Towards Computer System-Validation
Towards Computer System-Validation
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Research Article
Received date: 16 February 2018; Accepted date: 9 June 2018; Published date: 2 November 2018
Copyright © 2018. Marius Schönberger and Tatjana Vasiljeva. Distributed under Creative Commons
CC-BY 4.0
Abstract
The medical device industry in Europe is one of the sectors actively regulated by directives.
Medical device manufacturers face the challenge of implementing the statutory regulations. In
the context of current trends regarding the digitalization of enterprises, among other things, a
focus is on the computer system validation (CSV). The present research shows why the CSV in
the medical device industry is necessary, which different validation approaches exist, and which
tasks and activities are to be carried out within the CSV. One focus of this research is the critical
consideration of the problems associated with CSV for small and medium-sized enterprises
(SMEs). As a result of this research, it can be stated that the identified literature sources are
very homogeneous, and the validation approaches do not show any significant differences.
Keywords: Computer system validation, Business processes, Medical device industry, SME.
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Cite this Article as: Marius Schönberger and Tatjana Vasiljeva (2018), “Towards Computer System Validation:
An overview and evaluation of Existing procedures”, Journal of Innovation Management in Small and Medium
Enterprise, Vol. 2018 (2018), Article ID 512744, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 2
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devices are also being widely deployed in approach are not specified. This leads to the
clinical environment, which was enabled by, challenge, that all medical device manufac-
for example, shrinking technologies, portabil- turers shall determine what needs to be vali-
ity, or increasing interconnectedness dated and how much validation is enough to
(Alemzadeh et al., 2013). Therefore, software ensure that regulatory requirements are met
plays an important role in the critical func- (Hrgarek, 2008).
tions of medical devices. However, from 2002
to 2010, medical devices based on software This key problem forms the basis for the
resulted in over 537 recalls affecting more present research and, thus, the question
than 1.5 million devices. During this period, arises, whether standardised procedures for
11.3% of all recalls were due to software the implementation of the CSV exist for the
failures (Fu, 2011). As Appendix 1 shows, a medical device industry. Although there are
total of 195 recalls for medical devices, re- various guidelines, e.g. the Gamp 5 Guide, ISO
sulting from software errors, were reported 26262-8 Section 11 or IEEE Std. 829, they
to the US Food and Drug Administration cannot always reflect the existing diversity of
(FDA) only in 2017 (FDA, 2018). It is appar- industries, size differences, or special re-
ent that medical devices are often subject to a quirements of, in particular, small and me-
high number of errors with potentially catas- dium-sized medical device manufacturers. In
trophic effects on the patients (Alemzadeh et addition, the implementation of these direc-
al., 2013). According to AAMI (2016), medical tives in SMEs is often hampered by limited
errors are involved in more than 250,000 resources, such as the lack of existing staff
deaths each year in the US and account for capacities or insufficient funding (Nguyen,
nearly one in ten deaths. Finally, the recall of 2009; Razak et al., 2009; Buschfeld et al.,
medical devices poses a problem that affects 2011). With regard to the aforementioned
the entire healthcare sector (Foe Owono, key problem, the following research ques-
2015; Maisel et al., 2001). tions are to be answered within the scope of
this research:
Against this background, it seems that with
the current technological possibilities of the 1. Which SME-specific approaches to
software development, a considerable in- CSV in the medical device industry
crease in the complexity of the devices and are dealt with in the scientific litera-
thus major challenges for the reliability, pa- ture, and what differences or simi-
tient safety and security emerge (Faris, 2006; larities do these approaches have?
Fu, 2011; Alemzadeh et al., 2013). Therefore, 2. What concrete recommendations for
the computer system validation (CSV) is a action can be derived from the given
major means of avoiding such defects and CSV procedures in the medical de-
resultant recalls (Bhusnure et al., 2015) and, vice industry for SMEs?
according to the FDA, a requirement of the 3. What are the implications for future
quality system for medical device manufac- research in the area of CSV?
tures (FDA, 2002). The analysis of different
literature on the topic of CSV shows that the This research is structured as follows: First,
implementation of CSV is not only necessary the necessary terminological basics are ex-
due to legal regulations, but also from eco- plained in section two. In section three, the
nomic, social and technological aspects (e.g. underlying research methodology is de-
Vogel, 2011; Thirumalai and Sinha, 2011; scribed. In section four, SME-specific ap-
Faris, 2006; Fu, 2011). However, the regula- proaches to CSV will be collected and ana-
tions only determine that a CSV has to be lysed based on a literature review. In this
carried out and which system or software context, the results are compared and evalu-
type is to be taken into account in the com- ated with regard to the research questions.
