Software Validation
First Edition
© Copyright 2010 Premier Validation
All rights reserved. No part of the content or the design of this book maybe reproduced or transmitted in any form or by any means without the express written permission of Premier Validation.
The advice and guidelines in this book are based on the experience of the authors, after more than a decade in the Life Science industry, and as such is either a direct reflection of the "predicate rules" (the legislation governing the industry) or are best practices used within the industry. The author takes no responsibility for how this advice is implemented
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So what's this book all about?
Hey there,
This book has drawn on years of the authors' experience in the field of Software Validation within regulated environments, specifically Biotech and Pharmaceutical. We have wrote and published this book as an aid to anyone either working in the software validation field, as well as for anyone that is interested in software testing.
Every software validation effort seems to be a combination of checking procedures, updating procedures and reviewing good practice guides and industry trends in order to make the validation effort more robust and as easy as possible to put in place.
This can often be a tiresome and long-winded process with the techncial wording of each piece of legislation, the standards such as ASTM, ISO, etc. just seem to make us validation folks feel more like lawyers half of the time.
The purpose of this book is to try and pull all of that together - to make a Software Validaton book that is just written in an easy to understand language, to give help and guidance regarding the approach taken to validate the software whilst laying out an easy launchpad to allow users of the book to be able to search for more detailed information as and when it is required.
We hope that the information in this book will be as enjoyable for you to use, as it was for us to put together and that your next software validation project will be more welcomed than not.
So I think it's pretty clear, you've just purchased the Software Validation bible.
The brains behind the operation!
Program Director: Graham O'Keeffe Content Author: Orlando Lopez Technical Editor: Mark Richardson Editor: Anne-Marie Smith
Printing History: First Edition: February 2011 Cover and Graphic Design: Louis Je Tonno
Notes of Rights
All rights reserved. No part of this book may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, without the prior written permission of the copyright holder, except in the case of brief quotations embedded in critical articles or reviews.
Notes of Liability
The author and publisher have made every effort to ensure the accuracy of the information herein. However, the information contained in this book is sold without warranty, either express or implied. Neither the authors and Premier Validation Ltd, nor its dealers or distributors will be held liable for any damages to be caused either directly or indirectly by the instructions contained in this book
Published by Premier Validation Ltd Web: www.premiervalidation.com Forum: www.askaboutvalidation.com Email: [email protected]
ISBN 978-1-908084-02-6
Table of Contents
Purpose of this Document 1
What is Software Validation? 2
Why Validate? 3
Validation is a Journey, Not a Destination 5
Planning for Validation
1: Determine What Needs to be Validated 7
2: Establish a Framework 10
3: Create a Validation Plan for Each System 13
Software Development Life Cycle 16
Validation Protocols
Validation Protocol 23
Design Qualification (IQ) 24
Installation Qualification 25
Operational Qualification (OQ) 29
Performance Qualification (PQ) 31
Other Test Considerations 32
Validation Execution
Preparing for a Test 41
Maintaining the Validated State
Assessing change 50
Re-testing 54
Executing The Re-test 56
Reporting 56
Special Considerations
Commercial 58
Open Source Systems 62
Excel Spreadsheets 63
Retrospective Validation 65
Summary 66
Frequently Asked Questions 67
Appendix A: Handling Deviations 72
Appendix B: Handling Variances 74
Appendix C: Test Development Considerations 77
Appendix D: Capturing Tester Inputs and Results 81
References 84
Glossary 85
Purpose of this Document
This document addresses software validation for support systems—that is, systems used to develop, deliver, measure, maintain, or assess products such as, Document Management Systems, Manufacturing Execution Systems (MES) and CAPA applications; manufacturing and control systems. The main purpose of this document is to help you establish a solid validation process.
The validation procedures in this document address software that is vendor supplied, Commercial Off-The-Shelf (COTS), internally-developed software, or a hybrid (customized COTS software).
Throughout this document, “best practices,” which although are not required but have been proven to be invaluable in validating software, will be noted by a hand symbol as shown here.
Software validation is a comprehensive and methodical approach that ensures that a software program does what it's intended to do and works in your environment as intended. Some software vendors verify that the requirements of the software are fulfilled but do not validate the entire system (network, hardware, software, processing, and so on).
Verification is a systematic approach to verify that computerised systems (including software), acting singly or in combination, are fit for intended use, have been properly installed, and are operating correctly. This is an umbrella term that encompasses all types of approaches to assuring systems are fit for use such as qualification, commissioning and qualification, verification, system validation, or other.
What is
Regulations often drive the need to validate software including those required by:
- the United States Food and Drug Administration (FDA); - the Sarbanes-Oxley (SOX) Act;
- the European Medicines Agency (EMEA) (see Eudralex)
All countries and regions around the world have their own set of rules and regulations detailing validation requirements: EudraLex is the collection of rules and regulations governing medicinal products in the European Union; FDA is the US equivalent and in Japan it is the Japanese Ministry of Health & Welfare
Additionally, companies operating under standards such as ISO 9001 and ISO 13485 for medical devices also require software validation.
But over and above regulations, the most important reason for software validation is to ensure the system will meet the purpose for which
A robust Software validation effort also:
- Utilises established incident management, change management and release management procedures both operationally and to address any errors or system issues.
- Demonstrates that you have objective evidence to show that the software meets its requirements;
- Verifies the software is operating in the appropriate secure environment;
- Shows that any changes are being managed with change control (including the managed roll-out of upgrades) and with roll-back plans, where appropriate;
- Verify the data used or produced by the software is being backed up appropriately and can be restored.
- Ensures users are trained on the system and are using it within its intended purpose in conjunction with approved operating procedures (for commercially-procured software, this means in accordance with the manufacturers' scope of operations);
- Ensures that a business continuity plan is in place if a serious malfunction to the software or environment occurs.
Being in a validated state, by the way, does not mean that the software is bug-free or that once it's validated, you're done. Systems are not static.
