Validating Excel Sheets for Pharma QA
Validating Excel Sheets for Pharma QA
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Methods: All the sheets are designed in Excel- 2013 following the regulatory requirements. The data is collected
from the analytical laboratories following the standard procedures to perform the test.
Results: The sheets should validate and every action should be documented and all the sheets are assured to present
the quality data with complete maintenance of the security, accuracy and integrity of the data. By following these
principles, it is possible to fully validate and implement a standard spreadsheet in very less time.
Conclusions: The sheets provide the accuracy maintenance of data and calculations in order to protect the data from
any unauthorised access. The good documentation and manufacturing practices alongwith the regulatory authorities
made it important for getting regulatory compliance. Validation of process, equipment plays important role in
assuring the quality of product while the excel sheets ensure the data integrity and protection from any modification.
Therefore it necessary to validate the excel sheets as per the reference documents and to assure quality of the data.
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Decision Making
and Enforcement
Document Inspection of
Review local product
samples
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• Use data to make quality and GxP decisions. 2. The spreadsheet must be adaptable to produce results
• Control your data and define who has access to the even if values alter.
data. 3. The data that is utilised to calculate results should be
• Ensure your spreadsheet performs to specifications. readily visible in the spreadsheet.
• Query your data to better understand your business 4. It should be simple to validate and revalidate the
process. spreadsheet.
• Have documented evidence that your processes work 5. To prevent modifications or manipulation, the
as expected. spreadsheet cells holding important data should be secured. [27]
• Have increased confidence in your system. [24]
APPROACH TO SPECIFIC PART 11 REQUIREMENTS
DEVELOPMENT OF SPREADSHEETS Title 21 of the Code of Federal Regulations Part 11 (21 CFR
Designing of the spreadsheet should be: Part 11) is a set of regulations established by the U.S. Food and
• In an orderly manner Drug Administration (FDA) that specifically governs
electronic records and electronic signatures in the context of
• Data should be populated automatically, by a
pharmaceutical, biotechnology, and medical device industries.
system, or manually by an operator
These regulations outline the requirements for the use of
• It should provide a good summary concerning its electronic systems in capturing, storing, and managing data that
objective or purpose is subject to FDA regulations. Compliance with 21 CFR Part
• It should provide well-defined operations (e.g., limit 11 is crucial for companies operating in FDA-regulated
checks, transfer of data to other spreadsheets, online generation industries to ensure the integrity, confidentiality, and
of, use of macros), and calculations. authenticity of electronic data and to maintain regulatory
• Results of each individual product should be easily compliance. It covers aspects such as the security of electronic
traceable.[25] records, validation of computer systems, audit trails, electronic
signatures, and documentation practices as shown in (Fig.1.5)
KEY POINTS OF SPREADSHEETS .[28]
1. The spreadsheets can be used easily for other
products Electronic Validation
Records
2. The spreadsheet shall be flexible to give results if
21 CFR Part 11 Audit Trail
values are changed
Electronic
3. The spreadsheet should have clear visibility of data Signatures Record Copies
used for result calculations
4. The spreadsheet validation and revalidation should Record
Retention
be performed easily
5. The spreadsheet cells containing critical information Fig. 5 Criteria for 21 CFR Part 11
should be protected to avoid any changes or manipulation. [26]
OVERVIEW OF EXCEL SPREADSHEET
CREATION OF SPREADSHEETS Spreadsheet software of today can contain numerous
The spreadsheet's design should be: interconnected sheets, execute basic mathematical and
• Organized and structured arithmetic operations, and display data either graphically or as
• Data entry should be done either automatically or text and numbers. For typical economical and scientific
manually by the user activities, it offers integrated functions. In contrast, a
• Able to summarize a clear description of its goals and spreadsheet manipulates numerical data, text and the formula
objectives or the information. Spreadsheet can be useful in creating
• Able to include clearly defined procedures (such as budgets, data analysis, financial planning, and to perform the
limit checks, data transmission to other spreadsheets, online critical numerical operations. These sheets have tendency of
creation, and usage of macros), computations automatic recalculation, self feeded formulas by the user, or by
• Able to provide results that are simple to track for default included math functions, along with this changes in
each unique product. [27] already given command or formulas could also be seen
enhances the monitoring and error findings. [29]
OBJECTIVE OF SPREADSHEETS How to start Excel
1. The spreadsheets are simple to utilize for different • Go to START OPTION on the windows taskbar
goods • It can be find in the search bar as well
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• Conventions –
Consist of assuming data in
the sheets.
