3-Day Boot Camp
SEPTEMBER 28 - 30 | CAROLYN TROIANO
Registration Includes:– Checklist of documents and the direction for how to create
– Course Material
– Exercises to get a grasp on practical approaches.
– Final Examination and Evaluation
– Training Certification
– Hands-On Training
– A course designed to completely immerse you in computer system validation. This course delivers comprehension of the regulations impacting your systems and hands-on practice writing validation documents. You will leave ready to lead efficient, effective, inspection– ready validation projects.
Please bring a laptop to boot camp. You will need internet access, spreadsheet and word processing applications and a PDF reader.
EXERCISES: Independent StudyThe following exercises will be included in the course content and can be completed at each attendee’s discretion. If completed before the end of the Boot Camp, the attendee may ask questions during any Q&A session. If completed after the Boot Camp, the attendee may ask questions via Compliance Trainings and a response will be sent as quickly as possible. Note that both questions and answers are provided for each exercise.
Exercise 1: Exploring the Regulations using the fda.gov website
Exercise 2: FDA Guidance for ER/ES
Exercise 3: Validation Master Plan (VMP) Writing
Exercise 4: Interviews and URS/FRS Writing
Exercise 5: IQ, OQ, PQ Test Protocol Writing
Exercise 6: RTM Writing
Exercise 7: VSR Writing
Exercise 8: Be the Consultant – Example of a Data Integrity Audit by FDA at a pharmaceutical manufacturer
CSV Final Exam: Completed at the discretion of the attendee. Note that both questions and answers are provided for each exercise. (100 Questions/Answers)
Computer system validation has been regulated by FDA for more than 30 years, as it relates to systems used in the manufacturing, testing and distribution of a product in the pharmaceutical, biotechnology, medical device or other FDA-regulated industries. The FDA requirements ensure thorough planning, implementation, integration, testing and management of computer systems used to collect, analyze and/or report data.
Electronic records and electronic signatures (ER/ES) came into play through guidelines established by FDA in 1997, and disseminated through 21 CFR Part 11. This code describes the basic requirements for validating and documenting ER/ES capability in systems used in an FDA-regulated environment.
In the early 2000s, FDA recognized they could not inspect every computer system at every regulated company and placed the onus on industry to begin assessing all regulated computer systems based on risk. The level of potential risk, should the system fail to operate properly, needed to be the basis for each company’s approach to developing a validation approach and rationale as part of the planning process. System size, complexity, business criticality, GAMP 5 category and risk rating are the five key components for determining the scope and robustness of testing required to ensure data integrity and product safety.
FDA’s recent focus on data integrity during computer system validation inspections and audits has brought this issue to the forefront of importance for compliance of systems used in regulated industries. These include all systems that “touch” product, meaning they are used to create, collect, analyze, manage, transfer and report data regulated by FDA. All structured data, including databases, and unstructured data, including documents, spreadsheets, presentations, and image files, audio and video files, amongst others, must be managed and maintained with integrity throughout their entire life cycle.
We will explore the best practices and strategic approach for evaluating computer systems used in the conduct FDA-regulated activities and determining the level of potential risk, should they fail, on data integrity, process and product quality, and consumer/patient safety. We will walk through the System Development Life Cycle (SDLC) approach to validation, based on risk assessment, and will also discuss 21 CFR Part 11 and the importance of managing electronic records and signatures appropriately.
We will also walk through the entire set of essential policies and procedures, as well as other supporting documentation and activities that must be developed and followed to ensure compliance. We will provide an overview of practices to prepare for an FDA inspection, and will also touch on the importance of auditing vendors of computer system hardware, software, tools and utilities, and services.
Finally, we will provide an overview of industry best practices, with a focus on data integrity and risk assessment that can be leveraged to assist in all your GxP work.
Why Should You Attend:
We have used our real-world experience to design a computer system validation course that not only meets FDA, ICH, and Eudralex expectations for risk-based validation, but also prepares you to implement these practices in your company. The standard operating procedures and validation templates used in class have already been proven at other companies.
We are focused on your comprehension and application of the CSV techniques that will result in efficient, effective, and inspection-ready validation initiatives.
|SEMINAR OBJECTIVES||WHO SHOULD ATTEND|
IT, QA, & Business Managers and Professionals who need to:
– Manage or participate on computer system projects requiring validation
– Create or approve CSV project deliverables, such as requirements documents, validation protocols (IQ, OQ, PQ), Test Plans, and Test Reports.
– Understand the process of computer system validation
– Author, implement, or upgrade CSV policies and procedures that utilize a risk-based approach to meeting the latest regulatory expectations
– Understand the FDA and international regulatory landscape around CSV
This seminar is intended for those involved in planning, execution and support of computer system validation activities, working in the FDA-regulated industries, including pharmaceutical, medical device, biologics, tobacco and tobacco-related products (e-liquids, e-cigarettes, pouch tobacco, cigars, etc.). Functions that are applicable include research and development, manufacturing, Quality Control, distribution, clinical testing and management, sample labeling, adverse events management and post-marketing surveillance.
