When we talk about validation and the requirement to validate even the simplest of software solutions, there is nearly always a negative, resistant atmosphere created straight away. Furthermore, even though the art of validation has evolved as have rules, regulations, best practices and various methodologies. Validation is a lifecycle which is living and breathing, it has matured with age and doesn’t have to be cumbersome anymore.
Whether you’re validating some simple equipment as part of a process or validating a large computerised system supporting 20,000 global users, a robust tried and tested method will serve you equally as well. The industry has moved into taking a risk based approach to validation and this makes perfect sense; adopt a proficient risk management methodology, identify your risks what can’t be easily and safely mitigated can built into the systems requirements and you’re more or less good to go.
Myth Based Approach to Validation
For years a lot of pharma businesses have taken the approach that in order to satisfy regulatory expectations that everything should be validated all of the time, this is simply not the case; in most instances validating everything, everytime is just a waste of time, money, human resources and the various rain forests of the world.
I don’t know whether this has yielded as a result of validation or quality personnel being afraid they’ll be blamed if something were to go wrong, or whether the governing corporate policies and procedures, especially of the largest pharma companies have interpreted the predicate rules in an ‘overkill’ fashion to cover their own backs in the long run. Either way, it doesn’t matter – as long as the risk assessment or assessments are facilitated properly and the right mix of stakeholders and subject matter experts (SMEs) attend then there should be no issue.
Use a Proven Methodology
There are numerous approaches to risk management and I think that the ASTM Standard “E2476 – Standard Guide for Risk Assessment and Risk Control as it Impacts the Design, Development, and Operation of PAT Processes for Pharmaceutical Manufacture” is a very good document and will provide anyone new to risk management with a lot of valuable information, not least about the process of risk management but there is also a lot of very critical references within this standard that are also invaluable. This information in this standard will be beneficial to anyone, regardless of their experience in the field of risk management.
One of the most important aspects of risk management is to get the right mix of SMEs, for example if a project was raised to install, say 5 additional controllers to a SCADA system to reduce the risk of the existing controllers being at the maximum level of usage most of the time, a good risk assessment would provide the basis for determination of the level of validation required. Firstly you’d probably already have a validation framework and documentation repositories that would cater for the change, but who would you invite to the meeting?
Skill Sections VS Actual Skills
An automation resource would be a good starting point, but after review – you’d need both a software and hardware engineer, why? Because these two people see the change as two different things, the software guy is concerned with programming of the hardware; the hardware guy is concerned about the capability of the hardware and the operating environment. From a software point of view, the controller can be managed from the data centre or via remote desktop through the associated software application, but this wouldn’t be accessible without the hardware having firstly been basically configured and installed. In addition, without an IT SME we wouldn’t know truly whether the network can facilitate the change; we’d need an operations SME to help co-ordinate any potential downtime that this new installation might take and we’d need quality and validation staff to prepare and approve documentation.
The bottom line is to remember that people see things from different angles – and quite rightly so! The more time spent up front on the risk assessment means that the validation effort is reduced and usually more robust to go with it. Try and get the relevant stakeholders on board and get them to agree to supply you with your SMEs, if this is a problem for whatever reason, such as people are on different shifts or busy in other areas when you need them then consider holding multiple risk assessment meetings so that all stakeholders and SMEs are involved formally and everything has been covered. A few risk assessments of between 1 and 2 hours each is nothing in terms of time being well spent, without these the validation effort could be exponentially greater not to mention the risk of risk.
A Pointer in the Right Direction
If you’re unsure where to start, ITIL and PRINCE2 have risk management methodologies. ICH Q9 is a Guideline for Quality Risk Management and there are many risk management sources and concepts listed in the E2476 standard (as mentioned above), GAMP also has a section on risk management. If your company already has procedures in place and you think they’re cumbersome, overkill or both – trying reading up of the sources of the methodologies outlined. You may well be surprised and find that they do actually facilitate a lean, risk based approach to risk management if you understand the overall subject matter better.