Every regulated company that adopts a computerized system for quality management faces the same requirement: the system itself must be validated. GAMP 5 defines the framework. 21 CFR Part 11 mandates it for FDA-regulated industries. EU Annex 11 requires it for European pharmaceutical operations. ISO 13485 expects it for medical device quality systems.

The practical challenge is circular. You need a validated system to manage quality records. But validating the system requires the same kind of structured testing, documented evidence, and traceability that the system is supposed to provide. Most organizations solve this by hiring consultants, spending weeks writing validation protocols from scratch, and then executing tests against documentation that may not reflect the actual software.

QAtrial – Validation Package IQ/OQ/PQ
QAtrial · Validation & Compliance
Built-In
IQ / OQ / PQ
Validation Package
Every regulated company adopting a computerized quality management system must validate it. QAtrial v3.0.0 ships with its own validation package — five executable documents in docs/validation/ that a validation engineer can pick up and run. Not marketing materials. Actual protocols.
🔧
IQ
Installation Qualification
9
⚙️
OQ
Operational Qualification
18
📊
PQ
Performance Qualification (template)
📜
Compliance Statement
21 CFR Part 11 · EU Annex 11 · GAMP 5
3
🔗
Traceability Matrix
Regulation → Feature → Test ID
75
“The challenge is circular — you need a validated system to manage quality records, but validating the system requires the same structured testing and traceability the system is meant to provide.”
Installation Qualification
9 IQ Steps — Is the Software Correctly Installed in This Environment?
IQ-01 Server starts and responds on the configured port
IQ-02 PostgreSQL database connected and accessible
IQ-03 Frontend loads correctly in a browser
IQ-04 User registration creates a new account
IQ-05 User login returns valid authentication tokens
IQ-06 File storage for evidence uploads is functional
IQ-07 Theme switching (light/dark mode) works
IQ-08 Language selection changes the interface language
IQ-09 Status endpoint returns system health information
1–2
Hours to execute all 9 IQ steps. Each step includes: procedure, expected result, actual result field, pass/fail, tester initials, date. Do not proceed to OQ until all IQ steps pass.
Operational Qualification
18 OQ Steps — Does QAtrial Function Correctly Under Normal Operating Conditions?
Step What Is Verified Category
OQ-01Setup wizard completes and creates a projectCore Workflow
OQ-02Requirement creation with auto-generated sequential ID (REQ-NNN)Core Workflow
OQ-03Requirement editing and status transitionsCore Workflow
OQ-04Test case creation with auto-generated ID (TST-NNN)Core Workflow
OQ-05Test case editing and status transitionsCore Workflow
OQ-06Requirement-to-test linking (traceability)Core Workflow
OQ-07AI test case generation from a requirementAI Feature
OQ-08AI risk classification of requirementsAI Feature
OQ-09Approval workflow: request, approve, reject cycleCore Workflow
OQ-10Electronic signature with password re-authenticationE-Signature
OQ-11Evidence file attachment to a requirementCore Workflow
OQ-12CSV export of requirementsCore Workflow
OQ-13CSV import with column mapping and duplicate handlingCore Workflow
OQ-14Design control phase progression and gate statesCore Workflow
OQ-15ISO 13485 gap analysis execution (27 clauses)AI Feature
OQ-16CAPA creation and 6-state lifecycle transitionsCore Workflow
OQ-17Audit mode link generation and read-only access verificationAudit Access
OQ-18RBAC enforcement: non-admin cannot access admin; QA Engineer cannot approveSecurity
4–8
Hours to complete all 18 OQ steps. Steps are independent and can be executed in any order, though the sequence follows a logical workflow.
