Validation of Chromatography Data Systems: Meeting Business and Regulatory Requirements

Chapter 20: Maintaining the Validation Status During Operational Life

After operational release comes the most difficult part of computerised system validation maintaining the validation status of the system throughout its whole operational life. The key challenge is change control.

20.1 What do the Regulators Want?

20.1.1 FDA GMP Predicate Rule Requirements

211.68(b)12:

Appropriate controls shall be exercised over computer or related systems to assure that changes in master production and control records or other records are instituted only by authorized personnel.

20.1.2 EU GMP Annex 11

Clause 1127:

Alterations to a system or to a computer program should only be made in accordance with a defined procedure which should include provision for validating, checking, approving and implementing the change. Such an alteration should only be implemented with the agreement of the person responsible for the part of the system concerned, and the alteration should be recorded. Every significant modification should be validated.

20.1.3 PIC/S Guidance for GXP Systems

Table 28 lists some of the items that an inspector could look at during a visit to your laboratory; it is taken from the PIC/S Guidance on Computerised Systems in GXP Environments.31

Table 28: Change control requirements from PIC/S guidance

18 Change control and error report system (PIC/S guidance 200331)

18.1 The formal change control procedure should outline the necessary information and records for the following areas:

  • Records of details of proposed change(s) with reasoning

  • System status and controls impact prior to implementing change(s)

  • Review and change authorisation methods

  • Records of change reviews and sentencing (approval or rejection)

  • Method of indicating change ...

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