Road Map For CSV

CSV (Computerized System Validation)
Demands
FDA 21 CFR Part 11

GAMP 5
WHO
Problems cited from regulatory bodies
To meet these varied and global needs, pharmaceutical
manufacturers must
Manage consistent computer system validation and

system testing efforts across multiple projects and
multiple sites
Enable effective system inventory control, change
management, periodic evaluations, and validation to
ensure sustained compliance
Manage just-in-time deployment of qualified resources
to the right places
Provide global round-the-clock access to a validation
and testing center of excellence
Provide onsite and offshore validation and testing teams
that bring necessary skills at attractive cost.
Challenges
Defined roles and responsibilities of CSV Team.
Missing information: Documents or records omitted fundamental information or
content that should have been included.
Lack of Common Strategy: It was observed that companies have different computer
validation strategies for different areas in same plant or premises. This created a
museum of policies and procedures often confusing the implementer or user.
Inconsistency: Documents contained statements inconsistent with other statements
about the same topic in the same document or in the same validation package.
Lack of needed detail: This deficiency applied mostly to requirements documents. The
requirements in the validation package did not adequately describe the characteristics
of data, user interactions with business processes, or key processes internal to the
software.
Traceability: Most frequent traceability issues:
o Vendor depended action will not rectified during CSV Project
Recommendations
o Individually Performed
o GAP Assessment
o Functional Assessment
Challenges on the Way to the Target State
Challenge I. Standards: Various standards exist across the organization. Policies,
procedures, work instructions, and templates vary by business, department, or site.
Significant costs result from overlapping SOPs and inconsistent standards, which make
sharing of assets difficult. Industry-wide standard methodologies, guidelines, and tools
have been issued by global organizations, such as ISPE and ICH, but in order to make the
assets applicable to a wide range of companies, processes, systems, and products, they did
not replace the more detailed, localized standards.
Challenge II. Interpretation: A significant cost to validation projects is caused by long
debates among the various authors and reviewers, rework, and inconsistent interpretation
of standards and requirements. Most regulations include very high-level statements that
set objectives, but dont specify how to implement the controls or how much is good
enough. For example, 21 CFR Part 11 (11.10 (d)) requires Limiting system access to
authorized individuals. This one statement can be expanded to varied requirements for
technical security controls and procedural controls for managing access.
Challenge III. Organization and Governance: Many companies still have decentralized
governance and uncontrolled execution. The ownership and management of validation
activities vary from project to project and from one department to another. Projects are not
handled consistently with clear roles and responsibilities. Some are led by IT, other by
users or quality
Challenge IV. Efficiency Across Sites and Departments: Site-to-site efficiencies have
not been achieved due to site- and department-specific procedures, templates, and
interpretation.
Challenge V. Execution: Excessive rework being done by validation teams. Most often,
the rework is a result of different opinions and styles of project team members and
inconsistent quality of work that is done by unqualified individuals. A common scenario is
that individuals perform work that doesnt align with their level and skills. On the other
hand, highly-qualified, expensive resources performing low-level mechanical tasks,
because a fixed team is assigned to the project and must share the workload.
Challenge VI. Tools: System life cycle assets, such as templates, outlines, forms, and
guidance documents are often inconsistent across departments and are not targeted to
drive value. They are put in place to minimize the risk of project team members taking
shortcuts and skipping sections, but are not flexible and drive unnecessary efforts with
minimal value to quality or compliance.
Challenge VII. Training: Training is usually conducted within each business on standards
and processes; however, there is minimal coaching and guidance. The short training that is
usually provided is rarely enough to qualify individuals without coaching and support until
they gain hands-on experience. Often multiple training sessions have to be taken in a very
short period of time, where the individuals ability to absorb, understand and retain the
materials is in question.
Challenge VIII. Personnel: Working with many life science companies shows that usually
there are capable, knowledgeable central validation groups, but weaker decentralized
execution groups. CSV standards are often deployed without the appropriate training and
coaching and without assurance of consistent interpretation. Organizations believe that
simply reading standard operating procedures (SOPs) and receiving a few hours of training
enable individuals to follow a consistent approach.
Implementing a Global Delivery Model
Implementing a global delivery model must be done carefully and in stages. Working with an
experienced partner will prevent failure and disappointment. The process should be handled
in stages over a period of time. The implementation duration would vary from one company to
another, depending on its maturity with regard to best practices, the level of harmonization
across the enterprise, and the overall level of integration between sites. We normally
recommend a five-phase approach:
Phase 1: Start with initial on-site engagements to allow the pool of resources, which will
be the global team, to interface with key stakeholders at the site and active projects.
Phase 2: Establish repeatable processes to begin to accrue competitive advantages:

compliance, quality, reliability, consistency, responsiveness, lower cost.
Phase 3: Adopt a defined Global Delivery Model for pilot department, operating company
or selected set of technologies.
Phase 4: Expand Global Delivery Model globally under a quantitatively managed process
for continuous improvement.
Phase 5: Optimize the Global Delivery Model process to assure global compliance,
maximum efficiency, and strategic differentiation.

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CSV (Computerized System Validation)

FDA 21 CFR Part 11

Manage consistent computer system validation and

Phase 2: Establish repeatable processes to begin to accrue competitive advantages:

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