Software patches must be applied to fix issues, new disk space may need to be added as necessary, and additions and changes in users occur. Being in a “validated state” is a journey, not a destination. It's an iterative process to ensure the system is doing what it needs to do throughout its lifetime.
Note: Any changes to the validated system must be performed in a controlled fashion utilising change control procedures and performing documentation updates as necessary. The documentation must be a reflection of the actual system.
Validation is a Journey,
Not a Destination
Planning for Validation
As with most efforts, planning is a vital component for success. It's the same for validation. Before beginning the validation process, you must:
1. Determine what needs to be validated; 2. Establish a framework;
The first step is to create an inventory of software systems and identify which are candidates for validation. A good rule of thumb is to validate all software:
· That is required to be validated based on regulatory requirements; · Where there is a risk and where it can impact quality (directly or
indirectly).
This could include spreadsheets, desktop applications, manufacturing systems software, and enterprise-level applications. If your organization is small, this should be a relatively easy task. If you have a large organization, consider breaking up the tasks by functional area and delegating them to responsible individuals in those areas.
Risk Management
Validation efforts should be commensurate with the risks. If a human life depends on the software always functioning correctly, you'll want to take a more detailed approach to validation than for software that assesses color
1
Determine What Needs
to be Validated
If quality may be affected or if the decision is made that the system needs to be validated anyway, a risk assessment should be used to determine the level of effort required to validate the system. There are various ways to assess risk associated with a system. Three of the more common methods are:
· Failure Modes Effects and Analysis (FMEA) – an approach that considers how the system could fail with analysis of the ultimate effects;
· Hazard Analysis – a systematic approach that considers how systems could contribute to risks;
· Fault Tree Analysis (FTA) – a bottom-up approach looking at specific faults (failures) and identifying what happens to realize the fault.
For each system assessed, document the risk assessment findings, the individuals involved in the process, and the conclusions from the process.
Note: ASTM E2500 Standard Guide for Specification, Design, and Verification of Pharmaceutical and Biopharmaceutical Manufacturing Systems and Equipment is a very useful tool for developing a risk based approach to validation and achieving QbD (Quality by Design). Similarly, ISO 14971 is a good reference for general risk management.
Formal risk assessments provide a documented repository for the justification of approaches taken in determining the level of validation required and can be used in the future for reference purposes.
During the risk assessment, items that may lead to problems with the system, validation effort or both should be addressed; this is called risk mitigation and involves the systematic reduction in the extent of exposure to a risk and/or the likelihood of its occurrence (sometimes referred to as risk reduction).
A system owner should be appointed overall responsibility for each system – this person will be knowledgeable about system (or the business/system requirements for new systems) The person who purchased the product, or the person responsible for development of the system will usually become the system owner – this person will be a key representative at any risk assessment.
Document all decisions in a formal risk assessment document and make sure it is approved (signed-off) by all stakeholders including the System Owner and QA.
2
Establish a Framework
When building a house, the first thing you must do is create a blueprint. A Validation Master Plan (VMP) is a blueprint for the validation of your software. The VMP provides the framework for how validation is performed and documented, how issues are managed, how to assess validation impact for changes, and how to maintain systems in a validated state.
The VMP covers topics such as: The scope of the validation;
The approach for determining what is validated (unless covered in a separate corporate plan, for example, a quality plan);
Elements to be validated (and how to maintain the list); Inter-relationships between systems;
Validation responsibilities; Periodic reviews;
Re-validation approaches;
The rationale for not validating certain aspects of a system (so you don't have to revisit your decision during audits);
The approach to validating these applications if your company has applications that have been in production but have not been validated (retrospective vs prospective)
Then validation approach to validate a system that is already commissioned and live, but not formally validated.
General time lines, milestones, deliverables and roles and responsibilities of resources assigned to the validation project.
The majority of the VMP is static. To avoid re-releasing the entire document, maintain specific elements to be validated and the top-level schedule in separate, controlled documents.
The VMP should include a section on training and the minimum level of training/qualification. This can either be a statement referring to a training plan or a high-level statement.
The VMP should also include, in general terms, the resources (including minimum qualifications) necessary to support the validation. Again, you don't need to take it to the level of, “Mary will validate the user interface application <x>. It should be more like, “Two validation engineers who have completed at least three software validation projects and XYZ training.” Resources required may include outside help (contractors) and any special equipment needed.
Error handling
Finally, the VMP should describe how errors (both in the protocols and those revealed in the software by the protocols) are handled. This should include review boards, change control, and so on, as appropriate for the company. For a summary of a typical deviation, see Appendix A. For a summary of protocol error types and typical validation error-handling, see Appendix B.
Well-explained, rational decisions (say what you do and do what you say) in the VMP can avoid regulatory difficulties.
Note: For regulated industries, a VMP may also need to include non-software elements, such as manufacturing processes. This is outside the scope of this
You must create a validation plan for each software system you need to validate. Like the VMP, the validation plan specifies resources required and timelines for validation activities, but in far greater detail. The plan lists all activities involved in validation and includes a detailed schedule.
The validation plan's scope is one of the most difficult things to determine due to multiple considerations including servers, clients, and stand-alone applications. Is it required that the software be validated on every system on which the software runs? It depends on the risk the software poses to your organization or to people.
Generally, all servers must be validated. If there are a limited number of systems on which a stand-alone application runs, it may be better to qualify each one (and justify your approach in the plan). Again, it depends on the risk. For example, if human lives might be at stake if the system were to fail, it's probably necessary to validate each one. You must assess the risks and document them in the appropriate risk assessment.
3
Create a Validation Plan
for Each System
The results of your risk analysis become activities in the validation plan or requirements in your system specifications (e.g. URS). For example, if the risk analysis indicates that specific risk mitigations be verified, these mitigations become new requirements which will be verified. For example, if a web application is designed to run with fifty concurrent users, however during stress testing it is identified that the system becomes unstable after 40 concurrent logins, then a requirement of the system must be that the system has adequate resources to accommodate all fifty users.
