Skip to content
ValiTracAI

Data integrity for temperature records: ALCOA+ in practice

Temperature records are GxP records. Attributable, legible, contemporaneous, original and accurate — plus complete, consistent, enduring and available.

GDP / GMPValiTrac AI editorialUpdated 2026-10-093 min read

Regulators expect temperature monitoring and mapping data to meet the same data-integrity principles as any other GxP record. PIC/S guidance summarises them as ALCOA+: attributable, legible, contemporaneous, original, accurate, complete, consistent, enduring and available.

Applied to loggers and monitoring systems

  • Attributable: which logger, which location, who downloaded it, who reviewed it.
  • Original: the raw export retained unchanged; derived analyses stored separately with their inputs.
  • Accurate: calibration status and uncertainty known; unit confirmed.
  • Complete: gaps and exclusions visible, not silently dropped.
  • Enduring and available: retained for the defined period in a readable format.

Software that computes statistics from logger data should preserve the input dataset, record the version of the calculation, and keep an audit trail of review actions — which is how ValiTrac's mapping engine is structured.

ALCOA+ applied to a temperature record
PrincipleFor logger and monitoring dataHow it fails
AttributableWhich logger, which position, who downloaded it, who reviewed itA shared login, so every audit entry names the same account
LegibleReadable now and in five years, in an open formatA proprietary export whose software no longer runs
ContemporaneousRecorded as it happened, with a synchronised clockA logger whose clock was never set, or a review written up a fortnight later
OriginalThe raw export kept unchanged; analyses stored separately with their inputsA spreadsheet edited in place, with no evidence anything was ever different
AccurateCalibrated sensors, correct units, verified calculationsA unit inferred from the magnitude of the numbers
CompleteEvery reading, including the ones that failed and the gapsA dataset quietly cleaned before the statistics ran
ConsistentChronological, with timestamps that agree across systemsSensors and alarms on different clocks, so events cannot be ordered
EnduringRetained for the defined period, readable throughoutAn archive nobody has tried to read since the migration
AvailableRetrievable on request, for the whole periodData on a laptop that left with an employee
ALCOA+ applied to a temperature record

The two that fail most often

Original and Complete carry most of the real risk, and they fail together. A mapping dataset with a flat-lined sensor quietly removed before analysis is neither original nor complete, and the resulting report is internally consistent, plausible and unverifiable. The control is not a policy against editing; it is keeping the raw export unchanged, recording every exclusion with its reason and range, and storing the analysis separately with a pointer to its inputs.

Attributable fails almost as often, and more cheaply. A shared login makes an audit trail worthless because every entry names the same account, and it is free to fix — which is why it is such a poor finding to receive.

What software has to do

  • Preserve the input dataset unchanged, and store derived analyses separately with a reference to the exact input they used.
  • Record the version of the calculation code alongside every result, so a result can be tied to the code that produced it. A fixed bug in an excursion calculation immediately raises a question about every report from the previous version.
  • Keep an audit trail of review and approval actions, with user, timestamp and outcome, that cannot be disabled or silently edited.
  • Require the unit to be declared rather than inferred, and refuse the file rather than guess. Inferring °C from the magnitude of the numbers is how confident nonsense gets produced.
  • Synchronise to one time source, and record the time zone. Cross-system ordering is impossible otherwise.

The practical reason spreadsheets are hard to defend here is Original: a cell corrected in place leaves no evidence it was ever different, and a range that silently stopped one row short of the data produces a confident, wrong mean.

Frequently asked questions

Is a screenshot of a logger graph an acceptable record?
Not on its own. The underlying data export is the original record; a screenshot is a derived, non-verifiable representation.

References

  1. [1]PIC/S PI 041-1: Good Practices for Data Management and Integrity in Regulated GMP/GDP Environments (2021)
  2. [2]EudraLex Volume 4, Annex 11: Computerised Systems

General technical guidance written against the cited sources. It is not regulatory or legal advice and does not replace the applicable standard, guideline or a qualified reviewer's judgement.

Related articles