| Retention rule | Ask for the written procedure that sets retention periods for records required under 21 CFR Part 111. | Records must be retained for 1 year beyond the shelf-life date, if a shelf-life date is established, or 2 years beyond the date of distribution of the last batch associated with the records. | Procedure identifies both retention pathways and explains how the applicable pathway is selected for each record set. | Preferred: a documented rule, assigned responsibility, and a controlled process for preventing early disposal. |
| Batch-to-record traceability | Trace a selected batch identifier across its production record, associated quality records, and distribution information. | Confirm that the retention calculation is tied to the batch or batches associated with each record. | Illustrative test: one batch identifier links to its production record and the distribution record used to establish the last-distribution date. | Preferred: consistent identifiers and a clear audit trail; investigate missing links or unexplained identifier changes. |
| Shelf-life dating pathway | For a product with an established shelf-life date, check that the date is identifiable in the relevant product and batch documentation. | Calculate retention to at least 1 year beyond the established shelf-life date. | Worked example: shelf-life date 2027-09-30; minimum retain-through date 2028-09-30. | Preferred: the retention system calculates from the applicable shelf-life date and flags records approaching disposal eligibility. |
| No established shelf-life date pathway | Where no shelf-life date is established, verify that the OEM can identify the distribution date of the last associated batch. | Calculate retention to at least 2 years beyond the date of distribution of the last batch associated with the records. | Worked example: last associated batch distributed 2026-04-15; minimum retain-through date 2028-04-15. | Preferred: distribution evidence supports the date used, and the record set is not assigned an earlier disposal date. |
| Record inventory and ownership | Request a record inventory showing record type, associated product or batch, storage location, retention trigger, and responsible role. | Check that the procedure covers the records required by Part 111 and applies the relevant 111.605 retention period. | Illustrative inventory fields: batch production record; associated batch; shelf-life or last-distribution trigger; calculated retain-through date; record custodian. | Preferred: complete inventory with a named role accountable for retention and retrieval. |
| Storage, retrieval, and legibility | Ask the OEM to retrieve a sample batch record and associated documentation from its normal storage system. | Retention is useful only if retained records can be located and read. Also review applicable record-maintenance requirements, including 21 CFR 111.610. | Illustrative test: retrieve one selected record set by batch identifier and confirm pages or electronic files are legible and complete. | Preferred: retrieval is prompt, controlled, and documented; investigate inaccessible files or unreadable scans. |
| Electronic records and backups | For electronic records, review access controls, backup and recovery arrangements, change history where applicable, and migration procedures. | Confirm records remain available and retrievable throughout the applicable retention period; assess relevant requirements under 21 CFR 111.610. | Illustrative evidence: controlled user access, tested recovery process, and a documented method for preserving records during system changes. | Preferred: documented controls and evidence of periodic testing, rather than reliance on informal file storage. |
| Disposal controls | Review the procedure for authorizing record destruction and preventing disposal before the applicable retention period ends. | Check that disposal timing is calculated from the correct trigger and that holds or other applicable requirements are considered before destruction. | Illustrative control: a disposal list shows the record set, calculated retain-through date, review, and authorization before destruction. | Preferred: documented approval and a traceable disposal log; investigate automatic deletion without a retention review. |