“How can we perform an Installation Qualification (IQ) when the server is completely under the control of a vendor?”
“How do we know the vendor will be able to manage security, backups, disaster recovery, and other aspects required to ensure data is collected and maintained with integrity?”
“What about change control?”
“How will we handle compliance with 21 CFR Part 11, FDA’s guidance for electronic records and electronic signatures?”
“Won’t our validation documentation be lacking?”
Fortunately for these companies, there are good answers to all of these questions. First of all, a cloud service provider can generally deliver and manage cloud servers and software in a more cost-effective way. With multi-tenant cloud services, multiple clients can share the infrastructure and administrative services while the vendor maintains segregation of data and access. With a single-tenant solution, there is even greater security, and services can be more customized but at a higher cost to the cloud service provider and the client company.
Most of the concerns of the industry can be managed through contracts and Service Level Agreements (SLAs) that benefit both provider and client. It all depends on how much a company is willing to trust a vendor and how much money they’re willing and able to pay for the service. The key to success is having a tight contract where the client can include the leverage by which they may hold the cloud service provider accountable. It’s all a matter of figuring out a company’s tolerance for risk, its desire to provide state-of-the-art technology to internal clients, and its budget.
The FDA has been moving in the direction of newer technology in an effort to no longer be a bottleneck to industry innovation. As part of the Case for Quality program, the US FDA Center for Devices and Radiological Health noted how an excessive focus by the industry on compliance rather than quality may be diverting resources and management attention toward meeting regulatory compliance requirements vs. investing in automation and digital technologies, which could greatly improve quality and process control.
A key element is a risk-based, product quality, and patient-centric approach to Computer System Assurance (CSA) vs. the traditional Computer System Validation (CSV) waterfall approach. This encourages critical thinking based on product and process knowledge and quality risk management over prescriptive documentation-driven approaches.
This is where the FDA determined that “WHAT” is required can be done in different ways (the “HOW”) and does not have to be according to the “checklist” mindset of most CSV work, where you crank out documents without specifically addressing the risk of potential failure of each requirement.
GAMP®5 supports the use of incremental, iterative, and evolutionary approaches, including agile and automated testing for the development of custom applications. Keys to success include a robust Quality Management System (QMS) and well-trained and highly disciplined teams following well-defined processes supported by tools and automation.
Learning Objectives:-
Areas Covered:-
Background:-
Advancements in technology have forced organizations to rethink business models. Once controlled and orderly, these organizations are now more chaotic and complex, serving patients and customers who are better informed and with higher expectations than ever before. Work practices and tools must change to meet these challenges.
The approach to developing software, performing validation, and maintaining a system in a validated state through its entire life cycle should be carefully considered in order to meet changing needs. This webinar will include a comparison of the agile and waterfall methodologies, along with the pros and cons of each. There may not be one size that fits all, so it is important to understand what needs to be considered when making such a determination.
We’ll also cover COTS, SaaS, IaaS, PaaS, and cloud services, indicating the benefits and risks of each model. In discussing these hardware and software options, we’ll include the best practices for meeting FDA’s requirements for validation, 21 CFR Part 11, as applicable, and data integrity. Part of the session will identify the FDA’s current concerns and how to ensure your systems will meet their expectations.
Why Should You Attend?
The attendees will learn about the FDA’s approach to modernizing technology and how that will benefit both the Agency and the industry. We will discuss ways to modernize the System Development Life Cycle (SDLC) approach to Computer System Validation (CSV) by using automated testing tools that will result in a continuous validation of software products. This approach is amenable to the agile software development methodology, which can be adapted for use in validation. We’ll discuss the pros and cons of each approach and industry best practices for success.
We’ll cover Computer-Off-the-Shelf (COTS) software, Software-as-a-Service (SaaS), Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), and cloud services. You’ll learn how to select an optimal solution and ensure that whatever that might be, you can build a contract and Service Level Agreement (SLA) that best suits your environment and needs.
Who Will Benefit?
