CSV 1
CSV 1
CSV 1
GMP
Final draft
°°°°
Version 2
December 2002
Revision History:
Version 1 August 2002
Version 2 References to 21 CFR part 11 in Chapter 6. “Legal Reference” –
December 2002
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Contents
1 Contents.................................................................................................. 2
2 Acknowledgement .................................................................................. 2
3 Introduction ............................................................................................. 4
4 Glossary.................................................................................................. 4
5 Scope...................................................................................................... 4
6 Legal requirements ................................................................................. 5
7 Guidance ................................................................................................ 5
7.1 Strategy ................................................................................................... 5
7.1.1 Approach .....................................................................................................6
7.1.2 Analysis .......................................................................................................6
7.1.3 Inventory......................................................................................................6
7.1.4 Risk Analysis ...............................................................................................6
7.1.5 Economics ...................................................................................................7
7.2 Compliance.............................................................................................. 7
7.3 Project Plan ............................................................................................. 8
7.3.1 Description...................................................................................................8
7.3.2 Organisation ................................................................................................8
7.3.3 Project Manager ..........................................................................................8
7.3.4 System Owner and Sponsor ........................................................................8
7.3.5 Users ...........................................................................................................8
7.3.6 Developer/ Supplier .....................................................................................9
7.3.7 Site Computer Support ................................................................................9
7.3.8 Quality Unit ..................................................................................................9
7.3.9 Responsibility Matrix....................................................................................9
7.4 System Life Cycle.................................................................................... 9
7.4.1 Introduction..................................................................................................9
7.4.2 GAMP Categories......................................................................................10
7.4.3 System Life Cycle Process ........................................................................13
7.4.4 Planning ....................................................................................................13
7.4.5 Specification ..............................................................................................13
7.4.6 Supplier / Vendor selection ........................................................................14
7.4.7 Design and construction ............................................................................15
7.4.8 Acceptance Testing ...................................................................................15
7.4.9 Implementation and acceptance ................................................................16
7.4.10 Ongoing operation; ..................................................................................17
7.4.11 Use of system..........................................................................................17
7.4.12 Security ...................................................................................................18
7.4.13 Back up and Restore ...............................................................................18
7.4.14 Disaster recovery.....................................................................................18
7.4.15 Contingency planning ..............................................................................18
7.4.16 Business continuity ..................................................................................18
7.4.17 Preventive maintenance ..........................................................................19
7.4.18 Corrective maintenance (Problem reporting) ...........................................19
7.4.19 Change control ........................................................................................19
7.4.20 Audit trail..................................................................................................19
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2 Acknowledgement
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3 Introduction
In the last decade, computerised systems have become a vital part in the manufacture of
Active Pharmaceutical Ingredients.
Typical applications are Process Control Systems (DCS, PLC, SCADA), Laboratory
Information Management Systems (LIMS), Laboratory Instrument Control Systems and
Business Systems (ERP, MRP II).
cGMP regulations imply that the functionality’s of those computerised systems, which have
influence on the quality of the API, should be validated.
Validation shall demonstrate that the parameters defined as critical for its operation and
maintenance are properly (adequately) controlled/managed.
It is essential that the validation is practical and achievable, adds value to the project,
and is concentrated on the critical elements of the system.
This Guideline outlines the scope and legal requirements for the validation of computerised
systems, chapter 7 gives a comprehensive methodology suitable for most situations within
API production control and data handling situations.
For some specific cases the coverage may be less extensive and/or subsections may be
merged depending on the criticality and the importance of the systems to be validated.
Where specialist validation cases are to be handled chapter 8 gives the official guidance,
references and industry guidelines.
4 Glossary
Refer to chapter 8.8
5 Scope
This guide is intended for use by manufacturers of Active Pharmaceutical Ingredients (APIs)
and intermediates that use computerised systems for various parts of the process leading to
the manufacture of an API or intermediate. It provides interpretation of existing cGMP
guidelines related to the validation of quality critical computerised. These interpretations aim
to be practical on one hand and acceptable for both the industry and authorities on the other.
The emphasis is on explaining “what to do” and to a lesser degree in “how to do”.
Whenever practical and feasible, attention will be paid to linking validation of computerised
systems with other types of validation, like process validation and equipment validation.
Within this guide attention will be paid to two essential parts of computerised systems:
1. Infrastructure
2. Applications
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When applying the contents of this guide it should be realised that not all computerised
systems will contain all of the elements (a through e) mentioned below.
