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Due to the growth of the cybersecurity threat to electronic records, computer-controlled manufacturing, and medical devices, the US FDA has issued Guidances for Industry, e.g.: 1) "Cybersecurity for Networked Medical Devices Containing Off-the-Shelf (OTS) Software Document", and 2) "Content of Premarket Submissions for Management of Cybersecurity in Medical Devices", and 3) "Postmarket Management of Cybersecurity in Medical Devices" Draft.
This seminar will focus on the key issues raised by the FDA, not just for devices, but expectations for the industry. Cybersecurity in the medical products industry is coming under increased regulatory review. The Agency leaves the how of cybersecurity compliance up to the manufacturer, as long as the principles in the guidances are met in the resulting product and/or system; and on electronic-specific tools/techniques to achieve CGMP compliance.
Updates, upgrades, new revisions/releases, service packs, and similar are automatically uploaded to a company’s systems, which can pose security risks, with the potential for the introduction of compromised code, retrieval of confidential data, data integrity issues, and similar; and render previous computer systems’ verification and validations worthless. The necessary role of the system administrator adds another area of concern. This seminar will consider how cybersecurity is introduced into the CGMPs, design control (21 CFR 820.30) for devices, and post-production by the CAPA system, among others.
Why should you Attend:
Cybersecurity is a recent concern for medical products, due to the increased reliance on electronic software, records and signatures, stand-alone or networked.
Initially, there were regulations such as 21 CFR Part 11 in the U.S. and Annex 11 in Europe. But more must be done to ensure the integrity of CGMP documents/records/data. As a result, the US FDA issued several Guidance Documents on cybersecurity. Regulatory agencies leave the specifics up to the manufacturer, as long as the principles in the guidances are addressed. Related data integrity issues are addressed by the CGMPs, specifically design control (21 CFR 820.30) for devices, and post-production issues by the CAPA (Corrective and Preventive Action) system, among others. The U.S. FDA has increasingly observed CGMP violations involving data integrity and cybersecurity during CGMP compliance inspections and in security breaches related to medical device use. Adding to the problem is BYOD - "Bring Your Own Device"(laptop, tablet, smartphone, or other "smart" device) to the workplace. These growing trends pose problems to the integrity and security of data. The increasing use of cloud (Internet)-based software to accomplish CGMP tasks, store / retrieve data (data warehousing) and similar uses poses additional problems.
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