Published on 10/12/2025
Common Excursion Causes and How to Prevent Them
1. Understanding User Requirements Specifications (URS) and Risk Assessment
The first step in the validation lifecycle of computer system validation in pharmaceuticals is to develop a robust User Requirements Specification (URS). The URS serves as a foundational document that details the essential requirements and performance expectations for computer systems used in a pharmaceutical manufacturing and distribution environment. It encompasses both functional and non-functional requirements that must be strictly defined to ensure compliance with Good Manufacturing Practices (GMP).
The URS should include criteria related to system performance, data integrity, user access, and any regulatory requirements dictated by FDA, EMA, or WHO. Following the URS development, a risk assessment must be conducted to identify potential risks associated with the computer system’s operation, particularly how these risks could manifest as temperature excursions during transport and storage of pharmaceutical products.
The risk assessment process typically involves a team consisting of QA, regulatory, and operational personnel who evaluate the likelihood and impact of each
Proper documentation of the URS and risk assessment is crucial. This documentation should be reviewed and approved by all stakeholders before proceeding to the next steps in the validation lifecycle. Failure to properly address and document these foundational elements can lead to significant compliance issues.
2. Protocol Design for Validation Activities
Once the URS is established and risk factors are assessed, the next step is protocol design. This stage is critical as it lays out the exact validation activities that will be performed. The validation protocol should cover three primary activities: Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).
The Installation Qualification (IQ) ensures the computer system is installed correctly according to manufacturer specifications and requirements stated in the URS. This entails verifying hardware and software configurations as well as evaluating network connectivity and security arrangements.
Operational Qualification (OQ) focuses on verifying that the system operates within the specified operating ranges and responds to expected inputs correctly. It involves testing system functionality, including user interface behavior, database retrieval, data entry, and reports generation under normal and stress conditions.
Performance Qualification (PQ) confirms that the system performs its intended function consistently over time. This also includes validation of specific processes that the computer system controls or monitors, especially those crucial in maintaining temperature controls during product transport.
In a protocol, the acceptance criteria must be defined and justified based on prior assessments. This includes a summary of the rationale behind chosen testing methods, samples, and statistical analysis employed during the validation process. It is vital to obtain the approval of the protocol from all relevant stakeholders such as validation teams, management, and QA prior to execution.
3. Execution of Qualification Protocols
With the validation protocols developed and approved, the execution phase begins. Each qualification protocol requires stringent adherence to the predefined methodologies and thorough documentation of results, emphasizing transparency.
During Installation Qualification (IQ), detailed verification checklists must be completed. Documentation should include hardware and software inventory logs, installation photos, and records of key configurations. Each component must be validated against the original specifications outlined in the URS. Any discrepancies must be documented, investigated, and resolved promptly before moving forward in the validation lifecycle.
Next, the Operational Qualification (OQ) can begin. This entails running tests simulating various operational conditions. Each test must provide clear evidence that the system performs as intended. Test results should be collected, reviewed, and approved in real time to maintain data integrity. Here, deviation management becomes essential—any unexpected results should be investigated, and corrective actions documented.
For Performance Qualification (PQ), the focus shifts to a longer-term assessment of system stability and reliability. Consistency over multiple runs and variations in input conditions should confirm that the system can maintain control over critical parameters. Again, all findings must be captured meticulously.
4. Process Performance Qualification (PPQ) and Continuous Process Verification (CPV)
Following the successful qualification of the computer systems, attention shifts to Process Performance Qualification (PPQ). The PPQ phase is vital in understanding whether the system consistently performs its intended function throughout its lifecycle.
PPQ involves defining and executing validated processes with a focus on statistical process control. During this phase, multiple batches of products are monitored under real production conditions to evaluate system performance over time against pre-established acceptance criteria. A conclusion must be reached based on whether the performance meets standards set by regulatory bodies such as FDA and EMA.
Furthermore, Continuous Process Verification (CPV) extends the validation lifecycle into production, ensuring ongoing compliance. Unlike traditional validation, CPV leverages real-time data to periodically assess system performance and product quality. Automated systems collect data continuously, applying statistical techniques to assess trends that may indicate deviations or issues.
The establishment of a formal CPV plan requires documentation that outlines metrics to monitor, frequency of data collection, and protocols if deviations occur. Regulatory expectations dictate that any significant deviations or excursions must be thoroughly investigated and documented, with timely corrective actions. This ensures the integrity of pharmaceutical products transported under these controlled conditions.
5. Revalidation and Change Control Management
It is essential for validation efforts to be viewed as an ongoing commitment rather than a one-time project. Regulation bodies emphasize the need for periodic reevaluation of validated systems through revalidation. This typically arises from planned changes, new technologies, or changes in processes that may impact system performance and product safety.
Change Control Management is a critical component in ensuring that any modifications made to the computer systems are meticulously documented. Detailed procedures should be created outlining how the changes will be assessed, approved, and communicated across the relevant teams.
Any change in the computer system (such as updates, new integrations, or user access modifications) necessitates a thorough risk assessment to determine the impact on the validated state. Following this assessment, revalidation efforts may need to be executed in accordance with the foundational principles previously established during the initial qualification activities. Key performance indicators and their acceptance criteria should be revisited and redefined as necessary.
This iterative approach commands a strong emphasis on maintaining a robust quality management system that complies with guidelines from ICH Q10 and GMP principles, ensuring that both processes and systems in use are consistently validated against the most current regulatory requirements.
Conclusion: Best Practices for Effective Validation
Validation of computer systems in pharmaceuticals is a crucial element that requires thorough attention to detail and rigorous compliance with regulatory standards. Following a structured validation lifecycle—from URS and risk assessment through to CPV and revalidation—ensures that systems are consistently delivering safe and effective products.
By adhering to documented protocols and maintaining clear communication between all stakeholders, pharmaceutical organizations can mitigate risks associated with technology and operations that could affect product quality. Regularly updating validation documentation and employing best practices for change control will provide a framework for addressing excursions effectively and safeguarding against potential risks.
As the pharmaceutical industry continues to innovate and embrace new technologies, it remains imperative that regulatory expectations are met, ensuring that computer system validation in pharmaceuticals not only meets compliance standards but also safeguards public health.