The following aspects will be covered:
a. hardware
b. operating system
c. network system
d. data base management system
e. system software
f. strategy
g. compliance
h. project plan
i. system life cycle
j. change control
6 Legal requirements
Computerised systems used in the manufacture of API’s should be properly developed,
validated and maintained to assure data and product integrity.
The newly developed guidance for the manufacture of API’s (ICH Q7a) covers these
requirements. It should be noted that according to the current understanding, 21CFR part 11
is not legally binding for API manufacturers; however it is advisable to consider the principles
and recommendations contained in this document prior to validating computerized systems
as required by ICH Q7a.
7 Guidance
7.1 Strategy
In today’s business environment computerised systems are used more and more. It is critical
to design and validate them so that they are fit for purpose and meet user as well as
compliance requirements
There is a need for clarification of this very complex and often misunderstood area of
compliance. This area is increasingly the domain of a few consultants and experts.
This document will provide clear transparent guidance for API-manufacturers.
It will help industry to redress the balance between too much, often ineffective,
documentation with too little impact on quality assurance. This will bring about a cost
effective, added value efficient and effective way of performing validation of computer
systems that are maintained in compliance.
A strategy to achieve this will be set out in a pragmatic approach using a Validation Plan
including the elements below.
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7.1.1 Approach
1. The approach to validation of computer systems should be based on common sense and
use techniques that are familiar within other areas of validation and also business.
2. It is important to establish the final objective of validation and to choose an approach
where a positive response is given, every time the following questions are asked:
• Will this have added value?
• Is this the most efficient way?
• Is this the most effective way?
• Can we achieve 80 % of the objective with 20 % of the effort?
3. One way to assist with these decisions is to use simple flowcharts.
7.1.2 Analysis
A priority for validation activities can be established by analyzing a system inventory for the
criticality, validation status, software category and system type. This analysis aids validation
planning and prioritisation.
7.1.3 Inventory
For an effective approach the first make an inventory of existing and any proposed systems.
In compiling the inventory an assessment should be made on the criticality of each system
using a methodical approach. This list should be kept fully updated and the priorities should
be assigned once the current inventory is completed.
This inventory could include classifications based on potential impact on product quality (e.g.
critical, major, minor, none and further subdivide these into direct and indirect impact).
The inventory list (which can take the form of a spreadsheet or database) would normally
include headings like:
• system name and version number
• system type, e.g. legacy system or new system and modules
• system owner
• system use, e.g. materials management, process control, analytical control etc.
• criticality, e.g. product quality, compliance, business
• validation status
• implementation date (actual or planned)
• development category (e.g. off the shelf, user developed etc.)
• software category e.g. spreadsheets, PLC’s, process controls
• GAMP category
• CFR 21 part 11 e.g. compliant electronic records and signatures
• Last validation performance check.
• Priority (an outcome of risk analysis).
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system. Looking at the impact of the system on product quality, the validation status and the
potential impact on the business can do this.
Product quality can be impacted directly, indirectly or not at all. Examples are as follows:
• direct impact: process control of final purification step, assay of finished product
• indirect impact: distribution list of finished products, equipment maintenance program
Once validated, all computerised systems must be maintained according to the System Life
Cycle approach.
The cGMP approach to validation can be used in a total quality approach to computer
systems involved in safety, environment, finance, however there is no legal requirement to
do that and these systems should not be subject to cGMP inspection.
7.1.5 Economics
As API production usually takes place in a highly competitive environment it is of utmost
importance to perform validation in an efficient and cost effective way. To that end each
company has to decide how to execute validation.
Two main are used:
• to use own, well educated and trained personnel
• to hire consultants to guide and organise the validation task
The latter option should be considered especially for smaller companies. However, one has
to realise that some in-house expertise is needed to stay in control of computer system
activities and of the costs. It is a fundamental requirement that the company itself remains
responsible for the ultimate results.
To assist in control of costs it is useful to recognise that not all computerised systems are in
need of the same level of validation. Less critical systems should have appropriate level of
documentation.
7.2 Compliance
cGMP regulations imply that computerised systems that influence the quality of the API must
be validated.
The depth and scope of validation depend on the criticality of the computerised functionality.
This has to be established by means of a risk analysis at an early stage of the validation
process.
