Inspection readiness
Readiness is an assessment, not a permanent label
Section titled “Readiness is an assessment, not a permanent label”An active study can be ready for inspection today and develop new gaps tomorrow when another record becomes due, an external location becomes unavailable, or a quality finding is opened. “Inspection Ready” should therefore be a dated conclusion about a defined scope, not a permanent Study TMF status.
Completeness alone is not readiness. An inspection-ready scope must also be understandable, accurately indexed, timely, readable, accessible, protected, and supported by traceable history.
Inspection readiness assessment
Section titled “Inspection readiness assessment”| Field | Meaning |
|---|---|
| Assessment scope | Study, Country, Site, process, period, milestone, artifact group, or full TMF |
| Assessment date | Exact cut-off and time zone |
| Assessment reason | Routine, milestone, audit preparation, announced inspection, or for-cause |
| Filing Plan Revision | Approved instructions applied |
| Assessor and participants | Accountable persons and functions |
| Reference criteria | Approved readiness checklist or procedure version |
| Completeness evidence | Measure snapshot and detailed unresolved Filing Slots |
| Quality evidence | Open findings by severity, recent QC, systemic issues |
| Timeliness evidence | Late records and unresolved delays |
| Retrieval test | Search and retrieval cases, time taken, result |
| External-location test | Evidence that declared records remain directly retrievable |
| Access test | Confirmation of authorized, blinded, confidential, and read-only access |
| Audit-history test | Ability to reconstruct versions, corrections, filing, and decisions |
| Known limitations | Missing, unavailable, unreconciled, or poorly explained evidence |
| Conclusion | Ready, Ready with Declared Limitations, or Not Ready |
| Required actions | Owner, due date, and verification |
The conclusion is refused when the scope is vague, critical content is unassessed, or the evidence used cannot be reproduced.
Readiness questions in TMF language
Section titled “Readiness questions in TMF language”- Can the inspector locate all applicable essential records for the stated scope?
- Can the team explain why apparently missing records are Not Required or not yet due?
- Do the correct Document Versions show the sequence of approvals, amendments, implementation, and oversight?
- Can decisions and important communications be understood with their attachments and context?
- Are sponsor, investigator/institution, and service-provider records available under the correct control?
- Are unblinded, confidential, and directly identifying records protected while still retrievable by authorized people?
- Can changes to content, metadata, classification, and filing be reconstructed?
- Are source files, dynamic records, renditions, and certified copies usable and trustworthy?
- Are open findings, late records, approved Exception Decisions, and missing evidence visible rather than concealed by metrics?
- Can a person unfamiliar with the study understand the evidence without undocumented explanation?
Inspection request
Section titled “Inspection request”| Field | Meaning |
|---|---|
| Requesting authority or auditor | Who is requesting access |
| Legal or audit basis | Inspection, sponsor audit, due diligence, or other authorized purpose |
| Requested scope and period | Exact records, countries, sites, processes, and dates |
| Request and due times | Operational deadlines |
| Inspection contacts | Sponsor, TMF, quality, and technical coordinators |
| Clarifications | Questions, agreed interpretations, and scope changes |
| Status | Received, Clarifying, Preparing, Available, Closed |
Disclosed record set
Section titled “Disclosed record set”The records made available must be preserved as a defined set even while the active TMF continues to change.
Fields include:
- inspection request and scope;
- included TMF Documents and exact Document Versions;
- filing index and metadata as disclosed;
- included audit history;
- declared external records and retrieval route;
- excluded or redacted content and reason;
- generation time, checksum manifest, and preparer;
- later supplements or replacements with reason.
The disclosed record set is not a new authoritative TMF. It is evidence of what was provided at a specific time.
Controlled inspection access
Section titled “Controlled inspection access”Access is:
- read-only;
- limited to the agreed scope and time;
- restricted for blinding, participant privacy, legal privilege, and confidentiality;
- attributable to a named inspector, auditor, or authorized delegate;
- recorded with access time and materials viewed or exported where required;
- revoked when the approved period ends.
Providing access does not transfer record ownership. Sponsor personnel must not gain access to directly identifying investigator-controlled records merely because an inspection is underway.
Inspection during an active study
Section titled “Inspection during an active study”The eTMF must support continued controlled filing while preserving the disclosed record set.
- Establish the inspection cut-off and disclosed scope.
- Continue ordinary filing in the active TMF.
- Identify later records relevant to the requested period.
- Provide a governed supplement rather than silently changing the disclosed set.
- Retain the reason, preparer, time, and exact additional versions.
Findings and follow-up
Section titled “Findings and follow-up”Inspection observations are not automatically internal Quality Findings. A responsible quality role classifies each observation, links it to affected evidence, records the regulatory response, and creates correction or preventive work where appropriate. Closing the inspection request does not close unresolved TMF findings.
Required refusals
Section titled “Required refusals”- Refuse “Ready” when a Critical finding or inaccessible essential record remains unexplained.
- Refuse unrestricted or editable inspection access.
- Refuse silent removal or replacement of a disclosed Document Version.
- Refuse a readiness conclusion based only on a dashboard percentage.
- Refuse redaction that changes clinical meaning without visible explanation and retained source.
- Refuse to treat an inspection export as the new authoritative TMF.