copyright © 2005, sas institute inc. all rights reserved. maintaining a validated sas toolset...
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Copyright © 2005, SAS Institute Inc. All rights reserved.
Maintaining a Validated SAS Toolset
Co-Presenters: Edward Helton and Patricia Halley
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db
LIS
HIS
lab, ADT, meds, source documents
display
eCRF
complete chart note
Merged workflow: clinical trial data captured in initial CDA, re-used in chart note
validation
Proposed processes (single source)
CLINIC CRO
ODM
CDA & CDISC in Starbrite Trial
CDA(1)
CDA(2)
Source: Liora Alschuler, Landen Bain, Rebecca Kush, PhD.
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Near-term Goal: Create means of conversion to minimize risk of ODM adoption
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Agenda
Part 11 and the Predicate Rules
Applying the Predicate Rules to Maintenance of a Validated SAS Toolset
Support from SAS (now and future)
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Common Threads of GxPs
Calibrate
Test
Validate
Standardize
Retain Records
Maintain Written Procedures
Update on Part 11Update on Part 11 GMP by the SeaGMP by the SeaAugust 25, 2004August 25, 2004
Rick Friedman, Team LeaderGuidance & Policy
Division of Manufacturing and Product QualityOffice of Compliance, CDER
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FDA Regulation References - GCP
Strong New FDA Industry Guidances in GCPs
50.20 – 312.56 ( c) – sponsors shall review and evaluate evidence related to safety and effectiveness
312.57 (a) – Records must be Accurate & Complete
312.62(a,b,c) – Investigator Recordkeeping - drug disposition, case histories, record retention
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FDA Regulation References - GMP
211.22 (a) – Quality control unit has the authority to approve and reject
211.67 ( c) – Records shall be kept of maintenance, cleaning, sanitizing, and inspection
211.68 – Validation requirements of automated equipment
211.100 (a) - Written procedures for production and process control
211.180 (a), (b), and ( c) – Retention period for records
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FDA Regulation References - GLP
58.29 (b) – must maintain current summary of training for those engaged, or supervising the conduct of a non-clinical study
58.33 (b) – all experimental data… must be accurately recorded
58.35 (b) (4) – periodically submit a written status report noting problems and corrections
58.63 ( c) – records maintained of all inspections, maintenance records, testing, calibration and/or standardizing operations
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FDA Regulation References - Devices
21 CFR 812.145 (a) & (b) - Records must be Accurate & Complete
21 CFR 812.140 – must retain records required by 812
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21 CFR Part 11- Upcoming Amendment
Comments collected on the existing rule
Support for Part 11 in general
It is not going away – expect rewrite in future
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Standard Data / JANUS
Tools to receive, upload and analyze data
Unambiguous path of the source data to the analysis findings (metadata, derivations, flags, imputations, source code, analysis files)
Focus on standard data and standard analysis makes maintaining validation even more critical – valid interface, interaction between SAS systems
This makes your SAS configuration even more important!
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Standard Data / JANUS
Right now it takes analysis of many applications to find common trends.
One study took 10 person years.
We don’t have that kind of time to “find” the right data.
Standardization enhances the need for a validated SAS system.
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SAS Validation of SAS9
Customer Validation of SAS9 -- Toolset
Validated System
AERS Interim Analysis Integrated Safety Report
Customer Validation of SAS9 -- Applications
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Policies and Procedures
Staff Qualification
ConfigurationManagement
SecurityDisaster
Recovery
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Configuration Management
Identify functional and physical characteristics
Manage changes to those characteristicsSource -- IEEE
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Implement/Verify
Request/A
pproveDocument
Managing Changes
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Identify and Describe Changes Sources of Information
• Tech Support
• SAS Notes
• Mail & File Lists (TSNEWS-L)
• Monitoring Tools
Sources of SAS Updates• Hot Fixes
• Service Packs
Identify/D
escrib
e
Implement/Verify
Request/A
pproveDocument
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Identify and Describe Changes - Future
Electronic Software Downloads
i
SAS UpdatesAvailable Automatic Alert Notification
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Request and Approve Changes
Classify Change
Submit Request
Obtain ApprovalIdentify
/Desc
ribe
Implement/Verify
Request/A
pproveDocument
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Implement and Verify Changes
Test environment
SASIQ/SASOQ
Data Migration
Identify/D
escrib
e
Implement/Verify
Request/A
pproveDocument
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SASIQ/SASOQ
Automated
Tested
Repeatable
Reports and Stores Results (XML)
http://support.sas.com/rnd/migration/planning/validation/
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Data Migration
Proc Migrate
Migration Macros
Guidance and tools available at
http://support.sas.com/rnd/migration/fulltoc.html
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Implement and Verify Changes – Future
IQ/OQ Enhancements
Install Enhancements
Less media (1 instead of 19)
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Document
Initial Change Requests
IQ/OQ Output
SAS Logs
SAS Registry (Future)
Design / Configuration Specification Change Log
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Security
Physical
Logical• Operating System Level
• Account Maintenance
• Internet Security
• SAS Management Console
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Business Continuity Backups
Redundancy
Environmental Controls
Disaster Recovery
End-to-End Seamless Integration; Semantic Interoperability
Pharma
Medical & StatisticalReviewers
Approval
Open Data Model - XML based, CDISC compliant
Patients
Subject
CDMSOp DB
Investigator
Physician
ODM SDTM
LAB ADaM
Source: Dave Iberson-Hurst
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