{"id":5343,"date":"2024-12-10T20:44:26","date_gmt":"2024-12-10T20:44:26","guid":{"rendered":"https:\/\/complyguru.com\/en-ie\/?p=5343"},"modified":"2025-01-24T12:41:33","modified_gmt":"2025-01-24T12:41:33","slug":"practicalities-of-performing-spreadsheet-validation-under-iso-13485","status":"publish","type":"post","link":"https:\/\/complyguru.com\/en-ie\/practicalities-of-performing-spreadsheet-validation-under-iso-13485\/","title":{"rendered":"Practicalities of performing Spreadsheet Validation"},"content":{"rendered":"
When we last left off at Spreadsheet Validation (part 1<\/a>), we had covered the various standard and regulatory requirements that apply to spreadsheet validation and the types of spreadsheets that require validation.<\/p>\n Now, as promised, part 2.<\/p>\n Starting with determining criticality classification, we will also examine the relationship that exists between criticality classification and likelihood or occurrence of failure (Complexity Classification) and how this contributes to the risk assessment of the spreadsheet under validation to determine the level of validation required.<\/p>\n Finally, the approach to spreadsheet validation will round out the topic and hopefully illuminate the process for you, the reader!<\/p>\n Criticality Classification starts with understanding the risk management process associated with the spreadsheet validation.\u00a0 We do, after all, work in an industry where \u201cproportionate to risk\u201d is ingrained in our very fiber.<\/p>\n So much so, that ISO 13485<\/a> specifically mentions ISO 14971 in Section 3 \u2013 Terms and Definitions and again at Clause 7.1 where an organization is required to have one or more processes for risk management established, implemented and maintained as part of their Quality Management System (QMS).<\/p>\n The risk process should look loosely familiar to you all: Identification, Evaluation, Classification.<\/p>\n Once these three steps have been completed, its time to Mitigate.<\/p>\n Identification involves determining and documenting the hazards associated with the use of the spreadsheet, Evaluation is determining the severity of the identified hazard, Classification means categorizing the risk according to severity and finally Mitigation represents performing activities that reduce the severity or the likelihood of the risk.<\/p>\n Criticality Classification is broken into three level \u2013 Low, Medium and High.\u00a0 Sounds easy, right.<\/p>\n But sounding easy is not exactly useful unless you understand what is involved in each of the levels.<\/p>\n High Criticality represents direct impact to patient safety, product quality, or the integrity of the associated data.<\/p>\n Medium Criticality corresponds to an indirect impact to patient safety, product quality, or the integrity of the associated data, and to absolutely nobody\u2019s surprise.<\/p>\n Low Criticality signifies no impact to patient safety, product quality, or the integrity of the associated data.\u00a0 Let\u2019s break down this understanding further.<\/p>\n High Criticality includes:<\/p>\n <\/p>\n Medium Criticality includes:<\/p>\n <\/p>\n Low Criticality includes:<\/p>\n <\/p>\n Similar to Criticality Classification, Occurrence is also categorized into three categories: High Occurrence, Medium Occurrence and Low Occurrence, which represent various inputs to the spreadsheet that signify various levels of complexity classification.<\/p>\n For example, high occurrences are spreadsheets that include:<\/p>\n An example of Medium occurrences are advanced statistical functions, and Low occurrences are standard functions and basic statistical calculations such as addition, average and standard deviation.<\/p>\n But how does all of this translate into a Spreadsheet Risk Assessment?<\/p>\n Let\u2019s take for example a spreadsheet that tracks a training attendance record. In this case the criticality is Medium, and the Occurrence is low as there is indirect impact on quality and\/or safety and the spreadsheet will contain basic functionality.<\/p>\n What is an example of a high-risk spreadsheet?<\/p>\n Well, consider a spreadsheet that uses statistical analysis of clinical study data that includes complex macros.<\/p>\n This would warrant a combination of High Criticality and High occurrence as there is direct impact on patient safety and the spreadsheet contains a custom macro.<\/p>\n Can you have a High\/Low combination?<\/p>\n Indeed, you can.\u00a0 An organization may use a spreadsheet to perform simple arithmetic calculation for a linearity panel.\u00a0 In this case the criticality is High, but the occurrence is low.<\/p>\n The rationale?<\/p>\n There is direct impact to product quality, however, the spreadsheet has only basic spreadsheet functionality.<\/p>\n It\u2019s important to note that all scenarios will require a risk assessment.<\/p>\nSpreadsheet Validation under ISO 13485<\/h2>\n
Criticality Classification<\/h3>\n
What type of information falls into each of these categories?<\/h3>\n
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Likelihood or Occurrence of Failure (Complexity Classification)<\/strong><\/h3>\n
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Examples of Spreadsheet Risk Assessment<\/strong><\/h3>\n