pany (e.g. FDA, 2002; ISO, 2016), the exact Finally, the contribution concludes with a
scope of the validation as well as a structured
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
3 Journal of Innovation Management in Small and Medium Enterprise
____________________________________________________________________________________
summary of findings and an outlook on fur- medical technology (Klein, 2016). The medi-
ther research activities in section five. cal devices market in Europe is one of the
sectors actively regulated by directives (Foe
Basic Terminology Owono, 2015). As sometimes the lives of
patients depend on the proper functioning of
SMEs in Europe medical devices, new devices have to un-
dergo a stringent regulatory process before
they are ready to enter the market (Klein,
SMEs play an important role in Europe’s 2016). Two prominent regulatory bodies are
society and economy: The vast majority responsible for defining, updating and verify-
(99.8%) of all enterprises in the European ing compliance with these regulations for
Union are SMEs, 93% of these are micro en- medical devices in Europe: The European
terprises with fewer than ten employees. Medical Device Directive (93/42/EEC) regu-
SMEs employ more than half of the European lates which medical devices can be sold in the
workforce (66.8%) and are estimated to be European market, while the FDA uses the 21
responsible for 57.4% of the value added CFR 820 Quality Systems Regulation to pre-
(Muller et al., 2016). In view of the fact that scribe medical device manufacturers and
there is no single definition for SMEs nor any how to establish and maintain a quality as-
clear demarcation of SMEs and large enter- surance system (Francum, 2014). Although
prises (Schönberger and Kleinert, 2016), for the FDA is primarily responsible for the US
this research the definition according to the market, many European medical device
proposal by the European Commission is manufacturers are following FDA regula-
used (European Commission, 2003). Accord- tions, even if they do not sell their medical
ing to this recommendation, an enterprise devices in the US.
that has fewer than ten employees and an
annual turnover or annual total balance sheet
not exceeding two million euros is defined as Computer system validation in the medical
a micro enterprise. Small enterprises are device industry
companies that have fewer than 50 employ-
ees and an annual turnover or annual total The term validation is used in the corre-
balance sheet not exceeding ten million eu- sponding software-related literature in very
ros. Companies are referred to as medium- different meanings and must first be clearly
sized enterprises if they employ fewer than defined and delimited. Sommerville (2011)
250 employees and have an annual turnover describes the term validation as follows: “[…]
not exceeding 50 million euro or an annual validation is intended to show that a system
total balance sheet not exceeding 43 million both conforms to its specification and that it
euro (European Commission, 2003). meets the expectations of the system cus-
tomer”. The DIN ISO 9000:2015 norm defines
Medical device industry in Europe validation as a “confirmation, through the
provision of objective evidence, that the re-
quirements for a specific intended use or
The medical technology sector is one of the application have been fulfilled” (ISO, 2015).
most innovative industries in Europe (Klein, In this context, CSV is a requirement of the
2016). According to the research of MedTech quality system regulation. “Validation re-
(2015), around 7.5% of the total expenditure quirements apply to software used as com-
in health care is spent on medical technology ponents in medical devices, to software that
in 2015. Furthermore, 95% of the 25,000 is itself a medical device, and to software
medical technology companies in Europe are used in production of the device or in imple-
SMEs employing more than 575,000 people mentation of the device manufacturer's qual-
(MedTech, 2015). With approx. 30% of the ity system” (FDA, 2002). According to the
worldwide expenditure on medical devices, DIN norm mentioned before, any software
Europe holds one of the biggest markets for used to automate any part of the medical
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 4
____________________________________________________________________________________
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
5 Journal of Innovation Management in Small and Medium Enterprise
____________________________________________________________________________________
As the focus on SMEs implies the discovery of databases were searched for literature re-
only a few sources, there is no limitation search: Google Scholar, Elsevier, Scopus, Ebsco
regarding the time of the publication. A time Academic Search, Sciencedirect, Springer Link
limitation could thus possibly prevent the and Sage Journals. In a second step, a com-
identification of older relevant sources of prehensive keyword search was carried out
literature. Nevertheless, a consideration of in order to achieve better results for the lit-
current literature is being aspired. erature review. Therefore, the following
keywords were used: Software, Computer,
Literature Analysis Validation, Software Validation, Computer
Validation, Medical Device, Medical Device
Various criteria are used for the comparison Industry, SME, Business Information System,
and the analysis of the collected literature. Validation Process, Software Validation Proc-
On the one hand, the literature has to be ess, Computer Validation Process, Validation
addressed to SMEs or has to be oriented to- Approach, Software Validation Approach and
wards SMEs, on the other hand, the literature Computer Validation Approach. Finally, for
must show a systematic approach to CSV and the collection of other relevant literature, the
recommendations for action for SMEs. A bibliographies of the already determined
selection and definition of formal and didac- results were analysed.
