How to handle Discrepancies during Computer System validation?
In Earlier post we
understood What is Qualification protocol
(IQ/OQ/PQ/IFQP), Its Necessity & When requalification performed in CSV?
Computer system validation?
Now in this article we are going to understand How to handle Discrepancies during Computer System validation?
What is
Discrepancy?
Datum or result outside of the expected
range; an unfulfilled requirement; may be called nonconformity, defect,
deviation, out-of specification, out-of-limit, out-of-trend
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Discrepancy Form:
It is form on which any discrepancy
observed during computer system validation process has been recorded.
Quality Assurance Team shall issue the
Discrepancy form & assign unique number to each Discrepancy &
maintained log for the same.
Discrepancy Form
must include:
• Discrepancy Details,
• Type of
Discrepancy,
• Severity of
Discrepancy,
• Discrepancy
occurred & Recording Date,
• Discrepancy
Identified By,
• Target Complete
Date,
• Root Cause why
discrepancy occurred,
• Rectifications /
Corrective Actions taken for all type and severity of Discrepancy etc.
Discrepancy Log:
In Discrepancy Log maintained Log of all
discrepancy observed during computer system validation process.
It include Discrepancy Number, Recorded
by, Date of Discrepancy & Resolution status of Discrepancy
Finally same Discrepancy Log should be
reviewed by Quality assurance team.
How to handle
Discrepancy?
All discrepancies that occur during
qualification Testing should be documented on Discrepancy Form.
The all details of all discrepancy forms
should be recorded on Discrepancy Log which should summarize all the
discrepancies that occur during the execution of the qualification Tests
All discrepancies status should be
recorded in Qualification Report. Based on impact of discrepancy, risk
assessment may be required to perform for that particular requirement and
propose mitigation (procedural or technical) to close.
Categorization of
Discrepancies:
• Discrepancy Type
• Discrepancy Severity Level
•
Discrepancy Type.
All discrepancies that occur during
Qualification Testing will be assigned a discrepancy type as follows:
• System; The discrepancy is due to a failure of the application
software.
• Environmental/Setup: The discrepancy is due to
environmental and/or configuration parameters being set up improperly.
• Script: The discrepancy is due to the test script being
incorrect.
• Tester: The discrepancy is due to an error on the Tester’s part
when executing the test script.
• Other: The discrepancy is due to causes not covered by the
above mentioned Discrepancy types.
•
Discrepancy Severity Level: All discrepancies that occur during
qualification Testing will be assigned a severity level as follows:
• Critical
• Major
• Minor
•
Critical: A discrepancy determined to have a potential impact to
product quality, purity, strength, and integrity, an event representing a
significant breach of GxP or a failure of a GxP system
• Major: A discrepancy determined to have no impact to product
quality, purity, strength, and integrity. Impact to product and / or process
can be determined through preliminary analysis of data available at the time of
discrepancy. No evidence of a failure in GxP systems.
• Minor: Not a GxP failure, no product impact
“Trust but Verify “ Ronald Reagan
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