• Manuscript
[Link], expectations – Transparent
2. Absence of 3. Insufficient
Supnroea documentation of
rgdasnhieseetd Standard Documentation assumptions made in
Mdaatiantenance Operating
Immparoinpteern,ance Procedure Improper formulas.
unorganised Clear documentation • Data- This file
data instructions and contains raw data, such as
maintenance on the usage, compliance data records from which the
consistency model will execute
computations.
Fig. 8 Some specific problems of spreadsheet validation • Calculations –
Division of sheets into series
SPREADSHEET DESIGNING computation stages, and the
The framework of an Excel spreadsheet is almost identical to make one sheets with
that of an electronic programme. Spreadsheet formulas are different series and stages.
essentially a type of computer code. Alternative to generate the etc.
template file and then verifying for mistakes, check for
• Results – The end
problems throughout the different phases of the creation part should contain the final
process. A spreadsheet model is a collection of spreadsheets conclusion alongwith the
and custom sheets that are used to analyse and organize data or predictions done [22].
to solve a specific issue. This designing in appropriate format
• Ensures flexibility
is shown in (Table 1.1) [18]. The sheets shall be designed in
of model by reducing
such a way that they are easy to understand and to ease the
recalculations.
complexities of handling data generated from different
• Formula shall be
analytical procedures, validated excel spreadsheets containing Clear Visibility
3. written into different cells
relevant formulas are developed to ensure the process of data of formulas
instead of writing it in
handling will consistently produce the expected results. [36]
single cell, give cell
Table 1 Steps of Spreadsheet Designing
comments wherever
[Link] STEPS DESCRIPTION needed.
• Checks and
• Vertical
control measure shall be
calculation scheme should
included such as “IF and
be promoted. Control
4. ERROR conditions to avoid
• All the formulas Measures
mistakes such as #N/A,
Flexible should be written above its
1. #VALUE!, #REF!, #NUM!,
Designing respective cells [19].
#NAME?
• Proper color
formatting, border style and
STEPS IN PERFORMING VALIDATION
color should be done
The steps followed while performing the validation are as
appropriately [20].
follows:
• Documentation – Validation Planning
Must contain the title, scope,
author name, list, macros
and outlines.
Typical
2. • Menu – A one
Outline A comprehensive document consisting of actions done,
click consist of user
instructions such as drop approaches, schedule and validation activities.
down list, data entry location Validation procedure
etc.
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Development of Requirements
PQ will systematically, strictly and constantly test the software
by testing all involved and resultant values, records, procedure, Proper Flexibility Testing
and control flow logic [24].
Proper use of excel auditing
Validation report
Performance Testing
User Instructions
Validation Lifecycle
DATA
Data are quantitative or qualitative facts, figures and statistics
collected for reference or analysis.
Data may be captured or recorded:
It consists of preservation, controlling and maintenance of the • By manual recording, on paper or in an electronic
validated sheets. These controls include computerized systems system, of an observation or of an activity;
and it compliance with the regulations. Some controls to • By automatic recording, on paper or in an electronic
support the system includes system, using equipment that range from simple instruments
through to complex highly configurable computerised systems
• Preventive Maintenance
• Using a hybrid system where combinations of paper
• Environment Control and electronic records constitute the raw data
• Monitoring of performance • On other means of media such as photography,
• Retention imaging methods and technologies, etc. could be generated
• Recovery
manually, automatically or by hybrid system.
