General Principles of Software Validation

General Principles of Software Validation

One of the most important references in creating a software development lifecycle process to assure software quality is the FDA guidance document, “General Principles of Software Validation.”  This guidance document has been around for many years.  The current version, 2.0, was released in 2002.  To many in the industry, this guidance is simply referred to as the “GPSV.”

The guidance has a self-stated purpose to provide “validation principles that the FDA considers to be applicable to:

  1. the validation of medical device software or
  2. the validation of software used to design, develop, or manufacture medical devices.”

Of course the agency has quite a challenge in providing these principles.  One challenge is that medical device software can range widely in complexity and safety risk.  Consider what validation principles might be applicable to software controlling hemodialysis sub-systems compared to software displaying a patient’s weight in a scale.  A second challenge is how software technology and methods can change rapidly – so principles must stand the test of time.  Our opinion is that the GPSV meets these challenges well.  It remains a solid text for orienting, on-boarding, and referencing for software validation.

You can download a copy here: 2002-01-General Principles of Software Validation-Final Guidance

Of course, IEC 62304 is the more current, state-of-the-art thinking in the area of medical device software process.  One should use IEC 62304 as the basis for software process but we would recommend exploring how the GPSV can give greater insight into greater software quality.  Just a quick example is “test types.”  This is not found in IEC 62304 but is an essential technique in test case design for developing high quality software.

If you are interested in learning more, consider our 62304-FDA Compliance Training and other courses.

About the author

Partner and General Manager, Brian Pate is ISO 1385:2016 Lead Auditor certified for Medical Device Quality Management Systems (MD), and ISO 19011:2018 Management Systems Auditing (AU) and Leading Management Systems Audit Teams (TL). Brian started his medical device career in anesthesia clinical research in 1985 and has since worked both academia and industry including many years with Johnson & Johnson, Baxter Healthcare, and GE Medical. Brian’s roles have included software engineering, systems engineering, quality assurance, and regulatory affairs. Brian has served on multiple AAMI TIR working groups, including TIR32-2008 (Application of ISO 14971 Risk Management to Software; now IEC 80002-1) and TIR45-2012 (Guidance on the use of Agile practices in the development of medical device software) and served as a reviewer for the 2nd edition of TIR45. Brian serves on the AAMI Software Committee and as an AAMI instructor for the software, design controls, and agile methods courses. Brian also is a member of the Underwriters’ Laboratories (UL) Standards Technical Panel for UL1998 (Software in Programmable Components) and or UL5500 (Remote Software Updates).

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Being Agile & Yet CompliantISO 14971 SaMD Risk Management

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