Review of IVT's 10th Annual
Computer and Software Validation Conference
With John Murray, FDA's Computer Compliance Expert
May 18-20, 2009
Video Update from John Murray on current status and
future of 21 CDR Part 11
The video is available for Lacompliance
Userclub Members. For
information, preview and registration,
click here
Plenary Lectures and 30 Workshops/Discussion Sessions
Addressed Everybody's Needs
This year's format of the annual conference
with plenary lectures and four parallel workshop sessions did
address the needs of beginners as well advanced validation experts.
The plenary lectures did address FDA updates and new trends. In 30
workshops and interactive discussion sessions attendees not only got
good recommendations from industry practioners but could also
discuss and work on development of validation documents. Most
remarkable was that FDA did not only provided a well recognized
speaker for the conference but also did send several attendees to
learn all details about compliance requirements for computers and
electronic records.
For those who could not attend, Dr. Ludwig Huber will
give a detailed summary with key findings and recommendations in an
audio
seminar.

The Chairman Dr. Ludwig Huber (middle) with FDA's
computer compliance expert John Murray (left) and Martin Browning.
Martin has been working for the FDA for several years and helped to
develop several key FDA documents, for example, the CFR 820. Like
Ludwig Huber also Martin was plenary speaker at all 10 annual IVT
CSV conferences.
Key Learnings
- Validation experts are advised to focus and
better define User requirement Specifications.
- Device industry still makes all types of mistakes
related to computer validation. The number of warning letters in this
area is increasing.
- The inspection focus for pharmaceutical industry
is on data integrity with an increasing numbers of 483s and warning
letters. The main question to be asked is: How can you demonstrate, that
your printed computer records have not been changed on the computer, and
if so, is there a reliable audit trail. In case of any doubt inspectors
will ask for electronic raw data and the procession steps to get to
final results,
- Several FDA employees did attend. the
conferences, for example, to learn how to detect falsification of
electronic records. This may be part of FDA's training program to detect
computer related fraud as announced by FDA's Edwin Rivera at the
International GMP conference two years ago.
- It seems that with the new Annex 11 European
legislation is ahead of FDA related to using software and computer
systems.
- With computer system validation becoming more and
more mature the questions are not that much much related to validation
principles any more but how can validation become more cost effective.
Using a risk based approach for all validation steps, leveraging vendor
validation efforts and standardizing validation processes with
procedures and templates used throughout an organization are the tools
to make validation more cost effective.
Attend Ludwig Huber's
audio
seminar to get all the details .
Conference Highlights - Plenary Lectures
- FDA's computer compliance expert John
Murray gave an overview on FDA's findings when reviewing
software and computer validation documents.
- Martin Browning, former FDA computer
expert, gave recommendations on how to comply with FDA
expectations for CSV and data integrity
- Conference Chairman Ludwig Huber informed the audience about
the new EU GMP Annex 11 on 'Using Computerized Systems'. A
comparison with FDA's Part 11 revealed that Annex 11 is more
complete. It addresses all aspects of Good Computer Compliance
Practices with focus on quality, integrity and trackability of
printed results to e-records.
- Sharon Strause gave practical answers to the never ending
question: How much validation is enough. Much of the answer
comes from risk management.
Conference Highlights - Workshop and
interactive Discussion Sessions
In about 30 sessions presenters gave a short
introduction to the related topic. After that attendees worked on
practical examples and case studies. Most presenters also made bonus
material available, for example, case studies, SOPs, checklists and
literature references.
- Monica Cahilly's workshop focused on optimizing
validation to ensure integrity of electronic records. She started with
examples of FDA 483s/Warning Letters related to integrity of electronic
records. Then she defined essential technical and procedural controls
for electronic data integrity. In the interactive part participants
reviewed case studiers of various examples to detect validation gaps.
- Yana Collins of Vertex did lead a workshop on
User Requirements. The importance of this topic has been brought up in
several other presentations, for example, by FDA's John Murray. In the
practical session attendees did apply various models to define URS.
- One of the best attended session was Ludwig
Huber's interactive discussion session on FDA requirements for audit
trail. Amongst the audience were at two FDA employees who wanted to
learn how to detect falsification of electronic records. Attendees did
go through various applications based on what they have learned and with
prepared graphical templates could easily decide which systems need
electronic audit trail. Ludwig Huber also handed out several bonus
materials, for example, and SOP and checklist for specification and
implementation of electronic audit trail.
- Viramy Ortiz discussed (existing) legacy systems.
She pointed out the importance of standardization for validation of
existing systems. In the interactive part attendees did get tools to
identify the validation scope and steps of legacy systems.
- Tyson Mew of Ofni Systems, inc, lead the workshop
'Conducting an Effective Gap Analysis of CSV Programs'. He started with
examples from FDA warning letters and then did go through the entire
validation process.
- Probably the best attended workshop was entitled
'Inspected! My Comapny! What to do?' by Sharon Strause. Sharon gave
recommendations preparation, conduct and follow up of FDA and other
inspections. In the interactive part participants discussed concerns
regarding FDA inspections.
- Barbara Nollau of Abbot did lead a discussion an
Risk Based Validation. She introduced the newly launched GAMP 5 model
with focus on risk management and supplier management.
- Ludwig Huber gave an overview on new regulatory
and industry guidelines related to validation of laboratory computer
systems. He specifically focused on USP <1058>, EU Annex 11 and .GAMP 5.
In the interactive session the attendees did get templates to develop
key validation documents for chromatographic data systems. As bonus
material attendees did get SOPs on implementing USP <1058> and a full
set of 9 validation examples for a chromatographic data system.
Selected photos with annotations
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Plenary lectures and four parallel
workshops and interactive discussion sessions was an ideal
forum for both beginners and advanced validation, IT and QA
specialists. |
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Each of the 10 annual conferes did draw
big cowds, For example, more than 300 attended the
conference in 2003 |
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FDA's John Murray told the adience about
most important mistakes the industry is making when
validationd software and computer systems
He also gave an update on the status of 21 CFR Part 11
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After public qestion and answer session
Jogh Murray also anwered individual questions |
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John Kirchner has been managing this
conference since 1999.
Here he talks to Sharon Srauss about organizing Sharon's
workshop on FDA inspections. . |
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I would like to thank
John Kirchner of IVT/CBI for inviting me as keynote speaker
and chairman. I also thank all attendees for great
discussions. . |
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