Compliance critical key points to be considered include:
• Proven fit for purpose
• Access control /user management.
• Data integrity including: prevention of deletion, poor transcriptions and omission.
• Authorised / unauthorised changes to data and documents
• Critical Alarms handling (Process)
• Audit trails
• Disaster recovery / Back up and retrieval
• System maintenance and change control
• Training
Evidence of sufficient control of these issues should be demonstrated in the validation
documentation.
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This compliance must be integrated using the system life cycle approach (SLC), and clearly
identified in the user requirements phase for any new computerised systems as detailed in
chapter 0.
For existing systems, for which a life cycle model was not applied, a gap analysis must be
undertaken against cGMP compliance issues. Identified issues must be tested and
documented following a formal qualification plan/report.
For any identified non-conformances, the following alternatives should be considered:
• upgrading
• ensuring the requested control level through additional procedure (s) if the
upgrading is not feasible
• replacing/upgrading the system where gaps are substantial and cannot be
covered by the previous measures.
7.3.1 Description
The project plan is the backbone of any IT validation activity for any system. It describes the
objectives, the organization, schedule, step-by-step activities and their chronology including
milestones. Among these milestones are the deliverables.
It should address measures to control the project such as review and communication.
It is assumed that the major aspects covering GMP quality management system are in place.
A document describing the current computer validation situation should be available.
For the activities undertaken as part of the project plan see section 7.4.4.
7.3.2 Organisation
Special attention should be paid to the project organization.
7.3.5 Users
Key users must be identified prior to writing URS. For instance when a project covers
different specific areas, it is worthy to appoint a key user for each specific area.
They must approve the following documents:
URS
Functional/Design Specifications
They are involved in testing. It is key that the user has sufficient knowledge of the type of
system so that they can become involved in designing the system. If there is a lack of
knowledge it is critical that training be provided so that the user can provide an informed
opinion.
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E.g.
Responsibilities:
Writing: W
Reviewing: R
Approving: A
7.4.1 Introduction
This chapter details the actual validation activities to be performed to provide a computerised
system validated to current standards.
Validation activities for computerised systems are divided into qualification of infrastructure
(computers, system software and network) and validation of applications (including the
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A Validation (Master) Plan should be developed according to company policies and internal
procedures, including both infrastructure and applications.
Standard Operating Procedures (SOPs) should be in place together with a formal System
Life Cycle Concept which describes all the relevant activities for creating and maintaining
qualified infrastructure and application.
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2 Standard balances, logic on an These are driven by non-user programmable firmware. They are configurable
Instruments, pH meters, interface controller and the configuration should be recorded in the equipment IQ.
Micro bar code
Controllers, scanners,
Smart PID controllers.
Instruments
3 Standard Office Layered products These are called Canned or COTS (Commercial Off-The-Shelf) configurable
software applications, as DBMS, ACL packages in the USA. Examples include Lotus 1-2-3, Microsoft Excel software
packages spreadsheet, and (but not the spreadsheet itself since it includes generally calculations and
data base communication eventually macros). There is no requirement to validate the software package,
systems packages however new versions should be treated with caution.
4 Configurable LIMS, ERP (eg Users specific .
software MRPII based), applications which These are called custom configurable packages in the USA. Examples include
packages DCS, SCADA, are PLC based. Distributed Control Systems (DCS), Supervisory Control and Data Acquisition
MES, packages (SCADA), manufacturing execution systems and some LIMS and
Chromatography MRP packages. In these examples the system and platform should be well
data systems. known and mature before being considered in category 4, otherwise category 5
should apply. A typical feature of these systems is that they permit users to
develop their own applications by configuring/amending predefined software
modules and also developing new application software modules. Each
application (of the standard product) is therefore specific to the user process
and maintenance becomes a key issue, particularly when new versions of the
GMP
The System Life Cycle concept describes all aspects of the life cycle of a computerised
system that could consist of:
• planning;
• specification
• design
• construction
• testing
• implementation and acceptance
• ongoing operation;
• archiving of the system when replaced.
In the next chapters the validation activities are discussed step-by-step following the life-
cycle concept.
7.4.4 Planning
Typical activities and output in this phase are:
Activity Output
Define business need/problem Business justification/Problem description *
Assign project manager
Define project-/validation team
Describe main system requirements (Main) system requirements *
Perform feasibility study Results feasibility study *
Allocate project resources
Write project plan Project Plan
* May be incorporated in the project plan
7.4.5 Specification
Validation of a computerised system should demonstrate that the system meets
predetermined specifications. Testing is needed in several stages of the Life Cycle.
