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COMPUTER QUALIFICATION.


Computer qualification customer city skylines. this one is Quebec.


Computer Qualification Rationale.

Validation Online's GMP compliant computer qualification validation (CSQ) documentation and protocols start with our unique three level User Requirements Specification document (URS). Since most documents, post the URS, will either fully, or partially, base their contents on the URS, it is essential that this document clearly, concisely and in a manner that is testable, specifies the exact requirements of the end user. It is also essential that these exact testable requirements remain attributable through the development of the Functional Specification (FS) Design Specification (DS) to the actual lines or groups of lines of code that enable them.

The Validation Master Plan - VMP, must be specific about this and all cGMP requirements, and instruct all personnel involved in the computer qualification program, of the importance of maintaining this traceability through the Installation Qualification - IQ - Operational Qualification - OQ - Performance Qualification - PQ.
Traceabilty of URS functionality, to lines of code is an essential element in computer qualification. Once this traceability is establish future maintenance and modification of software is made much simpler and more manageable.


Computer Qualification and GAMP.

This graphic is of a Pen symbolizing documentation rules.

The guide-lines laid out in Good Automated Manufacturing Practices  GAMP 5, for the validation of automated systems including automatic computerized manufacturing equipment, control systems, automated laboratory systems, manufacturing execution systems and computers running laboratory or database systems. These computerized system generally consists of the hardware, software and network components, together with all control functions and GAMP 5 is a useful guide in scoping your validation activities for such systems.  It must be remembered at all times that GAMP is collective ideas from the industry and does try to be all things to all people.

Which at times means certain sections can appear to contradict other sections.  On a recent project when a group was set up to develop a Risk Assessment (RA) document from GAMP 5, after four weeks they were still divided and unable to reconcile their company's requirements with the alternative stratigies given in GAMP.  It bodes well to never forget that GAMP 5 is a guide from the end users point of view.  The actual legal requirements come from the regulators, and obviously takes precedence.  Validation Online's computer qualification protocols start with the development of a detailed three layer URS and progress through the VMP - IQ - OQ - PQ.  Each of these documents are interactive fully detailed and simple to use.  Each are preceded with an SOP which guides the user through all phases of protocol generation completion.


The verification that the end users requirements as detailed in the URS have been fully satisfied, is paramount to the equipment being correctly qualified.  Often this is hard to verify since the traceability from URS functionality to the actual hardware or software utilized is lost in the various spefication designations that range from the functional specification to the design specification to code requirements.  However unless the effort is made to maintain this traceability, validation is flawed and future maintenance and or modifications can become extremely problematic.

The Validation Master Plan -  VMP, must be specific about this requirement and instruct all personnel involved in the qualification program, of the importance of maintaining this traceability.


Qualification Tests and Interpretations.

Dynamic Testing.

Dynamic testing verifies the execution flow of software, including decision paths , inputs, and outputs. Dynamic testing involves creating test cases, test vectors and oracles, and executing the software against these tests. The results are then compared with expected or known correct behavior of the software.  Because the number of execution paths and conditions increases exponentially with the number of lines of code, testing for all possible execution traces and conditions for the software is impossible.

Static Analysis.  

Code inspections and testing can reduce coding errors; however, experience has shown that the process needs to be complemented with other methods . One such method is static analysis. This somewhat new method largely automates the software verification process.  The technique attempts to identify errors in the code, but does not necessarily prove their absence.  Static analysis is used to identify potential and actual defects in source code.

Abstract Interpretation Verification.

A code verification solution that includes abstract interpretation can be instrumental in assuring software safety and a good quality process. It is a sound verification process that enables the achievement of high integrity in embedded devices. Regulatory bodies such as the pharmaceutical regulators.

Revalidation Scheduled.

There is no regulatory requirement to re-validate a process as long as that process operates in a state of GMP control and no changes have been made to the process or output product, the process does not have to be revalidated. Whether the process is operating in a state of control is determined by analyzing day-to-day process control data and any finished device testing data for conformance with specifications and for variability.

Revalidation on Relocation.

When equipment is moved to a new location, installation and operation should be re-qualified. By comparing data from the original installation and operation qualification (IQ and OQ) and the re-qualification , the manufacturer can determine whether there have been any changes in equipment  performance  as a result of the move. Changes in equipment performance should be evaluated to determine whether it is necessary to revalidate the process.

 Revalidation Justification.

