FDA GMP PART 11.



FDA GMP Part 11 Downloadable Packages & Protocols.

This schematic is a graphic presentation of  FDA GMP PART 11 requirements.

Just what does FDA GMP PART 11 requirements apply to: It has become obvious to all persons who use any IT facility; that electronic data is extremely easy and simple to manipulate or corrupt, either knowingly or unknowingly. The regulation protects predicate rule information from such corruption, and is designed and enforced to give assurance of the integrity of all such data.

Validation protocols such as DQ, IQ, OQ, PQ, along with the associated VMP, URS, VRA, and VP can be prepared electronically, however they are completed by hand and are manually signed and reviewed, and as such; are not required to comply with FDA GMP Part 11 procedures.

Full Life Cycle validation (FLCV), including FDA GMP Part 11 requirements are portrayed visually in the diagram below. In this diagram the standard requirements are shown in BLUE boxes whereas the additional requirements for Full Life Cycle Validation (FLCV) are shown in ORANGE boxes. This layout is not definitive, and reasoned alternatives work just as well. The whole concept is that the software design must be planned, managed, and subjected to documented reviews throughout the entire design stage. All of this must be laid out in the QUALITY PLAN (QP), which must be a peer reviewed and company approved document. Without a QP being in place, it is almost impossible to achieve satisfactory FLCV. If these requirements are rigorously applied, it becomes impossible to achieve retrospectively, and inhibits the use of commercial off the shelf software (COTS). We know that some COTS software has, and is, used in a number of Product Quality Critical (PQC) software systems. The judgment whether a COTS system can or cannot be used is fraught.



On the 21st of October 2005 the US Federal Court decision against FDA in the Utah Medical case. Once and for all affirmed (among other things) that FDA may not adopt "industry standards" as "current" Good Manufacturing Practices (cGMP's) by fiat or Guidance. In order to be an action-able item, the any practice or procedure must be specifically mandated within CFR's.......Actual Court Case.


FDA GMP PART 11 Requirements and FLCV

This graphic is a schematic of the inter-relationships of validation documentation used for FDA GMP PART 11 Requirements qualification..

How do you adapt procedures and processes for www.21cfrpart11.com?

One of three approaches can be used by organizations to address the on-going FDA GMP PART 11 requirements regulations throughout the pharmaceutical and medical devices industries.

Paper.
The full FDA GMP Part 11 regulation still permits the full submission of paper-based documentation. The issues with this approach include high costs, decreased quality, information storage availability, information retrieval ability, and the general portability of information.

Partial Electronic.

The regulation allows for the electronic records to be stored as equivalent to paper records with handmade signatures executed. This approach requires a large amount of printed documentation that carries the same risks and challenges as a full-paper approach; mentioned above, regarding complacency with the regulations

Electronic.
This is the real intent of the FDA GMP PART 11 requirements regulatory requirements. This approach increases product quality, saves money with automation of processes, establishes easy data storage and retrieval, provides ease data analysis and reporting, increases the portability of information, and diminishes or eliminates human error.


Defined FDA-21-CFR-Part-11-requirements.

This graphic represent weight of opinion for fda 21 CFR Part 11 requirements.

What content will be in the new FDA GMP PART 11 requirement? Most end users feel that it will be patterned after the ‘Scope and application’ document, though with more emphasis on ‘how’ compliance can be achieved, and less on ‘what’ requirements must be satisfied.

FDA will more than likely defer to the predicate rules on most matters. And it will make significant concessions on having an audit trail for all systems. “Likely, they will simply remove the section in the current FDA GMP PART 11 requirements requirements for the audit trail,”

At a minimum, manufacturers might have to have a risk matrix for their computer systems. This includes an understanding of how systems impact risk to patients, and regulatory risk.

The full requirements as detailed in the current FDA GMP PART 11 will more than likely still be a requirement for data produced by electronic manufacturing controls for high-risk systems — such as quality controls for the release or rejection of product. These will still require you to have to have a validated system and ensure an audible backup.

Define the criticality of each record and, even more important, look at the entire life of a record from its origin to archiving. Identify steps where adulteration is possible and make sure these systems have an electronic audit trail built in.


FDA GMP Part 11.



Validation Risk Assessment (Issue 11) $125.00

Validation Risk Assessment template (Issue 11) $125.00 The Risk and Part 11 Validation Risk Assessment(VRA) protocol is becoming the most important document in the validation train. The VRA reassures the regulators that you have looked at specific equipment functionality and considered the appropriate level of validation that is required. You have also considered various aspects of its use and the implications of any malfunctions. From the results of this exercise the scope of all validation activity can and must be justified. This is a robust and simple to execute document, one that will lead you through the process and deliver a result that can be used as the foundation for your validation risk assessment template.

This VRA now includes the assessment table for categorizing and documenting the new 21 CFR Part 11 guidance ruling on what predicate data must be stored in a Part compliant system, along with the new broadsheet to establish your new database of part 11 records. (now mandatory).



Combined IQ-OQ-PQ Computer (Issue-4) $159.00

This Pharmaceutical Validation 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 and associated standard operating procedure TEMPLATE. The associated medical device validation  Master Plan template is interactive, easy to use and suitable for all mixes of equipment with and without software. Where temperature mapping is required it will included in this section. This of course may well be a validation risk Assessment template. As per 21 CFR Part 11.

