Article 2638
Article 2638
Qualification of Network
Components and Validation of
Networked Systems
GmbH, PO Box 1280 D-76337, Waldbronn, technology (IT) quality in a paper at the maintained or updated throughout the life of the
Germany, +49.7243.602.209, ECA conference (4). A special interest . . . software dating back to 1985 despite
fax +49.7243.602.501, [email protected], group at the Good Automated significant changes and modification[s] that
www.agilent.com. Rory Budihandojo is head of Manufacturing Practice (GAMP) forum (5) have taken place. These include program code,
R&D for IT quality and testing at the Centre of emphasized that quality assurance principles functional/structural design, diagrams,
Excellence, GlaxoSmithKline, Collegeville, PA are critical to the management of the IT specifications, and text descriptions of other
19426. infrastructure. That group recommended programs that interfere with [this program].
18 BioPharm OCTOBER 2001
v The software validation documentation failed during the transport and traffic control practice to validate all computer systems used
to adequately define, update, and control functions. Data integrity and security are for generating and evaluating critical data.
significant elements customized to configure the ensured by controlled and properly managed
system for the specific needs of the operations. network access and by appropriate security Networked Systems
v Validation documentation failed to include for data stored within the network. The diagram in Figure 1 shows a typical
complete and updated design documentation, Computer systems used in regulated client/server networked system connecting
and complete wiring/network diagrams to environments must be qualified and client computers in a laboratory and offices
identify all computers and devices connected to validated to demonstrate suitability for their to a server located in a computer room. The
the . . . system. intended use. That means all systems computer room also hosts mail servers.
v The QCU [Quality Control Unit] failed to (including networks) used for work Laboratory computers with data system
ensure that adequate procedures were put in regulated by Good Laboratory Practices, applications software acquire data using
place to define and control computerized Good Clinical Practices, and Good TCP/IP protocols and control equipment
production operations, equipment qualifications, Manufacturing Practices (together referred with built-in local area network (LAN) cards.
documentation review, and laboratory to as GXPs) must be validated. The Application software on the client computers
operations. (6) electronic record regulations in 21 CFR is also used for data evaluation. Computers
Part 11 give more detail on which computer are connected to servers through a hub. Each
The . . . computer system that is accessed by systems are regulated: all systems that server uses a relational database (such as
personnel from various departments to include create, modify, maintain, archive, retrieve, that from Oracle, www.oracle.com) with
manufacturing, testing laboratory, and Quality or distribute electronic records (10). To customized applications for data
Assurance lacked the following: ensure compliance, we recommend that you management; for control charting and other
v Audit trail function of the database to ensure analyze all information that FDA may statistical evaluation; for review, backup,
against possible deletion and loss of records. request during an inspection. If documents archiving, and retrieval of data; and for
v Absence of documentation defining the or data ever went through a computer or generating electronic signatures compliant
database, operating system, location of files, and other device with the possibility of being with 21 CFR Part 11.
security access to database. modified, then that computer or device Other examples of networked systems
[. . . .] should be validated. frequently used in the biopharmaceutical
Your response fails to discuss extending the Validation is therefore necessary for industry include enterprise asset
retrospective evaluation to other elements of the computers that acquire and evaluate critical management (EAM) systems, manufacturing
system needing to be defined and controlled as data from measurement systems in plant resource planning (MRP) systems,
part of the overall configuration management. (7) control and also for office computers that manufacturing execution systems (MES)
generate reports submitted to FDA. Word with electronic batch record functionality,
An FDA 483 from July 2000 cited a processing systems that generate standard and electronic document management
company for insufficiently documented operating procedures (SOPs) also must be systems (EDMS). The arrangement can be
training records: validated; and frequently, the computers the same for these systems as shown in
There are no records to document that the running them are connected through Figure 1; validation requirements can be the
Information Technology (IT) service provider networks. In addition to meeting regulatory same as well.
staff personnel have received training that requirements, it is simply good business
includes current good manufacturing practice
regulations and written procedures referred to by
the regulations. (8)
Office Laboratory
Installation Qualification • Check correct installation of computer system for specific application performance.
and network hardware and software PQ could involve a complete analysis using
sample equipment for specific hardware,
• Test key operational functions of hardware
Operational Qualification
and software
accessories, and software. It also includes
• Test security functions preventive maintenance. For example, PQ
would include both regular disk
• Test system for specified application maintenance and change control.