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Fig. 10 Types of Data Integrity • MHRA: The MHRA's guideline on GMP data
integrity requirements for the pharma sector is meant to
LOGICAL INTEGRITY (LI)
supplement the EU's current GMP standards for dosage forms
It is a crucial component of DI since it involves a physical
and active ingredients. The pharmaceutical quality system,
integrity procedure and safeguards data from human mistake,
which guarantees that medications are of the requisite quality,
piracy, and data hackers. In the pharmaceutical sector, logical
is fundamentally dependent on data integrity.
integrity is crucial for the preservation and processing of data
collected from the appropriate department. • TGA: The Therapeutic Goods Administration
(TGA), an Australian regulatory organization, specifies the
REFERENTIAL INTEGRITY (RI) need for data integrity as a deficit. A flaw in a procedure that
Integrity can take many different forms, including procedures might lead to a considerable risk of creating a user-harmful
and the application of laws related to data storage and retrieval. product.
Foreign keys are a crucial component of referential integrity. • WHO: Vital drugs and medical supplies, WHO
releases data integrity recommendations to safeguard patients
USER-DEFINED INTEGRITY (UDI) worldwide. In order to lessen instances of manufacturers A
Data acquired via post-marketing monitoring and information providing inadequate data or purposeful data fabrication, has
gathered from pharmacovigilance supervisors is specific to a
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Data 3. Methods
Backup
Processing
Validation Approach
Data Data A broad approach to spreadsheet validation has similarity to
Retention Migration that of the computerised system validation. The process of the
Computrised validation consists of same steps (user requirements, risk
System
Transcition assessments, provisions, design, challenging, reporting), the
project accountabilities, appropriate validation documents, and
Fig. 11 Data Lifecycle rules for the archival and change management processes.
Development Process
The V model is the most commonly adopted approach to
develop protocol for validation. The protocol is developed for
ALCOA various calculations and operations involved in pharmaceutical
"ALCOA" is an acronym used in the pharmaceutical and
industries. Some of the major tests includes IPQC test, Assays,
clinical research industries, as I mentioned earlier. It is used to
Molarity, Normality etc. The sheets and the process must be
ensure data integrity and accuracy in the recording of data
easy, reliable and adaptable in order to make it easy for the
during clinical trials and research studies. Each letter in the
acronym represents a fundamental principle that should be developer and user to make useful to maintain data integrity
followed when collecting and documenting data: The FDA uses and security throughout the operation.
ALCOA to define its expectations of electronic data as shown User Requirements
in [Fig.1.12]. The first step in the development of spreadsheet as per the User
Requirements Specifications Guidelines (URS) is to capture the
user’s spreadsheet demands.
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User Requirement Specification for Molarity and • Data entry is secured by error messages, dropdown
Normality determination spreadsheet: list and for time, date entries.
• Date and time should be electronically feeded with
URS‐1. The spreadsheet should be applicable for all
signatures of authorized personnel’s respectively.
parameters.
• Error messages should be there for invalid entries
URS‐2. The spreadsheet should be easy and quick to determine into the cell.
the given conditions. • The template is password‐protected (at sheet,
workbook and VBA code level).
URS-3. The format of spreadsheet should have Test name,
Sheet code, Standard taken with proper headings. • Defined location to save worksheet template and to
perform straightforward validation.
URS‐4. The spreadsheet should standard reference, calculation • All the information required for verification should
formulas and also the instructions wherever needed. be provided in the hardcopy and screenshots.
Development of Spreadsheet
URS‐5. The spreadsheet should use the Unique ID No. for
• The sheets are developed based on the User
specific compound in the form of dropdown list wherever
Requirement Specifications (URS).
applicable.
• The sheets should be designed systematically.
URS‐6. The spreadsheet should indicate invalid entries with • The user should include all the recommendations as
error messages and numerical value entries or any specific per URS step by step.
entries. • In case of Macro or VBA code recording should be
URS‐7. The spreadsheet input should only allow text, date, done by manual operations automatically.
time and signatures as well alongwith the approval details. • The code should be checked to ensure the correct cell
references.
Requirements concerning security, protection and GLP • At very first step user or the developer check the
compliance must also be taken into account. spreadsheet, cells, references and input values as per the user
URS‐8. The calculations in the spreadsheet should be protected requirement. This is done by the set of typical data.
against unauthorised modifications.
