CSA- Same Regulations; Different perspective
CSA- Same Regulations;
Different perspective
A system whose software
does not impact Patient Safety, Product Quality is considered Non-GxP, e.g.,
Systems or Tools used for Document Management, Compliance Management, and
Lifecycle Management.
The risk associated with
such systems is low, and the same level of rigor on Testing, Documentation is
not needed.
GxP systems (Systems
having a direct impact) such as LIMS, MES, Adverse event reporting have a
higher risk of impacting Patient Safety and Product Quality. Hence such systems
require adequate Testing and sufficient documentation.
In a nutshell, the
higher the risk, the higher the need for detailed Testing and Documentation.
The below picture
depicts how CSV and CSA differentiate from one another without compromising on
the regulation requirements.
This is done while
keeping in mind the critical aspect of documentation, which takes a lot
of time and effort in a System Validation process for a Life Sciences Company.
To adopt CSA (future of validation?), one needs to conduct a
GAP Assessment of the current CSV process within the organization to be able to
make the shift from the traditional way of validation.
Many organizations are piloting smaller programs to implement
this approach, as it is a cultural shift to make this transition
successful However, the most crucial aspect that organizations should not
forget is applying critical thinking to make Testing more efficient while
maintaining the effectiveness to truly differentiate the traditional way of
executing validation using Computer System Validation
“Trust but Verify “ Ronald Reagan
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