form, ALCOA-PLUS) is the foundational data integrity framework referenced by the FDA, WHO, EMA, and MHRA in their GMP and GLP guidance. It defines the essential attributes that all regulated records — paper or electronic — must possess. CERF ELN enforces all nine principles.

A
Attributable

It must be clear who collected or generated the data, and when

L
Legible

Records must be readable and understandable throughout their retention period

C
Contemporaneous

Data must be recorded at the time the activity is performed — not reconstructed later

O
Original

The first record of an observation — or a certified true copy — must be maintained

A
Accurate

Data must faithfully represent the activity performed, free from errors or omissions

+C
Complete

All data — including out-of-specification results — must be included; nothing omitted

+C
Consistent

Data must be recorded in a consistent sequence and chronological order

+E
Enduring

Records must last for as long as they are required — resistant to degradation

+A
Available

Records must be accessible for review and inspection throughout their retention period

How CERF ELN Enforces GXP Compliance — Feature by Feature

This table maps every major GXP compliance requirement to the specific, tested CERF capability that addresses it.

GXP / GLP / GMP Requirement CERF Feature How It Works
Raw data recorded directly, not reconstructed (GLP 58.130)Timestamped Notebook EntriesComputer-generated timestamps on all entries; no backdating possible
Changes visible; original not obscured (GLP 58.130, 21 CFR Part 11 11.10(e))Strike Out EntryStrikethrough displayed on screen and in all PDF prints; original always legible
Secure audit trail; all modifications recorded (21 CFR Part 11 11.10(e))Immutable Audit TrailComputer-generated, unalterable log of all user actions with timestamps and identities
All record versions retained permanentlyVersion Control (Check Out / Check In)All versions stored indefinitely; viewable and printable by authorized users at any time
Digital signatures unique, non-repudiable, linked to record (21 CFR Part 11 11.70)PKI Digital Signatures (DSA)MD5 hash + DSA private key; cryptographically linked; three-factor signing
Signature workflows for peer review and management approvalConfigurable Signature WorkflowsSubmitter → Peer Reviewer → Manager → Legal/Regulatory; co-signing with notifications
SOPs written, approved, distributed, and acknowledged (GLP 58.81)Controlled Documents SystemFull SOP lifecycle management; mandatory acknowledgment; expiry tracking and automated warnings
Work cannot be signed without applicable SOP in placeControlled Document PlaceholdersNotebook page templates require active SOP before signing is permitted
Personnel training documented before performing regulated workControlled Document Acceptance RecordsTimestamped acceptance logs per user per SOP version; exportable for inspection
Access limited to authorized individuals (21 CFR Part 11 11.10(d))Workgroup Role-Based Access ControlFive roles per workgroup; object-level permissions; search results filtered by access
Records available for regulatory inspection at all timesCERF Exporter + Official Printed CopyOn-demand bulk export as native files + XML; PDF generation with signature records
Long-term archiving; records retained for life of study (GLP 58.195)Ultra-Long-Term Storage ArchitectureNative file format storage; available perpetual license; sealed LAN capable; no cloud dependency
Instrument data captured promptly at time of generationCERF Automaton + Email-to-CERFAutomated ingestion of instrument data files; no manual transfer steps or chain-of-custody gaps
System validated for intended use (21 CFR Part 11 11.10(a))IQ / OQ Validation SupportLab-Ally and validation partners provide full IQ/OQ documentation and services

What Does "In the Spirit of GLP" Mean — and Why It Matters

"In the spirit of GLP" describes the voluntary adoption of GLP-quality data management practices by organizations not formally required to comply. It is increasingly common in academic research, early-stage biotech, and non-profit institutions that want to future-proof their data.

"Digital records should be collected and stored in a 21 CFR Part 11 compliant system if you want to eventually use your records as supporting evidence in any type of formal, legal, or regulatory proceeding, or if you want the records to be used in patent hearings, or other 'due diligence' / intellectual property verification events."

— Lab-Ally LLC, Resources Related to Compliance and 21 CFR Part 11

The standards that make GLP data legally defensible — audit trails, signed records, version control, SOP discipline — also make scientific data more credible, reproducible, and commercially valuable. Research that will never be submitted to the FDA can still benefit enormously from GLP-style record keeping if it might one day support a patent application, licensing negotiation, publication, or collaboration agreement.