Part 820.75  of the QS regulation requires that validated processes be monitored and controlled so that when changes or process deviations occur, a manufacturer will know to review and evaluate the process and perform revalidation when appropriate.  21 CFR 820.75(c ) requires you to have documented procedures in place for evaluating; when revalidation is required.

Procurement and Validation.

Recent research has highlighted that in the pharmaceutical and bio-medical industry, thirty two percent of all equipment procurements are unsatisfactory.  The major problem has been identified as companies not specifying in sufficient detail and or accuracy, what their  actual needs are.  The lack of a quality company approved User Requirements Specification (URS) , leads to many companies having to resort to otherwise un-necessary and costly retrospective  actions in modifying the equipment or producing unspecified documentation or engineering drawings, post procurement.  These extraneous GMP requirements often cost more than the equipment.

This graphic is a schematic of document inter-relationships for computer qualifcation.ow.


VIEW COMPUTER QUALIFICATION DOCUMENTS AVAILABLE.

Computer Qualification User Requirements.

The Software User Requirements Specification (SURS) document should contain a written definition of the software functions. This must define the functionallity that the end user requires from the system.  These requirements must be set out in a manner that is none ambiguous, clear and easy to understand. Further to this the requirements must be grouped or worded in a manner that renders them testable and verifiable. It is not possible for computer qualification to be properly executed without having predetermined and documented software strong requirements to validate against. Typical software requirements specify the following:

a)         All software system inputs ;

b)         All software system outputs;

c)         All functions that the software system will perform;

d)        All performance requirements that the software will meet, (e.g., data throughput, reliability, and timing);

e)         The definition of all external and user interfaces, as well as any internal software-to-system interfaces;

f)          How users will interact with the system;

g)         What constitutes an error and how errors should be handled ;

h)         Required response times;

i)           The intended operating environment for the software, if this is a design constraint (e.g., hardware platform, operating system);

j)           All ranges, limits, defaults, and specific values that the software will accept;

k)         All safety related requirements , specifications, features, or functions that will be implemented in software .

l)           The degree to which the  manufacturer is dependent upon that software or equipment for production of a their product.


GAMP 5 Software Categories.

Gamp Class

Category

Validation Scope

1

Operating Systems

Record Version

2

Measuring Devices (Embedded Software).

Record Configuration & calibration

3

Configurable Packages

Review supplier & validate functionality and any bespoke code.

4

Large Configurable Systems

Audit supplier, validate system functionality and review code IAW full life cycle requirements.

5

Systems Specifically written for Owner.

Audit supplier, validate all code IAW full life-cycle requirements.


Computer Qualification Sope (CSV).

Computer Validation (CSV), must include the under listed tests / inspections, but is not limited to them alone. The inclusion of the 21 CFR Part 11, Applicability is deliberate. This allows the executor of the computer qualification protocols to clear this requirement by cross referencing the risk assessment reference number and stating Yes or No, to the applicability question. The regulator now does not have to search further, he can see that requirements for 21 CFR Part 11 have been considered and judged.

a)        Introduction.

b)        Scope.

c)         Software Verification.

d)        Hardware Verification.

e)        Testing Personnel CV & Details Sheet.

f)         21 21 CFR Applicability.

g)       

h)        Menu Navigation.

i)           Operating Environment.

j)          System Security (physical/access to data).

k)        Power Failure Recovery.

l)           Test Alarms.

m)      System Stress Testing / Boundary Test.

n)        Interface Signals.

o)        Menu Navigation.

p)        21 21 CFR Part 11 Conformance.

q)        Functionality tests.

There is a degree of flexibility in deciding precisely at what stage in the validation process some of these test and inspections are executed. Where this flexibility exists the choice between the IQ or OQ or PQ, must be rationalized and documented in the validation master plan (VMP) or the validation plan (VP).


Automated processes:  When computers or automated computerized data processing systems are used in any way which can affect the quality, efficacy or regulatory records of a regulated product or process, the manufacturer must carryout computer qualification of the software and hardware that make up the system. Post computer qualification; proposed software and or computer changes must be approved prior to installation, and the validation status re-established post installation. These activities must be adequately documented.


Computerized System Design & Testing

In the diagram below it can readily be seen that the URS , along with the regulatory requirements as detailed in GAMP 5 , and the details of computer qualification requirements as given in the VMP, come together to form a document package consisting of the DQ, IQ, OQ and PQ from which the vendor can develop a fully legal and compliant product.  Computer qualification activities are grouped in two colours (orange and blue).  The blue colour is the requirement for standard computer qualification.

