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IT/OT Infrastructure in GxP Environments: Cloud Connectivity, System Qualification, and Inspection Readiness

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This course helps teams qualify and maintain connected GxP infrastructure using risk-based approaches that support validated status, clearer vendor accountability, secure data flows, and continuous inspection readiness across IT, OT, cloud, and hybrid environments.

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  • Course ID
    TF3247
  • Live Q&A +
    Continued Learning
  • Presentation Handout
    & Templates
  • Assessment
    & Certification Included

 

Why take this course?

As GxP operations become more interconnected, Information Technology and Operational Technology increasingly depend on cloud platforms, industrial networks, edge devices, integrations, and shared data flows. This convergence can improve operational visibility and decision-making, but it also creates additional qualification, cybersecurity, data integrity, vendor oversight, and compliance challenges across pharmaceutical, biotechnology, and medical device environments.


This webinar examines how modern IT/OT infrastructure should be designed, qualified, maintained, and supported throughout the system lifecycle. Participants will consider cloud connectivity, hybrid architectures, CSV and CSA approaches, vendor and cloud service provider responsibilities, cybersecurity controls, interfaces, integrations, and infrastructure changes. The discussion also addresses 21 CFR Part 11, data integrity requirements under 21 CFR Parts 211 and 212, objective evidence for inspections, and practical methods for maintaining validated status and continuous inspection readiness across connected GxP environments as systems undergo upgrades, migrations, and other infrastructure changes. 

Determine Qualification Requirements Across Connected Infrastructure

Develop a clearer basis for determining qualification and validation requirements across cloud-connected systems, hybrid architectures, edge devices, industrial networks, and integrated platforms. Understanding where IT and OT responsibilities intersect helps teams apply risk-based controls while maintaining data integrity, validated status, and appropriate oversight as infrastructure evolves.

Prepare Infrastructure Evidence for Regulatory Inspection

Strengthen preparation for inspections by understanding the records, qualification evidence, vendor information, cybersecurity controls, and lifecycle documentation regulators may request. This includes evaluating cloud service providers, maintaining control during upgrades and migrations, and identifying compliance gaps associated with interfaces, integrations, network connectivity, and data flows.

Key Areas Covered

  • IT and OT systems within GxP-regulated environments 
  • Cloud connectivity, edge devices, and hybrid architectures 
  • CSV and CSA approaches to infrastructure qualification 
  • 21 CFR Part 11 electronic records and electronic signatures 
  • Data integrity requirements under 21 CFR Parts 211 and 212 
  • Cybersecurity controls and cloud service provider qualification 
  • Interfaces, integrations, networks, and connected data flows 
  • Inspection readiness across infrastructure changes, upgrades, and migrations 

Who Must Attend

  • Quality Assurance Departments
  • Regulatory Affairs Departments
  • IT and Digital Transformation Departments
  • Manufacturing and Operations Departments
  • CSV and CSA Specialists
  • Data Integrity Specialists
  • Laboratory Informatics and LIMS Administrators
  • Cybersecurity and AI Governance Teams
  • Compliance and Audit Managers
  • System Owners and Subject Matter Experts
  • Vendors and Consultants Supporting GxP Systems
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Commonly Asked Questions About This Subject

The following questions address practical regulatory, compliance, validation, quality, operational, and inspection-related considerations commonly associated with this subject.

Where does responsibility sit when a GxP failure occurs across an IT/OT interface owned by different teams?

Responsibility cannot disappear at the interface. When IT owns infrastructure, Operations owns equipment, Automation owns controls, and a vendor manages the cloud service, the regulated organization still needs defined accountability for the end-to-end GxP function and its data. 


Interface failures expose this quickly. A production system may execute correctly while data transmission fails, timestamps become inconsistent, records are duplicated, or information reaches a downstream system incompletely. Each individual platform can remain operational while the regulated process has already lost integrity.


Investigations become difficult when every team demonstrates that its own component performed as designed but nobody owns the transaction across the boundary.


Effective governance identifies responsibility for interface monitoring, failure detection, reconciliation, incident assessment, recovery, and change impact. Evidence should demonstrate that critical data can be followed from its source through the connected environment.


During inspection, explaining individual systems is relatively easy. Explaining who controls the spaces between them is often where weaknesses become visible.

How much qualification evidence is enough for shared cloud infrastructure that the regulated company cannot directly inspect or control?

The evidence should be sufficient to establish confidence in the infrastructure services that support the regulated use, with depth based on their GxP significance and the controls retained by the customer. Attempting to qualify every underlying cloud component directly is often impractical, while relying solely on vendor assurances leaves important dependencies unexplained. 


The practical question is which infrastructure capabilities the validated application depends upon. Availability, backup and recovery, access control, data storage, time synchronization, security, monitoring, and change management may carry different significance depending on the system.


Supplier assessments, certifications, independent assurance reports, contractual commitments, service documentation, architecture information, and operational performance can contribute evidence. Their value depends on whether they address the services actually relied upon.


Inspection friction develops when qualification packages contain extensive vendor material but cannot explain what was reviewed or why it was sufficient. A smaller body of deliberately selected evidence can be more defensible than hundreds of pages collected without a clear qualification rationale.

What should happen when a cybersecurity event affects GxP infrastructure but there is no evidence that regulated data were altered?

The event still requires a quality impact assessment if it could have affected the availability, integrity, authenticity, or reliable processing of GxP information. Absence of confirmed data alteration does not by itself establish that the regulated state was unaffected.


Consider unauthorized access, network disruption, malware containment, failed authentication services, or compromised infrastructure credentials. IT may resolve the technical incident successfully, yet Quality still needs to understand what systems were exposed, what records or interfaces were potentially affected, and whether normal processing can be trusted for the relevant period.


This is where separate cybersecurity and quality workflows create problems. A security ticket may document containment thoroughly while leaving no evidence that GxP consequences were assessed.


Useful evidence includes system and security logs, access histories, data reconciliation, interface records, backup information, and documented evaluation of affected operations. Closing the cyber incident and closing the GxP impact question are separate decisions that should remain visibly connected.

What makes an IT/OT infrastructure inspection difficult even when every major system has a current validation package?

Problems emerge when the validation packages describe individual systems well but nobody can reconstruct the operating environment that connects them. Modern GxP processes may depend on cloud services, industrial networks, interfaces, edge devices, middleware, identity services, databases, and infrastructure components that cross several technical and organizational boundaries. 


An inspector may start with a regulated record and follow its path rather than review systems one at a time. That can expose undocumented dependencies, unclear data transfers, uncontrolled infrastructure changes, or components that fall between IT qualification and application validation.


Static architecture diagrams also create false confidence when they no longer match the live environment.


Inspection readiness improves when the organization can explain the current architecture, critical dependencies, data flows, ownership boundaries, qualified infrastructure, and significant changes without assembling the story during the inspection. The strongest evidence shows that the environment being described is the environment actually supporting GxP operations today.

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Testimonials

This is an upcoming session. Feedback below reflects experiences from similar programs delivered by our expert faculty.

“Session was easy to follow even for non-core team members. That helped.”
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“Good balance. Not too basic, not too deep. Worked well for mixed team.”
- Manager, Regulatory Affairs
“Team found it useful. Especially for aligning understanding across functions.”
- Director, Operations

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