Cannabis & GMP/GACP: Part 6 - Software Validation
Welcome to our summer series on cannabis and GMP/GACP. A new article will be published once a week throughout the summer. You can access related articles that have been published so far by clicking the Compliance category on the main News & Events index page: Compliance category
Validated Software vs GMP-ready Software
As noted, there is no certification for software. Software can only be validated.
For facilities seeking GMP certification, there are two types of software validation: system validation and process validation.
System validation involves a review of the software against the criteria for computerized systems in the quality system. The vendor must be qualified, along with their internal processes, to ensure that the software has been developed in a way that meets good practices for privacy, security, data integrity and more.
Process validation involves running tests of critical operations to ensure that the software performs as specified and that the results meet the guidelines.
These validations happen during the facility certification process.
Most computerized system vendors offer validation support to help their clients through the certification process. This support may include test scripts and documentation.
But be aware that just because software has been validated does not mean that it covers all GMP requirements. In fact, software that has been validated could have only one GMP-related feature, but that one feature was reviewed during the certification of a facility.
What validation does is ensure that the software meets the criteria for computerized systems and that any features that manage GMP-related processes are compliant.
Also be aware that any vendor can claim that their software is GMP-ready, whether it has been validated or not. GMP-readiness implies that the software meets the criteria for computerized systems and that features in the software are compliant. But only on-site validation against the facility’s processes will determine if it meets compliance for certification.
And GMP-readiness, or even validation, is not an indication of how many GMP-related features one software has in comparison with another. Also know that GMP certification of a cannabis facility is not dependent on the software in use being pre-validated or claiming GMP-readiness. The proof is in the review of the software in relation to the processes in the facility.
Essentially, one software application should not be assumed better for GMP than any other software based on a claim of being GMP-ready or validated. The proof is in the functionality that each software system has in relation to GMP. And if a software vendor claims their system is GMP-certified or GACP-certified, know that this is untrue. Software cannot be certified, neither can any piece of equipment. Only a facility can be certified.
Validation Process
During GMP certification, all software applications that have GMP implications will need to be validated during certification.
The vendor will be scrutinized to ensure that they are a legitimate business and that they follow accepted practices in their software development. This typically requires a review of business licensing and standard operating procedures.
The software will also be tested against specific workflows to ensure that it functions as designed and as required to meet compliance. This typically involves utilizing product instructions and test scripts.
In the certification process, only GMP-related activities are validated. Activities outside the scope of GMP are not validated. For example, since growing and harvesting are not covered by GMP, the facility would not validate those during the certification process. An LP selling dried cannabis would start the validation process at the drying stage and move on through testing, packaging, labelling, and distribution.
Plus, activities outside the scope of the facility are also not validated. If a facility is not manufacturing edibles, the GMP section that covers that type of product would not be included in the certification process.
Each certification process is unique to the facility and to the products being manufactured.
Links
Following are links to the various standards that could be applied to cannabis.
Good Agricultural & Collection Practices/GACP (also called GAP): International; Israel
https://www.who.int/publications/i/item/9241546271
https://www.gov.il/en/departments/topics/medical-cannabis/govil-landing-page
Good Production Practices GPP: Canada
Good Manufacturing Practices/GMP: International; European Union; Australia
Current Good Production Practices/cGMP: USA
Good Distribution Practices/GDP: United Kingdom
https://www.gov.uk/guidance/good-manufacturing-practice-and-good-distribution-practice
Software Validation for Cannabis Processors
One of the challenges for cannabis processers is that regulations require them to validate their extraction practices. In many cases, those practices involve the use of software. Therefore, any software used in relation to production must be validated along with the practices.
As tracking production reliability is an important part of meeting compliance, most tracking involves the use of software.
Software vendors are responsible for ensuring the software they sell works as described. But, validating that software is the responsibility of the processor. Why? Because every organization operates differently, and validation must be done in relation to actual production practices.
If you are using AirMed as your system-of-record, you will need to validate our software as it is used in your facility.
AirMed helps you through the validation process by providing test scripts that can be used to validate each task in the workflows that relate to extraction processes. These test scripts show what the software was designed to do, how the software should be used for that specific task and what the end result should be.
We can provide you with a validation report outlining how we meet software vendor compliance. Our validation report details how our software complies with security, privacy and accessibility requirements. AirMed software has been designed to not only meet compliance with Canada’s Cannabis Act but also to support and comply with Federal and Provincial privacy legislation and regulations (PIPEDA, PIPA, PHIPA, PHIA). AirMed also meets the standards outlined in the US FDA 21 CFR Part 11, which many other specifications are based on.
Our internal procedures have been through an external vendor audit for the pharmaceutical industry and passed with no observations.
If you’d like to learn more about good production practices for cannabis in Canada, the Government of Canada has published GPP guidance information here: https://www.canada.ca/en/health-canada/services/cannabis-regulations-licensed-producers/good-production-practices-guide/guidance-document.html
For more information on how AirMed helps you meet compliance, visit our Compliance page or our Frequently Asked Questions page. If you’d like to discuss your specific needs, please give us a call at 1-877-313-2442 or use one of the contact forms to start the ball rolling.