Performance Qualification • Establish preventive maintenance routine
• Determine backup and contingency
planning procedures Specific Requirements
• Establish change control and security Network computer systems have some
maintenance protocols specific characteristics that differ from
Figure 2. The 4Q model qualification phases of networked systems standalone equipment and need to be
addressed during validation. Unlike stand-
Validating a networked system requires for other components, then the validation of alone computer systems, which consist of
qualifying its individual components (such network-specific tasks should be added to the homogeneous hardware and software,
as the applications running on each validation plan. A networked component networks are heterogeneous. They usually
computer) and authorized access to the should be treated like any other piece of include a variety of hardware components,
system, as well as qualifying data transfer equipment that is installed and qualified. several software applications, and
between the related computers (that is, the A network component should be treated communication protocols. A change to one
interfaces of the components at both sites). like a piece of equipment, which is installed component can influence many other
The whole system, including the network and qualified (for example, chromatography components and applications.
itself, is validated by running typical daily software functions such as peak integration Cabling designs and specifications are as
applications under normal and worst-case and quantitation). Typical network functions important as the hardware and software in a
conditions and then verifying that the system such as limited access and network networked system — mainly because network
and its functions are meeting previously transactions should be qualified. Because of components can be far away from each other.
specified criteria. the complex nature of a network, a cross- Many people and departments often access
Both for qualifying the components and functional team should control validation the network as a common resource, so
for validating the complete system, it is activities. For the validation of the network, security issues are quite important. Networks
important to define a validation box. The any structured approach (such as a life cycle can include both components that must
goal of a validation box is achieved by model) should be followed; see, for comply with regulations and those that aren’t
subdividing the network into subnetworks example, the 4Q model in Figure 2. It regulated. IT personnel have not always been
(or sub-LANs) containing network involves design, installation, operational, trained in the GXPs.
components that are used by each and performance qualification.
application. A validation box helps define Design qualification (DQ) is the first step, Validation Plans and Teams
which parts of the complete network must ensuring that the design of a network meets Validation master plans are not required by
be qualified and which are unaffected. The the user’s requirements. In this phase, the regulation, but FDA inspectors may ask for
validation box for the laboratory data system user requirements for each function are an explanation of your company’s approach
in Figure 1 would include the lab computers, specified. For example, a user requirement toward validation. The master plan is a good
the file server, the applications server, and could state, “There should be limited access tool for demonstrating that approach, and
the database. Limiting the network to the networked system.” The required plans should be available for both multisite
qualification tasks to those components used function to ensure that requirement could be and single-site companies. Validation master
by the network applications saves time. stated, “There should be user ID and plans help ensure consistent and efficient
password entry fields when entering the implementation of validation throughout a
The 4Q Model system.” The computer system vendor site and throughout a company. If already
Validation of networked systems should, in should be qualified during the DQ phase. available, such plans can be extended easily
principle, follow the validation practices of Installation qualification (IQ) is the second to include networks and networked systems.
all other computer systems. Everything that phase. An individual checks whether an We recommend starting with a generic plan
is important in validating a single computer instrument arrives as purchased, installs and adding network specifics. For example,
is also important in validating a network. network components, and completes the include network terms in the glossary.
Network validation activities should follow a necessary documentation. Generic network specifications (such as
validation plan. If such a plan already exists Operational qualification (OQ) is the third cabling, security, and vendor qualification)
step, when critical key functions are tested. should be part of the master plan. It should
20 BioPharm OCTOBER 2001
Regulatory Issues
include recommendations for backup, problems at the application level. End users how many concurrent users can work on the
contingency planning, disaster recovery, also should be able to determine whether a network. Another user requirement is limiting
change control, validation reports, and network continues to operate effectively and authorizing access to the system.
archiving. The plan also should include after the validation activities are complete. Functional specifications define what
naming conventions, which make it easier to QA personnel should be part of the functions the system or its components will
identify components and track data flow validation team to ensure that documentation, need to meet those goals.
within a network. Templates for daily control, and use are in compliance with Two other types of specifications to
operations should be included as appendices regulations and company policies. The include in a validation master plan are
for consistent implementation, and reference software engineering department should be design and environmental specifications.
should be made to existing SOPs. The involved if all or part of the software has been Design specifications, which can be
master plan will be a good foundation for developed in house. Otherwise, vendor included as part of the functional
individual project validation plans. representatives can be included. Consultants specifications, specify the design of the
Validation teams can coordinate validation can be brought onto the team if necessary; computer hardware, software, connectors,
activities for networked systems. The they can be a great help with initial, big and cables necessary to meet specific
complexity of networks requires more than network validation projects. functional specifications and to ground
one expert for definitions, qualifications, electrical connections adequately.
and (most important) change control. The Types of Specifications Environmental specifications detail the
validation team should include expert IT All validation activities should begin with the environmental conditions (such as
professionals. They can best describe what single most important step: setting temperature or humidity) under which the
might go wrong with a system and how specifications. Good specifications can be network will be expected to operate.
