FDA Inspection Decision Scenario

Who Authorized This Computerized System Validation?

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

21 CFR Part 11 · EU Annex 11 · GAMP 5

Why this becomes difficult to defend

The decision exists. The basis for it may not be retrievable as one record.

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.

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.

What must be retrievable

The reviewer needs more than the final outcome.

  • Named individual accountable for the system validation authorization
  • Regulatory framework applied to the validation determination
  • Evidence reviewed before the validation was authorized
  • Authorization timestamp for the validation acceptance
  • Reasoning linking test evidence to the fit-for-intended-use determination

Relevant proof

See how the record connects evidence, judgment, risk, and authorization.

A completed ComplianceWorxs record shows the reasoning layer that is usually hardest to reconstruct after the decision has been made.

EvidenceWhat was known JudgmentHow it was evaluated RiskWhat was weighed AuthorizationWho decided and why

When this is your active decision

Preserve the reasoning before the context disappears.

Use the completed proof first. When the decision is consequential enough to preserve, create an Inspection Response Record for the actual decision.