General Checklist for Initial Risk
Assessment of GxP Software
Applications
1. System Identification
System Name and Version
Type of System (e.g., COTS, Customized, Bespoke)
Developed by (Internal/External Vendor)
Deployment Architecture (Client-Server, Web-based, Cloud, etc.)
Technology Stack (Database, OS, Development Language)
Environments Available (Development, Test, Validation, Production)
2. Intended Use & Functional Overview
Purpose of the System
Key Functional Modules and Operations
Regulated Process Support (GxP-relevant activity)
System's Role in Product Lifecycle (Direct or Indirect Impact)
3. Business Process Linkage
Identify Relevant Business Processes
Evaluate Integration Points with Other Systems
Assess System’s Influence on Batch Release, Product Quality, or Compliance
4. GxP Impact Assessment
Does the system support GxP processes?
Does it store or process GMP-critical data?
Are records required for batch release or audits?
Does the system use electronic signatures or require audit trails?
Is the system involved in decision-making impacting product safety or efficacy?
5. Regulatory Applicability
21 CFR Part 11 (Electronic Records and Signatures)
EU Annex 11 (Computerized Systems)
MHRA GxP Data Integrity Guidance
WHO TRS Guidelines
PIC/S PI-011 Guidelines
ICH Q9 (Quality Risk Management)
GAMP 5 (Validation of Automated Systems)
6. System Classification (GAMP 5)
Development Type (COTS, Configured, Bespoke)
Software Category (GAMP Category 3, 4, 5)
System Function (Infrastructure, Data Processing, Control System)
7. System Complexity Assessment
Architecture Complexity (Single-tier, Multi-tier)
Functional Logic and Workflow Rules
User Roles and Access Rights
Integration with Other Systems
Data Flow and Business Logic Implementation
8. System Criticality Assessment
Impact on Patient Safety
Impact on Product Quality
Impact on Regulatory Compliance
Criticality of Data Managed by the System
System Downtime Consequences
9. Data Integrity (ALCOA+) Considerations
Attributable – User Access Control & Logging
Legible – Human-readable Data Presentation
Contemporaneous – Real-time Logging
Original – Source Data Availability
Accurate – Input Validation and Output Verification
Complete – Audit Trails and Data Sets
Consistent – SOP Compliance and Uniform Use
Enduring – Backup and Archival Measures
Available – Controlled Access and Retrieval
10. Validation Planning
User Requirements Specification (URS)
Functional and Design Specifications (FS/DS)
Installation Qualification (IQ)
Operational Qualification (OQ)
Performance Qualification (PQ)
User Acceptance Testing (UAT)
Traceability Matrix (TM)
Validation Summary Report (VSR)
SOP Development & Training
Backup and Restore Procedures
Periodic Review Planning
11. Risk Determination Summary
GxP Impact: Yes/No
Regulatory Scope: Local/Global
System Criticality: Low/Medium/High
System Complexity: Low/Medium/High
Validation Scope: Full Lifecycle/Partial
12. Approval and Next Steps
Initiate or Plan Validation Activities Based on Risk Assessment
Document Controls and Safeguards to Mitigate Risks
Ensure Periodic Review and Change Control Alignment