Therefore, documented detailed specifications need to be available for each stage of
testing.
In the Specification Phase the detailed user requirements specification (URS) and the
acceptance criteria are specified, based on identified critical requirements.
Based upon this specification a supplier market survey may be performed to screen the
possible candidate suppliers. Usually, a supplier has detailed information about an existing
product in documents like the functional specification and/or the system design.
GMP
After approval of the DQ formal change control should be applied to all specification
documents.
Consider parallel validation activities (see table below)
Typical activities and output in this phase, not necessarily in this chronological order, are:
Activity Output
Develop validation plan Validation plan
Define User Requirement Specification (URS) User Requirements Specification
(URS)
Develop acceptance criteria Acceptance criteria *
Perform risk analysis Risk analysis report
Develop acceptance test plan (IQ/OQ protocols, Acceptance test plan (IQ/OQ/(PQ)
PQ protocol if applicable) protocols) *
Request for proposal (i.e. quotation) Request for proposal
Supplier review/audit Review/audit report
Supplier selection Supplier qualification
Draw-up of contract Contract with supplier; with
contractual requirements
Place order Acquisition order
*If the software is developed, these items are part of the System Design and Programming
Phase.
Generally, before supplier selection, the User Requirements Specification (URS) and the
acceptance criteria should be specified. The URS should contain three types of
requirements:
• process/user related requirements (detailing the required functionality's),
• technical/IT related requirements (including not only e.g., hardware and software
requirements and required interfaces with other computerised systems, but also
addressing the capability of the system to migrate data from previous as well as to
future versions or systems),
• quality/QA related requirements (including GMP-compliance and all requirements from
21 CFR Part 11).
All requirements should be unambiguous, complete, verifiable/testable and consistent with
each other. Preferably the URS are set up in a way that the traceability matrix can be built up
from there (see appendix 8.6).
At least for Category 4 and 5 systems used for GMP activities, a supplier quality review, and
if considered relevant an on-site audit, should be performed to assess the validity of potential
suppliers. The supplier review and/or audit should cover company information, Quality
Management System information, Software Development and Package information. The
supplier selection process should be documented and any deviations from the requirements
observed during an audit should be addressed.
For critical systems, this review and/or audit should be carried out before final supplier
selection.
GMP
When a supplier has been selected, contractual requirements should be defined. These
contractual requirements are usually a “blend” of user requirements and technical
specifications.
Activity Output
Define functional specification Functional specification
Design the system Design specification
Design Qualification DQ report (can be included in the URS traceability
matrix)
Programming and module testing Software; module test report
Audit supplier Audit report
Supply final system description System description (including hard/software diagrams)
Supply system installation procedure System installation procedure
Supply system documentation Manuals and user guides
In case the supplier is doing substantial programming, in this phase possibly an additional
supplier audit with a special focus on the SLC, adherence to procedures and proper
documentation may be useful.
The level of detail of in-house testing is depending upon the GAMP category and upon the
testing done by the supplier.
Typical activities and output in this phase are:
GMP
Activity Output
Installation Qualification IQ report (FAT, SAT can be included)
Operational Qualification OQ report (FAT, SAT can be included)
Training of users Qualified personnel
Audit/review of IQ/OQ and if applicable Internal Audit/review report
(parts of) PQ
Updated IQ/OQ report to QA for Final approved IQ/OQ reports
approval
If IQ/OQ protocols are used which the supplier develops, these protocols should be reviewed
and approved by the project team before starting the IQ/OQ. The IQ/OQ can be executed at
the user’s site, by the supplier or by a user representative or member(s) of the project team.
Each test shall be documented in a way that it can be reconstructed. This can be achieved
by creating log files, making printouts, using logbooks etc. If these options are not feasible or
practicable, witness testing is allowed. Testers should sign for each test performed.
Reviewers should sign for logical sets of tests. In the case of witness testing the witness
should sign for the same steps as the tester. Witness testing is required when a vendor or
contractor undertakes system testing.
Chronology of IQ, OQ and PQ is a critical compliance issue. The critical parts of the IQ
should be finished before executing OQ of that particular part, but parallel activities for other
parts are possible.
