CSA Application

CSA Application :- In the dynamic landscape of the pharmaceutical industry, computerized systems are pivotal in various stages including drug development, manufacturing, quality control, and regulatory compliance. With technological advancements, the focus on ensuring the reliability, security, and compliance of these systems grows more paramount. Introducing Computer Software Assurance (CSA), a contemporary approach to Computer System Validation (CSV), addresses these evolving needs. In this blog post, we endeavor to address the following inquiries:

CSV (Computer System Validation)

The traditional approach to validating computer systems, termed Computer System Validation (CSV), has been a standard practice since the introduction of the United States Food and Drug Administration (FDA) 21 CFR Part 11 in 1997. However, technological advancements since then have significantly altered the landscape, marked by increased automation reliance, widespread adoption of 21 CFR Part 11-compliant solutions, cloud integration, and a shift away from company data centers toward managed server farms. These changes have introduced ambiguity, confusion, and inconsistency in CSV practices across the industry. Moreover, CSV has evolved into a process primarily aimed at providing evidence for auditors rather than ensuring system quality. Along the way, the mindset shifted to prioritize quantity over quality.

Recognizing the technological evolution and the associated gaps in guidance, the US FDA Center for Devices and Radiologic Health (CDRH) embarked on a mission to address these challenges through the “Case for Quality” industry collaboration initiative.

CSA Application (Computer Software Assurance)

The FDA has recently unveiled an article titled “Computer Software Assurance for Manufacturing, Operations, and Quality System Software,” marking the introduction of a groundbreaking approach known as Computer Software Assurance (CSA). This innovative framework challenges the conventional methods of Computer System Validation (CSV). CSA promotes a shift towards a more deliberate and risk-centric approach, focusing on core objectives such as patient safety, product quality assurance, and data integrity preservation. It’s essential to underscore that CSA pertains specifically to non-product systems.

What are some key differences between Computer Software Assurance (CSA) and Computer System Validation (CSV)?

From a technical standpoint, both CSV and CSA share the fundamental goal of delivering high-quality products to end users. However, there are nuanced distinctions between the two approaches. Here are some key differences and the advantages offered by CSA:

Extent of Evidence:

• CSV often entails excessive documentation with limited value addition to system quality. CSA addresses this issue by defining the purpose of objective evidence and establishing criteria for acceptable records.

Critical Thinking and Risk Classification:

• In many cases, system requirements are classified without considering the associated risk levels or critical business scenarios. CSA emphasizes the involvement of experienced Subject Matter Experts (SMEs) in determining risk classes and designing relevant test scenarios based on their expertise.
• Risk class designation is crucial as it informs the level of testing effort required. Higher risk classes demand greater attention and may necessitate more complex tests, while lower-risk aspects may be subjected to dynamic testing.

Commercial Off-The-Shelf (COTS) Systems and Supplier Validation Packages:

• CSA recognizes the significance of leveraging validation packages provided by COTS suppliers. Suppliers often offer comprehensive validation packages, and CSA recommends filtering relevant tests based on organizational requirements.

Streamlined Deployment Timeline:

• By reducing bureaucratic burdens and simplifying processes, CSA facilitates quicker deployment timelines. This approach optimizes resource utilization, time, and effort allocation without compromising quality.

CSA Application guidance addresses the following pain points:

Shift in Focus:

• CSV traditionally emphasizes extensive documentation at the expense of critical thinking and comprehensive testing. CSA instigates a paradigm shift by prioritizing critical thinking over excessive documentation. Through CSA principles, organizations can conduct more rigorous testing while minimizing documentation requirements.

Utilization of Vendor Data:

• CSA advocates for leveraging validated data provided by trusted vendors. This includes utilizing pre-audited vendor assessments and relying on vendor-tested software releases. For cloud-based solutions, vendor assessments stored in the cloud enable swift referencing, reducing the time and effort spent on subsequent validation processes.

Emphasis on Intended Use:

• Computer Software Assurance directs focus towards validating software based on the manufacturer’s intended use. Unlike CSV, which may overlook out-of-the-box features of Software as a Service (SaaS) systems until client implementation, CSA emphasizes clearly defining the system’s intended focus to streamline validation efforts.

Adoption of Risk-Based Testing:

• CSA advocates for a streamlined risk assessment process, departing from traditional Failure Mode Effect Analysis (FMEA) methods that demand extensive time and effort. Instead, CSA recommends a simplified risk assessment framework focusing on the potential impact on user safety and product quality, as well as the implementation method of the functionality.

Unscripted Testing:

• Unlike the rigid click-by-click test scripts commonly associated with CSV, CSA encourages unscripted testing approaches. Unscripted testing allows testers to conduct free-form testing while documenting results without rigidly defined test steps. This approach reduces test script errors and enhances detection of functional irregularities, ultimately improving system testing effectiveness.