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CSV Gamp 5
CSV Gamp 5
VALIDATION DELIVERABLES
CSV & CSA
-ARIJIT DASGUPTA
GAMP
Full Form of GAMP is Good Automated Manufacturing Practices
To achieve computerized system that are fit for intended use &
meet current regulatory requirements
GAMP5 CATEGORY
CATEGORIES WHAT COMES UNDER? DESCRIPTION
Category 1 Infrastructure Software Operating Systems
(Standard Software)
Category 3 Non Configurable Software Products cannot be Configured or Sometimes can be Configured, Only
the default Configuration can be Used.
Commercial off the shelf software (COTS). For example; Laboratory
Instruments Software
Category 4 Configurable Software Configuration can be done to meet user specific needs.
For example; To meet end user requirements, few modules in Enterprise
System (LIMS, DMS) to be implemented as per User requirements.
Data migration requirements between two or more software.
Category 5 Customized Application These applications are developed to meet the specific needs of the
regulated company.
For example; Bespoke/ Tailor Made Software, Customized Application
TYPE V MODEL AS PER GAMP 5
Planning Reporting
Configuration & Coding
VALIDATION DELIVERABLES BASED
ON GAMP5 CATEGORIES
SOFTWARE VALIDATION DELIVERABLES
CATEGORY
IRA URS SA VP FS CS/DS IQ OQ PQ RTM VSR
Category 1 √ √ - - - - √ - - - -
Category 3 √ √ - √ - - √ √ √ √ √
Category 4 √ √ √ √ √ √ √ √ √ √ √
Category 5 √ √ √ √ √ √ √ √ √ √ √
COMPUTER SYSTEM VALIDATION
(CSV)
Computer System Validation (CSV) is a process used to test, validate and formally
document that a regulated computer based system does exactly what it is
designed to do in a consistent and accurate manner that is secure, reliable and
traceable.
FDA’s “Guidance for Industry Computer Systems Used in Clinical Trials” applies
to
the computerized systems used to create, modify, maintain, archive, retrieve or
transmit clinical data intended for submission to FDA.
HOW TO PLAN CSV DOCUMENTATION
PROCESS
1) What will be Validated?
A~ Software’s name and version number
System Build
SUPPLIER/ VENDOR ASSESSMENT
Supplier/Vendor Assessment should be evaluated based upon reputation,
experience, competition and certifications.
The inspection will be performed using a questionnaire which includes, but not
limited to:
1) Supplier Organizational Structure
2) Supplier Reputation and Experience
3) Business Process
4) Quality Process
5) Product Development Life Cycle
SUPPLIER/ VENDOR ASSESSMENT
1) Database
Design- Field definitions, File Structures, Entity relationship diagrams,
Data Flow Diagrams
6) Network Requirements
7) Specific peripheral device requirements such as scanners, printers etc.
VALIDATION PLAN
A Validation plan must be produced for each computerized System
The Validation plan will define the activities to be undertaken to demonstrate that the GxP
Computerized System is in complaint state and fit for intended use.
The Validation plan should include the below mentioned areas, but are not limited to:
1) Project and System Overview
2) Vendor
3) Roles and responsibilities
4) Validation Strategy
5) Supporting Process
6) Validation Deliverables
VALIDATION deliverables
A. Planning B. Specifications
Validation Deliverables
C. Verification
D. Reporting
VALIDATION deliverables
A. Planning- Validation Plan, Supplier Assessment and Initial Risk
Assessment
B. Specifications-User Requirement Specifications, Functional
Requirement Specifications and Configuration Specifications
C. Verification-Installation Qualification, Operational Qualification,
Performance Qualification, Requirement Traceability Matrix (RTM)
D. Reporting-Validation Summary Report
INSTALLATION QUALIFICATION (IQ)
A. IQ should demonstrate correct software and hardware are installed and
configured in line with specification documents in applicable environments
(Production/ Quality).
RTM ensures that the requirements are verified and can be traced and
shows that the requirement has been meet.
1) SOPs
2) Defects experienced during Qualification
3) Training
4) Change Control and Final System Validation Approval
COMPUTER SYSTEM ASSURANCE (CSA)
CSA is a risk based approach for establishing and maintaining
confidence that the software is fit for its intended use.
CSA Approach
Critical Thinking Targeted Testing Documentation
TRANSITIONING FROM CSV TO CSA
CSV focuses heavily on documentation. Whereas; CSA focuses a high
priority on areas affecting patient safety and product quality.
Low Not High nor Medium Risk Ad-Hoc Testing which include
User list, Roles and Privilege
Matrix
ADVANTAGES OF CSA
1) A reduction in cycle times (Test creation, Review and Approval) as
there is reduction in test scripts and test errors