Technical Controls of spreadsheet

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Technical Controls of spreadsheet

In order to meet specific regulations, for example audit trails within 21 CFR Part 11 [5], it may be necessary to add additional technical controls to Excel.


These controls can normally be added in one of two ways.

• Custom developed macros and functionality provided either on a spreadsheet by spreadsheet basis, or as a generic module which is added in the same format to multiple spreadsheets.

These customized developments will generally be classed as GAMP category 5 software [8], and as such merit a rigorous validation effort due to the risks associated with customized application and coding.

• Third party software packages that add additional technical controls to the Excel environment. These off the shelf software packages will generally be classed as GAMP category 3 / 4 software8, and as such require specific validation.

When either of these “add-on” options are implemented, the project should be planned such that the validation effort be performed only once for the add-on.

Each subsequent spreadsheet validation should then reference the add-on validation. The investment in additional, extended validation of these types of add-on components is usually repaid as it reduces the effort required to show security and traceability on each individual spreadsheet.

The larger the spreadsheet inventory, the more beneficial these options become. These options are most commonly used to comply with the necessary technical controls of 21 CFR Part 11.

 A typical spreadsheet validation project would include the installation of these additional controls, combined with the implementation of multiple spreadsheet templates.

An example process for a project incorporating the DaCS addon9 is depicted in Figure 2. The validation of the technical controls is only performed once; the validation of these add-on features can then be referenced on the streamlined validation of each spreadsheet.


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