>The regulation is an FDA regulation, so it only applies to records required
>by another FDA regulation, which primarily applies to drug manufactures,
>device manufacturers, etc.

In reality, this does not limit the regulation very much at all. 
Most academic centers want very much to participate in clinical 
trials of new drugs, for example, an area where the reg clearly 
applies.  I do not believe they would want to have *two* record 
keeping systems in place: one for regular use one for clinical 
trials.  I think that the reality is WYSIWYG.

John

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