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Regulatory requirements in Design Inputs - Audit Deficiency

  • 1.  Regulatory requirements in Design Inputs - Audit Deficiency

    This message was posted by a user wishing to remain anonymous
    Posted 18-Oct-2019 09:22
    This message was posted by a user wishing to remain anonymous

    ​Hi ,

    We received a deficiency from a mock audit and MDSAP stage 2 on not including clear regulatory  requirements in the Product requirement specification . Its not possible to actually state all the regulations into the PRS ? Is there an easier way , if we could reference a regulatory matrix defining the requirements of the MDSAP countries  and EU , would that be enough ? Its difficult to keep this up to date with the changing regulations and go through the change process each time a new country is added or a new requirement / standard becomes effective..

    Can you suggest how are you managing this requirement ?

    Thanks,



  • 2.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 02:08
    There are a few ways this could be done, but you are absolutely correct this can be difficult to keep up to date based on your product type and markets you are introducing product.  Depending on the product type or markets, having a regulatory requirements section in the Product Requirements Specifications (PRS) could be kept fairly high level, just identifying the markets for introduction.  This could also be Wave 1, Wave 2, Wave 3 approach as well.  To coincide with this, there should be a requirement either to identify standards and detailed regulatory requirements in the design documentation or have a list of standards in the PRS.  Yes, this can be difficult and unruly to manage depending on product type.  Another option is to create a Regulatory Plan or regulatory strategy type of document referenced from the PRS.  In the PRS it would say reference Regulatory Plan XXX, then a separate document could be managed listing this information in much more detail.  This regulatory plan or strategy could then be updated and managed more easily when this information is updated and changed, instead of having to update the PRS each time a new market is added or a standard is changed.  Your idea of having a regulatory matrix also works quite well and is something I have used before to meet the regulatory requirements for all the countries.  Again, this regulatory matrix could be referenced from the main PRS, so you can manage and update more easily.  The important aspect to remember is during an audit situation is making sure everything is clear, understandable, linked, and referenced so information flow is continuous.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 3.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 11:22
    Although I do agree with Richard and his suggestion, I am concerned with another part of your question. Why is it difficult to add regulatory requirements to product specs? Is it because of the difficulty in the change request/document control part? 
    • If you do a root cause analysis and it always points to this, you may have a systemic problem with an inflexible document change order. Whenever we've gone to a new country, the PRS is always in the list of being updated and it literally takes less than a day to implement and approve through the change request system (from opening up the document, creating a redline, submitting to doc control, approval, then release). The same amount of time as me writing up a regulatory letter/matrix.
    • If the root cause is the regulatory requirements include revision, like in standards required to comply, then remove those! Just say you'll comply with current. If they ask about how you do this, show your design change plan or SOP that shows what you do whenever a new standard revision comes out.
    • If the root cause analysis is that you have people who take too long to sign, you'll need to bring that up to management and have those people designate others to be able to sign for them. If you have an eQMS, then no one has an excuse of "I'm traveling" especially if it's a browser-based eQMS. Heck, when I had a manual system, no one had any excuse either because we accept approvals over the phone and via email (just document that out).
    Anyhow just thought I'd bring that up. I'd had engineers that come from other companies think this way and it turns out it's really not that hard to change the product specs. They ended up liking this route because it also counted as a change in the PRS so they don't have to do another review of it annually. The review is done at the same time of any change.

    ------------------------------
    Clarisa Tate
    VP, Product Development and Regulatory Affairs
    Medical Devices Professional, RA/QA/Engineering
    Bay Area, CA
    USA
    ------------------------------



  • 4.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 12:47
    I think it depends on what you consider "regulatory requirements."  Very broadly interpreted, I don't think they belong in a product specification document at all.  As an example, the product does not require a cleared 510(k), any of the forms (e.g., Truth and Accuracy, Class III Certification) included in a 510(k), nor demonstration of SE to a predicate.

    More narrowly interpreted, I think in most cases, there should be no difference between "regulatory requirements" and what is required to demonstrate that the device is safe and effective for its intended use.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 13:40
    Yes, Julie, a regulatory strategy or plan doesn't belong in an engineering product specifications requirements document. So, in this situation it's either a list of required testing according to known standards or harmonized standards is what an auditor usually looks for. It depends on the product.

    ------------------------------
    Clarisa Tate
    VP, Product Development and Regulatory Affairs
    Medical Devices Professional, RA/QA/Engineering
    Bay Area, CA
    USA
    ------------------------------



  • 6.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 14:22
    IMO, all testing is a design (V&V) requirement, not a regulatory requirement.  Regulators require you to have documentation of your testing; they don't require testing.  I'm not sure all regulators have the good sense to know this, nor how many regrettably think otherwise, but no white flag from me on this one.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 7.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 21-Oct-2019 17:33
    Maybe this will help: Some standards specify criteria you have to meet. Criteria is part of product specs. Therefore, some auditors (European ones primarily) look for these standards in the product specs to ensure you are complying with the "state of the art."

