Quality Management Systems (QMS) - Audits
Medical Devices (MDR) - Regulation (EU) 2017/745, and
In Vitro Diagnostic Devices (IVDR) - Regulation (EU) 2017/746
Medical devices and In Vitro Diagnostic Devices within the European Union (EU) must undergo a conformity assessment to demonstrate their safety and intended performance.
Manufacturers can place a CE (Conformité Européenne) mark on a medical device once it has passed the assessment.
The assessment typically involves:
1. An audit of the manufacturer’s quality system.
2. A review of technical documentation related to the device’s safety and performance.
3. Accredited notified bodies in EU Member States conduct these assessments.
4. For high-risk devices, expert panels provide opinions before issuing the certificate of conformity.
5. The European Medicines Agency (EMA) plays a role in supporting these assessments, especially for specific categories of medical devices:
-Medicines are used in combination with a medical device.
- Medical devices with an ancillary medicinal substance.
- Companion diagnostics (in vitro diagnostics).
- Medical devices are made of substances that are systemically absorbed
Key Components for the QMS Audit:
Quality Objectives:
Define how quality objectives are determined, recorded, and evaluated within your QMS.
Organizational Structures:
Specify organizational structures, staff responsibilities, and managerial authority related to critical procedures.
Monitoring of Processes and Product:
Describe methods for monitoring the efficiency of the quality management system and ensuring desired design and device quality.
Outsourced Processes:
If processes are carried out by another party, detail methods for monitoring their efficient operation and control.
Design and Development:
Address output records and procedures related to design changes, process verification/validation, and production process controls.
Risk Management:
Implement risk-based approaches throughout the QMS to assess and manage risks associated with IVDs.
Post-Market Surveillance:
Establish procedures for ongoing evaluation of laboratory QA/QC programs to ensure continuous improvement.
Remember that compliance with IVDR is crucial for manufacturers of IVDs, and adherence to QMS requirements plays a significant role in achieving safety and quality standards.
Medical Device Single Audit Program (MDSAP)
The Medical Device Single Audit Program (MDSAP) is a regulatory audit program jointly developed by multiple jurisdictions. Its purpose is to streamline quality management system audits for medical device manufacturers, allowing them to satisfy the requirements of all participating regulatory authorities with a single audit. International partners that are participating in the MDSAP include:
MDSAP Members:
- Therapeutic Goods Administration of Australia (TGA)
- Brazil’s Agência Nacional de Vigilância Sanitária (ANVISA)
- Health Canada
- Japan's Ministry of Health, Labour and Welfare, and the Japanese Pharmaceuticals and Medical Devices Agency
- U.S. Food and Drug Administration (FDA)
MDSAP Official Observers:
- European Union (EU)
- United Kingdom's Medicines and Healthcare products Regulatory Agency (MHRA)
- The World Health Organization (WHO) Prequalification of In Vitro Diagnostics (IVDs) Programme MDSAP Affiliate Members:
- Argentina's National Administration of Drugs, Foods and Medical Devices (ANMAT)
- Ministry of Health of Israel
- Kenya's Pharmacy and Poisons Board (NEW)
- Republic of Korea's Ministry of Food and Drug Safety
- Federal Commission for Protection from Sanitary Risks (COFEPRIS) of Mexico
- Singapore's Health Sciences Authority (HSA)
- TFDA - Taiwan Food and Drug Administration
Here are key points about the MDSAP audit approach:
Scope and Participants: MDSAP covers medical devices and in vitro diagnostic devices. Participating countries include Australia, Brazil, Canada, Japan, and the United States.
Process Approach:
- MDSAP audits follow a process-based approach.
- The focus is on risk management, ensuring that device safety and performance risks are identified and addressed.
- The audit sequence includes primary processes such as management, measurement, analysis, improvement, design and development, and production and service controls.
Impartiality and Communication:
- MDSAP emphasizes impartiality in audit processes.
- Communication between auditing organizations (AOs) and regulatory authorities (RAs) ensures transparency and compliance.
- In summary, the MDSAP audit approach simplifies regulatory compliance for manufacturers by harmonizing audit requirements across multiple jurisdictions.
