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* 각 단계별 CAPA와 관련된 기록물을 작성해보는 워크샵이 포함되어 있습니다. 2일차 - 시정 및 예방조치(CAPA) 프로세스의 목적 This guide contains everything your team needs to kickstart and complete a successful ISO 13485 accreditation journey and to get your medical device to market before your competitors. Let’s dive in. What does ISO 13485 mean?ISO 13485 is an internationally agreed upon set of standard quality management system (QMS) requirements for any company involved in the design, production, installation, servicing and manufacturing of medical devices. ISO 13485 was first published in 1996 and has since been revised in 2003 and 2016. The current version, ISO 13485:2016, came into effect in March 2016. The aim of these requirements is to ensure that medical devices and services consistently meet customer expectations and relevant regulatory requirements. Why is ISO 13485 certification important?The International Organization for Standardization (or ISO) is an international non-governmental organization of industry leaders who share their knowledge and expertise to provide solutions for global challenges. ISO 13485 effectively covers ISO 9001 with a few additional requirements. Consumers and the life science supply chain have come to trust ISO, and they’ll often refuse to purchase medical device products from companies that lack ISO 13485 certification. To obtain CE marking—which indicates conformity with safety standards for products sold in the European Economic Area—medical device manufacturers must either obtain certification with a notified body or have a quality system in place. 5 key elements of ISO 13485ISO 13485 includes requirements for design and development, risk management, production and post-production processes for medical device companies. Below are five key requirements from ISO 13485 that are critical for companies seeking certification. 1. Quality Management System (QMS)To be certified to ISO 13485, a company must implement and maintain a quality management system that meets the requirements set out in the standard. This section talks about general quality management system requirements, as well as the documentation needed to implement and maintain an effective quality management system. According to ISO, organizations need to:
2. Management responsibilityThis section outlines the unique roles and responsibilities of management as it pertains to quality management system implementation and maintenance. In short, management should provide evidence of its commitment to the development and maintenance of the quality management system and its effectiveness. To do that:
3. Resource managementThis phase outlines the resources life sciences organizations should commit to implement the quality management system and maintain system effectiveness. It outlines the provisions needed to meet major regulatory and customer requirements. Resources outlined in this section include:
4. Product realizationIn a rush to get products into development as soon as possible, many organizations often overlook the planning phase. Section 7.1 requires that you appropriately plan your realization efforts. More specifically, it states that you should:
Finally, you have to organize all of that information in such a way that it can be easily accessed and understood. 5. Measurement, analysis, improvementAccording to ISO, "the organization shall plan and implement the monitor, measurement, analysis, and improvement processes" related to the quality management system and products. In this pursuit, organizations need to:
ISO 13485 clausesISO 13485 contains 8 clauses as part of its requirements. They are:
Let's briefly review each clause: 1. ScopeThe scope sets out the intended outcomes of the modern medical device quality management system, including the significance of the process approach and continuous improvement. 2. Normative ReferencesProvides details of the reference standards or publications relevant to the particular standard, including ISO 9001:2015. 3. Terms & DefinitionsDetails terms and definitions applicable to the standard, including definitions of Active Implantable Medical Device, Active Medical Device, Advisory Notice, Customer Complaint, Implantable Medical Device, Labeling, Medical Device andSterile Medical Device 4. General requirementsLays out the broad requirements for a properly documented ISO 13485 QMS, including:
5. Management responsibilityConcerns the role of ‘top management’: the group of people who direct and control your organization at the highest level. Customer and patient satisfaction and safety should be overseen and maintained by top management with:
6. Resource managementRequirements for how resources are managed and applied to meet your quality objectives, including personnel, equipment and training. 7. Product realizationMaps out requirements for the end-to-end medical device product realization process, including:
