Does Life Technologies offer a Computer System Validation Service?
Yes, our experienced professionals perform Computer System Validation Services on various platforms.
Does Life Technologies provide 21 CFR Part 11 compliant software?
Part 11 sets forth criteria under which FDA considers electronic records, electronic signatures and handwritten signatures executed to electronic records to be trustworthy, reliable and generally equivalent to paper records and handwritten signatures executed on paper. These criteria include audits, system validations, audit trails and certain documentation. Vendors including Life Technologies, cannot provide software that complies with all these Part 11 requirements.
Life Technologies does provide software that has features (such as audit trails and electronic signatures) that enable customers to comply with various regulations, but only after the customer has gone through our Computer System Validation Service. Life Technologies provides Computer System Validation Service for several instrument platforms. Instruments for which we offer Computer System Validation Service.
Where can the requirements be found based on my regulated status?
| | GLP 21CFR 58 | ISO15189 | ISO17025 | CLIA 42 CFR 493 | State of NY Dept. of Health |
| Quality Management System | 58.31, 58.35 | 4.1.5, 4.2 | 4.2 | 493:903, 1357, 1405 | QMS S1-S5 |
| Lab Environment Controls | 58.41-51 | 4.10.1, 5.1, 5.3, 5.8 | 4.11, 5.3, 5.5, 5.10 | 493:1252 | GF S1 |
| Verification of Purchased Products | 58.83 | 4.6.2, 5.5.3, 4.6.4 | 4.6 | 493:1256 | LE SA, REAF S2-S7 |
| Controlling Computer Systems | 58:185-195 | 4.3.2, 4.13, 5.3, 5.8, AnnexB | 4.3, 4.13, 5.4.7, 5.5, 5.10 | 493:1283 | LIMS S1-S10 |
| Lab Equipment | | | | | |
| Validated/Verified | 58.61-63 | 5.3.2, 5.3.4 | 5.5 | 493:1253 | LS2-S5, S8 |
| Maintained, Calibrated, Functional Verification | 58.63 | 5.3.2, 5.3.4, 5.3.2, 5.3.4, 5.3.6, 5.3.7, 5.3.9-10 | 5.5, 5.6 | 493:1254-55 | LS2-S5, S8 |
| Training Record | | | | | |
| Supplier | 58.29 | 5.1.2, 5.1.10-11 | 5.5.3 | 493:1423, 1455 | HR S3 |
| Lab Personnel | 58.29 | 5.3.5 | 5.2, 5.3 | 493:1495 | HR S3 |
| Method Validation | 58.120 (limited) | 5.5 (limited) | 5.4 | Subparts | Validation S1-S6 |
GxP collectively refers to a set of quality-related regulations and guidelines that are followed by regulated industries such as pharmaceutical and life sciences to help ensure that products are safe and function as intended.
- Good Laboratory Practices (GLP)— framework for conducting nonclinical laboratory studies
- Good Clinical Practices (GCP)—framework for conducting clinical trials
- Good Manufacturing Practices (GMP)— methods, facilities and controls used in the manufacture, packaging, labeling, storage, installation and servicing of products to ensure their safety and effectiveness

Is a risk assessment mandatory to be compliant with GxP requirements?
No, a risk assessment is not mandatory, although it does help customers optimize their validation strategy. In keeping with GAMP5 , a risk-managed strategy will help reduce both the costs of validation and exposure to regulatory risk. Life Technologies provides a Risk Assessment Service that can be a starting point to help you with your compliance efforts.
Which Life Technologies™ platforms have software that can enable compliance with certian GxP and Part 11 requirements?
| Type | Platform | Enables Compliance? | Qualification Services | Computer System Validation Service |
| RT-PCR | SDS 1.4/1.5 software on 7500 FAST | Yes | Yes | Yes |
| RT-PCR | SDS Enterprise 2.4 software on 7900 HT | Yes | Yes | Yes |
| RT-PCR | AccuSEQ® software on 7500 FAST | Yes | Yes | Yes |
| GA | 3500 Data Collection 1.0 software, GeneMapper® v 4.1 software | Yes | Yes | Yes |
| GA | 3x30 Data Collection 3.x software, GeneMapper® v4.1 software | Yes | Yes | Yes |
Does Life Technologies operate under ISO standards?
Yes, Life Technologies™ software and platforms are developed under ISO 9001:2008 standards.
Is a vendor audit enough to ensure that software features such as audit trails and electronic signatures are all present and compliant?