 

The regulators have decreed that software used in a manner that can affect the quality of the product, without leaving visible evidence, that damaged has occurred, must be deemed as critical to the quality of that product.

 

The regulators have further mandated that all such software be identified as such - and subjected from concept to actual use, to Full Life Cycle Validation (FLCV) requirements.  This additional validation is represent in the diagram in orange.

 

The vendor therefore (be they in, or out, of house), must produce a Quality Plan that ensures the software development will follow a validation evolution similar to that shown in the diagram.  Your actual diagram must be planned and justified for the software system that you are proposing.

 

It is of paramount importance that your decision on software criticality is documented, and that your QP is reviewed and approved by QA, and the client or their  representative, prior to initiation of the design process.  Since these documents all form part of the computer qualification process, you must expect the regulators to want to review them. 

 

Graphic block display of the validation validation document system.


COMPUTER SYSTEM QUALIFICATION




Computer Combined IQ-OQ-PQ (Issue 3) -- $159.00

This combination protocol has been produced in response to several hundred reader suggestions we received in our ‘Suggestions Section’. It has been carefully designed to make it the preferred choice for Process and Laboratory stand-alone equipment. It is interactive, easy to use and suitable for all mixes of equipment with and without software.

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Computer User Requirements Specification (Issue 5.) -- $115.00

The document that sets the standard, and specifies your computer requirements in a manner that ensures when a system or piece of equipment is selected, it will deliver the functions you want, it will have maintenance standards, it will have calibration records, it will have all the documents and records to enable successful validation to be completed. This document was designed to be used as a live document up until the DQ is completed and approved.

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Computer Validation Master Plan (Issue 5.) -- $115.00

The Computer Validation Master Plan, is the starting point for validation, and hence the most important validation document. It improves validation efficiency greatly by forcing all concerned to document, review, and discuss, the proposed methods and allotted responsibilities. It is an expected document with the FDA, and a mandated document with the EU.

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Computer Validation Package 1. (Issue1) -- $675.00

This computer validation is suitable for all major validation projects and contains the under-listed interactive documents. VMP, VP, URS, VRA, DQ, IQ, OQ and PQ.

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Computer Validation Package 2. (Issue 3.) -- $580.00

The complete chain of regulatory required documentation; for the validation of a computer system, minus the VMP. This Validation Package contains one of each of these documents: VP, URS, DQ, VRA, IQ, OQ, PQ.

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Computer Vendor Audit (Issue 3.) -- $87.00

This Computer Vendor Audit document should be customised using the built in tools. The document can then be targeted to reflect your project priorities. The fifteen chapters all contain 10 questions, the total scored is then weighted to reflect your priorities. By assessing the importance of each of the chapter subjects in your project, the weighting is altered taking points from one and adding to others. This enables your assessment to be expressed simple and clearly as a percentage, allowing clear unambiguous comparisons to be presented for competing companies.

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CSV Design Qualification (Issue 3.) -- $89.00

The Standard Operating Procedure attached to this generic computer design qualification protocol, will chapter by chapter take you through the task of raising a fully detailed protocol. The main body is split into fourteen tables, each one probing the computer design requirements and standards for the individual requirement. Practically all the requirements are in table form. Allowing fast and clearly presented results to be obtained.

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CSV Installation Qualification (Issue 6.) -- $89.00

 Computer Installation Qualification (CIQ) is an important step in the overall validation and qualification process for software and computer systems. Our protocol leads you through the detailed requirements.

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CSV Operational Qualification (Issue 6.) -- $89.00

Operational Qualification (OQ) is an important step in the overall validation and qualification process for software and computer systems. Our protocol leads you through the detailed requirements, progressively and simply.

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CSV Validation Plan (Issue 3.) -- $89.00

This document follows Validation Online's standard method of using a fully detailed and interactive generic document and enabling to use the attached SOP to quickly convert this generic document into a first class company bespoke document. This CSV VP details and integrates all validation activities and procedures required for a small to medium sized project, involving production/facility/utility equipment using electronic controls or monitoring.

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Computer Performance Qualification (Issue 7.) -- $87.00

The Computer Performance Qualification is the culmination of the validation process. The protocol is used in conjunction with the system operating SOP, to verify that the system process is consistent and correct. The results of the testing must be recorder and reviewed with a view to ensuring that the deviancies (within permitted tolerances) that exist are random and not a trend that will lead to out of specification operation during production use.

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