8. Measurement, analysis and improvementBreaks down how to monitor and analyze your processes with a view to continuous refinement and improvement. Core considerations include:
ISO 13485 vs. ISO 9001ISO 9001 lays the framework for a quality management system that can be applied no matter what industry you’re in or what your product, service, or company size is. If your company intends to manufacture medical devices, you’ll need to seek ISO 13485 certification. ISO 13485 has additional requirements not found in ISO 9001 that are specific to medical device manufacturers. Let’s take a look at the similarities and differences between ISO 9001 and ISO 13485, so you can get a better understanding of where you need to raise the bar on quality as a medical device manufacturer. Similarities between ISO 13485 and ISO 9001
Additional requirements for ISO 13485
9 tips to prepare for ISO 13485 certificationNow that we understand the key components and clauses of ISO 13485 and the differences with ISO 9001, it's time to look at preparation for certification. This process doesn't have to be complicated or overwhelming. Follow these nine tips to help you get your certification faster. Familiarize yourself with the guidelinesTake time to read the guidelines thoroughly and make sure you understand what’s required of you to become certified. You can view a preview and purchase the complete document on ISO 13485 from ISO’s website here. Meet CAPA standardsRefer to the FDA’s inspection guidelines, ISO 13485 8.5.3 (prevention), and ISO 13485 8.5.2 (correction) to ensure your company meets CAPA standards. Failure to meet CAPA standards is the number one trigger for FDA citations in the medical device industry. Implement complaint proceduresEstablish complaint procedures that follow the guidelines laid out in FDA CFR 820.198 and ISO 13485 8.2.2. A lack of standard procedures for handling complaints or failure to provide evidence that they followed procedures is the second most common reason organizations received a 483 observation. Include purchasing controlsCreate a written procedure for supply chain management to reduce the risk of noncompliance or supplier risks that could compromise your device quality. Develop MDR proceduresMDR (Medical Device Reporting) should include events and annual reports as detailed under FDA CFR 803.17 and ISO 13485:2016. 9 steps to prepare for ISO 13485 certification 16 Written procedures and systems are critical for compliance with record-keeping guidelines for MDR. Create a process to prepare for the auditReview the following areas every three months, so you aren’t putting internal audits off until the last minute:
Focus on upstream qualityManufacturers use the term “Upstream Quality (UQA)” to refer to a concept that relates to quality from the start. Focusing on UQA means putting effort into planning in the early stages to reduce quality issues later down the line Prepare to talk to the auditorAuditors don’t fail or pass you right there on the spot. Interactions are generally lowpressure and more conversational. Avoid giving any information you aren’t sure of and be prepared to have a productive conversation. Use an eQMS — not a paperbased systemElectronic quality management systems designed for life sciences companies — like Qualio — are built using the ISO 13485 framework for quality control, operational efficiency, regulatory compliance and the safe manufacture of medical devices. Unless you want to hire an in-house team of IT staff to run your eQMS, you need software that’s simple and easy to use. The perfect eQMS should provide essential functions such as document control, training, and the ability to expand to other areas — like CAPA — as you get closer to product approval. And as your company grows, your eQMS needs to grow with you. A robust eQMS should offer essential components for risk management, testing, and other procedures to streamline product submission. An International Trade Administration study found that 73% of medical device manufacturers have 20 or fewer employees, so utilizing a cloud-based eQMS is critical for effective collaboration among a distributed workforce. Benefits of ISO 13485:2016 accreditationWhile ISO 9001:2015 covers a broad range of businesses and industries, ISO 13485:2016 has a narrower focus on the medical device industry. By adhering to the guidelines set out in ISO 13485:2016, your organization can enjoy several benefits, including:
Use QMS software to get aheadImplementing a quality management system cannot cure an organization that isn't led by quality-driven management. Successfully shifting to a quality-driven culture requires full support from the leadership team and a commitment to change. Quality management software offers a diverse range of business benefits. When you implement a robust eQMS like Qualio for your life sciences company, you’re instantly one step closer to obtaining – and keeping – ISO 13485 certification. |