Preparing for FDA Inspections: QSIT Mock Audits for Medical Device Manufacturers
Introduction: FDA inspections can occur unexpectedly, and their purpose is to ensure that medical device manufacturers comply with quality standards. Being prepared for these inspections is crucial. Let’s explore how QSIT mock audits can help you assess your readiness and address any issues before an FDA inspector arrives.
1. Understanding QSIT Mock Audits:
- A QSIT mock audit (Quality System Inspection Technique) is a valuable tool to test your internal systems and personnel before an actual FDA inspection.
- Our auditors assume the role of FDA inspectors and delve into your processes using the FDA’s quality system inspection technique.
2. Key Steps in a QSIT Mock Audit:
- Internal Audit Plan: We create a customized plan for the mock inspection.
- Documentation Review: Thoroughly assess your quality manual and standard operating procedures (SOPs).
- Mock FDA Inspection: Our auditors simulate an FDA inspection, identifying potential gaps.
- Audit Report: We compile findings and provide a detailed report to your management team.
- Remediation Planning: Collaborate on a quality transition plan to address any issues.
- Assistance with Gap Closure: We would like to help you fix identified gaps as you'd like.
3. Baseline FDA Audit:
- Conducted during QMS implementation or upgrades, this audit assesses your compliance with relevant quality standards and regulations (e.g., FDA QSR/QMSR, ISO 13485, MDSAP, EU MDR, EU IVDR).
- The audit results in a roadmap for achieving compliance.
4. Private FDA Inspection Readiness Training:
- Learn effective strategies for managing inspections.
- Our workshop-based training covers front-room/back-room audit approaches and handling FDA inspector queries.
5. Why Choose Us?
- Our experienced team has assisted numerous medical device companies in preparing for FDA inspections.
- Let’s discuss how we can support your company’s inspection readiness.
Please remember, being proactive and well-prepared makes sure a smoother FDA inspection process.
FDA (U.S. Food and Drug Administration)
The FDA (U.S. Food and Drug Administration) plays a crucial role in ensuring the safety and effectiveness of medical devices throughout their lifecycle. The FDA has established Quality System Regulations (QSR)/Quality Management System Regulation (QMSR) that specifically address device design, validation, and good manufacturing practices to achieve this.
Here are the key types of FDA inspections:
Surveillance Inspections:
Purpose:
- To monitor the manufacturing process and the quality of FDA-regulated products already on the market.
Evaluation:
- Assess whether a manufacturer complies with quality manufacturing practices.
Trigger:
- Routine inspections conducted periodically.
For-Cause Inspections:
Purpose:
Triggered when the agency suspects a facility has quality problems, needs to follow up on complaints, or evaluate corrections made to address previous violations.
Focus:
- Investigate adverse events, serious manufacturing issues, or consumer complaints.
Application-Based Inspections:
Purpose:
- Part of the application review process for new drugs, devices, or biologics.
Evaluation:
-Determine if the new product complies with FDA regulations and if the facility can consistently manufacture it.
Risk-Based Approach to Inspections:
Criteria: The FDA uses a risk-based evaluation to select both foreign and domestic medical product manufacturing facilities for inspection.
Factors Considered:
- Facility type (e.g., manufacturer, control laboratory)
- Compliance history (recent inspections)
Hazard signals (product recalls linked to the facility)
- Inherent risks of the product manufactured - Whether the facility has been inspected by a foreign regulatory partner
Remember that FDA inspections are critical snapshots in time, and they are part of a comprehensive approach to oversee the safety and quality of FDA-regulated products.
UKCA (United Kingdom Conformity Assessed)
The UKCA (United Kingdom Conformity Assessed) marking signifies that a product meets the necessary regulatory standards for sale within Great Britain. Below are essential details regarding the UKCA marking:
Scope and Applicability:
- The UKCA marking must be affixed to certain products entering the Great Britain market, including England, Wales, and Scotland.
- This marking applies to most goods that previously necessitated a CE marking.
- However, the UKCA marking is not recognized within the EU market.