OQ-07
08, 15
AI-dependent steps require a configured LLM provider. If unavailable, document as a planned deviation. Validate when AI is configured.
Performance Qualification
PQ Template — Intentionally Left for Customer Completion
📋 PQ Template Sections Customer fills
Environment description: hardware, OS, database version, network configuration
Customer-specific test cases reflecting actual usage patterns and data volumes
Performance criteria and acceptance thresholds for this deployment
Load testing scenarios: concurrent users, simultaneous operations
Re-validation schedule — triggers for periodic review
Result recording fields: actual results, pass/fail, tester, date, co-signer
“Performance qualification must reflect the specific deployment — the customer’s hardware, network, user count, data volume, and concurrent usage patterns. QAtrial cannot pre-define these parameters.”
Estimated: 1–3 days depending on scope Example PQ test: “Import 5,000 requirements from CSV in under 60 seconds in the production environment.” This can only be defined by the customer — not by QAtrial’s developers.
Compliance Statement
Regulatory Alignment Mapped to QAtrial Features
21 CFR Part 11
15 sections — §11.10(a) through §11.200
§11.10(e) — Audit Trails
Append-only audit log captures who, what, when, why for every change. Previous and new values recorded as JSON snapshots. No delete or update endpoint exists for audit entries.
§11.10(d) — Access Controls
Five-role RBAC enforced at API level via requirePermission() middleware. Role extraction from JWT on every request.
§11.200 — E-Signature Authentication
Password re-authentication required at signing. 15-minute window for subsequent signatures per single continuous access session.
EU Annex 11
17 sections — risk management through archiving
§9 — Audit Trail
Chronological log capturing identity, action, timestamp, old/new values, and reason. Exportable as CSV and PDF. Immutable by design.
§12 — Security
JWT logical access control plus RBAC operational controls. OIDC SSO for identity governance integration.
§14 — Electronic Signatures
Signatures carry same regulatory weight as handwritten within the organization — verified identity, defined meaning, permanent trail binding.
GAMP 5 2nd Ed.
Category 4 — Configured Product
Classification Rationale
Customers configure QAtrial for their specific country, vertical, and modules without modifying source code. No custom code = Configured Product, not Bespoke.
Validation Approach
IQ/OQ/PQ follows GAMP 5 guidelines for risk-based validation of Category 4 configured products. Risk-proportionate testing scope.
Configuration Management
Source code in Git repository. Every change traceable to a commit. Version-controlled releases provide clear re-validation triggers.
GAMP 5 Category 4 — Configured Product: QAtrial meets the configured product definition because regulatory customization is achieved through data (country/vertical/module selection, template content) not source code modification. This classification determines validation scope: focus on configuration testing, not bespoke code review.
Traceability Matrix
Regulation → Feature → Test — 75 Requirements, Six Standards
Regulatory Ref
QAtrial Feature
Test ID
21 CFR 11.10(e)
Append-only AuditLog table
OQ-03
21 CFR 11.10(d)
RBAC requirePermission() middleware
OQ-18
21 CFR 11.200
Password re-auth at signing + 15-min window
OQ-10
EU Annex 11 §9
Chronological audit trail export (CSV/PDF)
OQ-12
ISO 13485 §4.2.3
Traceability matrix + linked requirements
OQ-06
GAMP 5 §10
CAPA 6-state lifecycle + audit log
OQ-16
75
Regulatory requirements mapped
6
Standards covered: 21 CFR Part 11 · EU Annex 11 · GAMP 5 · ISO 13485 · 21 CFR 820/QMSR · ICH Q7/Q10
Each row: regulation
QAtrial feature
IQ/OQ/PQ test ID

