For electronic quality management systems, i.e. document control, corrective action, customer complaints, where all information is kept digital and interfaced on the computer, generally I use GAMP5 for computer system validation (CSV)
https://ispe.org/publications/guidance-documents/gamp-5. The FDA guidance as cited is helpful, but if you really want to know the ins and outs of software validation in supporting roles of quality management systems GxP processes GAMP5 is fairly comprehensive. Keep in mind GAMP5 was generated for the pharmaceutical industry, so you will have to adjust as necessary if working in medical device area.
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Richard Vincins RAC
Vice President Global Regulatory Affairs
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Original Message:
Sent: 18-Sep-2019 14:17
From: Kevin Randall
Subject: Software Validation
When I validate QMS software applications (off-the-shelf or designed in-house), I also now apply ISO/TR 80002-2 in addition to GAMP 5 and FDA's guidance document, as ISO/TR 80002-2 is recommended regarding ISO 13485:2016 clauses 4.1.6, 7.5.6 (fourth paragraph), and 7.6 (sixth paragraph).
Hope this helps,
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Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
Principal Consultant
ComplianceAcuity, Inc.
Golden CO
United States
www.complianceacuity.com
Original Message:
Sent: 18-Sep-2019 13:05
From: Meghan Moore
Subject: Software Validation
Hello -
I am new to software validations. Where should I start when learning about and considering validating software that is used under the QMS? My company will be moving to a new management system but I am unsure how to support from a regulatory perspective to get SAP validated.
Thank you,
Meghan Moore
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Meghan Moore
Regulatory Affairs Specialist
Andover MN
United States
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