Computerised System Validation: How to handle Legacy Systems?
Query / Discussion - Problems / Expectations
- Which systems are affected?
- Why have these systems not been adequately qualified?
- Retrospective qualification
Legacy Systems regulatory Requirements and Inspections
- Old systems, legacy systems and existing non-compliant systems - characteristics and problems
- Regulatory considerations
- Annex 11 and Annex 15
- PIC/S PI 011
- GAMP GPG: The Validation of Legacy Systems
- Inspection considerations
Legacy Systems: Ensuring Compliance from a QA Perspective
- Legacy systems: IT security / virus protection / data protection
- On-site infrastructure
- System-side IT components
- Qualification / validation of legacy IT systems
How to write URS for existing Systems
- How to write URS for existing Systems
- URS for existing systems: Waste of time or added value?
- Why creating URS is easier for existing systems
- Beyond the URS: the functional description
Case Studies: Contingency Planning / Support from the Manufacturer
- Initial situation for existing systems
- Manufacturer support: Hardware & software, Security Patches
- Mechanical spare parts
- How and what can be planned?
- What “unsolvable” dependencies exist?
What does risk-based Deployment mean for existing Systems?
- Suitability for use
- Learning from operational experience
- Importance of periodic evaluation and its results
- Quality efficiency
Old Systems, Legacy Systems and existing Systems - Data Integrity light?
- Brief overview of the ALCOA++ principles
- PIC/S PI 041-1: Data integrity
- General problems: inadequate knowledge of the pharmaceutical process and data flow, lack of data definitions, non-existent definition of the GxP relevance of the generated data
- Examples of problems with legacy systems and possible solutions
- Missing audit trail functionality vs. necessity of an operational audit trail
- Problems with user administration (no/too few users can be parameterized within the system)
- Data management: ring memory, system data on USB sticks/SD cards > how to deal with this?
Computerised System Validation: Maintaining Compliance during Operation
Welcome / Opening session: What the delegates expect?
- Overview of the Operation Phase
- Capturing delegates expectations
- Sharing and reducing to key points in groups
- Sharing with all delegates and tutors
Periodic Evaluation: Establishing a scalable PE strategy
- Objectives and intention
- Scope of Periodic Evaluation
- Periodic Evaluation: Between efficiency and effectiveness
- What information should be considered?
Handover
- Objectives and purposes
- Roles & Responsibilities
- Handover process
- Acceptance criteria
- Records and reports
Data Integrity in Operation
- ALCOA++ principles
- Technical controls vs procedural controls
- Data governance principles and responsibilities
- Data governance vs IT governance
- Governance pitfalls
Risk Management in Operation
- Risk management according to Q9(R1)
- Risk management applied to change management
- Risk management applied to incident and deviation management
- Keeping risk information up-to-date
Data Management in Operation & Business Continuity
- Understanding the data management processes
- Backup & Restore
- Archiving & Retrieval
- Disaster Recovery & Business Continuity
- Monitoring data management activities
- Records and reports
Change & Configuration Management in Operation
- Objectives
- Configuration management
- Change management
- Types of change
- Organizing effective operational change and configuration management
Incident, Problem & Deviation Management in Operation
- Objectives
- Incident & problem vs deviation
- Incident & problem management process
- Effective Root cause analysis
- Records and reports
CAPA Management in Operation
- CAPA objectives
- Correction vs prevention
- Process collaboration
- Records and reports
Service & Contract Management
- Objective of service and contract management
- Establishing a Service Level Agreement (SLA) and contracts
- SLA key topics
- Monitoring SLAs and contracts
- Records and reports
System Management / System Administration
- Objectives
- Roles & Responsibilities
- Activities to cover
- Records and reports
User Management & Access Control
- Objectives
- User management process
- User management pitfalls
- Records and reports
Security & Performance Monitoring
- Objectives
- Security areas of concern
- Efficient and effective performance monitoring
- Records and reports
Repair & Maintenance
- Objectives
- Points to consider
- Reporting
- Records
Patch & Update Management
- Between security, performance, and compliance
- Risk-based approach to patch and update management
- Patch and update management pitfalls
- Records and reports
Maintaining Cloud / SaaS compliance
- Objectives
- Required controls
- What and how to monitor
- Securing data availability
- Record and Reports
Audit Trail / Audit Trail Review in Operation
- Objectives of audit trail review during operation
- Process relevant vs administrative audit trails
- What to review & how to review
- Records and reports
Performing Periodic Evaluation
- Implementing a scalable approach
- Leveraging existing records
- Learning from the experience
- Securing operational reliability and capability
Retirement Management
- Retirement process objective
- Retirement planning
- Performing retirement
- Consideration to data migration
- Retirement report
Inspection Readiness
- MCO Benchmarking Exercise
- What are the problems with Handover?
- Identifying Risks for Computer Systems in use
- Creating a SLA – What are the key elements?