Technical Controls of spreadsheet
Data Integrity App |
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.
“Trust but Verify “ Ronald Reagan
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