What are need of computer system assurance?
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What are need of computer system assurance?
In a nutshell, assurance
needs are the activities you need to address to ensure that a computer system
works as intended. According to the FDA's Case
for Quality initiative, determining
these activities is a three-step process.
First, you must identify the
intended use of the system, which is explained in the user requirements.
Second, you must employ a risk-based approach to pinpoint the high-risk areas
of the system, focusing primarily on areas that directly impact patient safety.
The final step is to
determine when a failure in these identified areas will have a high-risk impact
on the system's quality and safety. These areas will require the most rigorous
validation.
Risk-based assurance activities
Once you have determined the
assurance needs of the system, you will know the activities you must perform to
address these needs. Key activities include:
·
Meet
and validate user requirements: The intended use of the system must be clear.
You must ensure that all user requirements have been met and validated and that
using the system does not jeopardize quality or safety, with patient safety
being the primary concern.
·
Ensure
you are working from a quality-centric (not compliance-centric) mindset: The driving force behind CSA is the
need to reclaim the quality-centric mindset lost to CSV. With CSV, the focus is on gathering documentary
records for auditors.
But focusing too much on regulatory
requirements and compliance can cause (and has caused) life sciences
professionals to lose sight of quality. Take an honest look at your
organization. Do you have a quality culture? If you do, compliance is more or
less assured.
· Conduct a risk assessment: Assessing risk at the beginning of the validation initiative is critical to avoid wasting time and resources validating low- to medium-risk areas that do not warrant the highest degree of rigor.
Risk-based assurance requires applying the appropriate
level of rigor for the determined level of risk to patient safety or product
quality. The risk assessment drives everything else that happens during the
validation of the software.
·
Leverage
available tools: The
advancement of new technology means we have many tools at our disposal to
perform validation. The CSA
methodology encourages
the use of computer system validation tools to automate assurance activities.
· Test appropriately: Testing is the third phase of CSA, but determining which testing methods (scripted, ad hoc, exploratory or automated) to use and how much testing is required starts in the assurance needs phase.
I'll deep dive into testing in my next post. The
overall goal is to focus more on testing, less on scripting.
· Identify documentation needs: Documentation is the fourth and final phase of CSA, but again, understanding the assurance needs associated with the documentation you will produce starts during this phase.
What is adequate documentation? What
is the objective evidence? These are the questions you must consider. I'll deep
dive into documentation in a future post.
The end goal
In the assurance needs phase of CSA, you must demonstrate that the software will perform as intended and that you are using the right technologies, techniques, systems (manual and automated) at the right time.
The end goal is to assure everyone, including
regulators, that the validation effort meets or exceeds your quality standards
and is in line with regulatory requirements.
“Trust but Verify “ Ronald Reagan
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