Failure to Validate Software


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Warning Letter: Electronic files not properly validated or maintained (ucm178453)

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During the FDA inspection it was discovered that electronic records are used to establish the firm?s Complaint Files, 21 CFR 820.198. However there is no documentation to establish that these electronic records meet the requirements of 21 CFR Part 11, Electronic Records; Electronic Signatures. The requirements of 21 CFR Part 11 are designed to ensure that electronic records are trustworthy, reliable, and generally equivalent to paper records.

For example, review of your electronic complaint files reveals they have not been properly validated there is no ability to generate accurate and complete copies of records in human readable and electronic form, there is no protection of records] to enable their accurate and ready retrieval, access to your system has not been limited, as well as other significant deficiencies.

We strongly encourage you to perform a thorough and complete evaluation of all your electronic records in accordance with 21 CFR Part 11 as well as any guidance generated by FDA to assure conformance to our requirements.

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Warning Letter: MS Access and MS Excel Not Validated (g1483d)

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Your firm failed to validate several computer databases that are used for quality functions including your Access database , your [redacted] software, and your MS Excel spreadsheet program as required by 21 CFR 820.70(i).

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Warning Letter: Failure to comply(g1120d)

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References validation and lab documentation - "...requires that all drugs be manufactured, processed, packed, and held according to current good manufacturing practice. No distinction is made between active pharmaceutical ingredients and finished pharmaceuticals, and failure of either to comply with CGMP constitutes a failure to
comply with the requirements
of the Act...."s."

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Warning Letter: Spreadsheets not Validated (g5699d)

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There are no data to demonstrate that the quality control/quality assurance spreadsheets used for tracking and trending various quality metrics have been properly validated (installation qualification, operational qualification, and performance qualification) and are performing as intended.

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