tic comparison criteria, for example the year
of appearance, page numbers, learning objec- In the second phase of the literature review,
tives or best practices, will not be under- eleven relevant literature sources were iden-
taken. tified after the excluding of duplicates by
using the aforementioned keywords. These
Research findings results were structured according to author,
title, publication type, year and focused sec-
tor (see Table 1). Following this, the identi-
Results of the Literature Research fied literature was examined and selected for
its relevance with regard to the research
At the beginning of the study, a total of 1,231 topic and the previously defined limitation
sources of literature were identified in which criteria. For this purpose, the abstracts, in-
the term “computer system validation” was dexes and introductions of the publications
mentioned (see Appendix 2). However, this were analysed. Below, the contents of the
search has not yet been restricted to the identified literature sources, shown in Table
medical device industry, SMEs or standard- 1, are briefly explained and summarised
ised procedures. The following literature
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 6
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
7 Journal of Innovation Management in Small and Medium Enterprise
____________________________________________________________________________________
ran and Vishal Gupta, 2016). Others refer to steps compared to the general approach as
general CSV approaches given by the Euro- well as to the other procedures. The com-
pean Commission (2015) or the FDA (2002), parison shows that the validation approaches
for example Bendale et al. (2011) or Yogesh have a common basic pattern, although the
et al. (2015). individual procedures vary in the number of
phases, the description of the phases and the
In order to allow a comparison of the differ- temporal sequence. As can be seen, there are
ent approaches to CSV, the literature sources differences as well as similarities regarding
listed in Table 1 were analysed more pre- the beginning and the end of each validation
cisely. To ensure better comparability of process. While the EU Guideline provides for
procedures and as this research focuses on the preparation of a validation master plan
the European sector, the approach of the within the planning phase of the CSV (Euro-
European Commission (2015) has been cho- pean Commission, 2015), this task is defined
sen as a general approach that complies with as an independent process step by Bhusnure
the GAMP 5 standard. Therefore, the ap- et al. (2015), Yogesh et al. (2015), and Tracy
proach of the FDA (2002) will not be consid- and Nash (2002). Moreover, the approaches
ered further. Based on the analysis of the of Bhusnure et al. (2015), Hrgarek (2008),
literature sources, it has been shown that the and Esch et al. (2007) go beyond the conven-
authors Bendale et al. (2011), Huber (2005), tional validation and describe further phases
McDowall (2016), and von Culin (2011) do for error correction, system retirement or
not show any specific approaches or proce- vendor audits. Furthermore, the approaches
dures, but rather describe the principles of of Bhusnure et al. (2015), Tracy and Nash
CSV. The approach of Charan and Vishal (2002) and Esch et al. (2007) end with the
Gupta (2016) was also excluded because they phase of the revalidation which complies
used the GAMP 5 standard and, thus, it corre- with the EU Guideline. In this context, the
sponds to the general approach. Finally, the revalidation or re-qualification is defined as
approaches of the authors Bhusnure et al. the performance of a controlled manner to
(2015), Esch et al. (2007), Hrgarek (2008), maintain the validated status after any
Tracy and Nash (2002) and Yogesh et al. change of the computer system during its
(2015) were selected for the comparison. operational use (European Commission,
Although Bhusnure et al. (2015), Esch et al. 2015; Esch et al., 2007). Within the approach
(2007), and Tracy and Nash (2002) do not of Esch et al. (2007), the re-qualification is
focus on the medical devices industry, the divided into the two steps system in progress
described approaches can be applied to com- and change control. The approach of Yogesh
panies in the named industry. et al. (2015) ends with the phase of the per-
formance qualification, which is justified by
In a first step, the CSV procedures are exam- the fact that at the end of this phase, the
ined superficially, and the individual phases software has been checked for its intended
of the procedures are analysed and com- purpose and, thus, the validation process has
pared to the phases of the general approach. ended. Finally, it is conspicuous that the ap-
The results of the analysis and the compari- proach of Hrgarek (2008) establishes the
son of the procedures are shown in Figure 1. installation qualification as a validation-
The grey fields represent missing process inducing phase and has no preceding phases.
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 8
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follow-up
up phase, the documentation of Fai Fail- similarities. Within all validation approaches,
approaches
ure Mode and Effects Analysis (FMEA) is the documentation of the user requirements
defined by Bhusnure et al.. (2015) and Hrg
Hrga- specification
tion as well as the design, installa-
install
rek (2008) as the final validation task. As the tion, operational and performance qualifica-
qualific
follow-up
up phase of the CSV is not provided by tion is required.
each of the approaches, there are only a few
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
11 Journal of Innovation Management in Small and Medium Enterprise
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 12
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
Journal of Innovation Management in Small and Medium Enterprise 14
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Appendix
Appendix 1: Total medical device recalls resulting from software errors in 2017. Own elabo-
ration using the FDA Medical Device Recall Database. Recall date from 01/01/2017 to
31/12/2017 (FDA, 2018).
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Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744
15 Journal of Innovation Management in Small and Medium Enterprise
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Elsevier 192
Scopus 166
Sciencedirect 90
Springer Link 54
Sage Journals 26
Appendix 2: Total number of literature sources that have been identified in various litera-
ture databases with regard to the term "computer system validation". Own elaboration us-
ing the databases Google Scholar, Elsevier, Scopus, Ebsco Academic Search, Sciencedirect,
Springer Link and Sage Journals. Databases accessed 11 February 2018
______________
Marius Schönberger and Tatjana Vasiljeva (2018), Journal of Innovation Management in Small and Medium
Enterprise, DOI: 10.5171/2018.512744