Life Science Compliance Navigating the Complexity of Life Science Compliance Riya Cao – Director Vertical Marketing, QAD Ray Greenwood, VP Consulting Services, Strategic Information Group 1 Life Science Compliance Safe Harbor Statement The following is intended to outline QAD’s general product direction. It is intended for information purposes only, and may not be incorporated into any contract. It is not a commitment to deliver any material, code, functional capabilities, and should not be relied upon in making purchasing decisions. The development, release, and timing of any features or functional capabilities described for QAD’s products remains at the sole discretion of QAD. 2 Life Science Compliance Agenda Introductions Compliance challenges What is validation? Planning your upgrade with validation in mind • QAD life sciences update • • • • 3 Life Science Compliance QAD Life Sciences At-A-Glance • 600+ Accounts in 64 Countries • 21 New Accounts FY10 • 24 New Accounts FY11 • 27% Revenue increase FY11 Regions Namer 40% Lamer 7% APAC 18% EMEA 35% Sectors Other 12% Pharma Biotech 37% Medical Device 51% 4 Life Sciences Sample Customers 5 Life Science Compliance Meeting Life Sciences Industry Requirements Regulatory Compliance • cGMP • FDA 21 CFR Part 11 • European Commission Annex 11 • ePedigree • GAAP, SOX, IFRS Suppliers Quality Accountability • Product safety • In-coming inspection • Supplier performance Finished Product Mfgr Customer Satisfaction • Configured products • After sales services • Returned goods • Complaints Distribution Channels Customers Supply Chain Distribution • Contracts • Packaging & labeling • EDI 6 Winner of Best White Papers Category http://www.qad.com/erp/Life-Sciences/ 7 Life Science Compliance 21 CFR Part 11 / Annex 11 • • • • • • Security Audit trails Electronic signatures Training Supporting procedural infrastructure Computer system validation 8 Life Science Compliance QAD Enhanced Controls • Enhanced security • Audit trails • E-Signatures QAD Enterprise Applications Enhanced security QAD Enhanced Controls Audit trails e-Signatures Sarbanes-Oxley infrastructure 21 CFR Part 11 9 Life Science Compliance 21 CFR Part 11 / Annex 11 • • • • • • Security Audit trails Electronic signatures Training Supporting procedural infrastructure Computer system validation 10 Life Science Compliance Training & Procedural Control Life Sciences Easy On Boarding 11 Training & Procedural Control • • • • 25 processes 230+ Work Instructions 137 Compliance points 30 Training links 12 Life Science Compliance 21 CFR Part 11 / Annex 11 • • • • • • Security Audit trails Electronic signatures Training Supporting procedural infrastructure Computer system validation 13 STRATEGIC INFORMATION GROUP QAD Validation Product Partner What is Validation? Proof That a System Is “Performing As Designed” 14 Life Science Compliance A Definition for FDA Validation All production and/or quality system software should have documented requirements that fully define its intended use, and information against which testing results and other evidence can be compared, to show that the software is validated for its intended use Food & Drug Administration 15 Life Science Compliance Validation Deliverables and Definitions • System development lifecycle policy for computer related systems - • User specification/requirements-high level - • Is system specific and defines the scope, approach, tasks, roles, responsibilities, testing environment and acceptance criteria for the computer system. Hardware Installation Qualification (IQ) protocol - • Created as an aide for the software selection process Computer system validation plan - • SOP describing the lifecycle for the acquisition, development, implementation, upgrade and retirement of software applications and computerized systems. Verify and document that all critical aspects of the server installation adheres to company specifications and manufacturer’s specifications. Software Installation Qualification (IQ) protocol - The purpose of this protocol is to provide documented evidence to a high degree of assurance that the QAD enterprise applications software application has been installed in accordance with vendor specifications and company requirements. 16 Life Science Compliance Validation Deliverables and Definitions • • • Configuration baseline - Modules implemented - Control file settings - GMP related item status codes, inventory status codes - Sets the stage for change control System design requirements - Define the intended use of the system - Generated by evaluating user requirements against intended use of QAD, cGxP and Sarbanes-Oxley requirements. - If the software is configurable, off the shelf software, and the configuration will be done in an iterative fashion, the software design specification may be omitted. Functional requirements - Define the intended use of the system. - Generated by evaluating the user specification/requirements document against the intended use of the system. - Describe the functions that the system will perform. 