No, a vendor audit is just one step in your validation process. FDA regulations provide that Computer System Validation involves testing the system in the customer environment, and is ultimately the customer’s responsibility. The customer is also responsible for implementing procedural and administrative controls for regulatory compliance. The Risk Assessment Service provided by Life Technologies includes a Computer System Validation that helps to identify computer system gaps and provides recommendations to improve your laboratory’s efficiency.
When does Part 11 apply?
21 CFR Part 11 applies to records, required by FDA’s regulations, that are in electronic form and are created, modified, maintained, archived, retrieved or transmitted. Part 11 also applies to electronic records submitted to FDA.
Good Automated Manufacturing Practices Version 5 (GAMP5), specifies that regulated companies have the responsibility for documentation, approval, and compliance of each element of the computerized system lifecycle. GAMP5 provides that such companies utilize vendor audits to ensure quality of the product and development process. The guide also suggests that regulated companies maximize supplier involvement to help with gathering requirements, creation of functional and other specifications, system configuration, testing, support, maintenance, and system retirement.

How does quality system management differ among GxP?
| | GLP | GCP | GMP |
 SOP System Management | - Site Management has oversight of SOPs
- QAU verifies GLP compliance
| - Sponsor has the responsibility
| - Aides departments in drafting SOPs
- QA approves SOP
|
 Approval | - Study Director responsible for scientific content
- QAU inspects final report
| | - QC issues certificate for authorizing use
- Quality assurance unit reviews documentation
|
 Material Management | - Study records include test and reference item characterization, receipt and expiration date, quantity received and used
| - Traceability, accountability and reconciliation of materials
| - Verify strict material controls from warehouse arrival through final product
|
 Facilities and Equipment | - Prevention of cross contamination and mix-ups; separation of activities to assure proper study conduct
| | - Premises and equipment must be located, designed, constructed, adapted and maintained to suit the operations and minimize adverse effects on quality of products
|
 Facilities and Maintenance | - Facilities, equipment, and utilities should be qualified to assure adequate performance
| | - Facilities, equipment and utilities should be qualified to assure adequate performance
|
 Calibration | - Periodically inspect, clean, maintain and Calibration/Assure of consistent performance for equipment should be described in SOP and records maintained
- Where possible; traceable to NIST
| | - Calibration/Assure of consistent performance for equipment should be described in SOP and master plan available
|
 CVS | - Full life-cycle validation required
| - Full life-cycle validation required
| - Full life-cycle validation required
|
 Method Validation | | | - Method validation is essential
|
 Reserve Samples | - Sample for analytical purposes from each test batch should be retained
| | - Mandatory to keep appropriate amount of reference materials from raw to finished
|
 Audits | - 3 types of inspections:
- Study-based
- Facility-based
- Process-based
| - Sponsor Audit; looking at trial conduct, compliance to protocol, SOPs, GCP and applicable regulatory requirements
| - Personnel, premises, equipment, documentation, production, quality control, medicinal product distribution, complaint handling, recalls and self inspection to verify conformance with QA
|
Outsourcing Control | - Must audit “live” and “historical” sample preparation
| - Audit prior to starting clinical activities
| |
 Change Control | | | - Formal investigation detailed in SOP
|
How do GxP responsibilities differ?
| Function | GLP | GCP | GMP |
| Ownership | Facility Management | Sponseor | Manufacture/Holder of Authorization |
| Responsibility | Study Director | Principal Investigator | Qualified Person |
| Responsibility for "Production" | Principal Investigator | Pharmcist | Head of Production |
| Quality | Quality Assurance | Monitor Quality Assurance | Quality Control |
| Archive | Archivist | Archivist | |
What are some frequently cited issues?
For Computer Computerized Laboratory Systems
| Instrument | | Software | | Method |
- Inadequate equipment testing and calibration
- No verification of outside contractor to complete and perform
- No written procedure that includes requirement performance verification
- IQ, OQ, OM never completed
| | - Failure to validate
- User access levels and poorly controlled
- Ability to overwrite raw data
- Failure to ensure e-records are trustworthy, accurate, and reliable
- No established (or poorly followed) procedures for change control
| | - Inadequate testing and calibration of the equipment
- No reproducibility
- No linearity tests
- Documentation incomplete
|
What are the main cases of incorrect test data?
Does Life Technologies offer flexible pricing plans?
Yes. To help you control validation costs, we offer discounts when you sign up for validation services on multiple systems.