History of Computer System Assurance
“Quality is never an accident; it is always the result of high intention, sincere effort, intelligent direction and skillful execution; it represents the wise choice of many alternatives.” William A. Foster
Regulations exist all over the world for the protection and safety of consumers. They serve a vital purpose in economies and societies and are depended on by practically every individual in the world in some way, shape or form.
Without any or
with little regulations, consumers would be at a great risk, with their safety
jeopardized and no way of determining whether or not a product is able to
perform as marketed.
The FDA’s regulation 21 CFR Part 11 in 1997 and the related guidance of 2003 created the clear foundation for implementation of
Computer System Validation (CSV) processes.
Adhering to FDA CSV guidance can be a challenge for life
science organizations, however. CSV guidelines prioritize documentation,
primarily to appease auditors, which can be both time-consuming and costly.
This emphasis on documentation impedes the application of
critical thinking during the validation process, along with opportunities to
improve automation via system modernization.
To address these issues, the CDRH, in collaboration with the
Center for Biologics Evaluation and Research (CBER) and the Center for Drug
Evaluation and Research (CDER), is planning to release a new guidance document
entitled Computer Software Assurance for
Manufacturing and Quality System Software.
This guidance will create opportunities for streamlining
documentation by shifting the focus of CSV processes towards critical thinking,
risk management, patient and product safety, data integrity, and quality
assurance.
FDA decided to partner with industry to strike a balance
between promoting automation and value-add CSV activities.
The FDA has advised life sciences companies to take a
risk-based, least burdensome approach to CSV for two decades
The FDA aimed to improve quality, remove non-value add
activities, and focus testing on high risk areas, therefore reducing validation
cost and time by focusing on the software’s impact to patient safety, impact to
product quality, and impact to quality system integrity (Direct or Indirect
system).
Too often, testers spend time ensuring their protocol is
error free, as opposed to spending time on automated solutions that verify the
software meets it’s intended use
Burdensome, documentation heavy CSV approaches have been a
deterrent to faster technology adoption in Life Sciences industry.
CSA truly walks the walk of risk based
computer system validation. It advocates leveraging
documentation from trusted vendors, reducing documentation burden and viewing
technology as a risk reducing enabler.
“Trust but Verify “ Ronald Reagan
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Our Data integrity app will helpful for understanding what Data integrity & CSV really means & How 21 CFR Part 11, EU Annex 11 & other regulatory guidelines affects in pharmaceutical Industry.
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- ERES & Its Requirement
- CSV & Its best practices
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- Checklist for inspection
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