Session T3-1, Track 3 “Computerized Systems Validation in ... t3-1_kim nitahara.pdfMay 17, 2011...
Transcript of Session T3-1, Track 3 “Computerized Systems Validation in ... t3-1_kim nitahara.pdfMay 17, 2011...
Session T3-1, Track 3 “Computerized Systems Validation in the e-Clinical System’s Life Cycle
May 17, 2011 | Beijing, China
Kim NitaharaPrincipal Consultant and CEOMETA Solutions, Inc. (USA)
• To understand the requirements and processes for the validation of computerized systems used in clinical
Purpose of this session:
computerized systems used in clinical trials
• To review key issues related to computerized e-clinical systems validation
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• What is a computerized system?
• What is computerized systems validation?
Computerized Systems Validation Topics:
• What is computerized systems validation?
• What are the regulatory requirements for e-
clinical computerized systems validation?
• What does a validation include?
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What is a computerized system?• Hardware• Software• Trained Personnel
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• Procedures• Infrastructure and
Equipment
PIC/S PI 011-3 Good Practices for Computerised Systems in Regulated ‘GXP’ Environments)
“Confirmation by examination and provision of objective evidence that software specifications conform to
What is computerized system validation?
software specifications conform to user needs and intended uses, and that the particular requirements implemented through software can be consistently fulfilled”
(FDA Guidance: General Principles of Software Validation)5www.diahome.orgDrug Information Association
(another definition)
“Establishing documented evidence
What is computerized system validation?
Establishing documented evidence that a computerized system conforms with user requirements, and that it will continue to do so in the future”
(PMA/IEEE/Consensus Workshop)
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“The computerized systems should be
What are the Regulatory requirements for e-clinical computerized systems?
designed: (1) to satisfy the processes assigned to these systems…; and, (2) to prevent errors in data creation, modification, maintenance, archiving, retrieval or transmission.”
(FDA Guidance: Computerized SystemsUsed in Clinical Investigations IV.A)
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“The sponsor is responsible for
What are the regulatory requirements for e-clinical computerized systems?
p pimplementing and maintaining quality assurance… systems… to ensure that trials are conducted … in compliance with the protocol [and] GCP…”
(ICH E6 GCP Guidance)8www.diahome.orgDrug Information Association
“Validation of systems to ensure
What are the regulatory requirements for e-clinical computerized systems?
yaccuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records.”
(FDA 21 CFR 11.10a Controls for Closed Systems)
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• Ensure and document…validation.
What are the regulatory requirements for e-clinical computerized systems?
• Maintain SOPs for using these systems.• Maintain an audit trail…• Maintain a security system…• Maintain adequate backup of the data…”
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• Ability to Generate Accurate and Complete Copies
What are the regulatory requirements for e-clinical computerized systems?
• Protection of Records
• System Controls
• Validation
• Audit Trails
• Personnel Training
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(FDA 21 CFR 11.10 Controls for Closed Systems)
• Has the software been validated?
What are the regulatory requirements for e-clinical computerized systems?
• Who validated the software?• What was the process used to validate the
software?• How was the validation process documented?
(CP 7348.810 Sponsors, Monitors and CROs)
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• Computerized systems used to:- Create - Modify
Which systems should be validated?
- Maintain - Archive - Retrieve - Transmit
data intended for submission to FDA
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• Written Design Specification– “what the software is intended to do and how it is
What are the minimum requirements for computerized systems validation?
intended to do it”
• Written Test Plan– “structural and functional analysis”
• Test Results and Evaluation– “demonstrate the… specification has been met”
(Clinical Systems Guidance VIII.B.2 System Dependability)
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• “Software validation is a matter of developing a level of confidence”
What are the minimum requirements for computerized systems validation?
level of confidence• “The level of confidence, and therefore the level of
software validation, verification, and testing effort needed, will vary depending upon the safety risk(hazard) …”
(General Principles of Software Validation3.1.2 Verification and Validation)
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Example of risk evaluation
Source Record
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Monitoring Report
Query Log
Paper CRF
eCRF Data
“Risk”
• Validation Plan• Requirements Specification
User Functional Technical
What does a typical validation include?
– User, Functional, Technical
• Design Specification• Test Plans
– Completed Test Results
• Test Reports• Validation Report
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Example computer validation project documentation
ValidationPlan SOPs
Validation Summary
Report
Remediation Plans and
Results
Test Plans & Reports
(IQ/OQ/PQ)
VendorAudit
Compliance and Risk
Assessments
Employee Training Records
Software Documentation“Validation
Package”
• What is a computerized system?
What is computerized systems validation?
Summary of Validation Topics:
• What is computerized systems validation?
• What are the requirements for e-clinical
computerized systems validation?
• What does a validation include?
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• Computerized systems include hardware, software, trained personnel, SOPs, and infrastructure
Conclusions:
infrastructure• Regulations require e-clinical systems to
be validated to ensure that they will consistently and reliably meet the needs of the user performing the clinical trial
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• At a minimum, e-clinical systems validations require 1) a written design specification 2) a written test plan and 3)
Conclusions (continued):
specification, 2) a written test plan, and 3) documented test results that demonstrate that the specification has been met.
• The amount of validation effort should depend on the significance (risks) of the e-clinical system and data in a clinical trial
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Questions and discussiondiscussion
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