If any test or challenge does not meet the specification or other deviations are found, this
should be documented and, if necessary covered by corrective actions (e.g. identification of
the cause of the deviation, corrective actions and additional tests).
After installation, the Operational Qualification (OQ) verifies the functional specifications of
any individual system or sub-system. If needed to confirm whether the system meets the
contractual requirements, relevant parts of the PQ need to be performed in this phase.
(Additional PQ testing against other user requirements is often still required after
acceptance). Results from previous testing e.g. FAT can also be used in this phase.
These results from an IQ/OQ must be reported as a formal report (combined it is often called
an acceptance testing report). At this stage the system is approved for handing over to user
for PQ to take place.
GMP
Activity Output
Develop implementation plan Implementation plan
Performance Qualification (PQ) PQ report
Develop procedures Procedures
Complete system description System description
Training of additional users Qualified personnel
Write validation report Validation report
Validation review Internal Audit report
The computer system may be formally released for PQ. PQ will take place in a production
environment. During the period of Performance Qualification of the system additional
monitoring is undertaken. Depending on the nature of the system the PQ can consist of a
monitoring period or process validation (e.g. production of validation batches).
The implementation plan specifies the actions for implementing the computer system in its
operational environment:
• Necessary activities and other documentation as required for the ongoing operation
phase
• Training of additional system users
• Remaining test activities, like production of Process validation batches
GMP
7.4.12 Security
There needs to be proper access control procedures on three levels:
1. Wide and/or Local Area Network level
2. System, or Application level
3. PC level.
Items that need to be covered include how access is controlled, a password policy and audit
trails. At all three levels there should be continuously updated lists of approved users and
their authorisation levels.
Note: if the same tapes are used, the tapes may be getting worse without noticing it.
The procedures have to be carried out, controlled and documented.
GMP
7.4.21 Training
All users of the system should be trained. This training should be documented and where
applicable evaluated. Users should be informed about current standards or changes of the
system. The training responsibilities should be defined.
7.4.23 Archiving
All documentation generated in the Operation and Maintenance and Change Control
procedures should be properly archived.
Data and the necessary software to retrieve those should be archived.
GMP
7.4.25 Infrastructure
Qualification of the infrastructure e.g. of the local area network, contains the following
elements:
• high level documentation of the network e.g. security, reliability and availability.
• installation documentation including current schematic diagram.
• configuration management (an up to date inventory of hardware and software
[incl. versions] components)
• monitoring of the performance of the infrastructure
Testing of infrastructure is normally included in the functional testing of the application (e.g.
loop testing, process control systems etc).
Well-known operating systems should be used. Record the name and version number in the
Hardware Acceptance tests or equipment IQ. New versions of operating systems should be
reviewed prior to use and consideration given to the impact of new, amended or removed
features on the application. This could lead to a formal re-testing program of the application,
particularly where a major upgrade of the operating system has occurred.
The configuration should be recorded in the equipment IQ. The unintended and
undocumented introduction of new versions of firmware during maintenance must be
avoided through the application of rigorous change control. The impact of new versions on
the validity of the IQ documentation should be reviewed and appropriate action taken.
GMP
As for other categories, change control should be applied stringently, since changing these
applications is often very easy, and with limited security. User training should emphasize the
importance of change control and the validated integrity of these systems.
The life cycle should be used partially to specify, design, test and maintain the application.
Particular attention should be paid to any additional or amended code and to the
configuration of the standard modules. A software review of the modified code (including any
algorithms in the configuration) should be undertaken.
In addition, an audit/review of the supplier is required to determine the level of quality and
structural testing built into the standard product. The audit/review needs to consider the
development of the standard product, which may have followed a prototyping methodology
without a user being involved. The European Guide to Good Manufacturing Practices, Annex
11, requires that the development process is controlled and documented.
A Validation Plan should be prepared to document precisely what activities are necessary to
validate an application, based on the results of the audit and on the complexity of the
application.
For these systems the full Life cycle should be followed for all parts of the system. An audit
of the supplier is required to examine their existing quality management systems and a
Validation Plan should then be prepared to document precisely what activities are
necessary, based on the results of the audit and on the complexity of the proposed bespoke
system.
Guidance on validation documentation required for each GAMP category of software is given
in the table below. GAMP 1 operating systems are not included in this table, as only version
control should be applied. Wherever possible and practicable documents or items listed
below may be combined. If documents are combined, it should be clear which of the
indicated items are actually covered in which document(s).