The validation plan must also identify required equipment and whether calibration of that equipment is necessary. Generally, for software applications, calibrated equipment is not necessary (but not out of the question).
The validation plan should specify whether specialized training or testers with specialized skills are needed. For example, if the source code is written in Java, someone with Java experience would be needed.
Finally, if the software is to be installed at multiple sites or on multiple machines, the validation plan should address the approach to take. For example, if the computers are exactly the same (operating system, libraries, and so on) then a defensible justifiable solution for validation across the installation base could be to perform installation verification (or possibly even a subset) of each location the software is installed. To further mitigate risk, OQ or parts of OQ could also be run, whatever the strategy it should be
documented in the VMP, Risk Assessment or both (without too much duplication of data).
For customised or highly-configurable software, your plan may need to include an audit or assessment of the vendor. This would be necessary to show that the vendor has appropriate quality systems in place, manages and tracks problems, and has a controlled software development life cycle.
If safety risks exist, you will be in a better defensible position if you isolate tests for those risks and perform them on each installation.
The VP/VMP are live documents that are part of the System Development Lifecycle (SDLC) and can be updated as required. Typical updates can include cross reference changes and any other detail that might have changed due to existing business, process or predicate quality system changes.
Both the development of software and the validation of that software should be performed in accordance with a proven System Development Lifecycle (SDLC) methodology.
A properly implement SDLC allows the system and validation documentation to be produce in a way such that a great level of understanding about the system can be gained by the design, implementation and validation teams whilst putting down the foundations for maintenance and managing changes and configurations.
There are many SDLC models that are acceptable and there are benefits and drawbacks with each. The important thing is that:
There is objective evidence that a process was followed;
There are defined outputs that help ensure the effort is controlled.
It's not always the case that a software product is developed under such controlled conditions. Sometimes, a software application evolves from a home-grown tool which, at the time, wasn't expected to become a system
Software Development
Life Cycle
Similarly, a product may be purchased from a vendor that may or may not have been developed using a proven process. In these cases, a set of requirements must exist, at a minimum, in order to know what to verify, and the support systems must be established to ensure the system can be maintained.
Let's look at a typical “V” development model:
In this model, the defined outputs of one stage are inputs to a subsequent stage. The outputs from each stage are verified before moving to the next stage. Let's look at the requirements and support stages a bit more closely. requirements analysis System testing High level design Integration testing Unit testing Detailed design implementation
The Requirements stage
Requirement specifications are critical components of any validation process because you can verify only what you specify—and your verification can be only as good as your specifications. If your specifications are vague, your tests will be vague, and you run the risk of having a system that doesn't do what you really want. Without requirements, no amount of testing will get you to a validated state.
How to specify requirements
Because systems are ever evolving—whether to fix problems, add a new capability, or support infrastructure changes—it's important to keep the requirements specifications (User/Functional and Design Specs) up to date. However, if requirements are continually changing, you run the risk of delays and synchronization issues and cost overruns. To avoid this, “baseline” your requirements specifications and updates so they are controlled and released in a managed manner. Well-structured specification documents facilitate upkeep and allow for the verification protocols to be structured so that ongoing validation activities can be isolated to only the changed areas and regression testing.
Requirements must be specified in a manner in which they can be measured and verified.
Use “shall” to specify requirements. Doing so makes verifiable requirements easy to find. Each requirement should contain only one “shall.” If there is more than one, consider breaking up the requirement.
It's easy, by the way, to create “statements of fact” requirements, which force the testing of something that adds little value. For example, “The user interface module shall contain all the user interface code.” Yes, you could verify this, but why? And what would you do if it failed? Completely restructuring the code would greatly increase risk, so it's likely nothing would be done. These types of requirements can still be stated in a specification as design expectations or goals, just not as verifiable requirements.
Requirements traceability
Part of the validation effort is to show that all requirements have been fulfilled via verification testing. Thus, it's necessary to trace requirements to the tests. For small systems, this can be done with simple spreadsheets. If the system is large, traceability can quickly become complex, so investing in a trace management tool is recommended. These tools provide the ability to generate trace reports quickly, “sliced and diced” any way you want.
Additionally, some tools provide the ability to define attributes. The attributes can then be used to refine trace criteria further. Attributes can also be used to track test status. The tracing effort culminates in a Trace Matrix (or Traceability Matrix). The purpose of a matrix is to map the design elements of a validation project to the test cases that verified or validated these requirements. The matrix becomes part of the validation evidence showing that all requirements are fully verified.
Tracing and trace reporting can easily become a project in itself. The tools help reduce effort, but if allowed to grow unchecked they can become a budget drain.
Requirements reviews
Requirements reviews are key to ensuring solid requirements. They are conducted and documented to ensure that the appropriate stakeholders are part of the overall validation effort. Reviewers should include:
· System architects, to confirm the requirements represent and can support the architecture;
· Developers, to ensure requirements can be developed; · Testers, to confirm the requirements can be verified;
· Quality assurance, to ensure that the requirements are complete;
Caution:
Validation Maintenance and Project Control
Support processes are an important component of all software development and maintenance efforts. Even if the software was not developed under a controlled process, at the time of validation the following support processes must be defined and operational to ensure that the software remains in a validated state and will be maintained in a validated state beyond initial deployment:
· Reviews (change reviews, release reviews, and so on); · Document control;
· Software configuration management (configuration control, release management, configuration status accounting, and so on); · Problem/incident management (such as fault reporting and
tracking to resolution); · Change control.
Design Qualification (DQ)
Installation Qualification (IQ)
Operational Qualification (OQ)
Performance Qualification (PQ)
Other Considerations
So now that you've assigned your testers to develop protocols to challenge the system and you have solid requirements, you must structure the tests to fully address the system and to support ongoing validation.