individual network components can affect used throughout validation activities. User When establishing network
each other. requirements set as specifications define what specifications, be sure to answer these
Laboratory personnel (or others who will users intend to do with the networked system. questions: How much traffic will the
use the network) should be part of the team Typical requirements for networks include network carry, especially under highest-load
because they should be aware of possible sharing and printing files and determining or worst-case conditions? What is the
Maintaining Security
Networks change frequently, whether something, you need to ask yourself several
changes are made to hardware, software, or questions. Is the change really needed?
both. All changes should be managed, Compare benefits and costs. Cost
controlled, and documented. In some cases calculations should not only include those
revalidation may be required, which can be a for purchasing but also validation, which
huge effort. Before deciding to change can be higher. How will the change affect
Info #17 BioPharm OCTOBER 2001 25
Regulatory Issues
the system and its components? What will should be present: project specific plan, or add network-specific information to
need to be tested and documented after the documentation describing validation for an existing computer validation master plan.
change? Who should be informed about it? each project and generic documentation Form a project-specific validation team.
Those questions must be answered by a describing policies, master plans, and Develop user requirements along with
validation team rather than an individual. A processes. Templates can facilitate functional and design specifications.
chemist in the laboratory can hardly estimate consistent implementation and use. Good Treat each network component like a
the impact of adding another client to an documentation is very important for piece of equipment, which must be
already busy network. But IT specialists can troubleshooting. qualified, but qualify only those that are
do that best when informed by that chemist Generic documentation should include the used when running applications. Install
as to the potential data traffic coming from validation master plan and additions to individual components and test components
the new computer. existing computer validation master plans and (qualification). Integrate components and
Requalify network components after each procedures for adding and removing network test them. Validate the networked system by
change, with qualification results components; connecting to the network; running complete applications. For complex
documented. Update the contents of controlling network security, including networks, don’t test everything; be selective.
equipment databases and drawings after the physical and logical security, password Use risk assessment. If you have 20 identical
change. Limited access to computer rooms, policies, and administration procedures; clients with identical software, testing two
computer hardware, network hardware, and network management between multiple sites; or three of those clients can be enough.
selected tasks and data should be checked configuration management; change control For changes, evaluate whether each
regularly. Maintain access rights and update procedures (equipment, hardware, software, change is really needed and assess whether
those rights when employees change jobs. firmware, cables, connectors), and training it makes good business sense to implement.
records for GXP regulations. After you have made a change, test its
Documentation All procedures should be reviewed yearly effects on other components. Don’t assume
All validation activities, including with regular confirmation that they are being that everything else still works as before
qualification and validation plans and results followed. Practice version control for when a change has been made. Don’t forget
for networked systems and databases, should changes. Project-specific documentation to continue qualification through all change
be documented. Two types of documents must be reviewed periodically and updated control procedures.
if necessary. See the Develop backup, contingency, and
“Project-Specific disaster-recovery plans. Documentation
Documentation” must be in order: SOPs, templates,
box for a list of maintenance logs, and so on. And train
what to include. people — even your IT staff — on
techniques and operations, but also on the
Implementation regulations.
In summary, the
qualification of References
network (1) L. Huber, Validation of Computerized
Analytical Instruments (Interpharm Press, Inc.,
components and Buffalo Grove, IL, May 1995).
validation of (2) N. Jenkins and S. Schatt, Understanding Local
networked systems Area Networks: Easy Introduction to Network
are equally Concepts and Products (SAMS Publishing,
Indianapolis, 1998).
important for (3) J.E. Crosson, M.W. Campbell, and T. Noonan,
meeting regulations “Network Management in an FDA-Regulated
and business Environment,” PDA Journal 53(6), 280–286
requirements. We (1999).
(4) H. Olthof, “GXP Requirements for IT
recommend Infrastructure,” presented at the ECA
following a stepwise conference: FDA 21 CFR Part 11 Compliance
approach. for Pharmaceutical Laboratories (European
Follow good Compliance Academy, Copenhagen,
Denmark), October 2000.
computer validation (5) IT Infrastructure Special Interest Group,
practices. It is most Quality Assurance (GAMP, Tampa, FL, 2000),
important to follow draft document.
(6) J.C. Famulare, Warning Letter #320-01-08
life cycle procedures (Center for Drug Evaluation and Research,
in validation and 11 January 2001). Available at
qualification. www.fda.gov/foi/warning_letters/m5056n.pdf.
