Periodic System Review /Evaluation
Data Integrity App |
Periodic System Review is to ensure that the
computer system remains compliant with regulation, is fit for its intended use
and satisfies company policies and procedures.
Conducting periodic reviews on GxP systems, assets and/or processes
that have already been validated is a critical aspect in any validated
environment.
It is important to review a system or process for changes – both
physical and procedural – in order to verify that a system or process is
operating as expected.
For the most part, management of periodic reviews is achieved using
spreadsheets and other paper-driven tools.
This in turn equates to reliance upon a single user or group of
users to ensure that periodic reviews are completed on time and documented
accordingly. Through this reliance on human interaction the possibility of
errors heightens and risk increases.
In this way human errors are removed from the process ensuring that
users are aware in real time of the status of any periodic review.
Both the FDA and EU
GMP’s detail the requirement for demonstrating that a computer system remains
in a validated state throughout its operating history.
FDA 21 CFR 211.68(b)
States:
“Input to and output from the computer or related system of formulas or other
records or data shall be checked for accuracy. The degree and frequency of
input/output verification shall be based on the complexity and reliability of
the computer or related system.”
EU Annex 15 States:
“Facilities, systems, equipment and processes, including cleaning, should be
periodically evaluated to confirm that they remain valid. Where no significant
changes have been made to the validated status, a review with evidence that
facilities, systems, equipment and processes meet the prescribed requirements
fulfils the need for revalidation.”
The frequency of
Periodic Reviews based on the Complexity, Criticality, Novelty, and Operating
History of the computer system.
For example an automated control system
(Category 4 / 5) the computer system periodic review should be performed more
frequently than an off the shelf item. The frequency of review should be
defined with a minimum and maximum time between reviews. For example a scale of
1 to 4 years can be set for the review period.
Only new GAMP category 4 and 5 Computer Systems
would have an annual review period.
Category 4/5 is configurable software so
periodic review should be annually performed. For non-configurable systems
starting with a frequency of 2 years when first installed through to a maximum
4 years once a stable operating history is established.
Method of periodic review:
The first is the traditional periodic review of
the computer system which is performed at a predefined period.
The second is continual monitoring and trending
with a review report.
Periodic system review considers:
Physical & Logical security
Relevant Documentation (Incident, Deviation,
change control, SOP’s)
Backup, Restore& Disaster recovery
Validation Status
Inventory (system ID, location &
application software )
Audit trail
Periodic Review performed by
Process Owner – Laboratory
person who is responsible for the system
System Owner –Person
responsible for the availability and support of the system
IT – System/IT
Administrator
Quality Assurance
Benefits
of Computer System Periodic Review
Quality and the Business
Improve the operation
Maintain compliance
Support the continuous improvement
What other points are consider
in the Periodic Review?
·
Roles and Responsibilities
·
Service Agreements
·
Validation/Qualification and Project Deliverables:
·
System Control Procedures
·
Audit Trail management
·
Incidents, Problems
·
Changes, Upgrades
·
Security, User Access, User Administration
·
User Guides
·
Backup, BCP, Performance, Reliability Monitoring
·
System Access Training
· Archived Data
“Trust but Verify “ Ronald Reagan
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Data Integrity App |
Our Data integrity app will helpful for understanding what Data integrity & CSV really means & How 21 CFR Part 11, EU Annex 11 & other regulatory guidelines affects in pharmaceutical Industry.
- Basic Data Integrity Concepts
- ERES & Its Requirement
- CSV & Its best practices
- Mock Inspection and General Q&A
- Checklist for inspection
- Inspection Readiness
- Useful SOP’s
- Stay Regulatory Compliant.
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