Presentation on theme: "TRANSITIONING FROM ISO 9001:2008 TO ISO 13485:2003 GOING AFTER MEDICAL DEVICE BUSINESS ASQ Las Vegas section 705 December 16, 2009 Presented by Michelle."— Presentation transcript:
TRANSITIONING FROM ISO 9001:2008 TO ISO 13485:2003 GOING AFTER MEDICAL DEVICE BUSINESS ASQ Las Vegas section 705 December 16, 2009 Presented by Michelle M. Johnston, RAC Advanced Quality System Solutions
The Medical Device Sector 2 $100B industry More recession-proof than other sectors but hit in 2008/2009 Ageing US population (baby boomers) Growth in the following segments: Cardiac Orthopedic (record level of private equity) Neurotechnology (electronic devices interact with the nervous system) 15k medical device companies >400k jobs
What the Heck is EN ISO 13485:2003? 3 Quality system standard intended for medical device industry Format based on ISO 9001, process approach Intended to promote harmonization in the global market Regulators dont recognize ISO 9001
What the Heck is EN ISO 13485:2003? 4 Emphasis on effectiveness of quality management system as opposed to improvement More controls than ISO 9001 Higher the risk of the device=more controls However, if you dont manufacture the finished device, not all requirements are applicable
What the Heck is EN ISO 13485:2003? 5 It is the medical device manufacturers responsibility to define and implement the requirements. As applicable, they will pass along the requirements to their suppliers, usually in the form of a purchase spec or Supplier Agreement
From A Manufacturers Perspective 6 Assurance that their suppliers have adequate controls in place Selecting a supplier who is registered to ISO can mean reduced monitoring by the manufacturer From a regulatory perspective, much greater scrutiny on how manufacturers evaluate and monitor their suppliers. High visibility recalls where problems originated at the supplier.
What are the Differences? 7 Lets examine some of the important differences between ISO 9001 and ISO 13485
What are the Differences? 8 The biggest difference is the intent of the standard. In the regulatory world, customer satisfaction and continuous improvement are superseded by the safety and effectiveness of medical devices.
1.2 Application 9 Can only exclude section 7.3, Design and Developmenthowever, other regulations may preclude this Other requirements in section 7 may be non-applicable based on the nature of the medical device (sterilization, implants) or activities performed by the organization Exclusions/non-applications to be justified
4.1 General Requirements 10 The organization shall establish, document, implement and maintain a quality management system and maintain its effectiveness in accordance with the requirements of this International Standard.
4.2 Documentation Requirements 11 The quality management system documentation shall include: Any other documentation requirements specified by national or regional regulations.
4.2 Documentation Requirements 12 There is a requirement or a particular type of document, commonly referred to as a Device Master Record. The organization shall establish and maintain a file containing documents defining for each type / model of medical device product specifications and quality system requirements (process and quality assurance) for: complete manufacturing, and installation and servicing, if appropriate
4.2 Documentation Requirements 13 The Quality Manual must outline the structure of the documentation used in the quality management system. Typically 4-tier structure: Quality manual SOPs Work instructions Forms/records
4.2.4 Records 14 The importance of records in the medical device industry cannot be overstated. Universal rule: If it isnt documented, it wasnt done. Documentation, documentation, documentation Stringent rules regarding recording of information Blue or black ink only No crossouts, write overs Most organizations have a Good Documentation Practices procedure and intensive training.
4.2.4 Records 15 Retention requirements based on the lifetime of the device Retention equivalent to lifetime of device or not less than 2 years from date of release for distribution Other regulations have more stringent requirements Most medical device manufacturers do not often destroy records Records specific to the medical device industry Device History Record (traveler, work order) Adverse event reports to regulatory agencies
5Management Responsibility 16 Management must maintain the effectiveness of the quality management system Independence and authority of those who perform tasks affecting quality Management rep promotes customer and regulatory requirements throughout the organization Management review must include new or revised regulatory requirements
6Resource Management 17 Determine and provide resources to implement the QMS and maintain its effectiveness And to meet customer and regulatory requirements May need a documented procedure to satisfy other regulatory requirements
6.3 Infrastructure 18 Preventive Maintenance Documented requirements for maintenance Records maintained
6.4 Work Environment 19 Can be very critical, dependent on the device Controls must be established if the environment could adversely impact the medical device (concern for devices intended to be sterilized) Cleanroom or environmentally controlled manufacturing Gowning Documented procedure for environmental controls and monitoring No food and drink
6.4 Work Environment 20 Controls for used (returned) product to prevent contamination Personnel who work under special environmental conditions must be trained
6.4 Work Environment 21 Can also include ESD controls Designated ESD work areas Wrist/ankle straps Daily testing or continuous monitoring Handling and storage of ESD sensitive devices Records
7.1 Planning of Product Realization 22 Specific reference to ISO 14971Medical Devices Risk Management Medical device manufacturers would expect suppliers to have a documented pFMEA in place.
7.3 Design and Development 23 A documented procedure is required. More records are required Design inputs must include safety and performance requirements Design inputs must be approved Records of design outputs are required Independent person required at design review Clinical evaluation as part of design validation
7.4 Purchasing 24 Documented procedure required FDA requirement: Where appropriate, purchasing documents will include an agreement that the supplier will notify the manufacturer of any changes to the product or service so that the manufacturer may assess the impact of the change on the finished device Unauthorized changes can have a significant impact and result in recalls by the manufacturer Evaluation of suppliers is typically risk-based
7.5 Production and Service Provision 25 The availability of documented procedures, requirements, work instructions, and reference materials and reference measurement procedures as necessary The implementation of defined operations for labelling and packaging Record that shows manufacturing history including quantity. Record shall be reviewed and approved.
7.5 Production and Service Provision 26 Cleanliness of product and contamination control A documented procedure is required Intended for devices sold sterile or Devices to be sterilized by the end user Installation and servicing procedures and controls Specific requirements for sterile and implantable devices
7.5 Production and Service Provision 27 Procedure for the validation of computer software Records of these activities Procedure for ID and traceabilitymore stringent controls or implantable devices Procedure to distinguished returned product from conforming product Status of productmust be known at all times throughout the product realization process Procedure for the preservation of product conformity handling, storage
7.5 Production and Service Provision 28 Procedure for devices with a limited shelf life or special storage conditions Storage conditions will be controlled and recorded. Procedure required for calibration activities
8.2 Monitoring and Measurement 29 Specific requirements for customer complaints as opposed to customer satisfaction Some types of complaints must be reported to regulatory agencies
8.2.4 Monitoring and Measurement of Product 30 Documented procedure for inspection activities Specific requirements for active implantable and implantable devices
8.3 Control of Nonconforming Product 31 UAI disposition only if regulatory requirements continue to be met Must record person who authorizes UAI Work instructions for rework activities Determine and document any adverse impact of rework on the device
8.5.1 General (Improvement) 32 Customer complaints Documented procedures for product recalls Must record reason if a complaint is not followed by CAPA Procedure for notification of complaints to regulatory agencies
8.5.2 CAPA 33 Record the results of any investigation Determine the effectiveness of the corrective action taken Same for preventive action
Industry Trade Shows 34 MD&M showsannually East coast West coast Midwest
Questions? 35 Thanks for your time. Michelle Johnston Advanced Quality System Solutions