🎓

Academic Labs

Pursuing technology licensing or spin-out companies. GLP-quality records become invaluable during technology transfer and IP verification.

🧪

Early-Stage Biotech

Drug discovery organizations pre-IND, and medical device companies in development stages where future regulatory submissions are anticipated.

🌿

Agrochemical & Environmental

Research organizations seeking NIH or federal grant funding where FAIR data compliance is increasingly required as a condition of funding.

⚖️

Legal, Financial & Engineering

Any organization managing high-stakes records that may be subject to due diligence review, litigation, or acquisition scrutiny benefits from CERF's audit infrastructure.

GLP, GMP, GXP and CERF: Common Questions

What is the difference between GLP, GMP, and GXP?
GLP (Good Laboratory Practice) governs the conduct of non-clinical safety studies — the data generated in labs before a drug or chemical enters human or clinical trials. GMP (Good Manufacturing Practice) governs the manufacturing of pharmaceutical, food, and medical device products — the production environment, batch records, equipment logs, and quality control systems. GXP is the umbrella term for all "Good Practice" frameworks, including GLP, GMP, and GCP (clinical trials). All of them require robust record keeping, audit trails, and data integrity practices, and all of them rely on 21 CFR Part 11 as the regulatory foundation for electronic records and signatures.
Does my academic or non-pharmaceutical lab need to follow GLP?
GLP compliance is a mandatory regulatory requirement only for organizations conducting non-clinical safety studies that will be submitted to the FDA or equivalent international regulators. However, many academic labs and non-pharmaceutical research organizations voluntarily adopt GLP-style record keeping — often described as working "in the spirit of GLP" — because the same practices that make data legally defensible for regulatory purposes also protect intellectual property, support patent applications, and make data more credible in licensing and partnership negotiations.
Can CERF be used for both GLP and GMP environments?
Yes. CERF provides the core compliance infrastructure required in both GLP and GMP regulated environments. The key requirements — audit trails, digital signatures linked to records, version control, SOP management, role-based access, and long-term archiving — are the same across both frameworks. CERF additionally supports IQ/OQ validation in situ, which is required before any electronic system can be considered validated for GLP or GMP use. Lab-Ally works with qualified third-party validation partners who can assist with the validation process.
What is ALCOA-PLUS and how does it relate to GLP and GMP?
ALCOA (Attributable, Legible, Contemporaneous, Original, Accurate) and its extended form ALCOA-PLUS (adding Complete, Consistent, Enduring, and Available) is the data integrity framework that underpins GMP and GLP regulatory expectations globally. The FDA, EMA, WHO, and MHRA all reference ALCOA principles in their data integrity guidance documents. ALCOA-PLUS is not itself a regulation — it is a framework that expresses what GMP and GLP regulations require of your data. CERF ELN enforces all nine ALCOA-PLUS principles through its combination of timestamped entries, immutable audit trails, version control, digital signatures, semantic metadata, and ultra-long-term archiving.
What does "validated in situ" mean for an ELN system?
Validation in situ means that a computer system is formally validated within the specific environment in which it will be used — on your specific hardware, with your specific configuration, users, and workflows. No ELN vendor can truthfully claim that their system is "21 CFR Part 11 validated" before it has been deployed and tested at your site. CERF is designed and built to be compatible with 21 CFR Part 11 and GLP requirements, but the validation itself must be conducted after deployment. Lab-Ally and its partner network can assist organizations with the IQ and OQ process required to formally validate CERF in your environment.
How does CERF handle errors or corrections to notebook entries in a GLP-compliant way?
GLP and GMP both require that corrections to raw data be made in a way that does not obscure the original entry — equivalent to drawing a single line through an error in a paper notebook and initialing the change. In CERF, this is handled by the "Strike Out Entry" function, which applies a visible strikethrough to the incorrect entry. The struck-out content remains fully visible on screen and appears with a red X overlay on any printed or PDF copy of the page. The correction is captured in the audit trail with the timestamp and user identity. The notebook page must be checked out before any entry can be struck out, creating a formal record of the correction event.

See How CERF Supports GLP, GMP & GXP Compliance

Talk to a CERF specialist about your organization's specific regulatory environment. We'll show you exactly how CERF addresses your compliance requirements — whether you're a fully GLP-regulated CRO, a pharmaceutical QA team, or a research lab working in the spirit of GLP.