Legislative Context:
- The UK government intends to legislate to continue recognition of EU requirements, including the CE marking, indefinitely for a range of product regulations.
- Businesses have the flexibility to use either the UKCA or CE marking to sell products in Great Britain. - Manufacturers can benefit from a new fast-track provision, allowing them to place products on the GB market if they meet EU essential requirements and have been conformity assessed by an EU recognized body.
- Products falling under multiple regulations can use a mixture of both UKCA and CE conformity assessment procedures.
- This provides longer-term certainty and flexibility for businesses.
Recent Developments:
- Continued recognition of current EU requirements, including the CE and reversed epsilon markings, applies to 21 product regulations.
- Feedback from the industry led to the recognition of three additional regulations covering ecodesign, civil explosives, and, in most cases, the restriction of hazardous substances (in electrical equipment).
- Note that this announcement does not apply to regulations for medical devices, construction products, marine equipment, rail products, cableways, and unmanned aircraft systems.
Labelling Flexibility:
- The government plans to introduce a statutory instrument to provide permanent labelling flexibility: - The UKCA marking can be placed on a sticky label or accompanying document.
- Importers from countries outside the UK can provide their details on the product itself, an accompanying document, packaging, or an adhesive label.
European Medicines Agency (EMA)
Conformity assessment involves auditing the manufacturer’s quality system and reviewing technical documentation on device safety and performance.
European Medicines Agency (EMA) is a decentralized agency of the European Union (EU) responsible for the scientific evaluation, supervision, and safety monitoring of medicines.
Here are key points about the EMA:
Scope and Jurisdiction:
- The EMA serves the EU member states as well as three countries from the European Economic Area (EEA): Iceland, Norway, and Liechtenstein.
- Its primary focus is on evaluating and ensuring the safety and efficacy of pharmaceutical products.
Functions and Responsibilities:
Scientific Evaluation:
- The EMA assesses medicines' quality, safety, and efficacy before they are authorized for use in the EU.
Supervision:
- It monitors the safety and performance of authorized medicines throughout their lifecycle.
Pharmacovigilance:
- The EMA practices pharmacovigilance to detect and manage adverse effects related to medicines.
Orphan Medicines:
- The agency supports the authorization of treatments for rare diseases (orphan medicines).
Real-World Data (RWD):
- Recently, the EMA launched public electronic catalogues for real-world data sources and studies, enhancing transparency and research capabilities.
Ensuring Supplier Quality: Medical Device CDMO and Critical Supplier QMS Audits
Introduction: In the complex landscape of medical device manufacturing, external suppliers play a crucial role. Whether they provide critical components or handle final assembly, their impact on product quality cannot be overstated. - - But how can you be certain that their delivered products consistently meet your specifications? - - How well does their Quality Management System (QMS) function?, and most importantly, - Will your overall quality management program withstand regulatory scrutiny?
The answer lies in conducting thorough supplier audits.
1. Why Supplier Audits Matter:
- Dependency on Suppliers: Virtually every medical device manufacturer relies on external suppliers.
- Quality Assurance Concerns: Ensuring that suppliers meet your quality standards is essential. - Regulatory Compliance: Regulatory bodies expect robust oversight of suppliers.
- Efficiency and Consistency: Supplier audits are efficient and effective in verifying compliance.
2. Key Considerations for Supplier Audits:
- Specification Adherence: Verify that delivered products align with your specifications.
- QMS Evaluation: Assess the effectiveness of suppliers’ Quality Management Systems.
- Regulatory Alignment: Ensure compliance with ISO 13485, FDA 21 CFR Part 820, and other relevant standards.
- Risk Mitigation: Address quality issues at the root level (suppliers) to prevent recurrence.
3. Developing a Risk-Based Audit Program:
- Customized Approach: Tailor audits based on supplier criticality and product impact.
- Supplier Development: Collaborate with non-compliant suppliers to improve their processes.
- Lean and Six Sigma: Implement improvement methodologies as needed.
4. Global Auditors Ready to Assist:
- Our experienced auditors are strategically located worldwide.