The de-facto standard for validating software is the IQ/OQ/PQ approach, a solid methodology and one that auditors are familiar with (a benefit). Not following this approach shouldn't get you written up for a citation, but expect auditors to look a little more closely.
Note:
Appendix C describes several aspects of test development. These are general An example V-Model Methodology Diagram is depicted above on page x of y
Design Qualification (DQ) is an often overlooked protocol, but can be a valuable tool in your validation toolbox. You can use DQ to verify both the design itself and specific design aspects. DQ is also a proven mechanism for achieving Quality by Design (QbD).
If software is developed internally and design documents are produced, DQ can be used to determine whether the design meets the design aspects of the requirements. For example, if the requirement states that a system must run on both 16-bit and 32-bit operating systems, does the design take into account everything that the requirement implies?
This, too, is generally a traceability exercise and requires expertise in software and architecture. Tracing can also show that the implementation fully meets the design. In many cases, this level of tracing is not required. It's often sufficient to show that the requirements are fully verified through test.
The DQ may also be used to address requirements that don't lend themselves to operations-level testing. These are generally non-functional, static tests. The concept is mostly out of system validations (for example, the system shall use a specific camera or a specific software library shall be
Design
Installation Qualification (IQ) consists of a set of tests that confirm the software is installed properly. IQ may verify stated requirements. Where this is the case, the requirements should be traced to the specific test objective(s).
There are three aspects to assessing IQ:
· Physical installation;
· Software lifecycle management; · Personnel.
Where the system is client-server based, both physical installation and software lifecycle management must be addressed. The client side is often the most difficult due to the difficulty of maintaining the configuration.
Physical installation
There are many factors that can be considered for software Installation Qualification, including:
Installation
· Type of processor (for example, 16-bit, 32-bit) on which the software will run;
· Available disk space;
· Support applications (including revisions); · Operating system patches;
· Peripherals.
A potential issue with some applications, especially those that are web-based, is the browser. If you're a Firefox user, for example, you've probably gone to some sites where the pages don't display correctly and you can see the full site only if you use Internet Explorer. These cases may require that every client configuration be confirmed during IQ.
Where commercial products or components are used, the requirements for them need to be well understood and, if not documented elsewhere, documented (and verified) in the IQ.
The “cloud” and other virtual concepts are tough because you haverelinquished control over where your application runs or where the data is stored. Does that rule out the use of such environments in a regulated environment? Not necessarily. Again, it comes back to risk.
If there's no risk to human life, then the solution may be viable. If the system maintains records that are required by regulation, it will take considerable justification and verification. And, as always, if the decision is
mitigated. In certain cases the Risk Assessment may require re-visiting.
Software Lifecycle Management
The IQ should assess the software's lifecycle management aspects to be sure that necessary support processes are in place to ensure the software can continually deliver the expected performance throughout its life. These include:
· General management processes (change management, software configuration management, problem management);
· Maintenance processes (backup and recovery, database maintenance, disk maintenance).
· Verification that appropriate Disaster Recovery procedures are in place.
These areas are more abstract than the physical aspects. It's fairly easy to determine if the specified amount of disk space is available. It's far more difficult to determine if the software content management system is sufficient to ensure the proper configuration is maintained across multiple branches. Clearly, though, these aspects cannot be ignored if a full assessment is to be made of the software's ability to consistently deliver required functionality. Most large companies have specialists that can help in these areas. If such specialists are not available, outside consulting can provide invaluable feedback.
externally. For example, if your company purchases and distributes a software package, you will need to accept problems from the field and manage them. You will likely pass on these problems to the vendor for correction. So, even if some processes are contracted out, it does not relieve you of the responsibility to ensure their adequacy.
Audits can be carried out either internally or externally to verify that software lifecycle components are being addressed and managed correctly. The finding of such audits is usually written-up in an audit report and may be cross referenced from a validation report as necessary.
Personnel
If the use of a system requires special training, an assessment needs to be made to determine if the company has the plans in place to ensure that users are properly trained before a system is deployed. Of course, if the system has been deployed and operators are not adequately trained, this would be a cause for concern.
Consider usage scenarios when assessing training needs. For example, general users may not need any training. Individuals assigned to database maintenance, however, may require substantial skills and, thus, training.
As part of any validation effort, training must be verified – an appropriate training plan must be in place to ensure that all users are trained and that any changes to systems or processes trigger additional training. All
Operational Qualification (OQ) consists of a set of tests that verify that requirements are implemented correctly. This is the most straight-forward of the protocols: see requirement, verify requirement. While this is a gross simplification—verifying requirements can be extremely challenging—the concept is straightforward. OQ must:
· Confirm that error and alarm conditions are properly detected and handled;
· Verify that start-ups and shutdowns perform as expected; · Confirm all applicable user functions and operator controls; · Examine maximum and minimum ranges of allowed values. · OQ Tests the Functional Requirements of the system.
OQ can also be used to verify compliance to required external standards. For example, if 21 CFR Part 11 is required, OQ is the place where the system's ability to maintain an audit trail is confirmed.
Be sure to have clear, quantifiable expected results. If you have vague
Operational
“Fast” is subjective. Verifiable requirements are quantifiable (for example, “Response time to a query shall always be within 15 seconds.” A good expected result will give the tester a clear path to determine whether or not the objective was met. If vague requirements do slip through, however, at least define something quantifiable in the test via a textual description of the test objectives.
Performance Qualification (PQ) is where confirmation is made that a system properly handles stress conditions applicable to the intended use of the equipment. The origination of PQ was in manufacturing systems validation, where PQ shows the ability of equipment to sustain operations over an extended period, usually several shifts.
Those concepts don't translate well to software applications. There are, however, good cases where PQ can be used to fully validate software. Web-based applications, for example, may need to be evaluated for connectivity issues, such as what happens when a large number of users hit the server at once. Another example is a database application. Performance can be shown for simultaneous access and for what happens when a database begins to grow.