Develop a network (7) J.C. Famulare, Warning Letter #320-01-07
(Center for Drug Evaluation and Research,
qualification master
Continued on page 46
26 BioPharm OCTOBER 2001 Info #16
Glossary Network Qualification continued from page 26
11 January 2001). Available at www.fda.gov/
bus An electronic pathway along which they are, where they are located, and how foi/warning_letters/m5057n.pdf.
signals are sent from one part of a they are used). (8) “FDA 483 Observations Related to IT”
(Labcompliance, July 2000). Available at
computer to another. A PC contains fault tolerance The ability of a system to www.labcompliance.com/publications/
several buses, each used for a different respond gracefully to unexpected lit-references.htm.
purpose. The address bus allocates (9) “FDA 483 Inspectional Observations and
hardware or software failures. The lowest Warning Letters Related to Computers”
memory addresses. A data bus carries level of fault tolerance is an ability to (Labcompliance web site). Available at
data between the processor and the continue operation in the event of a power www.labcompliance.com/computer/
memory. The control bus carries signals failure. Many fault-tolerant computer fda-observations.htm.
from the control unit. (10) Code of Federal Regulations, Food and
systems mirror all operations — that is, Drugs, “Electronic Records; Electronic
checksum A record of the number of bits perform each on two or more duplicate Signatures,” Title 21, Part 11 (U.S.
transmitted and included with a systems — so that if one fails the other Government Printing Office, Washington DC),
transmission so that the receiving can take over. issued March 2000. Also Federal Register
62(54), 13429–13466. Available at
program can determine whether the same File transfer protocol (FTP) The TCP/IP Internet www.fda.gov/ora/compliance_ref/ part11. BP
number of bits arrived. If the counts protocol used when transferring single or
match, it’s assumed that the complete multiple files from one computer to
transmission was received. another. hot site A site designated to operate a
client/server A network architecture in network if the normal operation center
GPIB-IEEE A general purpose interface bus
which each computer or process on the fails (for example, in case of a natural
standard from the Institute of Electrical
network is either a client or a server. disaster or fire).
and Electronic Engineers, which develops
Servers are powerful computers or standards for computers and the hub A common connection point for
processors dedicated to managing disk electronics industry. This standard allows devices in a network, such as a LAN. A
drives (file servers), printers (print up to 15 intelligent devices to share a hub contains multiple ports. When a
servers), or network traffic (network single bus, with the slowest device packet of data arrives at one port, it is
servers). Clients (PCs or workstations on participating in the control and data copied to the other ports so that all
which users run applications) rely on transfer handshakes to drive the speed of segments of the LAN can see all packets.
servers for resources such as files, the transaction. A passive hub serves simply as a conduit
devices, and even processing power. for data, enabling it to go from one device
GXP All of the regulations that apply to
data flow Movement of information (or segment) to another. So-called
Good Laboratory Practices, Good Clinical
between clients and servers that is intelligent hubs (or manageable hubs)
Practices, and Good Manufacturing
tracked to ensure accuracy and security. include additional features that enable an
Practices, taken as a whole.
administrator to monitor traffic passing
data system applications software The software handshake Requires the recipient of a data through the hub and configure each port.
that controls equipment, such as record to acknowledge to the sender that A third type of hub, called a switching
chromatographs, and acquires, evaluates, the record has been received. hub, actually reads the destination
prints, and stores data.
hash algorithms (hash values) A hash value is address of each packet and forwards it to
distributed databases Computing is said to be an algorithmic method. Sometimes called the correct port.
“distributed” when the programming and the “digest” of a document in digital form, information technology (IT) The broad area
the data that computers work on are a number is generated from a string of concerned with all aspects of managing
spread out over more than one computer, text. The hash is substantially smaller and processing electronic and
usually over a network. than the text itself, generated by a formula computerized information. Some
electronic document management system (EDMS) A that makes it extremely unlikely for some companies refer to the department as
system for tracking and locating electronic other text to produce the same value. information services (IS) or management
documents and for managing them Hashes are used in security systems to information services (MIS).
throughout their life cycle. ensure that transmitted messages have
integrated databases Databases that have
enterprise asset management (EAM) Knowledge not been tampered with. The sender
two or more components merged together
within a company exists in many forms: in generates a hash of the message,
into a single system. Increasingly, the
databases, knowledge bases, filing encrypts it, and sends it with the message
term “integrated” is reserved for software
cabinets, and peoples’ heads. All too itself. The recipient then decrypts both the
that combines word processing, database
often one part of an enterprise repeats the message and the hash, produces another
management, spreadsheet functions, and
work of another part simply because that hash from the received message, and
communications into a single package.
knowledge is poorly tracked. EAMs allow compares the two. If they’re the same, it
is highly probable that the message was local-area networks (LANs) Networks with
companies to manage legacy and object
transmitted intact. computers geographically close together
components, inventorying assets (what