GxP Assessment & Categorization of Computerized System
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The result of the GxP Assessment and system Category checklist decided whether Validation required for computerized system.
If Outcome is “GxP Applicable” then follow Computer system validation procedure and other risk assessment for validating the system.
All systems which handle data or processes which fall under the impact
of GxP or any other regulatory requirements must be validated
Determine whether the application has been validated elsewhere you in
organization. The amount of work required may be significantly reduced by
referring some of the deliverables in as in state or with slight changes. The
details must be addressed in the change control.
If required any “Non GxP Applicable “systems that process data critical
to operations of the business such as those involving financial, certain
personal data etc.
Quality assurance, IT, CSV responsibility person, HOD of User department may consider the validation of such systems as a part of good business practice.
GxP Assessment of computerized system:
Perform GxP
assessment using below questioners:
1 Is the system used to generate data used in support of a regulatory
submission?
2 Is the system is used to monitor, control or supervise a
GxP manufacturing or packaging process and have the potential to affect Product
Quality, Safety, Identity or Efficacy?
3 Is the system used to hold and/or
manipulate clinical study data?
4 Is the system used to monitor, control or
supervise packaging and labeling operations?
5 Is system used to create critical study control
data?
6 Does the system hold electronic records that are or could be used in
electronic form to make GxP decisions?
7 Is the system
used to transmit e-data/ records to other systems for the execution of GxP
activities?
8
Is the system is used for GxP analytical quality control?
9 The system manipulates data, or produces reports, to be
used by GxP quality related decision authorization / approval processes, where
the data supports the decision process or the electronic record constitutes the
master record.
10 Is the system is used to maintain compliance with a GxP
requirement?
11 Is the system is used to monitor, control or supervise
warehouse or distribution within a GxP requirement?
12
Is the system is used for GxP batch sentencing or batch records?
13 Is the system used to store GxP
documents for example SOPs, Specifications, BMR ,BPR ,DMF
14 Is the system used for GxP data backup,
restore, archival or storage, data security or access / domain control?
15 Is the system used for physical access to GxP to the environment (i.e. area or location)?
16 Does the system support a GxP
application i.e. LAN/WAN?
If any of the
above questions are answered “Yes” then the system has a GxP impact and the
system requires a level of Validation and control through the Computer Systems
Validation.
If all the
questions are answered “No” then the system may be deemed not to have a GxP
Impact. This should be documented to support the decision not to perform formal
validation. .
System categorization
Refer below checklist shall be used to classify the systems into one of
the System Categories
1 Is the system established commercially and is used to run
other programs/applications?
2 Does the system consist of software which is not directly
useful for business purposes but makes the computer hardware useful? An example
is the Windows Operating System?
3 Is the system used to perform basic tasks, such as
recognizing input
from the keyboard,
sending output
to the display
screen, keeping track of files
and directories
on the disk,
and controlling peripheral
devices such as disk drives
and printers?
4 Is the system available as a ready-made product for sale to
the general public?
5 Can the system be implemented without performing any
customization or configuration to it (i.e. system will be used “As-Is”)?
6 Can the system be configured for use for a specific
function without altering the basic program? In other words, can the system be
tailored to meet your business requirements/needs?
7 Does the system consist of a program or group of programs
specially designed for the end users?
Based on above mentioned question Application
software falls into one of the categories as -
Category 1: Operating System
[Note: If the answer to
question 1 to 3 is Yes, then this category is applicable]
Category 3: Standard Software
Packages (Commercial Off the Shelf (COTS) As-Is)
[Note: If the answer to
question 4 and 5 is Yes, then this category is applicable]
Category 4: Configurable Software Packages (Configurable
COTS)
[Note: If the answer to
question 4 and 6 is Yes, then this category is applicable]
Category 5: Custom (Bespoke)
Software
[Note: If the answer to
question 7 is Yes, then this category is applicable.]
“Trust but Verify “ Ronald Reagan
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