Critical thinking about what could impact performance is key to developing a PQ strategy. It may well be the case that a PQ is not applicable for an application. The decision and rationale should, once again, be documented in the validation plan.
Performance
So if you do IQ, OQ, and PQ, do you have a bug-free system? No. Have you met regulatory expectations? To some degree, yes. You are still, however, expected to deliver software that is safe, effective, and, if you want return business, as error free as possible.
Generally, most validation functional testing is, “black box” testing. That is, the system is treated as a black box: you know what goes in and what's supposed to come out. (As opposed to white-box, where test design allows one to peek inside the "box," and focuses specifically on using internal knowledge of the software to guide the selection of test data.)
There are a number of other tools in the validation toolbox that can be used to supplement regulatory-required validation. These are not required, but agencies such as the US FDA have been pushing for more test-based analysis to minimize the likelihood of software bugs escaping to the customer. They include:
· Static analysis; · Unit-level test;
· Dynamic analysis; Easy to Understand Guide to oftware
Other Test
Ad-hoc, or exploratory testing; Misuse testing.
We'll briefly look at these tools. Generally, you want to choose the methods that best suit the verification effort.
Static analysis
Static analysis provides a variety of information, from coding style compliance to complexity measurements. Static testing is gaining more and more attention by companies looking to improve their software, and by regulatory agencies. Recent publications by the US FDA have encouraged companies to use static analysis to supplement validation efforts.
Static analysis tools are becoming increasingly sophisticated, providing more insight into code. Static analysis can't replace formal testing, but it can provide invaluable feedback at very little cost.
Static analysis can generate many warnings, and each must be addressed. This doesn't mean they need to be corrected, but you do need to assess them and determine if the risk of making changes outweighs the benefits. For “working” software, even a change to make variables comply with case standards is probably too risky.
Static analysis is best done before formal testing. The results don't need to be included in the formal test report. A static analysis report should,
retrieval. The report should address all warnings and provide rationale for not correcting them. The formal test report can reference the static analysis report as supplemental information; doing so, however, will bring the report under regulatory scrutiny, so take care in managing it.
Unit-level test
Some things shouldn't be tested from a user perspective only. Examples using this approach include scenarios where a requirement is tested in a stand-alone environment. For example, when software is run in debug mode and breakpoints are set, or verifying results via software code inspection.
Another good use of unit testing is for requirements that are not operational functionality but do need to be thoroughly tested. For example, an ERP system with a requirement to allow an administrator to customise a screen. A well-structured unit test or set of tests can greatly simplify matters.
Unit tests and test results are quality records and need to be managed as such. There are several methods you can use to cite objective evidence to verify requirements using unit-level testing. One way is to collect all original data (executed unit tests) and retain in a unit test folder or binder (in document control). The test report could then cite the results. Another way is to reference the unit tests in formal protocols. Using this method, the unit tests can either be kept in the folder or attached to the formal protocols.
Version identifiers for unit tests and for referencing units tested greatly clarify matters when citing results. For example, revision A of the unit test may be used on revision 1.5 of the software for the first release of the system. The system then changes, and a new validation effort is started. The unit test needs to change, so you bump it to revision B and it cites revision 2.1 of the software release. Citing the specific version of everything involved in the test (including the unit test) minimizes the risk of configuration questions or mistakes.
Dynamic analysis
Dynamic analysis provides feedback on code covered in testing and is, generally, for non-embedded applications as the code has to be instrumented (typically an automated process done by the tool; instrumenting allows the tool to know the state of the software and which lines of code were executed – as well as providing other useful information) and generates data that has to be output as the software runs. The fact that the software is instrumented adds a level of concern regarding the results, but in a limited scope gives an insight into testing not otherwise possible.
Dynamic analysis is also best done prior to and outside the scope of formal testing. Results from a dynamic analysis are not likely needed in the
included. Again, referencing the report would bring it under regulatory scrutiny, so be sure it's very clear if taking that route.
Ad-hoc or exploratory testing
Structured testing, by nature, cannot cover every aspect of the application. Another area getting critical acclaim from both internal testing and from regulatory agencies is ad-hoc, or exploratory, testing. With a good tester (critical thinking skills), exploratory testing can uncover issues, concerns, and bugs that would otherwise go undetected, until the product hits the field.
We'll use an application's user interface as an example. A text box on a screen is intended to accept a string of characters representing a ten character serial number. Acceptable formal testing might verify that the field can't be left blank, the user can't type more than 10 characters, and that a valid string is accepted. What's missing? What if someone tries to copy and paste a string with embedded carriage returns, or a string greater than ten characters? What happens if special characters are entered? Again, the possibilities are nearly endless.
All scenarios can't be formally tested, so ad-hoc testing provides a vehicle to expand testing. This is largely informal testing carried out by the developer and SMEs to eliminate as many problems as possible before dry-running and demonstrating to the user base.
The problem lies in how to manage exploratory testing and reporting the results. All regulatory agencies expect protocols to be approved before they are executed. This is not possible with exploratory testing since the actual test results aren't discovered until the tester begins testing. This is overcome by addressing the approach in the VMP and/or the product-specific validation plan. Explain how formal testing will satisfy all regulatory requirements, and then exploratory testing will be used to further analyze the software in an unstructured manner.
Reporting results is more difficult. You can't expect a tester to jot down every test attempted. This would be a waste of time and effort and would not add any value. So, it's reasonable to have the tester summarize the efforts undertaken. For example, using the user interface example, the tester wouldn't report on every test attempted on the text box; instead, the tester would report that exploratory testing was performed on the user interface, focusing on challenging the text box data entry mechanism. Such reporting would be more suited to a project reporting mechanism and information sharing initiative rather than being formal validation testing.
All failures must be captured, so it's a good idea to include tests that failed into formal protocols. Additionally, encourage the tester to capture issues (things that didn't fail but didn't give expected results) and observations (things that may just not seem right). The change management process can control any changes required.
