| Radiant's
multi-step Part 11 Implementation Process is designed
to capture the required phases to properly implement
Part 11 compliant systems. |
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Instill CFR
Part II Awareness |
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A General awareness is to be given
to foster company-wide support for compliance, to make
personnel available for appropriate responsibilities
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Develop Standard Operating
Procedures |
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Radiant will
assist in identifying all SOPs currently in place
that relate to a company’s computer systems
and preparing the SOPs |
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Radiant would assist in establishing
a validation program through a series of SOPs.
We would provide a sample industry standard validation
practices that can serve as baseline documents
and assist in modifying these baseline procedures
into detailed practices and procedures that are
functional for their specific company |
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Perform GAP
Analysis |
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It is necessary to
conduct a Gap analysis once all the policy statements
and SOPs are in place. Each system will be physically
tested according to the requirements. Any computer system
that does not meet one or more of the requirements of
the validation program must be considered a gap and
requires remediation. Compliance only exists when there
are no gaps. Each system is evaluated for various assessment
areas. |
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Take Inventory
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Radiant will assist
in Carrying out a system inventory of all new and legacy
systems |
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System Lifecycle
which includes development |
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Requirement gathering,
Design implementations, Testing & Commissioning
for GxP compliant applications |
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Requirements
Phase: A requirements definition is written
for each system to identify specific operating
and use requirements for the computer system.
They will be used as the basis of the design phase.
The testing phase will assure that all requirements
elements have been accounted for in the design
phase. |
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Design Phase:
The design phase follows the requirements phase.
The purpose is to assure that each element defined
in the requirements phase is addressed. |
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Implementation Phase:
During the implementation phase all elements of
the system, as defined in the design phase, are
brought together. The product is a fully functioning
piece of software that meets the original requirements.
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Testing Phase:
During this phase, the computer system is tested
against specifications in the requirements definition
phase. Tests are structured to provide traceability
to both design and requirements documentation.
Testing has three elements >
Installation Testing e.g., environment, power,
plumbing > Operational
Testing e.g., each individual function
> Performance
Testing e.g., maximum users, maximum data flow
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Decommissioning /
Commissioning phase: Starting over can
be a new version/upgrade of currently used software
or it can be replacement of the current system.
In any case, all data is archived and/or migrated
to the new system. The old system is then removed
from operation and a full audit trail of the dates
and reasons for decommissioning is kept |
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Change Control:
The final SOP in the validation program defines
how changes to a validated computer system are
managed and documented. Changes are tested on
a non-production system before they are implemented
on the target system. The computer systems validation
specialist must evaluate the impact of the change
on the validation system. If it is significant
change, revalidation may be required. Minor changes
may require only documentation |
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