FDA Spreadsheet Comments
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FDA
Spreadsheet Comments.
·
Nearly all of the spreadsheets in the laboratory showed
rounding-off errors and none used the Excel rounding function, when needed to
avoid rounding-off discrepancies between the original and check calculations by
the second analyst.
·
Formulas in the analytical procedures did not follow the Excel
equations.
·
Conversion factors were not expressed in the analytical
procedures.
·
The formulas used by the check analyst for manual calculations
were not the same as those used in the Excel spreadsheet validation.
·
The pre-determined specifications or limits were not shown in the
spreadsheets.
·
Spreadsheets were not clearly documented. For example, the product
declaration was not indicated, replaced by only a number in a cell.
·
Units were expressed as numbers without descriptive labels such as
mg/mL or mg/g.
·
Sample weights were described as sample volume and areas as
ratios.
·
Spreadsheets did not contain provisions for security and integrity
of data.
·
Spreadsheet applications were not protected from changes, meaning
analysts could freely change labels and formulas.
·
Regression analysis was calculated with the y and x axis inverted
in the Excel formula, which generated erroneous slope and intercept results.
“Trust but Verify “ Ronald Reagan
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