Auditors can trace any regulation forward to a specific test and its recorded result.
The Open-Source Advantage
Source Code Access Changes the Assurance Model
🔓 QAtrial — AGPL-3.0 Open Source Source access
Auditor can inspect audit.service.ts — the actual implementation of the append-only audit log
Verify that audit records cannot be deleted by inspecting the route handlers — no DELETE endpoint for AuditLog
Confirm timestamps are server-generated (UTC, from JWT context) not client-supplied
Validate that user identity is captured from JWT token — not from a request parameter
AGPL-3.0 guarantees source code remains available — no vendor can revoke access or change license
System validated not just by testing behavior but by inspecting implementation
🔒 Proprietary Vendor QMS Black box
Audit trail implementation described in marketing materials and high-level architecture diagrams
Cannot verify immutability except by testing — no access to route handlers to confirm no delete endpoint
Timestamp generation mechanism unverifiable without source access
Identity capture mechanism must be trusted, not verified
Source access can be revoked, restricted, or changed by vendor without notice
Validation limited to behavioral testing — black-box assurance only
Execution Guide
Running the Validation — Phase by Phase
1
IQ Execution
Estimated 1–2 hours
1Deploy QAtrial (docker-compose up) and have validation engineer with system access
2Open IQ protocol from docs/validation/. Execute IQ-01 through IQ-09 in sequence
3Record: actual result, pass/fail, tester initials, date for each step
4If a step fails, document deviation and assess. Do not proceed to OQ until all IQ steps pass or deviations formally accepted
5Sign and date the IQ protocol. Second person reviews and co-signs
2
OQ Execution
Estimated 4–8 hours
1Confirm IQ is completed and formally approved before beginning OQ
2Execute OQ-01 through OQ-18. Each step describes specific actions and expected system response
3For AI steps (OQ-07, OQ-08, OQ-15): ensure LLM provider configured. Document as planned deviation if not available
4Document any deviations with impact assessment. Steps are independent — deviation on one step does not block execution of others
5Sign and date the OQ protocol. Reviewer co-signs
3
PQ Execution
Estimated 1–3 days
1Complete the PQ template with your environment-specific hardware, OS, database version, user count, and network details
2Define customer-specific test cases based on actual usage patterns and data volumes
3Execute all tests in the production environment — not in staging or development
4Document results against acceptance thresholds. Sign. Obtain formal approval for production use
Complete Documentation Package After Execution
Completed and signed IQ protocol
Completed and signed OQ protocol
Completed and signed PQ protocol
Compliance Statement — reviewed and acknowledged
Traceability Matrix — reviewed for completeness
Deviation reports with impact assessments
Validation Summary Report (AI-generated via QAtrial VSR)
“The complete validation — from first test to signed protocol — can be accomplished in days, not months. The package is audit-ready. It can be stored within QAtrial itself as evidence attachments, or in the organization’s document management system.”
📋
27 test steps (9 IQ + 18 OQ) ready to execute. Each includes procedure, expected result, and result recording fields.
🔗
75 requirements mapped across 6 standards. Auditors can trace any regulation forward to a test ID and its recorded result.
🔓
Source code access via AGPL-3.0. Validate by inspecting the implementation, not just testing the behavior.
🤖
VSR can be AI-generated using QAtrial’s own Validation Summary Report function after execution is complete.

