The question is "Can Amazon AWS or Microsoft Azure be qualified so that Life Science companies can run validated apps on it?"   

Cloud releases updates and changes at such great velocities that leaves all validation specialists continuously wondering on how to qualify it.  Traditional strategies including GAMP 5 was never designed to address continuous changes.  These models were designed for a "waterfall" world and not an "agile" one.  It is not possible to qualify an infrastructure where changes are released without release notes with such an outdated mindset and toolset.

Does this mean that the Life Science world should stay in the dark ages with their paper based, wet signature toolset and a brick and mortar data center?  You need continuous Qualification for Continuous Compliance that works better than ever, just like the Cloud!

Here is a step by step guide to Continuous Qualification:

1. Step 1: Design your BASE Cloud Infrastructure (combination of IaaS / PaaS)

2. Step 2: Divide your BASE into logical Services

   1. Core Services (e.g. Networking, Compute)

   2. Management Services (e.g. Auditing, Monitoring)

3. Step 3: Build your DEV BASE IaaS/PaaS.  Finalize and test your configuration.

4. Step 4: Develop a Qualification Plan / Governance Framework

5. Step 5: Subscribe to our IaaS / PaaS Qualification Service.  We have built a sophisticated infrastructure to qualify Microsoft Azure or AWS Services.  Our Service Qualification coverage is unmatched.  We post the following on a "Weekly" basis on our customer portal:

   1. Service Qualification Plan

   2. Service Requirements Specification (with Comprehensive Coverage)

   3. Service Risk Assessment

   4. Service Qualification Protocols & Execution Reports

   5. Service Qualification Summary Reports

   6. Service Release Certificates

6. Step 6:  You don't have to Qualify any Service.  We will do that for you on a continuous basis.  Our "continuous" qualification platform for each Service will provide documented evidence that your Service continuous to work as designed (irrespective of many changes pushed by the Cloud Vendor)

7. Step 7:  Deploy PROD BASE IaaS/PaaS

8. Step 8: Add or Modify Services to build out your Cloud under Change Control