Software Validation Inadequate


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Warning Letter: Inadequate electronic documentation system (ucm162970)

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Specifically, your firm creates and stores all written information as electronic files and you do not keep any hard copies of these records. Your electronic documentation system does not meet system validations, system access limitations, audit trails, signature manifestations, and signatures to record linking requirements to ensure they are trustworthy, reliable and generally equivalent to paper records as required by 21 CFR Part 11.

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Warning Letter: No validation of calculations (ucm162874)

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Failure to maintain a written record and appropriate of computer or other automated processes used to perform calculations in connection with laboratory analysis [21 CFR § 211.68(b)]. Refer to FDA 483, Observation 12. For example, the accuracy of calculations performed by the [redacted] Spectrophotometer has not been verified.

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Warning Letter: Spreadsheet Calculations not Verified or Documented (ucm174100)

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Your laboratory records did not include a record of all calculations performed in connection with laboratory tests as required by 21 CFR § 211.194(a)(5). For example, laboratory notebook #7, page 49, documents the assay results, but not the calculations performed in Test number DSFS D-13 and Test number TG 521 for the analysis of [redacted], lot #HI7908. The notebook does not document reference to the spreadsheet calculation used to generate the results. In addition, the assay results generated by the spreadsheet were not verified for accuracy. Your response dated February 16, 2009, states that you have established procedures to ensure that calculations of method validation studies are recorded. The Records Management SOP, Section 5.7.4.7, states that the procedures shall define what and how data is to be recorded in respective logbooks. However, this SOP omits instructions to include in the notebook the reference to the spreadsheet calculation used to generate the results, as well as the raw data and calculations. In addition, you continued to release products based on assay results generated by the spreadsheet that have not been verified for accuracy.

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Warning Letter: Failure to establish procedures (ucm165301)

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Failure to establish procedures for quality audits and conduct such audits to assure that the quality system is in compliance with the established quality system requirements and to determine the effectiveness of the quality system, as required by 21 CFR 820.22.

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Warning Letter: Failure to provide validation plans and reports (s6845c)

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“you have not provided verification and validation data to demonstrate the software revision will be effective over the life of the device. In your response to this warning letter, please provide the verification and validation plans and reports for Software [redacted]”

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Warning Letter: Failure to provide documentation of validaiton (s6786c)

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“Failure to establish and maintain procedures for validating the device design, including software validation , as required by 21 CFR 820.30(g). For example, your firm provided no documentation of validation of the embedded software in the SAFERsleep device.”

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Warning Letter: Failure to adequately establish and maintain procedures for software validation (s6730c)

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Failure to adequately establish and maintain procedures for software validation and to perform risk analysis, where appropriate, as required by 21 CFR 820.30(g). For example: a. Design validation of device software was not performed for some versions of the software and is inadequate for other versions. Specifically, your firm has not conducted validation of your [redacted] Software after changes to the software’s functionality have been made from your first distribution of Version [redacted] through your current Version [redacted]. Also your firm’s most current software validation of the [redacted] Software [redacted] Platform is inadequate in that the validation that was conducted for Version [redacted] consisted primarily of functional testing (black-box testing) and lacks other elements of software validation including structural testing (white-box testing).

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Warning Letter: Failure to validate computer software (s6537c)

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Failure to validate computer software for its intended use according to an established protocol when computers or automated data processing systems are used as part of production or the quality system; as required by 21 CFR 820.70(i). For example: For yours, Asheboro, NC, facility, the [redacted] Training Database software validation used to document employee training was deficient in that the test scripts were not available to show the execution of the software validation protocol. It appears that at least five (5) tests specified in the approved protocol were not performed.”

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Warning Letter: Failure to maintain records (s6526c)

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Failure to maintain accurate, complete, and current records of each subject’s case history and exposure to the device [21 CFR 812.140(a)(3)].” “We also note that according to Ms. Little-Tierney, all of the original medical records involved in this study were discarded after they were scanned. Your response to the FDA 483 indicates that your medical practice normally operates as a [redacted] office, relying on [redacted] copies of records. Any [redacted] records you maintain must be sufficient to meet your underlying recordkeeping obligations. As we noted above, as an investigator, you are required to maintain accurate, complete, and current records as provided for in 21 CFR 812.140 (a). You must maintain all required records for a period of two years after the latter of the following two dates: the date on which the investigation is terminated or completed, or the date that the records were no longer required for purposes of supporting a premarket approval application or a notice of completion of a product development protocol. (See 21 CFR 812.140(d)).

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Warning Letter: Failure to Validate MS Excel Spreadsheets (s6366c)

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Failure to adequately validate the intended use of this PC and its software, as required by 21 CFR 820.70(i). “For example: the dedicated PC [redacted] attached to the [redacted] was not secure in that access to the data on [redacted] was not granted by a unique username and password or equivalent method; there as no documentation associated with the electronic data for whom was responsible for collection of the analytical results as several quality control personnel have access to the [redacted] no software changes in the study data could be detected as there was no audit trail capability ; and finally, the electronic data did not correlate with the paper records.”

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