QAtrial v3.0.0 takes a different approach: it ships with its own validation package.

What Is in the Validation Package

The validation package consists of five documents in the docs/validation/ directory of the QAtrial repository. These are not marketing materials. They are executable validation protocols that a validation engineer can pick up and run.

Installation Qualification (IQ)

Purpose: Verify that QAtrial is correctly installed and all components are operational.

9 test steps:

StepWhat Is Verified
IQ-01Server starts and responds on the configured port
IQ-02PostgreSQL database is connected and accessible
IQ-03Frontend loads in a browser
IQ-04User registration creates a new account
IQ-05User login returns valid authentication tokens
IQ-06File storage (evidence uploads) is functional
IQ-07Theme switching (light/dark mode) works
IQ-08Language selection changes the interface language
IQ-09Status endpoint returns system health information

Each step includes: test ID, description, prerequisite, procedure, expected result, and fields for actual result, pass/fail, tester initials, and date.

The IQ confirms that the infrastructure layer is working. It answers the fundamental question: “Is the software installed correctly in this environment?”

Operational Qualification (OQ)

Purpose: Verify that QAtrial’s core workflows function correctly under normal operating conditions.

18 test steps:

StepWhat Is Verified
OQ-01Setup wizard completes and creates a project
OQ-02Requirement creation with auto-generated ID
OQ-03Requirement editing and status changes
OQ-04Test case creation with auto-generated ID
OQ-05Test case editing and status changes
OQ-06Requirement-to-test linking (traceability)
OQ-07AI test case generation from a requirement
OQ-08AI risk classification
OQ-09Approval workflow (request, approve, reject)
OQ-10Electronic signature with password re-authentication
OQ-11Evidence file attachment to a requirement
OQ-12CSV export of requirements
OQ-13CSV import with column mapping
OQ-14Design control phase progression
OQ-15ISO 13485 gap analysis execution
OQ-16CAPA creation and lifecycle transitions
OQ-17Audit mode link generation and read-only access
OQ-18RBAC enforcement (role-based permission checks)

The OQ is the workhorse of the validation. It exercises every major feature path and verifies that the system behaves as documented. Each test step is independent and can be executed in any order, though the listed sequence follows a logical workflow.

Performance Qualification (PQ)

Purpose: Verify that QAtrial performs acceptably in the customer’s specific production environment with their actual data volumes and usage patterns.

The PQ is a template, not a pre-filled protocol. This is intentional. Performance qualification must reflect the specific deployment: the customer’s hardware, network, user count, data volume, and concurrent usage patterns. QAtrial cannot pre-define these parameters.

The PQ template includes sections for:

  • Environment description (hardware, OS, database version, network configuration)
  • Customer-specific test cases (e.g., “Import 5,000 requirements from CSV in under 60 seconds”)
  • Performance criteria and acceptance thresholds
  • Load testing scenarios (concurrent users, simultaneous operations)
  • Result recording and sign-off

Compliance Statement

Purpose: Document QAtrial’s alignment with applicable regulatory requirements.

The Compliance Statement maps QAtrial features against three regulatory frameworks:

21 CFR Part 11 — Electronic Records and Electronic Signatures (15 sections):
Every section from 11.10(a) through 11.200 is addressed. For each, the statement describes QAtrial’s specific implementation. Example: Section 11.10(e) (audit trail) maps to QAtrial’s append-only audit log capturing who, what, when, why for every change, with previous and new values recorded.

EU Annex 11 — Computerised Systems (17 sections):
Every section from risk management (section 1) through archiving (section 17) is addressed. Example: Section 9 (audit trail) maps to QAtrial’s chronological log capturing identity, action, timestamp, old/new values, and reason.

GAMP 5 Second Edition:
QAtrial is classified as Category 4 — Configured Product. The rationale: customers configure QAtrial for their specific country, vertical, and module needs without modifying source code. The validation approach follows GAMP 5 guidelines for risk-based validation of configured products.

Traceability Matrix

Purpose: Map regulatory requirements to QAtrial features and validation test IDs.

The matrix contains 75 regulatory requirements drawn from six standards:

  • 21 CFR Part 11
  • EU Annex 11
  • GAMP 5
  • ISO 13485
  • 21 CFR Part 820 / QMSR
  • ICH Q7/Q10

Each requirement row includes: the regulatory reference, the requirement text, the QAtrial feature that addresses it, and the specific IQ/OQ/PQ test ID that verifies the feature. This creates a three-way linkage: regulation to feature to test.

Auditors reviewing QAtrial’s validation can trace any regulatory requirement forward to a specific test and its result. This is the traceability that 21 CFR Part 11 section 11.10(a) demands and that auditors expect to see.

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How to Execute the IQ/OQ

Prerequisites

  1. QAtrial deployed and running (Docker recommended: docker-compose up).
  2. A validation engineer with access to the system.
  3. Printed or electronic copies of the IQ and OQ protocols from docs/validation/.
  4. A pen (for paper execution) or a controlled document system (for electronic execution).

