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ISO 13485: 2003 – Medical devices – Quality management
systems requirements By
Brandon Kerkstra
Many companies are in the process
of upgrading their management systems to include Aerospace and Medical
certifications. Registration to these Standards is the key to
diversifying your client base.
Management Solutions Group, Inc.
has been in the forefront of this effort to provide our clients with
assistance in training and implementation. We hope that the following
information will be useful as you explore new opportunities in the
medical device industry.
This standard is based on ISO 9001:
2000 as are ISO / TS 16949: 2002 and AS 9100 B. Therefore companies
that have a strong ISO 9001 or TS 16949 system will find that they have
many of the required processes in place. They will still, however, need
to address the requirements specific to the medical device industry as
required in ISO 13485. We will highlight some of the additional and
specific requirements here.
Many of the new requirements relate
to design, manufacturing environmental control, regulatory requirements,
traceability and records required. This new management system also
includes additional procedures. Specific details are outlined below:
Requiring that Management ensures awareness of regulatory requirements
· There
are several references in the standard that explicitly call out
management’s responsibility.
Product
documentation requirements (Records)
· Product
files with specific required documentation
Requires
risk analysis and management during design and product development /
realization with associated records.
· A
FMEA including actions and records may be able to be used to implement
this requirement.
For
companies responsible for design; documented procedures, reviews,
verifications, validations and design transfer activities must be more
formally addressed.
· This
is slightly different but parallel to many of the requirements in TS
16949 and the associated APQP process. An effective & documented
product launch process will address many of the requirements. This is
also an appropriate place to ensure all requirements are covered.
Companies
must establish procedures in the manufacturing and work environment to
ensure product safety
·
For many medical products there are cleanliness,
contamination control, and environmental condition requirements (e.g.
clean room and sterilization). This also applies to installation and
services where applicable.
Sterilization records (Traceability and process validation) are required
when applicable.
There are
traceability requirements for implantable devices, and where required by
the standard and/or regulatory or customer, that must be addressed in
the procedures and the process.
Validation
of processes is required for sterile medical devices
In the
measurement, analysis, and improvement section of the standard there are
additional, slightly more prescriptive requirements within ISO 13485
that include:
· Procedures
for feedback of quality problems
· Monitoring
of product requirements
· Inspection
Personnel records
· Recording
of customer complaints
· Verification
of the effectiveness of corrective and preventive actions.
While there are specific
requirements that a company must address to become registered to ISO
13485, if the company has a strong and effective ISO 9001 quality
system, the additional implementation work is not tremendous.
Following formal registration /
certification, the ongoing effort and cost will be largely based on the
type of manufacturing and products. For companies further down the
supply chain (Tier 2 & 3), these requirements are typically minimal.
However having a good process to ensure understanding of customer
requirements is essential. Many customers will also assist with
specific regulatory requirements for the specific products. |