Review of codes
URS‐9. The sheet should have color coding system for input, • These codes should be evaluated twice by the
output cells and locking and unlocking system for formula developer and the experienced personnel who are accustomed
cells. with the planned use and functionality.
• In excel sheets it includes inspection of cell content,
URS‐10. After completion of the calculation, the spreadsheet
especially formulas, formula locations, cell numbers and
should be initialed, dated and put time electronically by the
user. ranges, syntax of additional functionality, and VBA code.
• The content and reference of the cell can be evaluated
URS‐11. Making changes to the spreadsheet by auditing the formula cells, dropdown list by zooming and
(modification/deletion) after signing off (initials/date) should scrolling to check mouse sensitivity.
not be possible. • Formula Auditing Tools in Excel by doing following:
URS‐12. The spreadsheet template and completed spreadsheets 1. Trace Precedents.
should be retained in a secure location in an electronic form 2. Remove Arrows.
with access control in the form of worksheet protection. 3. Trace Dependents.
4. Show Formulas.
URS‐13. The sheet should consist of the macro code and audit 5. Error Checking.
trail.
Trace Precedents
Designing of Excel sheet
• The “Trace Precedents” command can be seen in
The designing of the spreadsheet is related to the system
and version of the program and a worthy design ensures the “Formula Auditing” group under the “Formulas” tab to
the: trace precedents as shown in (Fig.13)
• Reduction of mistakes while operating the sheets.
• Easily understandable, adaptable and versatile.
• Easy verification of the formulas and cells to inhibit
unauthorised access.
Security, Error messages and Password
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Remove Arrows
• We can use the “Remove Arrows” command in
the “Formula Auditing” group under the “Formulas” tab to
remove these arrows as shown below in (Fig.14). Fig.16 Show Formula Command
Error Checking
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Formula Formula
Function Description
Example Description
The formula
returns TRUE
if a value in
Returns
AND cell A2 is
TRUE if all =AND(A2
greater than or
of the >=10,
equal to 10,
arguments B2<5)
and a value in
evaluate to
B2 is less than
TRUE.
5, FALSE
otherwise.
The formula
returns TRUE
if A2 is
greater than or
Fig.20Spreadsheet Protection Window OR equal to 10 or
Cell Locking B2 is less than
Returns
=OR(A2> 5, or both
TRUE if any
• Cells containing formulas, sheet code, and Batch no. =10, conditions are
argument
and test name are locked. B2<5) met. If neither
evaluates to
• To Lock Cell go to Home > Format > Fromat Cells of the
TRUE.
> Protection as shown in (Fig.5.9) conditions it
met, the
formula
returns
FALSE.
The formula
returns TRUE
if either A2 is
XOR greater than or
equal to 10 or
Returns a B2 is less than
=XOR(A2
logical 5. If neither of
>=10,
Exclusive the conditions
B2<5)
Or of all is met or both
arguments. conditions are
Fig.21 Cell locking Window met, the
Logical Formula formula
returns
• Microsoft Excel provides 4 logical functions to work FALSE.
with the logical values. The functions are AND, OR, XOR and
NOT as given in (Table.5.1)
• These functions are used to compare formula or
several test conditions instead of just one.
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Returns the
reversed
NOT logical value The formula
of its returns
argument. FALSE if a
I.e. If the =NOT(A2 value in cell
argument is >=10) A1 is greater
FALSE, than or equal
then TRUE to 10; TRUE
is returned otherwise.
and vice
versa.
Calculation Formula
Conditional Formatting
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Validation Protocol
It is a documented plan consisting of all the experiments, their Confirmed Notes
designing and the procedure to carry out the validation. This Whether the signature
plan is a written procedure which consists of all the information 1. log book maintained
such as product description, testing parameters, production or not
process, planning and the acceptance criteria. Validation
Are the employees
protocol consists of two major points such as:
know about
• Procedure: It defines the steps involved in the
2.
[Link], GAMP
procedure of the validation. and 21CFR Part 11
• Form: It is the documentation of the any change or Is the all operating
modification done in the pre-approved validation protocols. 3. system update in the
company?