IQ Execution (Estimated: 1-2 hours)

Execute each of the 9 IQ steps in sequence:

  1. Open the protocol to IQ-01.
  2. Read the procedure. Follow it exactly as written.
  3. Compare the actual result to the expected result.
  4. Record: actual result, pass/fail, tester initials, date.
  5. If a step fails, document the deviation and investigate. Do not proceed to OQ until all IQ steps pass or deviations are formally documented and assessed.
  6. Repeat for IQ-02 through IQ-09.
  7. Sign and date the IQ protocol. Have a second person review and co-sign.

OQ Execution (Estimated: 4-8 hours)

Execute each of the 18 OQ steps:

  1. Ensure IQ has been completed and approved.
  2. Open the protocol to OQ-01.
  3. Follow the procedure. Each step describes the specific actions to take and the expected system response.
  4. Record results for each step.
  5. For AI-dependent steps (OQ-07, OQ-08, OQ-15), ensure an AI provider is configured. If no AI provider is available, document this as a planned deviation and note that these features will be validated when AI is configured.
  6. Complete all 18 steps. Sign and date. Review and co-sign.

PQ Execution (Estimated: 1-3 days, depending on scope)

  1. Complete the PQ template with environment-specific information.
  2. Define customer-specific test cases based on actual usage patterns.
  3. Execute the tests in the production environment.
  4. Document results and obtain approval.

Documentation Package

After execution, the complete validation package consists of:

  • Completed and signed IQ protocol
  • Completed and signed OQ protocol
  • Completed and signed PQ protocol
  • Compliance Statement (reviewed and acknowledged)
  • Traceability Matrix (reviewed for completeness)
  • Any deviation reports with impact assessments
  • Validation Summary Report (can be AI-generated using QAtrial’s VSR function)

This package is audit-ready. It can be stored within QAtrial itself (as evidence attachments) or in the organization’s document management system.

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What Auditors Want to See

Based on common FDA and Notified Body audit observations, auditors evaluating a quality management system’s validation typically look for:

  1. Documented validation plan. QAtrial’s IQ/OQ/PQ protocols serve as the plan. The Traceability Matrix demonstrates that the plan covers applicable regulatory requirements.
  2. Executed test protocols with results. The IQ and OQ protocols include fields for actual results, pass/fail determination, and tester identification.
  3. Traceability from regulations to tests. The 75-requirement Traceability Matrix provides this linkage explicitly.
  4. Deviation handling. Any test that does not pass as expected requires a documented deviation with impact assessment. The protocols include space for deviation references.
  5. Periodic review. The PQ template includes a section for defining the re-validation schedule. QAtrial’s version-controlled releases provide clear triggers for re-validation.
  6. Evidence of change control. QAtrial’s source code is in a Git repository. Every change is traceable to a commit. The Compliance Statement notes this as part of GAMP 5’s configuration management requirements.
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The Open-Source Advantage

There is one thing QAtrial’s validation package provides that no proprietary vendor can match: source code access.

When an auditor asks “How does the audit trail work?”, the answer is not a vendor’s marketing document or a high-level architecture diagram. The answer is server/services/audit.service.ts — the actual code that implements the append-only audit log. The auditor can inspect the implementation, verify that records cannot be deleted, confirm that timestamps are server-generated, and validate that user identity is captured from the JWT token.

This level of transparency is unique to open-source software. Under AGPL-3.0, the source code is not just available — it is guaranteed to remain available. No vendor can revoke access. No license change can hide the implementation.

For validation engineers accustomed to treating vendor software as a black box, this transparency fundamentally changes the assurance model. The system can be validated not just by testing its behavior but by inspecting its implementation.

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Conclusion

QAtrial’s built-in validation package eliminates the most time-consuming aspect of adopting a new quality management system in a regulated environment. The IQ, OQ, and PQ protocols are ready to execute. The Compliance Statement documents regulatory alignment. The Traceability Matrix links 75 requirements to features and tests. The complete validation — from first test to signed protocol — can be accomplished in days, not months.

QAtrial v3.0.0 and its validation package are available under the AGPL-3.0 license at https://github.com/MeyerThorsten/QAtrial.

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