The activities listed below are not necessarily in a chronological order.
GMP
8 Appendices
This checklist is a quick reference; for more information reference is made to the relevant
chapters
1
1. The results from an IQ/OQ can be reported as a formal report (combined it is often
called an acceptance testing report). At this stage the system is approved for handing
over to user for PQ to take place. PQ will take place in a production environment. During
the period of Performance Qualification of the system additional monitoring is
undertaken. Depending on the nature of the system the PQ can consist of a monitoring
period or process validation (e.g. production of validation batches).
GMP
3) Changes to the documentation mention the changes from the previous version
of this document.
4) Validation team, members and responsibilities
Team members/participants X X
Authorisation of protocols and documents X X
Who does the testing / who does verification X X
Responsibilities for the member X X
Authorisation of documents X X
Resources X X
5) Validation Strategy / Activities
Verification of URS X X
GAMP categories X
Risk analysis x X
References to URS – DQ X X
Testing criteria / acceptance criteria X X
References to applicable SOP’s – change control X X
IQ, OQ and PQ protocols X X
Testing activities X X
IQ, OQ activities X X
Documentation of findings, reporting X X
Creation of infrastructure and application manuals X X
PQ activities X
Review validation file X X
Validation report X X
6) Planning of activities X X
System requirements in the URS to be covered by the Hardware, network, I/O Application software
succeeding specification requirements cards, work stations,
servers, alarms
Detailed URS including users specific configurations X X
GMP
GMP
8.3 Definition
The first two columns identify the section number and title in the User Requirements Specifications. The remaining columns identify the
document and the specific section where each user requirement was verified.
User
URS Spec User Requirements Specification Validation and Functional Installation Operational Acceptance Performance
Reference Description Project Plan Specifications Qualification Qualification Testing Qualification
< Document < Document < Document < Document < Document < Document
< Document reference > reference > reference > reference > reference > reference > reference >
Document approval
System owner (name, date, signature)
8.4.1 Scope
During the process of development, construction, validation, use and termination of
computerised systems an SOP/system for controlling changes should be in place.
The purpose is to ensure that any change to the computerised system application is
controlled in such a way that it will remain compliant with the GMP regulations. This can
include hardware, software, authorisations, training and documents.
It must be considered very important that a global view is taken when dealing with change
control.
If based upon the impact analysis the change is minor and no testing or documentation
updates are required, this should be documented.
The system should be kept as simple as possible: a procedure using change request forms
can be adequate.
8.5 Matrix
Refer to section 7.3.9
8.6 Benefits
Business benefits:
Strong project management will minimise re-engineering/designing and reduce redesign
costs. The project discipline which computer validation brings can help to ensure that the
team is in control of automated system.
By highlighting the critical phases it can be ensured that the project team spends the most
effort and time on the most critical systems. Well defined User Requirements documentation
provide clear indications of future requirements and make vendors aware of them.
Computer validation also brings discipline to an idealistic environment
Compliance benefits:
By following the system life cycle approach the following benefits will be achieved.
You will:
• meet regulatory expectations for computerised systems and ensure that the
system is fit for purpose.
• ensure the system has data that is secure and control with protection against
fraud, mistakes, system errors.
• use audit trails and passwords to assist control of the system.
• ensure that changes do not cause system failure by controlling and testing
changes.
• meet new regulations by including them in user requirements, e.g. Electronic
records and signatures
• ensure that suppliers understand the compliance requirements prior to design
• by version controlling help with debugging and disaster recovery.
• by limit testing ensure that the system performs as required and will not fail during
times of stress or when unusual entry combinations are undertaken.
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8.7 References
8.7.2 ICH Q7a Good Manufacturing Practice for Active Pharmaceutical Ingredients
(current guideline); chapter 12
8.7.4 IEEE (Institute of Electrical and Electronics Engineers) 730, 828, 829, 830,
1012; (including guidance on software quality and Development).
8.8 Glossary
Action Levels: Levels or ranges distinct from product specifications which, when deviated
from, signal a drift from normal operating conditions and which require actions.
Alert or Warning Levels: Levels or ranges which, when deviated from, signal a potential
drift from normal operating conditions but which do not necessarily require action.
GMP
Application Software: (PMA CSVC) a program adapted or tailored to the specific user
requirements for the purpose of data collection, data manipulation, data archiving or process
control.
