CSA method

Functional Risk Assessment

Assess each GxP function, realistic failure scenario, potential impact, existing control, and required testing before selecting validation evidence.

Author
Sandip Thorat
Published
12 September 2026
Last reviewed
12 September 2026
Version
1.0
Content type
Practitioner guidance
Primary references
See related regulations, guidance, and approved procedures

A GxP function is a bounded use that you can describe, assess, and support with evidence. It is an assessment aid, not necessarily a screen, module, or microservice.

A training platform might have separate units for training assignment, completion approval, and operator eligibility. Split these uses because their failure consequences and evidence differ. Keep dependencies visible: eligibility still depends on completion data and role mapping.

How to apply it

Describe the activity and decision. Identify its inputs, outputs, actors, and interfaces. State the failure that matters. Identify shared dependencies. Link controls and evidence. Explain the conclusion within that boundary.

Do not split a system so finely that you lose the end-to-end process. A perfectly tested field does not prove that the correct record reaches the correct downstream decision.

Completed example — fictional

FieldExample
GxP functionF-03: operator eligibility for OP-21
Intended usePrevent task start unless required training is current
InputsOperator ID, role requirements, completion records, effective dates
OutputEligible/ineligible response with transaction identity
FailureExpired training produces eligible response
DependenciesIdentity mapping, time configuration, training records, MES handling
EvidenceExpiry boundary, role mapping, timeout, interface and override tests
LimitDoes not establish practical competency beyond the training process

Contrasting uses

An overdue-training dashboard may be a separate unit if it serves a distinct review process. An AI summary and an AI-executed workflow action should normally be examined separately because the action introduces permissions and consequences beyond the text.

Reusable worksheet

Write: function name; process decision; users; inputs and provenance; outputs and consumers; boundaries; failure; controls; dependencies; evidence; unresolved uncertainty; authorized conclusion; reassessment criterion.

Exercise: Should a LIMS–ERP transfer be divided into “send” and “receive” and then assessed independently?

Answer: Component assessments can help, but retain an end-to-end function view or explicit integration evidence. Otherwise, both sides can pass while using different units or meanings.