17 Life Science Compliance Validation Deliverables and Definitions • • Functional specification - Define the intended use of the system in support of the functional requirements - Process flows/design document Part 11 assessment - • Risk assessment/hazard analysis - • • 21 CFR part 11 compliance assessment Identify and evaluate cGxP risks for the QAD ERP system. Operational Qualification (OQ) protocol/test scripts - Provide documented verification that a system operates according to written and pre-approved specifications throughout all specified operating ranges and may include testing outside operational ranges. - Discrete test scripts Performance Qualification (PQ) protocol/test scripts - Provide documented verification that the system is capable of performing and controlling the activities of the process it is required to perform or control while operating in its specified operating environment. 18 Life Science Compliance Validation Deliverables and Definitions • Stress test - • Traceability matrix - • Matrix that ties user requirements, functional requirements, user instructions, OQ test scrip document ID and test number. Data migration Installation Qualification (IQ) protocol/test scripts - • Verify and document that the QAD system performance is acceptable to all company locations while operating under typical load conditions. The IQ provides documented evidence that cGxP related data was successfully loaded by comparing source and target reports/files. Validation final report - Review/summary of all validation deliverables. Sign-off that the system is approved. 19 STRATEGIC INFORMATION GROUP QAD Validation Product Partner Planning Your Upgrade With Validation In Mind 21 Life Science Compliance Validation Approaches When Upgrading • Determine scope - Technical upgrade only with new .NET UI and QAD EE • Rely on QAD release notes for guidance on enhancements with potential compliance impacts • Rely on QAD ECO information for guidance on fixes with potential compliance impacts - Upgrade and implement new modules/functionality 22 Life Science Compliance Validation Approaches When Upgrading • Option A: Revalidate everything - Draft required new/revised cGxP related functional requirements. - Identify previous functional requirements that may be affected by product enhancements or eco’s. - Combine the above with previous functional requirements - Perform risk assessment on all of the above functional requirements. - Write and execute OQ protocol/test scripts for medium or high risk requirements - Re-execute PQs. 23 Life Science Compliance Validation Approaches When Upgrading • Option B: Leverage previous validation packages - Draft required new/revised cGxP related functional requirements. - Identify previous functional requirements that may have be affected by product enhancements or ECO’s. - Perform risk assessment on the above new/revised or affected functional requirements. - Write and execute OQ protocol/test scripts for medium or high risk requirements - Re-execute PQs. 24 Life Science Compliance Where Do I Find Release Notes and ECO Information? • support.qad.com 25 Computer System Validation QAD Release Notes 26 Computer System Validation QAD Release Notes 27 Computer System Validation QAD Release Notes Sample 28 Life Science Compliance QAD ECO Information 29 Life Science Compliance QAD ECO Information 30 Life Science Compliance Validation Deliverables to Consider • • • • Computer systems validation plan Hardware installation qualification Software installation qualification User/functional requirements 31 Life Science Compliance Validation Deliverables To Consider • Risk assessment • Operational qualification protocol/test scripts • Performance qualification protocol/test scripts • Baseline configuration 32 Life Science Compliance Validation Deliverables to Consider Backup & restore protocol/test scripts Traceability matrix Stress test Data migration plan/protocol - Possibly was not part of the initial validation • Validation final report • • • • 33 Life Science Compliance QAD Life Sciences Update 34 Life Science Compliance Serialization ePedigree Wholesaler EPCIS Pedigree Messaging EPCIS Data Collection ePedigree Retailer EPCIS Serialized Inventory Mgmt Packaging Line Product Serialization Distributor EPCIS Pick/Pack/ Ship Wholesaler ERP Print Packer/ Case/Pallet labels Distributor ERP RxASN Retailer ERP 35 Life Science Compliance On Demand LS Edition • Qualified environment including - Qualified IT infrastructure • Hardware (IQ/IR) • Operation systems (IQ/IR ) • QAD enterprise applications (IQ/IR) - Qualified processes • 18 SOPs - Qualified personnel • Extensive experience in admin & network • Employees trained to SOPs • Training records 36 Life Science Compliance Meeting FDA QS Requirements QMS Corrective and Preventative Actions PLM QAD EA Production and Process Controls Design Controls Management Equipment and Facility Controls Material Controls QAD EA Records, Documents, Change Controls QAD EA EAM QMS http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/ucm126252.htm 37 Life Science Compliance Metrics Affected Process Benefit Value • On Demand Risk mitigation Scalability Qualified environment Compliance Best practice IT Administration •Computer System Validation CFR21 Part 11 Compliance Risk based Industry validation best practice 38 Life Science Compliance Next Steps • Ask your account manager to arrange an Upgrade Q−Scan • On Demand Q−Scan • Stop by the Strategic booth • Attend Thursday morning QMS presentation • QAD Life Sciences website http://www.qad.com/erp/Life-Sciences/ 39 Life Science Compliance Questions & Answers • Riya Cao: zrc@qad.com • Ray Greenwood: rayg@strategic.com 40 www.qad.com © QAD Inc 41