EU GMP Annex 11, 21 CFR Part 11, ALCOA+

Data integrity is
a chain, not a field

ALCOA+ asks whether a record is attributable, contemporaneous and traceable to its origin. In practice that question is asked about one value, and answering it means walking backwards through batch records, deviations, change control and validation documentation.

The question it comes down to

"This result was released. Show me the chain from the raw value to the release decision."

The raw value sits in an instrument record, the correction in a deviation report, the justification in a CAPA, and the authority to release in an SOP whose current version is two revisions newer than the batch.

Why ordinary search does not get there

The chain crosses systems that were never joined.

LIMS, MES, document management and paper archives each hold one link. The chain exists conceptually and nowhere physically.

Versions matter more than content.

Which SOP version applied on the day of manufacture is often the whole question. An answer that ignores versioning is worse than no answer.

An inspector asks about one batch, not about the process.

General process descriptions do not answer specific questions, and the specific answer has to be reconstructed under time pressure.

A worked example

The query

What is the basis for releasing batch 2026-0417?

  1. 01
    Analytical record

    Holds the raw value and the instrument identity.

  2. 02
    Deviation report DEV-2026-088

    Documents the out-of-trend observation and its investigation.

  3. 03
    CAPA-2026-031

    Records the corrective action and the effectiveness check.

  4. 04
    SOP QA-07, revision 4

    The revision in force on the manufacturing date, defining release authority.

The answer

A release chain with four cited links and the SOP revision that actually applied at the time, rather than the current one.

What ARGUS does here

Version-correct answers

Where several revisions are indexed, answers name the revision they relied on — the difference between a usable answer and an inspection finding.

Cross-system reasoning

Batch documentation, deviations, CAPAs and SOPs are reasoned over together, not searched one system at a time.

No invented links

Where the chain breaks, the break is the output. The system does not bridge a missing link with plausible language.

Validated environment friendly

Deployment on your infrastructure, deterministic retrieval settings, and a full trace per query for qualification purposes.

What it does not do

Stated here rather than discovered in week three of a pilot.

  • ARGUS is not a validated GxP system out of the box. Validation is performed by you, for your intended use, in your environment.
  • It does not write to your LIMS, MES or eQMS — it reads and reasons.
  • It does not make release decisions and holds no signature authority.
  • Built and demonstrated scenarios; no production installations in a regulated manufacturing environment to date.

Questions we get asked

How do you handle qualification?+
Retrieval and reasoning settings are configurable and recorded, and every query produces a complete trace. That trace is the artefact your qualification documentation is built on. We support the exercise; we do not certify it.
Is anything sent to a model provider?+
Only if you choose an external model. With a locally hosted model nothing leaves your network. Either way, documents are never used for training — that is enforced architecturally.
Can it work on paper archives?+
With OCR, yes — that is often where the oldest and most contested records are. Low-confidence extractions are flagged, not silently accepted.

Test it on a question you already lost time on

Bring one question your own documents should be able to answer, and the documents that ought to contain the answer. If the evidence is not there, that is the result — and it is worth knowing before an auditor finds it.