Misuse testing is a hybrid of formal testing and exploratory testing. For example, if software is running on a device that has a software-controlled button, misuse testing would include actions such as holding the button down, or rapidly pressing the button. Unlike exploratory testing, all tests attempted should be documented and the results captured in a formal test report.
People with general knowledge of the technology but not of the software makes good misuse testers. They aren't biased by any implementation details. If they do something “wrong,” it may be an indication of a potential problem with the software.
Preparing for a test
Executing and recording results
Reporting
Managing the results
Execution of validation protocols is pretty straightforward: follow the protocols. Of course, few things go as planned, so in addition to discussing the basics of execution, we'll also discuss how to handle anomalies.
Before jumping into protocol execution, conduct a Test Readiness Review, before the start of each phase (before IQ, before OQ, and so on) ideally. This review assesses the organization's readiness to begin validation work. All requirements are reviewed to ensure both human and equipment resources are available and in the proper state (for example, testers are adequately trained, or equipment is available and within calibration).
The first step in preparing for a test is to establish the environment, which should be as close to “production” as possible. This means that the software is:
· Developed using a defined, controlled configuration management and build process;
· Installed according to the defined installation procedure; · Installed on production or production-equivalent equipment.
These elements would be part of the Test Readiness Review. If, for example, production-equivalent equipment is not available, the team could analyze what's available and determine if some or all of testing can proceed. Such risk assessments must be documented; the Test Readiness Review minutes are a good place.
In parallel, you must prepare to identify and allocate test personnel. Test personnel must be sufficiently trained, educated, and experienced to
personnel decisions are not arbitrary.
Furthermore, you must make sure test personnel are not put in conflict-of-interest positions. Ideally, a separate QA team should be used. Clearly, members of the development team should not be selected, but the lines get fuzzy quickly after that. Just make sure that your selection is defensible. For example, if a developer is needed to perform a unit test (typical, since QA folks may not have the code-reading skills of a developer), then ensure the developer is not associated with the development of that unit.
Note: It is absolutely forbidden for anyone to review AND approve their own work.
Executing and recording results
Record all test results using Good Documentation Practices (GDP)! A summary of what to capture is provided in Appendix D.
Minimize annotations, but don't hesitate to make them if it helps clarify results or test efforts. For example, if a test is stopped at the end of one day and resumed the next day, an annotation should be made to show where and when (the day) testing stopped and where and when testing resumed.
Similarly, if a test is performed by multiple testers, a sign-off should be available for all testers. If this is not possible, then an annotation should be made indicating which steps were executed by whom, and which steps were performed by which tester.
If a screen shot is captured to provide evidence of compliance, the screen shot becomes a part of the test record. It's important, therefore, to properly annotate the screen shot. Annotations must include:
· A unique “attachment” reference (for example “Attachment 1 of VPR-ENG-001”);
· The tester's initials (or signature, if required by company procedures);
· The date the screenshot was taken;
· A reference to the test protocol and test step;
· Correct pagination in the form “page x of y” (even if a single page). Annotations must ensure complete linkage to the originating test and are in line with GDP.
Protocol variances are to be handled as defined in the VMP. Appendix B provides a summary of standard techniques. Company policies and procedures must be followed, as always.
Issues and observations should be noted by the tester. Support tools (for example, problem reporting systems) should be provided to facilitate such reporting, but do not need to be detailed in the test report since they don't represent a test failure.
Reporting
At its core, the test report summarizes the results (from IQ, OQ, and PQ) of the test efforts. Testers and reviewers involved in testing, along with test dates, should be recorded. In general, a report follows the following outline:
I. System Description
II. Testing Summary (test dates, protocols used, testers involved) III. Results
IV. Deviations, Variances, and Incidents V. Observations and Recommendations VI. Conclusions
In many cases, there will be variances (for example, the test protocol steps or the expected results were incorrect) and/or deviations (expected results not met), which should be handled in accordance with the VMP. Generally, variances and deviations are summarized in the test report, showing that they are recognized and being dealt with properly.
Failures, on the other hand, must be explicitly described and explained. For each failure, provide a link to the formal problem report. It's typical to summarize the results in the “Results” section of the report and then use an appendix to provide additional details (for example, a problem report tracking number).
situation the system runs extremely slow. Perhaps the requirements were met, but the customer or end user may not be happy with the application. Allowing recommendations in the report can highlight areas that may need further investigation before launch. The report should draw a conclusion based on objective evidence that the product:
· Sufficiently meets the requirements · Is safe (per verified risk mitigations)
· Can consistently fulfill its intended purpose (or not).
Observations and recommendations should be followed up by the development team.
If there are test failures, a risk assessment should be performed to determine whether the system can or cannot be used in a production environment. For example, if a requirement specifies that a response to a particular input is made within five seconds, but one response time comes back after five seconds, an assessment can be performed. If the team agrees that this is acceptable for production (and this is the only failure), the rationale can be documented in the test report (or release report), and the system can be accepted for production use. Of course, if the failure is in a safety-critical area, there's probably no reasonable rationale for releasing the system. (presuming it's justifiable).
If the validation effort is contracted out, however, the test report may not be available or appropriate to determine whether the system can be released with test failures—especially if the impact of some of the failures cannot be fully be assessed by the test team. In such cases, it's acceptable for a report addendum or a separate “release report” to be produced with the company's rationale for releasing the system (presuming it's justifiable).
Depending on the size of the system, multiple reports can be used as required. For example, a unit testing report may be issued after a batch of unit tests have completed; or on the other side of the scale there may be a requirement for each test to be reported on in its own right.
Managing the results
User requirements;
Supporting documentation (internal and external – user manuals, maintenance manuals, admin, and so on);
Vendor data (functional specification, FAT, SAT, validation protocols);
Design documentation; Executed protocols;
· An archive copy of the software (including libraries, data, and so on);
· Protocol execution results; · The test report;
· A known bug list with impact assessment.
Then, when the auditor asks whether the software has been validated, present the Validation Pack (or at least take them to the relevant library). You'll make his or her day.