The Installation Qualification Template or IQ section establishes documented verification that all medical device validation template online executables are catered for and that key aspects of the equipment Qualification adhere to approved design Qualification template and the recommendations of the manufacturer have been suitably considered. The Operational Qualification Template section establishes that there is documented verification that the installed system functions as specified and that there is sufficient documented process validation A executables to demonstrate this. The PQ section develops documented evidence that all the requirements specified in your corporate validation 4U manual have been verified as operating consistently and exactly as specified in the medical device validation template; The User Requirements Specification template 



User Requirements Specification (Issue 8) $115.00

This document was designed to be used as a live document up until the DQ is completed and approved. It uses three levels of URS, URS Level 1, 2 and 3, and is the only URS to guarantee traceability from the User requirements specification template through to the final PQ and OQ functionality testing. A mandatory requirement for Full Life Cycle Validation of computer systems and compliance with Current Good Manufacturing Practice legislation. It can be used on mechanical, electrical and software controlled, monitored or driven systems and of course medical device validatioN Template along with the Software Qualification template.



Installation Qualification. SOP & Protocol (Issue 9.) $115.00 10000020

The Standard Operating Procedure template (SOP) used to generate this installation Qualification template (IQ), takes you through the process line by line, chapter by chapter. It really is unique to find a SOP document so easy to use, all the work is done for you. All the documents are detailed, all the drawings listed and all the checks and tests detailed. The final product is a professional and comprehensive Installation Qualification template. One that you can produce in less than 60 minutes. Yes, think about it, we all know how long producing IQ documents has taken in the past, whether for current Good Manufacturing Practice use medical device use or a simple installation qualification template. 



Operational Qualification, SOP & Protocol (Issue 10.) $115.00 

You will find the Operational Qualification template (OQ) delightfully simple and straightforward to use, as it takes you through the process of customization of your Operational Qualification Protocol template. Following the attached SOP will quickly and smoothly convert your template into an equipment specific 21 CFR Part 11 compliant Installation  Qualification Template. The OQ template comes complete with all the standard test scripts, more specialist test scripts can be found listed below. These can easily be pasted into the standard OQ, allowing you to quickly build your own fully detailed and referenced company bespoke Operational Qualification Protocol, along with the installation qualification template.




Combined IQ/OQ/PQ for Spreadsheets. (issue-2) $159.00

This combination protocol has been specifically designed to verify that all aspects of your spreadsheet conform to best practice and that the spreadsheet layout ensures consistent and accurate use and results. The tests and inspections normally authored in separate protocols have been assembled in one protocol which is divided into three sections. This protocol enables you to verify that your developed spreadsheet application is GMP compliant, thus avoiding 483s and warning letters. You can now validate your application with minimal documentation. Equipment Validation Protocol, validation protocol template.



Design Qualification (Issue 5) -- $115.00

The Standard Operating Procedure attached to this generic design Performance qualification Template, will chapter by chapter, take you through the task of raising a fully detailed document. The main body is split into fourteen tables, each one probing the design requirements and standards for the individual requirement. Safety and security along with user operability are very detailed. The document will lead you through all these design aspects allowing you to delete some you feel are not important to your equipment. It is an easy document to use and will ensure that you’re DQ’s are relevant, up to date and easy to execute. Practically all the requirements are in table form. Allowing fast and clearly presented results to be obtained



VrrP_Equipment
Issue - 4. 

This Validation Risk & Requirements Plan (VrrP) is one document designed specifically to replace three. The contents of the three original documents were completely revised and edited into a more compact and interactive format.  Resulting in the document becoming notably easier to use and quicker to review and amend.  This new format will make a very significant difference to the man hours required to produce and execute these documents.  There will also be a very noticeable reduction in the time required for the reviewing and approving tasks.  This new document titled the VrrP replaces the VP, VRA & URS and now compliments our equally new 4Q Protocol, which integrates the DQ/IQ/OQ/PQ into one document. 


12000006_4Q_Equip
Issue - 4. 

4Q Equipment Validation4u Protocol (4Q-Equip) has been designed specifically to replace four standard protocols.   By taking the contents of the four protocol and carefully weaving them into one notably easy to use protocol, we have made a significant advance in the task of streamlining validation4u  documentation by reducing protocol numbers by close to 75%.  The new bang up to date 4Q protocol replaces the DQ, IQ, OQ & Performance qualification template P1Q) and now compliments our equally new VrrP Protocol.  By integrating the old style DQ/IQ/OQ/PQ into one 4Q document there will be enormous savings in man hours in the authoring, reviewing, updating and approving tasks.
For everyone's convenience, it is still written in word and compliant with FDA GMP Part 11 legislation.



Combined IQ-OQ-PQ Equipment. (Issue-8)  $159.00

This quite unique two document package is all that is required to fully validate; to cGMP standards, equipment used in a regulated facility. A lot of effort has gone into ensuring that repetitive instructions and actions have been designed out and innovative and intuitive risk-based methodologies have been incorporated.
Both documents are prefaced with a methods' Standard Operating Practice (SOP) document. These SOP’s lead you through the task of converting these highly detailed templates into your very own company bespoke protocols. The hyperlinks and cross-references within the package are; not only unique but also highly cost-effective and intuitive to use. Each document is preloaded with the test scripts (complete with acceptance criteria). All test and inspection scripts are written in MS word, to facilitate simple editing of text, layout, tables and schematics and are compliant with FDA GMP Part 11 regulations.