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Inspection Decision Scenarios Regulatory Impact Decisions

FDA Inspection Decision Scenario

Who Authorized This Computerized System Validation?

21 CFR Part 11EU Annex 11GAMP 5

What FDA investigators are actually asking

FDA Investigator Question

"Who made the determination that this system was validated for its intended use, and what was the regulatory basis?"

Inspector's Line of Inquiry

When investigators ask this question, they typically follow with:

  • Who reviewed the test execution results before the system was authorized for GxP use?
  • What GAMP 5 risk category was applied and who made that determination?
  • What critical requirements were verified before the validation was accepted?
  • What test failures or deviations were evaluated before the conclusion was made?
  • When was the system validation formally authorized, and who is the named decision owner?

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The authorization gap this scenario reveals

The investigator is reviewing a CSV package for a GxP system. Protocols and test scripts are present. The investigator asks who made the formal validation authorization decision.

Authorization Gap

The CSV package documents test execution and results. It does not document who evaluated the totality of validation evidence and made the formal authorization that the system was fit for its intended GxP use. This is the authorization gap: the decision was made, but it was never documented as an authorization event — with a named decision owner, the evidence reviewed, the regulatory standard applied, and a timestamped record of when the authorization occurred.

What evidence the investigator expects

Organizations operating with authorization infrastructure produce this record at the moment the decision is made.

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These gaps are not documentation failures. They are authorization failures. The Authorization Assessment maps exactly where your decision trail is missing these elements.

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Authorization Assessment

Which of your decisions
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The Authorization Assessment identifies where your compliance decisions are undocumented as authorization events — the exact gap inspectors expose in scenarios like this one.

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Inspection Case Files document the authorization gap in detail — showing exactly what a Decision Defense Record resolves and what inspectors expect to see.

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