Archiving: The provision to ensure the long-term retention requirements for the type of data
held and the expected life of the computerised system. System changes must provide for
continued access to and retention of the raw data without integrity risks.
Audit: (ANSI N45.2.10-1973) an activity to determine through investigation the adequacy of,
and adherence to, established procedures, instructions, specifications, codes, and standards
or other applicable contractual and licensing requirements, and the effectiveness of
implementation.
Audit Trail: For the purpose of computerised systems, audit trail means a secure, computer
generated, time-stamped electronic record that allows reconstruction of the course of events
relating to the creation, modification, and deletion of an electronic record. The data must be
able to be interrogate, sorted by date, time, reason for change, person.
Automated System: Term used to cover a broad range of systems, including automated
manufacturing equipment, control systems, automated laboratory systems, manufacturing
execution systems and computers running laboratory or manufacturing database systems.
The automated system consists of the hardware, software and network components,
together with the controlled functions and associated documentation. Automated systems
are sometimes referred to as computerised systems; in this Guide the two terms are
synonymous.
Back-up: Provisions made for the recovery of data files or software, for restart of processing,
or for use of alternative computer equipment after a system failure or a disaster (see
restore).
Bespoke: A system produced for a customer, specifically to order, to meet a defined set of
user requirements.
GMP
• The procedure and action by a duly authorised body of determining, verifying, and
attesting in writing to the qualifications of personnel, processes, procedures, or items
in accordance with applicable requirements.
Change Plan: A plan defining the details of the authorised change request, defining actions,
responsibilities and procedures.
Compiler: (ANSI/IEEE): A program used to translate a higher order language into its re-
locatable or absolute machine code equivalent.
Computer Hardware: (PMA CSVC) Any physical element used in a computer system.
Contingency plan: A document that describes how work is continued after total failure of
the system for a period of time
NOTE: In combination with this plan, there should be a Disaster recovery plan. (See:
"Disaster recovery plan")
Control software: application software such as utilities and tools which is used to control
and manage computerized systems
GMP
Control Parameters: Those operating variables that can be assigned values that are used
as control levels.
Control Parameter Range: Range of values for a given control parameter that lies between
its two outer limits or control levels.
1. Superseded code from earlier versions. Avoided by using quality software development
standards;
Removal of code in category 3 leads to serious potential future problems. "Idle code" can be
"parked" in libraries until needed.
Debugging: (IEEE) The process of locating, analysing, and correcting suspected faults.
Design Qualification (DQ): Formal and systematic verification that the requirements
defined during specification are completely covered by the succeeding specification or
implementation.
Disaster recovery plan: A document that lists all activities required to restore a system to
the conditions that prevailed before the disaster (e.g., power failure) occurred.
NOTE: In combination with this plan, there should be a Contingency plan. (See:
"Contingency plan")
GMP
Electronic Approval: An input command requiring restricted entry made under a level of
higher authorisation, which signifies an act of approval.
Electronic Identification: (eID) An electronic measure that can be substituted for a hand-
written signature or initials for the purpose of signifying approval, authorisation or verification
of specific data entries.
Embedded System: A system, usually microprocessor or PLC based, whose sole purpose
is to control a particular piece of automated equipment. This is contrasted with a standalone
computer system.
Frozen Software: This is software which is under configuration control and may not be
altered without change control.
GMP
Functional Testing: Also known as "BLACK BOX" testing, since source code is not
needed. Involves inputting normal and abnormal test cases; then, evaluating outputs against
those expected. Can apply to computer software or to a total system.
Hardware Design Specification: (APV) Description of the hardware on which the software
resides and how it is to be connected to any system or equipment.
Installation Qualification [IQ]: (PMA CSVC) Documented verification that all key aspects of
[software and] hardware installation adhere to appropriate codes and approved design
intentions and that the recommendations of the manufacturer have been suitably considered.
Legacy system: Software applications and computerised systems that have been working
for many years and have never been validated. For systems that are critical to a regulated
process a retrospective evaluation should be performed.
Life Cycle Concept: (PMA CSVC) An approach to computer system development that
begins with identification of the user's requirements, continues through design, integration,
qualification, user validation, control and maintenance, and ends only when commercial use
of the system is discontinued.
Loop Testing: Checking the installed combination of elements characterising each type of
input/output loop.
