It has been considerably enhanced and restructured, following principles and recommendations defined by the Industry Board. However one must remember GAMP 5 is only a guide.
The regulators mandate that all good automated manufacturing processes and methods used to produce a regulated product must be documented and be company approved. The original SOP once approved will reside in a safe and secure location in change control this is a regularly audited requirement.
It really depends on your company practices and procedure which also must be documented and approved as to whether the GAMP 5 doctrine is in electronic format with; or without, e signatures. Security of this document is initially by physical access and then by a series of cascading passwords. The cascade must ensure that the person accessing the document can only access the document to the level that the company has authorized.
Continuous control of all issued copies must be maintained by change control. Change control must at all times another regularly audited point know the location of all the SOP copies in circulation and must have the capability to be able to recall them for incorporation of amendments or destruction. As an auditor, I have audited for these features for many years and I have never found a case of un-authorized SOP changes.
At the time that GAMP4 was issued firmware was considered to be used for simple instruments. However as technology has advanced the it has been recognised that complex software can be embedded firmware within systems. Vendor documentation, including test documents may be used as part of the verification documentation, providing the regulated company has assessed the vendor.
This implies a level of governance to be applied over suppliers independent of the maturity or complexity of the software. In V - Model development and testing process are kept quite separate.
It is not as reliable as Agile Model. Annex 11 is part of the European GMP Guidelines and defines the terms of reference for computerised systems used by organizations in the pharmaceutical industry.
Annex 11 is a guideline and is key to compliance with GMP principles in EU directives regulations covering human and veterinary medicinal products. Computer system validation is a critical tool to assure quality of computer system performance. CSV enhances the reliability of system , resulting in fewer errors and less risk to process and data integrity.
It also reduces long term system and project cost by minimizing the cost of maintenance and rework. It is also known as Verification and Validation model. It is based on the association of a testing phase for each corresponding development stage.
Development of each step directly associated with the testing phase. Process validation means establishing by objective evidence that a process consistently produces a result or product meeting its predetermined specifications. Retrospective process validation is validation of a process for a product already in distribution based upon accumulated production, testing and control data. In its vanilla version, SharePoint would serve as a collaborative workspace only and would not be very useful for the management of electronic records that are subject to the regulatory restrictions of predicate rules because functionality for versioning, audit trails, and record restrictions are not enabled by default.
In other words, it is improbable that SharePoint would fall under this category. Even if it did, the intended use of this SharePoint instance would probably not have any regulatory purpose that would necessitate validation.
More importantly, certain functionality such as information management policies, auditing, and versioning must be configured if SharePoint is to be used in a 21 CFR 11 compliant manner for the management of regulated content e-records. In this case, SharePoint is configured to meet business process needs and, therefore, would be considered as a Software Category 4.
If specific configuration of out-of-the-box functionality is insufficient to meet business process needs, it may be necessary to customize SharePoint for the management of regulated content e-records. Using bespoke workflows and features would elevate the SharePoint instance to Software Category 5. Suppose you are able to clearly delineate which functions will be used in their native state vs. Then a "mix and match" approach could be used.
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