Examples of who will benefit from this webinar include:
– Information Technology Analysts
– Information Technology Developers and Testers
– QC/QA Managers and Analysts
– Analytical Chemists
– Compliance and Audit Managers
– Laboratory Managers
– Automation Analysts
– Manufacturing Specialists and Managers
– Supply Chain Specialists and Managers
– Regulatory Affairs Specialists
– Regulatory Submissions Specialists
– Clinical Data Analysts
– Clinical Data Managers
– Clinical Trial Sponsors
– Computer System Validation Specialists
– GMP Training Specialists
– Business Stakeholders/Subject Matter Experts
– Business System/Application Testers
This seminar will also benefit any vendors and consultants working in the life sciences industry who are involved in computer system implementation, validation and compliance.
AGENDA - DAY 1
|Module 1: Computer System Validation (CSV) and the System Development Life Cycle (SDLC) Methodology|
– FDA Compliance and Guidance
– Other Regulations and Guidance (EMA, EU, MHRA)
– Exercise: Exploring the Regulations using the fda.gov website
Module 2: CSV Methods and Models
– GxP Systems
– Computer System Validation (CSV)
– Validation, Verification, and Qualification
– Common SDLC Methodologies
– GAMP 5 “V” Model
|Module 3: Software and Services|
– Computer Off-the-Shelf (COTS) Software
– Cloud Systems
– FDA’s “Case for Quality”
– Software as a Service (SaaS)
– Case Study: Cloud SaaS
– Platform as a Service (PaaS) & Infrastructure as a Service (IaaS)
– Single Sign On (SSO)
– Medical Devices and Software as a Medical Device (SaaMD)
– Software Quality Assurance (SQA) Plan
– Mobile Devices and Medical Application
– Spreadsheet Validation
Module 4: 21 CFR Part 11, FDA’s Guidance for ER/ES
– 21 CFR Part 11 Guidance
– Electronic Records/Signatures (ER/ES) Requirements
– Exercise: FDA Guidance for ER/ES
– Vendor Audit
Module 5: Data Integrity and Governance
– Data Life Cycle Approach
– Data Integrity
– Data Governance
AGENDA - DAY 2
|Module 6: CSV Planning|
– Validation Strategy Document (VSD)
– Validation Strategy Components
– Rationale for Validation Testing
– GAMP 5 System Categorization
Module 7: CSV Supporting Components
– Good Documentation Practices (GDPs)
– Organizational Change Management (OCM)
– CSV Policies and Procedures
Module 8: Risk-Based CSV
– Risk Assessment
– Risk Mitigation
– Exercise: Validation Master Plan (VMP) Writing
|Module 9: Clinical Trials|
– Clinical Trial Master File (TMF)
– Electronic Trial Master File (eTMF)
– Trial Master File Content
– Before the Clinical Trial Begins
– During the Clinical Trial
– After the Clinical Trial
Module 10: System Requirements and Design
– Requirements Development
– User Requirements Specification (URS)
– Functional Requirements Specification (FRS)
– Exercise: Interviews and URS/FRS Writing
– System Design/Configuration Management Specification
Module 11: IQ, OQ, PQ Test Planning and Execution
– IQ, OQ, PQ Purpose and Contents
– CSV Test Execution
– Exercise: IQ, OQ, PQ Test Protocol Writing
– CSV Test Summary Report
AGENDA - DAY3
|Module 12: Requirements Traceability Matrix (RTM)|
– RTM Purpose and Contents
– Exercise: RTM Writing
Module 13: Test and Validation Reports
– Validation Summary Report (VSR) Purpose and Contents
– System Acceptance and Release Notification
Module 14: Change Management
– Maintaining Validation Status
– Change Control Process
– Security and Access
– Audit Trail Review
– Incident Reporting
– Periodic System Review
– Disaster Recovery Planning
– Business Continuity Planning
|Module 15: System Retirement|
– Record Retention
– System Retirement Challenges
– Legacy Systems and Integration
– Data Migration
Module 16: FDA Warning Letters
– Regulatory Influences
– Regulatory Trends
– Critical Thinking
– Current Compliance and Enforcement Trends
– FDA Inspection Readiness
– Exercise: Be the Consultant
– Industry Best Practices
Q&A AND EVALUATIONS
Carolyn Troiano has more than 35 years of experience in computer system validation in the pharmaceutical, medical device, animal health, tobacco and other FDA-regulated industries. She is currently an independent consultant, advising companies on computer system validation and large-scale IT system implementation projects.
During her career, Carolyn worked directly, or on a consulting basis, for many of the larger pharmaceutical companies in the US and Europe. She developed validation programs and strategies back in the mid-1980s, when the first FDA guidebook was published on the subject, and collaborated with FDA and other industry representatives on 21 CFR Part 11, the FDA’s electronic record/electronic signature regulation.
Carolyn has participated in industry conferences. She is currently active in the PMI, AITP, and RichTech, and volunteers for the PMI’s Educational Fund as a project management instructor for non-profit organizations.
The boot camp by Carolyn Troiano was fantastic, both I and the QA Manager loved it and had extensive conversation afterwards about it. Thank you Compliance Trainings for bringing on board such wonderful expertGeneral Manager - Quality Assurance: Baxter
For me the training was useful in order to clarify requirements from the FDA in regards to the expectation for the Computerized System Validation process. I will definitely recommend this course to others.Manager – QA IT: Pfizer
Among the best training our team has ever attended. Well organized, full of good tips, actually provided useful information. The speaker clearly had appropriate experience. This course should be conducted regularly.Director Quality: Abbott