Testing is done, the software is released, and you're making money. What could go wrong? Audits and auditors—the reality that everyone in a regulated industry faces. You can mitigate potential problems by preparing a Validation Pack that contains:
Assessing Change
Re-testing
Executing the re-test
Reporting
Maintaining the
Validated state
It's common knowledge that changes increase the risk of introducing errors. The current validation is challenged by:
· Any change to the system's environment;
· Any change to requirements or implementation;
· Daily use, as databases grow, disks fill, and additional users are added.
That's why it's critical to assess validated systems continually and take action when the validation is challenged. As stated earlier, validation is a journey, not a destination. Once you achieve the desired validated state, you're not finished. In fact, it's possible the work gets harder.
Maintaining
Change will happen, so you might as well prepare for it. Change comes from just about everywhere, including:
· Specification changes (users want new features, different modes); · Software changes (driven by specification changes and bug fixes).
Infrastructure changes (additions of new equipment on the network, changes to the network architecture, new peripherals installed, change from local servers to the cloud);
· System upgrades (auto- and manually-installed upgrades to the operating system, tools, and libraries);
· Interface changes (to front-end or back-end with which the system communicates, browser changes);
· User changes (new users, change of user roles, modification of user permissions);
· An aging system (databases grow, disks fill up, more users slow down the system);
· Expansion (the system needs to be installed and used at another site).
These are just a few examples. The answer is not to re-run all validation tests on a weekly basis. That would be a waste of time and money. So, how do you know what changes push you out of validation and require re-test?
Risk Assessment. The easiest changes to analyze are specification and software changes. They are, generally, controlled pretty well in terms of knowing when changes are made, the scope of the change, and the likely impact.
Assess each change in terms of risk to the existing validation results. Could the change affect the results of the test? If so, it's likely some re-testing is in order.
For software changes, it's important to understand the scope of the change and assess the potential impacts so you can define a rational regression test effort, in addition to the tests for the specific changes.
Timing releases
So, you can see that you should plan out updates and not push releases out on a daily or weekly basis. Of course, if a customer demands a new release, or there are critical bugs that need to be corrected, you don't want to delay installing it. But delaying releases saves time because you can do the re-test on a batch of changes where there are likely overlaps in testing.
Risk analysis and the Trace Matrix
Risk analysis is best facilitated through the Trace Matrix. Using the matrix enables you to:
· See what requirements were affected; · Identify related requirements;
· Establish the full regression test suite.
The applicable segments of the Trace Matrix should be used to document the rationale for the test and regression suite.
Indirect changes
How do you address indirect changes—that is, those changes that you may not have direct control over, or potentially not even know about?
Understand that anything your IT folks do may well have an impact on the validated states of your systems. So, the first order of business is to get friendly with your IT staff. Establish a working relationship with them so you'll be able to monitor their plans. This is not to be obstructive, it's just good planning. The earlier on in planning you can get involved, the less chaotic things will be after the changes are made. Dealing with a non-compliance audit because of an IT change will cost more than dealing with any potential problems up front.
Again, assess all changes in terms of system impact. Most likely, the IQ will be impacted and those tests may need to be developed before
re-For cases where the install base must be expanded (additional sites, additional equipment, and so on), you'll need to assess the level of validation required for each additional installation. If this has already been addressed in the validation plan, the effort should be consistent with the plan. If, however, it makes sense to expand the test effort based on experience, you should update the validation plan and perform the extra testing as required. If it's not addressed in the validation plan, perform a risk assessment, update the validation plan (so you don't have to re-visit the exercise should the need arise again in the future), and perform the validation.
General Observations
General observations are another source of input to the risk analysis.
Are customers or users complaining that the system is slower? Do some transactions time out? These factors may signify a degrading system. Don't ignore such complaints; monitor them closely. They could be leading indicators that the performance (PQ) is no longer adequate.
Re-testing
Risk assessment gives you a good idea what to re-test. But is that sufficient? Before launching the re-test effort, take a step back and re-read the VMP. Make sure that you're staying compliant with what the master plan says. Then, update the validation plan for the system. This will:
· Lay out what tests you plan to execute for the re-test;
· Provide the rationale from the risk analysis for the scope of the retest.
In most cases, not all tests in the validation suite will need to be re-run. For example, if the change is isolated to a user interface screen (a text box went from 10 characters long to 20 characters), you likely don't need to re-run IQ. Consider the back-end consequences, however, because it's possible that such a change fills up a database faster, so be sure to look at the big picture.
As mentioned previously, a well-structured test suite facilitates isolating the testing to a limited scope. For example, if you have a user
testing to just the UI protocol. If, however, you scatter UI tests throughout the functional tests, it may not be possible to test the UI in isolation and, depending on the change, may require all tests to be executed.
Regression testing
You may run into a case where something changed that was considered isolated to a particular function, but testing revealed it also impacted another function. These “regressions” can be difficult to manage. Such relationships are generally better understood over time.
The best advice is to look for any connections between any changes and existing functionality and be sure to include regression testing (testing related functions even though no direct impact from the known changes) in the validation plan. Better to expand test scope and find them in testing than let a customer or user find them.
Test Invalidation
Hopefully, you never run into a situation where something turns up that invalidates the original testing, but it's been known to happen.
For example, if calibrated equipment used in the test was found to be out of calibration in the next calibration update, there's no fault and deception, but you must re-run the test. Or, worse-case scenario, a test failed originally but the tester didn't write it up as a failure (due to fear, or
possible that this is a systemic issue and auditors may not have any faith in any of the results, so plenty of analysis and rationale will have to go into test scope reduction. In fact, this may even require a CAPA to fully reveal the root cause and fix the systemic issue. But better to find it, admit it, and fix it than have an auditor find it.
