Managing Change Requests for a Validated Environment: What You Need to Know
As the primary change manager for a client’s learning management system (LMS) for over a year, I have gathered key information and considerations for anyone working in a similar role within a validated environment. This is the first of two blog posts on the topic of validation – We’ll start with the fundamental basics in this post before expanding into best practices.
What is different about a validated environment?
For most companies looking to make a change in their learning management systems, the process of doing so can be as simple as testing to ensure it works and then putting the change into their live Production environment. However, the process is much more in-depth in industries such as Healthcare and Life Sciences, where training compliance and data integrity are of tantamount importance. Companies within these industries use validated environments to manage that data because there is an indirect or direct impact to product or patients, and they serve as the system of record for compliance. There are certain standards that these companies must meet in accordance with regulatory requirements, such as FDA 21 CFR Part 11 and EU Annex 11, which govern computerized systems and electronic records/signatures for regulated activities. (For more information on the history of FDA regulation, click here.)
Anything considered to have “Good Practice” (GxP) compliance impact, i.e., training for lab technicians, will need to follow these guidelines. If these requirements are not met, there could be severe consequences imposed by the government and industry regulatory bodies, including monetary fines or halting the manufacturing of products. As a result, each GxP change must go through a more rigorous vetting process, including documentation, impact analysis, testing in several environments, evidence of change success, and approvals at several stages. Anything that is not considered to have GxP impact, such as changing the text in an email notification, would not need to go through this strict process.
What is the risk?
The three main questions to ask yourself when evaluating a change request are:
1.) What is the probability of harm occurring due to the problem/issue and the proposed change?
2.) What is the severity of impact of the problem/issue and the proposed change?
3.) What is the detectability of the problem/issue and the proposed change?
The answers to these questions will determine the risk of the fix or update. A change considered high risk would likely require more detailed testing and verification compared to something classified as low risk. The difference could mean a lengthy test script compared to just a screenshot attachment.
How do you prioritize change requests?
An LMS is constantly evolving and being improved upon, so coordinating requests according to priority helps keep the client organized and moving forward. Change requests can be voluntarily initiated by anyone using the LMS from learners to administrators, or may be necessary due to software updates. The reasoning behind the change request will be the most important factor in determining its priority and where it falls in the list of enhancements. For example, fixing a system issue or validating an upcoming software release will take the highest priority, whereas aesthetic changes to the home page or notifications will be low priority.
Who takes part in the change control process?
There are many stakeholders involved in the change control process, including the change manager, the LMS business and system owners, and the quality assurance team. The change manager is responsible for leading the change through the process from beginning to end, but it is a collaborative effort involving feedback from and coordination between all roles until the change is implemented in Production. The chart below outlines the main responsibilities of each role along the process workflow:
Now that we have covered the basics of change management in validated environments, check out my second post on best practices to follow.