Failure to Validate Software


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Warning Letter: Software not validated (ucm165771)

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Some system components on the part lists were not depicted on the [redacted] drawings of the water purification systems installed at the [redacted] dialysis sites. Your computer software used to perform the [redacted] calculations has not been validated.

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Warning Letter: Failure to provide documentation for validation (ucm181430)

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Purchase software specific to contact lens firms, which has quality system modules. You stated that you had purchased the software and planned to have it installed by January 2009, with implementation and validation within 5 to 6 months. However, you did not provide any documentation regarding the software system, the validation plan, or your firm’s plan to train personnel on the use of the system.

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Warning Letter: Failure to validate computer system (s7045c)

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Failure to establish written procedures for production and process control designed to assure that the drug products have the identity, strength, quality, and purity they purport or are represented to possess [21 CFR § 211.100(a)]. For example, your firm’s automated packaging line processes and their respective software systems have not been validated .

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Warning Letter: Failure to maintain validation documentation (s6847c)

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“Specifically, your firm has not conducted quality audits and established adequate procedures for … acceptance activities and computer software validation … your firm has not established written procedures describing how it evaluates, verifies or validates, documents, and approves design changes. Failure to validate software used as part of production and quality system for its intended use according to an established protocol, and failure to document the results of the software validation, as required by 21 C.F.R. § 820.70(i). FDA 483 Item 8. Specifically, your firm has not maintained documentation of the validation of the computer software used to (a) receive encrypted patient treatment data and decrypt/encrypt it; (b) convert decrypted patient treatment data into […] codes that are converted into […] codes that are then sent to your contract manufacturer’s […] milling machine to produce the compensators.”

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Warning Letter: Failure to validate/Insufficient Controls (s6630c)

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Failure to have a validated and secure computerized system. Additionally, there were no written protocols to assign levels of responsibilities for the system. It was noted that the [redacted] instrument model [redacted] used for the analysis of [redacted] failed to have password control for the analysts and the supervisor. It was observed that the data stored on the computer can be deleted, removed, transferred, renamed or altered. While your firm’s management stated that they would like to implement certain improvements in order to establish a security system, no documentation or commitment has been provided. Please note that computerized systems should have sufficient controls to prevent unauthorized access or changes to data. There should be controls to prevent data omissions and assure back-up. There should be a record of any data change made, the previous entry, who made the change, and when the change was made.

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Warning Letter: Computer systems not validated (s6381c)

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"Software used as part of the production quality system
was not validated
for its intended use according to an established protocol [21 C.F.R. 820.70(i)]. Specifically,
 
(a)
Spreadsheets
intended to check for outliers and calculate mean, SC, % CV, value assignments for finished devices.
(b) Complaint handling software
(c) Quantrol database program"

 

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Warning Letter: Failure to validate software (s6357c)

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Appropriate controls are not exercised over computers or related systems to assure that changes in analytical methods or other control records are instituted only by authorized personnel [21 CFR 211.68(b)]. Specifically,

  • There was a failure to validate the [redacted] software to assure that all data generated by the system was secure. This software runs the laboratory HPLC equipment, generates and stores data, and performs calculations during testing of raw materials, in-process materials, finished products, and stability samples.
  • User access levels for the [redacted] software were not established and documented. Currently, laboratory personnel use a common password to gain access to the system and there are no user access level restrictions for deleting or modifying data. Furthermore, your system does not have an audit trail to document changes.

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Warning Letter: Lack of procedures and instructions (g6173d)

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  • Failure to have production and process controls for automated processes, as required by 21 CFR 820.70(i). when computers or automated data processing systems are used as part of production or the quality system. A manufacturer is required to validate computer software for its intended use according to an established protocol. For example, databases that are maintained for data analysis and other tracking and trending functions, including complaint and services access databases, have riot [sic] been validated for their intended use.
  • Failure to establish and maintain instructions and procedures for performing and verifying that servicing meets the specified requirements, as required by 21 CFR 820.200(b). Each manufacturer must analyze service reports with appropriate: statistical methodology in accordance with Section 820. 100. For example, your quality group reviews narrative summaries of service reports every two weeks, but the data is not tracked and trended according to a statistical method.

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Warning Letter: Failure to Create Validation and CAPA Procedures (g4452d)

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Failure to establish and maintain adequate procedures for implementing corrective and preventive action, as required by 21 CFR 820.100(a) and (b). For-example:

a. The procedure titled corrective Action Handling [redacted] was not approved and implemented to address corrective and preventive action and no established procedure was found to have been in place.

b. Microsoft 2000 Excel spreadsheet software used manufacturing has not been validated for the purpose of generating a worksheet for formulation of reagents. No documentation was found to establish or verify corrections made to the program.

A report dated November 11, 2002 on non-conforming material on [redacted] was filed and a possible cause for the [redacted] was given; however no documentation was provided to verify or validate the adequacy of the corrective and preventive actions.

Problems were recorded relating to the use of the new dosing/dispensing machine [redacted]; however no documentation/evidence was provided
to verify or validate the adequacy of the corrective and preventive actions.”

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Warning Letter: Failure to validate computer software (g3667d)

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Failure to validate computer software for its intended use according to an established protocol, as required by 21 CFR 820-70(i). For example:

  • [redacted]software validation has not been completed.
  • [redacted] software validation plan does not address the user requirements of inputting data into the [redacted] spreadsheet used as a tool for trending.
  • [redacted] software used for trending has not been validated for its intended uses.

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