• Parts of Validation Protocol Is all the sheets used
• The important parts to be included in the protocol are 4. for calculation are
described in (Table 3): validated or not?
Table 3 Validation Protocol Parts Is all the sheets have
[Link] Parts Description 5. password protection to
open the sheets or not?
It shall be done by the Is all the sheets have
Protocol concerned departments and 6. color coding system or
1.
Approval taken for final approval from not?
quality assurance department. Is the system have raw
7.
It includes the objective to data captured
2. Purpose
made validation protocol. All the sheets are
It includes the specific 8. properly named and
3. Scope departments following this coded
protocol Is the original data
The reason to carry out 9. captured in readable
Reason of validation process either of the form or not?
4.
Validation new, process, method or the Is the sheets follow
equipment. 10. electronic signature
model or not?
Revalidation The need of revalidation such
5. All information
Criteria as change to any part or step.
11. recorded both in paper
The responsibilities of every and electronic form?
6. Responsibilities department should be All the sheets can be
mentioned appropriately. 12. run on the entire
All appropriate documents version or not?
Reference
7. (BMR, BPR, SOPs) should be The sheets have
Documents
mentioned. 13. acceptance criteria
Procedure/Devi Mention a stepwise procedure limits or not?
8. The sheets are
ations with required deviation.
provided with the
All the obtained results as per 14.
9. Conclusions VBA codes and Audit
acceptance criteria or not.
trails or not?
Report/ Report The report should be made
10. The sheets are
Approval with department approval
provided with error
15.
and warning messages
or not?
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Sheets saved in
16. appropriate formats as
per SOPs or not?
4. Results
Validation Approach
In terms of duties, the spreadsheet designer is frequently
interchangeable with the researcher who is also in charge of a
certain test methods. It must be ensured in this scenario that the
programmer is constantly aware of his present job and that both
the creation and validation stages are clearly divided. If
modifications are required during the validation process, they
must be reported, assessed, and tested again. Version control
may be the core in handling changes, and essential
modifications may be done with fewer efforts than using CSV. Fig.34 Spreadsheet Layout
At last the approach of validating a spreadsheet is to assess the
Development of Spreadsheet
risk with short and systematic procedures in order to delete
• Testing of spreadsheet efficiency as per User
some steps of the process.
Requirement Specifications (URS)
Development Process
• The spreadsheets includes the formula auditing tools
The sheets should be designed as per the user requirements or
namely :
can be designed as a standard format for some common tests
1. Trace Precedents.
can be used as per the need. The key components of the sheets
2. Remove Arrows.
includes the password protection, color coding, locking and
3. Trace Dependents.
unlocking of the cell, limits as per the guidelines etc.
4. Show Formulas.
User Requirement Specifications
5. Error Checking.
This includes calculations, formulas, layout, security and
integrity of data, included in Functional Specifications. • The designed sheets must have these command as
6.4 Designing of Excel sheet described in (Fig.35)
To depict a sophisticated spreadsheet design the sheet is • The sheets were tested for the formulas feeded for the
divided into the colour coded area as shown in (Fig. 6.1) calculations.
where,
• First three rows (2, 3, and 4) contain heading as Test
name, Sheet code, and Standard reference.
• The next columns contains subheadings (G to P: ID
No., Vol. and Strength of solution required, Name of
compound, Formula Weight of compound, Weight of
Compound taken and Points to remember ).
• The heading and subheading cells are separated by
different colours.
• The designed sheets were easy to understand and
colour coded as well.
Input and output cells are separated and color coded as
well:
• The first three columns (G.H, I, J, and M to P) are
INPUT CELLS in YELLOW COLOUR.
• The next two columns (K and L) are OUTPUT
CELLS in BLUE COLOUR.
• The input cells are UNLOCKED CELLS while the
output cells are LOCKED CELLS.
• Formulas, Calculations and other parameters cannot Fig.35 Formula Auditing Tools
be changed by the users in locked cells.
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Trace Precedents. • This could be one of the ways including one more
• Suppose we have the following formula in the L7 cell appropriate way to check precedents for the formula cell.
for calculating weight of the compound to make molar solution
as shown in (Fig.36) Remove Arrows
Show Formulas
• In (Fig.41), the cells containing formulas in the entire
sheets are shown.
