2-DAY EXCLUSIVE SEMINAR
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Risk-Based CSV/CSA for Modern GxP Systems: Making Defensible Validation Decisions in Practice

  • Date
    24 - 25 September 2026
  • 11.00 AM - 02.00 PM Eastern Time (US/Canada)
    03.00 PM - 06.00 PM GMT

Course is now LIVE. Click below to join the session.

This course helps teams make scientifically justified validation decisions, concentrate effort on higher-risk functions, use supplier evidence appropriately, and maintain modern GxP systems in a continuous state of compliance. This Seminar is designed for Professionals responsible for computerized system assurance, validation decisions, system compliance, quality oversight, or inspection readiness.

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US $290 per learner
  • This course is Included in Subscription Pack
Subscription include access to entire Learning Library
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  • Faculty
    Carolyn Troiano
  • Duration
    2 Days - 3 Hours each
  • Course ID
    TF3244
  • Live Q&A +
    Post-live Continued Learning
  • Presentation Handout
    & Templates
  • Assessment
    & Certification Included

 

Why take this course?

Computer System Validation is moving from documentation-heavy practices toward FDA’s risk-based Computer Software Assurance approach, increasing the importance of intended use, critical thinking, patient safety, product quality, and data integrity. Validation effort must be proportionate to system risk and supported by scientifically justified decisions, particularly as regulated organizations adopt cloud, SaaS, configurable, and AI-enabled platforms across modern GxP operations.


This intensive two-day course examines how CSV, CSA, GAMP® 5, and quality risk management can be applied to determine validation scope, testing depth, supplier reliance, and evidence requirements. Participants will work through system criticality, requirements and traceability, scripted and unscripted testing, vendor documentation, data integrity, 21 CFR Part 11, change control, and maintenance of the validated state. The course also addresses Agile, DevOps, continuous deployment, AI-enabled systems, inspection-ready validation packages, and practical decision exercises for applying risk-based validation principles.

Determine Validation Effort Based on Actual System Risk

Develop the ability to determine validation scope and testing effort according to intended use, system criticality, complexity, patient safety, product quality, and data integrity. This supports focused testing and clearer rationale for why particular functions received greater or lesser validation attention when decisions are examined during audits or regulatory inspections.

Apply Risk-Based Validation to Modern GxP Technologies

Strengthen validation approaches for cloud, SaaS, configurable, and AI-enabled systems while accounting for supplier documentation, Agile development, DevOps, continuous deployment, and change control. Participants will connect these practices with maintaining the validated state and assembling evidence that clearly supports validation decisions under FDA, EMA, MHRA, and customer scrutiny.

Key Areas Covered

  • Transition from traditional CSV to risk-based CSA
  • System criticality, intended use, complexity, and validation scope
  • GAMP® 5 principles and quality risk management
  • Scripted, unscripted, and exploratory risk-based testing
  • Supplier assessments and use of vendor documentation
  • Validation of cloud, SaaS, configurable, and AI-enabled systems
  • Data integrity and 21 CFR Part 11 considerations
  • Change control, validated state maintenance, and inspection-ready evidence

Who Must Attend

  • Quality Assurance Departments
  • Validation and CSV Practitioners
  • IT and Digital Transformation Leaders
  • System Owners
  • Data Integrity Specialists
  • Compliance Departments
  • AI Governance Teams
  • Regulatory Affairs Departments
  • Everyone responsible for maintaining compliant and validated cloud-based and AI-enabled systems.
Meredith Crabtree
COURSE DIRECTOR

Carolyn Troiano

Carolyn Troiano has more than 45 years of experience in computer system validation across pharmaceutical, medical device, biotechnology, and other FDA-regulated industries. Her consulting and training work spans FDA compliance, CSV, 21 CFR Part 11, Data Integrity, and large-scale IT implementations, directly supporting the risk-based validation and modern GxP system considerations addressed in this course.

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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.

How can a validation team defend performing less testing for a GxP system without creating the appearance that compliance effort was simply reduced?

Reduced testing is defensible when the excluded or simplified testing can be traced to a deliberate assessment of intended use, failure impact, existing controls, supplier evidence, and the importance of the function to product quality, patient safety, or data integrity. The rationale carries more weight than the number of test scripts executed.


Inspection problems arise when a risk-based strategy exists only as a label. Statements such as "low risk, therefore limited testing" provide little insight into how that conclusion was reached. An investigator may select a function that received minimal testing and ask what could happen if it failed, which controls would detect the failure, and what evidence supported the chosen level of assurance.


Good decisions remain understandable after the project team has dispersed. The record should show why intensive testing was necessary for some functions and unnecessary for others.


Risk-based validation becomes credible when differences in effort correspond visibly to differences in risk rather than to schedule, budget, or convenience.

What should happen when a SaaS vendor releases changes faster than the regulated company can perform traditional validation cycles?

The validation model has to accommodate the vendor's actual release process while preserving control over changes that can affect GxP use. Attempting to force every SaaS update through a full traditional validation cycle often produces backlogs, retrospective assessments, and approvals that occur after the changed functionality is already available.


The practical control point is the regulated use of the system. Vendor release information should be screened against intended use, configured functions, interfaces, critical data, and existing controls. Changes with no plausible GxP impact can be documented and dispositioned quickly. Changes affecting critical functionality require deeper assessment and appropriate assurance activities before reliance on the changed function.


Inspection friction develops when companies cannot explain which vendor changes occurred, how they were evaluated, or why no additional testing was performed.


A workable SaaS validation process therefore depends on disciplined change triage. Speed itself is manageable. Unexamined change is much harder to defend.

When can supplier testing legitimately replace testing performed by the regulated company?

Supplier evidence can carry substantial weight when the company understands exactly what was tested, under which configuration and conditions, and whether that evidence addresses the risks associated with its own intended use. Simply possessing a vendor test package does not establish that the relevant functions have been adequately assured.


This becomes particularly important with configurable platforms. A supplier may have thoroughly tested the standard product while the regulated implementation depends on workflows, permissions, calculations, interfaces, master data, or configurations that the supplier never tested in the customer's environment.


The decision should identify which assurance questions have already been answered credibly by supplier evidence and which remain specific to the regulated implementation. Supplier capability and development controls also affect how much confidence that evidence deserves.


Duplicating reliable supplier testing adds little value. Accepting it without understanding its boundaries creates exposure. A defensible package makes those boundaries visible and directs internal testing toward the remaining uncertainty.

What is the strongest indication that a risk-based CSV or CSA program has become too aggressive in reducing validation effort?

Recurring production issues that expose assumptions never adequately challenged during validation are a strong warning sign. When incidents repeatedly reveal untested workflows, misunderstood configurations, weak interfaces, inadequate permissions, or failure modes dismissed as low risk, the original assurance strategy deserves reassessment.


The important evidence comes from operational experience. Deviations, help-desk records, data corrections, access issues, audit trail findings, failed integrations, manual workarounds, and recurring user errors can show whether the original risk model accurately predicted where failures mattered.


A program can look efficient on paper while accumulating operational rework that exceeds the effort saved during validation. That pattern also weakens future risk-based decisions because previous classifications begin to look optimistic rather than evidence-based.


Risk assessments should therefore learn from actual system performance. When post-implementation experience repeatedly contradicts the assumptions used to reduce testing, increasing assurance activity is appropriate. Continuing to cite the original risk classification after contrary evidence has accumulated becomes progressively harder to defend.

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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.”
- Production Officer
“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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