Data Governance for Computer Systems Regulated by FDA

The FDA governs the computer systems used to collect, analyze, transfer and report data that is in support of FDA regulated activities required for drug development and approval. FDA oversight is based on a Predicate Rule, known as “Good Practices,” or simply, “GxPs.”

Computer systems subject to GxP requirements must be thoroughly and appropriately validated in accordance with FDA’s guidance on computer system validation. This involves a rigorous set of phases and steps to ensure that, in the language of FDA, “a system does what it purports to do.”

The cost of adequately validating a GxP computer system can be high, and must be weighed against system risk and usage. GAMP 5 system classification guidelines can help ensure that a GxP system is categorized appropriately, based on the type of system and technology involved. Along with risk, system classification can provide a clear-cut pathway for validating a system, based on the appropriate level of testing and validation effort.

All types of data management and information systems will be discussed, including those based on in-house developed code, configurable systems and custom designed systems. Best industry practices and potential pitfalls in validating laboratory systems, along with examples, will be covered in detail.

Ongoing maintenance of the system in a validated state will be discussed, as well as governance, archival and retirement. These functions are critical to maintaining data in a state of integrity. We will also cover the establishment of a Data Governance Committee, the Charter, roles and responsibilities, and oversight. Such a committee is critical to successfully maintaining control over GxP systems and governing the state of integrity of the data housed in them.

We will also discuss the importance of applying good project management, business process re-engineering and organizational change management principles through the validation process and beyond.