• The sheet shows all the formulas from the average
calculation to the every single function involved in the
calculation.
• The show formulas command allows to identify the
Fig.38 Formula Precedents Check
cells containing the type and cells involved in the formulas.
• We can see that H7 is written with blue in the formula
cell, and with the same color, the H7 cell is bordered.
• In the same way, I7cell has a green color and K7 cell
has a purple color.
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• T
he formula description is described in (Table.6)
Examples of Sheets containing Logical Formulas:
There are some sheets containing logical formulas as shown in
(Fig. 6.19, 6.20 and 6.21)
➢ T
hickness, Hardness and Disintegration Sheet
=IF (AND (K8<1, K8>0.5),"PASS","FAIL")
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Conditional Formatting
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Fig. 64 VBA Code List Fig.67 Macro book saving dialog box
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Audit Trail
• The changes done in the sheet are tracked in new
sheets as shown in the (Fig.69).
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8. Procedure/Deviations: CONCLUSION
• To prevent unauthorised access to the files, a file This research has introduced a simplified and efficient method
must be password protected or should be in the read-only for validating Excel spreadsheets. This method combines
status. industry best practices into two comprehensive documents,
with more specific information to follow in upcoming articles.
• The cell containing formulas or involved in
By following these principles, it is possible to fully validate and
calculation must be locked to maintain data accuracy and
implement a standard spreadsheet in less than four days. This
integrity. approach offers a practical solution to the widespread issue of
compliance, minimizing risk through an affordable and
• The version of the operating systems shall be fixed to consistent process. It is adaptable to various quantities of
prevent any problem during the change or revalidation. spreadsheets and can be easily integrated into a company's
• The format of the sheets should be fixed and such that computer systems validation policies.
it the header contains the Product name, Sheet code, Test name,
Batch no. and company name , logo (if applicable) Spreadsheet creation often point out that the process of creating
• The middle part shall contain the calculation, where spreadsheets is more casual in nature, and only a small number
entry to be filled from Raw Data Sheet, formulas and the of organizations possess thorough guidelines for spreadsheet
development. While there are instructive pieces that emphasize
information needed to make results.
practices like modular design and including sections for
• The footer of the sheets must contain the in-out
assumptions, these might not hold as much significance as other
timing, start-end date alongwith the prepared, checked and
advancements, particularly the meticulous inspection of
approval information with the signature. individual cells' code following the development stage.
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Acknowledgments involve the installation and checkout phase, 10. Rockville (MD): Agency for Healthcare Research and
which requires shifting the application software from the Quality (US), Registries for Evaluating Patient Outcomes: A
development lab to the plant site. Upon installation on-site, User's Guide; Data collection and Quality Assurance, 2014; 3rd
functional testing with the process can commence. Before this edition
phase starts, a procedure for documented change control (defect
identification, review, software and document updates) must be 11. Chapter 19 Quality Assurance for Pharmaceuticals.
defined and implemented. Outputs encompass functional test Management Sciences for Health, 2012
results, change control reports, and a validated computer 12. Loo M. P. J. & Jonge E. Data Validation. 2020, Wiley Stats
system.
Ref Statistics: 1–7
The sheets provide the accuracy maintenance of data and
13. Heiko Brunner. Chapter 18 Validation of Excel
calculations in order to protect the data from any unauthorised Spreadsheet, Analytical Method Validation and Instrument
access. The good documentation and manufacturing practices
Performance Verification, 2004: 277-298
alongwith the regulatory authorities made it important for
getting regulatory compliance. Validation of process, 14. Ayalasomayajula U.L. [Link], Review on Pharmaceutical
equipment plays important role in assuring the quality of Calculations, Res. J. Pharm. Tech. 2016; 9 (11):2043-2047
product while the excel sheets ensure the data integrity and
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16. OECD Series on Principles of Good Laboratory Practice
generation of the quality data. The necessary steps required to
and Compliance Monitoring, Number 22 Advisory Document
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of the Working Party on Good Laboratory Practice on GLP
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