Regaldi Notes

Notes from a regulated practice.

Short explainers on the frameworks pharmacy software runs under, written the way the practice reads them: the provision first, the mechanism second, no slogans. Each note states what the law requires, where operations actually fail it, and what software can and cannot carry.

21 CFR Part 211

What an electronic batch record must hold under 21 CFR 211.188

The thirteen things a batch record must document for a 503B facility, the master record it points back to, the investigation it must contain, where Part 11 governs the signatures, and why a skipped step cannot be an available action.

September 7, 2026 · read the note →
DEA recordkeeping

Controlled-substance reconciliation in a compounding pharmacy: what 21 CFR 1304 requires

Initial and biennial inventory, exact count versus estimate, records of receipt and disposal, Form 222, two-year retention, theft or loss within one business day. And what a software reconciliation must do to make the arithmetic close.

September 7, 2026 · read the note →
Method

A public-records dossier in one afternoon

A consumer billing dispute, worked registry by registry: a licensing gap found, a complaint pattern established, and a statute-cited demand letter drafted before evening. Every document under a human signature.

August 13, 2026 · read the note →
Regulatory frameworks

503A vs 503B: what changes for the software

The line between a compounding pharmacy and an outsourcing facility runs through the data model: prescriptions vs batches, state boards vs cGMP, dispensing records vs electronic batch records.

June 11, 2026 · read the note →
21 CFR Part 11

What Part 11 actually requires of an audit trail

One sentence of regulation, read closely: secure, computer-generated, time-stamped, never obscuring a prior entry. And the four questions that separate a real trail from slideware.

June 11, 2026 · read the note →
Sterile compounding

USP <797> documentation: where errors actually happen

Garbing records, environmental logs, Beyond-Use Dates, the second check. The same structural failure in different clothes, and what a system can prevent by construction.

June 11, 2026 · read the note →
Computerized system validation

GAMP 5 Category 5: validating custom-built pharmacy software

What the deep end of the validation framework obliges a vendor to produce, and the difference between a package that is authored and one that is executed.

June 11, 2026 · read the note →
Privacy and consent

HIPAA and call recording in a pharmacy

Three bodies of law on one phone line: the recording as PHI, state two-party consent, and the TCPA on the outbound side. What the software must provide, and what stays with the covered entity.

June 11, 2026 · read the note →

Say where you work. Ita reads it before she says hello.

AI assistant Ita is software. A principal reads the transcript afterwards.