GMP
Purposes:
Characteristics:
• requires highly trained experts who are familiar with software/hardware systems on
which program is based
Major Change: (PMA CSVC) A change to a validated system that, in the opinion of change-
control reviewers, necessitates a revalidation of the system.
Minor Change: (PMA CSVC) A change to a validated system that, in the opinion of change-
control reviewers, does not necessitate a revalidation of the system.
Operating Environment: All outside influences that interface with the computer system.
a. A set of programs provided with a computer that function as the interface between
the hardware and the application programs.
GMP
b. Software that controls the execution of programs. An operating system may provide
services, such as resource allocation, scheduling, input/output control, and data
management.
Operational Qualification [OQ]: (PMA CSVC) Documented verification that the equipment-
related system or subsystem performs as intended throughout representative or anticipated
operating ranges.
Performance Qualification [PQ]: Documented verification that the process and/or the total
process-related system performs as intended throughout all anticipated operating ranges.
Planned Change: (PMA CSVC) An intentional change to a validated system for which the
implementation and evaluation program is predetermined.
Process System: (PMA CSVC) The combination of process equipment, support systems
(such as utilities), and procedures used to execute a process.
Product: Any computer system supplied by the supplier to the customer as the result of an
agreed contract between the two parties.
Prospective Validation: The validation of new or recently installed systems following a Life
Cycle Concept (see PMA definition).
Proven Acceptable Range (PAR): All values of a given control parameter that fall between
Acceptance Criteria (ANSI/IEEE): The criteria a software product must meet to successfully
complete a test phase or to achieve delivery requirements.
Quality Control [QC]: (Dr J M Juran): The regulatory process through which industry
measures actual quality performance, compares it with standards, and acts on the
difference.
GMP
Quality Function: The entire collection of activities from which fitness for use is achieved,
no matter where these activities are performed.
Quality Plan: A plan created by the supplier to define actions, deliverables, responsibilities
and procedures to satisfy the customer quality and validation requirements.
Range Testing: Checking each input output loop across its intended operating range.
Raw Data: Any work-sheets, records, memoranda, notes, or exact copies thereof, that are
the result of original observations and activities and which are necessary for the
reconstruction and evaluation of a work project, process or study report, etc. Raw data may
be hard/paper copy or electronic but must be known and defined in system procedures.
Requirement: (ANSI/IEEE)
Restore: Recovery of data files or software from a back-up, for restart of processing, or for
use of alternative computer equipment after a system failure or a disaster (see back-up).
Security: (IEEE) The protection of computer hardware and software from accidental or
malicious access, use, modification, destruction, or disclosure. Security also pertains to
personnel, data, communications, and the physical protection of computer installations.
Shall: This word is used in the example procedures throughout the appendices so that they
may be used without alteration.
GMP
Software: (PMA CSVC): A collection of programs, routines, and subroutines that controls
the operation of a computer or a computerised system.
Software Life Cycle: (ANSI/IEEE) The period of time that starts when a software product is
conceived and ends when the product is no longer available for use. The software life cycle
typically includes a requirements phase, test phase, installation and checkout phase, and
operation and maintenance phase.
Structural Testing: (Bluhm, Meyers, Hetzel) Examining the internal structure of the source
code. Includes low-level and high-level code review, path analysis, auditing of programming
procedures, and standards actually used, inspection for extraneous "dead code", boundary
analysis and other techniques. Requires specific computer science and programming
expertise.
Sub-program: A self contained program unit which forms part of a program. Sub-programs
are sometimes referred to as procedures, subroutines or functions.
System Software: (ANSI/IEEE) Software designed for a specific computer system or family
of computer systems to facilitate the operation and maintenance of the computer system and
associated programs, for example, operating systems, compilers, utilities.
GMP
System Specifications: (PMA CSVC proposed) Describes how the system will meet the
functional requirements.
Technical infrastructure: the operating system plus layered software and libraries, use to
control the computer hardware and provide services to application software.
Testing: Structural & Functional: Both forms of testing are essential. Neither form of testing
can be exhaustive. Structural testing should occur chiefly during software development.
Validation Protocol: (PMA CSVC) A prospective experimental plan that when executed is
intended to produce documented evidence that the system has been validated.
Worst case: (FDA 1987) A set of conditions encompassing upper and lower processing
limits and circumstances, including those within standard operating procedures, which pose
the greatest chance of process or product failure when compared to ideal conditions. Such
conditions do not necessarily induce product or process failure.