Always Validate Software Used for Data Acquisition in GMP
Remember: Any software system used for capturing GMP data must be validated to ensure accuracy, reliability, and regulatory compliance.
Why This Matters in GMP
In modern pharmaceutical manufacturing, electronic systems are commonly used to acquire, store, and report critical GMP data. Unvalidated software may contain errors, produce inaccurate data, or lack necessary audit trails. This undermines product quality and regulatory compliance. Software validation ensures the system performs as intended, under all operating conditions, and protects against data corruption. It is a cornerstone of data integrity and compliance with ALCOA+ principles. If the system fails or is manipulated, batch release decisions and product safety may be compromised. Hence, validation must cover the entire system lifecycle—from design to decommissioning.
Regulatory and Compliance Implications
FDA 21 CFR Part 11 and EU GMP Annex 11 require computerized systems used in GMP processes to be validated. WHO GMP and Schedule M also mandate validation of software for data collection and product release decisions. During audits, inspectors review validation protocols, risk assessments, qualification records, and change control logs. Lack of software validation can result in data integrity observations, 483s, or product holds. Regulators expect documented evidence that systems are tested, secure, and compliant with intended use requirements.
Implementation Best Practices
- Develop a software validation plan covering user requirements, functional specs, and risk assessment.
- Execute IQ/OQ/PQ protocols and retain all documentation in validation files.
- Control access to validated software and maintain complete audit trails.
- Revalidate systems upon upgrades, configuration changes, or extended usage.
- Train QA, IT, and end-users on software validation and data handling protocols.
Regulatory References
- FDA 21 CFR Part 11 – Electronic Records and Electronic Signatures
- EU GMP Annex 11 – Computerized Systems
- WHO GMP – Validation of Computerized Systems
- Schedule M – Validation and Electronic Data Systems