FDA Computer Software Assurance (CSA) shifts the validation paradigm for non-product automated manufacturing and QMS software from generating reams of low-value paper evidence to high-impact risk analysis, unscripted exploratory testing, and continuous automated CI/CD assurance.
1. CSA vs Traditional CSV Paradigm
Under traditional Computer System Validation (CSV), 80% of effort was spent writing documentation and only 20% on actual testing. CSA flips this ratio:
- Focus testing strictly on features that directly impact product quality and patient safety.
- Leverage vendor audits and supplier documentation for standard commercial off-the-shelf (COTS) features.
- Utilize automated testing, exploratory testing, and unscripted testing with captured error screenshots rather than manual step-by-step paper test scripts.