Executing the re-test
No matter how good your tests are structured, there will likely be some things that are simply out of scope. For example, if you structured your tests to isolate the UI (User Interface), and then had only minor change to the UI, it probably doesn't make sense to re-test the entire UI. Instead of writing a new protocol, one approach is to note which steps will be executed in the updated validation plan and then strike through the unused steps and mark as N/A (using GDP). The validation plan and mark-ups absolutely have to jive, so check and double-check. Explanatory annotations on the executed test (referring to the validation plan) also help.
Reporting
Report the re-test effort similar to the results from the original execution. Show that the re-validation plans were met through testing and report the results. Handle failures and deviations as before.
Commercial
Open Source Systems
Excel Spreadsheet
Commercial
Commercial applications have a supplier and, thus, the purchase falls under supplier management. This means the supplier must be approved, so you must have criteria to approve a supplier.
Since commercial software falls under regulatory scrutiny, part of the supplier approval criteria must include confirmation that the software is developed and maintained in a controlled manner.
Depending on the level of risk or how critical the application is, an assessment of the vendor's capabilities, including and up to an audit of the vendor, may be warranted. Any such assessment should be available in the Validation Pack. Supplier Assessments are common are in the validation world.
One of the issues when validating purchased software is how to verify large, commercial packages. Many companies purchase packages for enterprise-level systems—Enterprise Resource Planning (ERP), Manufacturing Resource Planning (MRP), Electronic Document Management System (EDMS), and so on. By nature, these are “do all” applications. Most companies use only a fraction of the capabilities and,
Some systems allow add-on applications to be built either by the provider or by the client. If you don't use certain built-in capabilities of an application, those capabilities need not be in the validation scope.
When you purchase software, you can: · Use it out-of-the-box;
Tailor it for use in your facility; Customize it.
Using out-of-the-box
Since validation is done on the system's intended use, for out-of-the-box systems, the testing part of validation would be only on how it's used in your facility (per your specifications on how you expect it to work).
Tailoring
Tailoring takes the complexity to the next level. In addition to testing for your intended use, you should also add tests to verify that the customized components function as required, consistently.
Frequently, systems allow you to define levels of security, or assign users to pre-defined levels of security (such as administrator, maintenance, engineer, operator, and so on). Part of the testing, in this case, would include that users are defined with the appropriate security access levels and the
Customizing
Customized systems are the most complex in terms of test effort. Customizations need to be thoroughly tested to ensure the custom functions perform as specified.
In addition, substantial regression testing must be performed to ensure that related areas of the base (out-of-the-box) functionality are not adversely impacted.
Due diligence
Regardless of how the software is incorporated into use, due diligence should be performed to get problem reports related to commercial software. These may be available online through the vendor site, or may need to be requested from the vendor. Once obtained, be sure to assess each issue against how the software will be used at your site to determine if concessions or workarounds (or additional risk mitigations) need to be made to ensure the software will consistently meet its intended use. This analysis and any decisions become part of the validation file.
For systems that are customized by the vendor, there may be proprietary information involved in implementing the customizations. Ensure that the contracts protect your Intellectual Property (IP).
Protecting yourself
With commercial software, especially mission-critical software, you are at risk if the vendor is sold or goes out of business. One way to protect your company is to put the software into an “escrow” account. Should the company fold or decide to no longer support the software, at least the software source can be salvaged. This has inherent risks. For example, now that you have the software, what do you do with it? Most complex applications require a certain level of expertise to maintain. This all needs to be considered when purchasing an application.
Documentation
A “How We Use the System Here” or "SOP (Standard Operating Procedure)" specification facilitates the validation effort regardless of how the system is incorporated into the environment. The validation plan specifies how commercial systems will be validated.
SOPs are written to detail how the system should be operated, everyone must follow the SOPs meaning that the system is used in a consistent fashion at all times.
Conventional wisdom says to stay away from open source systems. Many say that you can't expect quality when using an open source system.
From experience, however, a widely-used open source system is robust. So, you have to weigh the potential risks against the benefits. It's probably not a good idea to use an open source system for a mission-critical application.
The easy road is to avoid open source systems altogether. If, however, the benefits outweigh the risks you can probably expect some very critical scrutiny. Thus, your validation efforts will need to be extremely robust. Since the system is open source, you should plan on capturing the source code and all of the tools to build the system into the configuration management system. Testing should be very detailed and should include tests such as misuse, exploratory, and dynamic analysis.
Spreadsheets are a sticky issue. If you do any research, you'll see assertions such as, “You can't validate a spreadsheet.” The truth is, you can't validate the spreadsheet software (e.g Excel), but you can validate a spreadsheet. It's done quite frequently. But you need to take a rigid stance on usage. You must:
· Validate all formulas, macros, and data validation items;
· Lock down (protect) the spreadsheet to prevent changes (only data entry fields should be open for editing);
· Set up data entry fields to validate the data entered (numeric values should be bound, and so on).
There are arguments that a spreadsheet can be used without validation if the final results are printed out (and signed). This would constitute the “typewriter rule” for electronic records. However, when a spreadsheet uses formulas, the only way for this approach to be valid would be to manually verify each calculation. This would bypass the use of the spreadsheet, so
It is a common myth that according to 21 CFR, Part 11 (US FDA regulation on Electronic Records/Electronic Signatures), Spreadsheets cannot be validated for e-signatures. To do so, add-on packages are required. Whilst it is accepted that Microsoft Excel doesn't faciliate electronic signatures (yet!), other spreadsheet packages may be able to do so.
If a system has not been validated and isn't in production use and validation is required, a “retrospective” validation exercise needs to be performed, which is no different from a normal validation exercise (except that the validation of the system isn't incorporated into this initial project delivery). The concern is what to do if anomalies are revealed during validation.
This is a risk management exercise and is beyond the scope of this document. It is sufficient to say that any anomaly would need to be analyzed to determine if subsequent actions are warranted. Depending on the severity of the anomaly, actions such as customer notification or recall could be necessary. So, it's always better to validate before production use to minimize the likelihood of such drastic actions.