- Specialization in ISO 9001, ISO 13485, and FDA QSR/QMSR compliance.
- Hundreds of successful CDMO supplier audits for both small companies and multinationals.
5. Conclusion:
- Supplier audits are not just about compliance; they are a proactive step toward consistent quality.
Let’s discuss how we can assist you in ensuring that what you specified is indeed what you received.
ISO 27001 Information Security Management System (ISMS) and Medical Device Cybersecurity and IEC 62304 - Medical device software life cycle processes Audits
ISO 27001 ISMS and Cybersecurity:
- ISO 27001 provides an international methodology for implementing, managing, and maintaining information security within a company.
- It focuses on safeguarding sensitive data, mitigating cybersecurity risks, and ensuring confidentiality, integrity, and availability.
- Our team has expertly guided numerous organizations to achieve ISO 27001 certification.
The program emphasizes:
- It is increasing organizational effectiveness and efficiency.
- Knowledge transfer through coaching, mentoring, and training.
Phase I (Steps 1 – 3):
- Assess your current ISMS compliance.
- Identify improvement opportunities.
- Create a detailed roadmap for ISO 27001 certification.
- Optional risk assessment to ISO/IEC 27005.
Phase II (Steps 4 – 14):
- Develop an action plan leading to ISO 27001 certification.
- Key step: Policy Development (e.g., information security policy, ISMS scoping, risk assessment plan).
- Training for effective implementation and management.
Advantages of ISO 27001 Compliance:
- It enhanced risk management by proactively addressing security gaps.
- Alignment with international standards for quality management systems.
- Legal and regulatory compliance.
- Comprehensive documentation and control.
Remember, ISO 27001 certification ensures robust information security practices and builds trust with clients and partners.
IEC 62304 - Medical device software life cycle processes Audits for Medical Device Software.
Understanding ISO 62304:
- ISO 62304 is an international standard specifically designed for medical device software. - It outlines the processes that span the entire lifecycle of the device and software.
- These requirements apply whenever software is an integral component of the device, used in its production, or if it is the device itself (also known as Software as a Medical Device (SaMD)).
Risk Control Measures:
- Risk management is a key part of ISO 62304.
- When considering software, you must assess potential risk factors related to:
Software failure.
Software reconfiguration and validation.
Data protection and cybersecurity.
Software safety classification:
- ISO 62304 identifies three classification categories for medical device software:
Class A:
- The software system cannot contribute to a hazardous situation; or
- The software system can contribute to a hazardous situation that does not result in unacceptable risk after consideration of risk control measures external to the software system.
Class B:
- The software system can contribute to a hazardous situation which results in unacceptable risk after consideration of risk control measures external to the software system and the resulting possible harm is non-serious injury.
Class C:
- The software system can contribute to a hazardous situation, which results in unacceptable risk after consideration of risk control measures external to the software system, and the resulting possible harm is death or serious injury.
FDA Alignment:
- If you’re developing medical device software for the U.S. market(e.g. Content of Premarket Submissions for
Device Software Functions), you’ll need to comply with corresponding FDA requirements.
A good rule of thumb is to work toward satisfying ISO 62304 requirements first, then apply necessary FDA requirements.
- The FDA classifies medical device software based on the level of concern:
Major:
- if a failure or latent flaw could directly result in death or serious injury to the patient or operator. - if a failure or latent flaw could indirectly result in death or serious injury of the patient or operator through incorrect or delayed information or through the action of a care provider.
Moderate:
- if a failure or latent design flaw could directly result in minor injury to the patient or operator.
- if a failure or latent flaw could indirectly result in minor injury to the patient or operator through incorrect or delayed information or through the action of a care provider
Minor:
- if failures or latent design flaws are unlikely to cause any injury to the patient or operator.
Verification and Testing:
- Compliance with ISO 62304 requires thorough verification and testing.
- Establish a testing protocol to demonstrate that design outputs meet design inputs.
- Ensure that your requirement specifications are verified during the testing process.
Remember, ISO 62304 ensures that medical device software is developed, validated, and maintained with safety and effectiveness in mind.