My last discussion of Off-The-Shelf software validation only considered the high-level regulatory requirements. What I want to do now is dig deeper into the strategies for answering question #5:
How do you know it works?
This is the tough one. The other questions are important, but relative to #5, answering them is pretty easy. How to answer this question (i.e. accomplish this validation) is the source of a lot of confusion.
There are many business and technical considerations that go into the decision to use OTS or SOUP software as part of a medical device. Articles and books are available that include guidance and general OTS validation approaches. e.g. Off-the-Shelf Software: A Broader Picture (warning PDF) is very informative in this regard:
- Define business’ use of the system, ideally including use cases and explicit clarification of in-scope and out-of-scope functionality
- Determine validation deliverables set based on system type, system risk, project scope, and degree of system modification
- Review existing vendor system and validation documentation
- Devise strategy for validation that leverages vendor documentation/systems as applicable
- Create applicable system requirements specification and design documentation
- Generate requirements-traceable validation protocol and execute validation
- Put in place system use, administration, and maintenance procedures to ensure the system is used as intended and remains in a validated state
This is great stuff, but unfortunately it does not help you answer question #5 for a particular type of software. That’s what I want to try to do here.
OTS really implies Commercial off-the-shelf (COTS) software. The “commercial” component is important because it presumes that the software in question is a purchased product (typically in a “shrink-wrapped” package) that is designed, developed, and supported by a real company. You can presumably find out what design controls and quality systems are in place for the production of their software and incorporate these findings into your own OTS validation. If not, then the product is essentially SOUP (keep reading).
Contrast OTS with Software of Unknown Provenance (SOUP). It is very unlikely that you can determine how this software was developed, so it’s up to you to validate that it does what it’s supposed to do. In some instances this may be legacy custom software, but these days it probably means the integration of an open source program or library into your product.
This following list is by no means complete. It is only meant to provide some typical software categories and the strategies used for validating them. Some notes:
- I’ve included a Hazard Analysis section in each category because the amount of validation necessary is dependent on the level of concern.
- The example requirements are not comprehensive. I just wanted to give you a flavor for what is expected.
- Always remember, requirements must be testable. The test protocol has to include a pass/fail criteria for each requirement. This is QA 101, but is often forgotten.
- I have not included any example test protocol steps or reports. If you’re going to continue reading, you probably don’t need help in that area.
- Windows XP SP3
- Windows 7 32-bit and 64-bit
- Red Hat Linux
- Hazard Analysis: Do a full assessment of the risks associated with each OS.
- Pay particular attention to the hazards associated with device and device driver interactions.
- List all hazard mitigations.
- Provide a residual Level of Concern (LOC) assessment after mitigation — hopefully this will be negligible.
- If the residual LOC is major, then Special Documentation can still be provided to justify its use.
- Visual Studio .NET 2010 (C# or C++)
- Hazard Analysis:
- For a vast majority of cases, I think it is safe to say that a compiler does not directly affect the functioning of the software or the integrity of the data. What a program does (or doesn’t do) depends on the source code, not on the compiled version of that code.
- The compiler is also not responsible for faults that may occur in devices it controls. The application just needs to be written so that it handles these conditions properly.
- For some embedded applications that use specialized hardware and an associated compiler, the above will not necessarily be true. All functionality of the compiler must be validated in these cases.
- Hazard Analysis: Both of these open source libraries are integrated into the product software. The impact on product functioning, in particular data integrity, must be fully assessed.
- You first list the requirements that you will be using. For example, typical logging functionality that might include:
- The logging system shall be able to post an entry labeled as INFO in a text file .
- The logging system shall be able to post an entry labeled as INFO in a LEVEL column of a SQL Server database.
- … same for ERROR, DEBUG, WARN, etc.
- The logging system shall include time/date and other process information formatted as “YYYY-MM-DD HH:MM:SS…” for each log entry.
- The logging system shall be able to log exceptions at all log levels, and include full stack traces.
Version Control Systems
- Hazard Analysis: These are configuration management tools and are not part of the product. As such, the level of concern is generally low.
- As above, you first list the specific functionality that you expect the VCS to perform. Here are some examples of the types of requirements that need to be tested:
- The product shall be able to add a directory to a repository.
- The product shall be able to add a file to a repository.
- The product shall be able to update a file in a repository.
- The product shall be able to retrieve the latest revision of files and directories.
- The product shall be able to branch a revision of files and directories.
- The product shall be able to merge branched files and directories.
Issue Tracking Tools
- Hazard Analysis: These tools are used for the management of the development project. Again, the level of concern is generally low.
- You only need to validate the functionality you intend to use. The features that you don’t use do not need to be tested.
- You simply need to test the specific functionality. Some example requirements — the roles, naming conventions, and workflow will of course depend on your organization and the tool being used:
- A User shall be able to create a new issue.
- A User shall be able to comment on an issue.
- A Project Manager shall be able to assign an issue to a Developer.
- A Developer shall be able change the state of an issue to ‘ready for test’.
- A Tester shall be able to change the state of an issue to ‘verified’.
- The tool shall be able to send e-mail notifications when an issue has been modified.
- An Administrator shall be able to define a milestone.
Validation is a lot of work but is necessary to ensure that all of the tools and components used in the development of medical device software meet their intended functionality.