    I consider V&V as a regulatory requirement. As in we're supposed to do it and in some cases, our criteria or spec has to be a certain range (i.e. dealing with devices that generate frequency, emit a particular wavelength, etc.). It's all part of Design Controls (US) or Product Realization Process (EU) which is part of the regulations.

    Hope that helps clarify what I meant by it.

    ------------------------------
    Clarisa Tate
    VP, Product Development and Regulatory Affairs
    Medical Devices Professional, RA/QA/Engineering
    Bay Area, CA
    USA
    ------------------------------



  • 8.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 04:00

    I think this discussion may be confusing Product Requirements (Design Inputs) with Product Specifications (Design Outputs).  Not helped by the (typically US based) terminology "Product Requirements Specification"

    The Input Requirements certainly need to address regulatory requirements in some way  - as per the earlier posts, this can be at varying levels of detail. 

    The Output specifications are usually things like drawings and Bills of Materials.

    Arthur



    ------------------------------
    Arthur Brandwood PhD FRAPS
    Director and Principal Consultant
    Brandwood CKC
    Sydney, Australia
    Arthur.brandwood@brandwoodckc.com
    ------------------------------



  • 9.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 14:23
    Edited by Julie Omohundro 22-Oct-2019 14:24
    I don't think we should be doing anything because any third party says we are supposed to do it, but because we figured out for ourselves that we are supposed to do it assure the safety and effectiveness of OUR product for its intended use, and we don't want to put products on the market that are not safe and effective.  THAT's the reason V&V is required, and the reason it's a design requirement, rather than a regulatory requirement. Regulators should NOT require V&V.  They should require documentation of V&V, with which they may then take issue, and then the onus is on us to justify what we did.

    To be clear, I realize easier said than done, and if we need to cave for the regulators, we cave.  But I don't think we start with what somebody else says we are supposed to do.  And I don't want to point to the regulations as the reason we do V&V.

    And now I'm going to stop, because I realize I'm out of step with many in industry and many regulators and many NBs (which are not regulators) on this, but I don't care.  No white flag.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 10.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 15:09
    Hi Julie,

    It's not a third party requirement. It's a regulatory requirement for some types of products to meet some standards.

    Let me give you this as an example: Product Code GEX. It shows certain recognized standards (ANSI or IEC) that FDA expects the company to use/comply with either the test methods used therein and/or the criteria specified in there. As an engineer, I can make my own test, I can justify why my test works, but I still have to explain to the FDA in the submission or during an inspection why I did what I did instead of just following the standard. For CE Marking, I've had to explain why I didn't follow a set criteria in a particular standard at some point. I've had to justify why it won't work or doesn't apply to my product. My product requirements say I still have to meet the standard, but my product spec will specify that I have to meet everything except X.  Everyone documents it all differently, but this is what I've seen normally happen.

    Most of the time, it's easier, and makes more sense to comply with the recognized standard that the industry uses because it supports the basic safety/performance tests related to that type of device (i.e. device that uses electrical energy to function). Meaning it's easy to compare pass/failure on the regulator side because the test method is standardized. Other specific product/feature-related criteria testing, of course, is done with its own test protocol that won't apply to other products.

    I'm not looking for a white flag :). Just explaining that regulatory requirements definition can be broad and usually matches good engineering practices, what we would test for or do anyway to prove that the device is safe and performing as intended.

    ------------------------------
    Clarisa Tate
    VP, Product Development and Regulatory Affairs
    Medical Devices Professional, RA/QA/Engineering
    Bay Area, CA
    USA
    ------------------------------



  • 11.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 19:18
    LOL, I guess I was thinking "third party," because usually one party in this conversation is me, and the other is the design engineer.  FDA is nowhere to be found.

    Certainly, if everyone agrees it makes more sense to conform to the recognized standard, that's fine.  More broadly, if you are the design engineer, it's your call as to what test you do and how you do it.  But your life will go better if you can convince me it's an appropriate test (of which I'm sure there is more than one, and it does not have to be the best test ever, just appropriate). If you can to convince me, then what FDA expects is not something I want to hear. That's something I will tell you, and if you are good with having to justify something different than what FDA expects, I'm not going to stand in your way.  No promises about executive management, though. :)

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 12.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 09:22

    Two short notes from my end as a small contribution to this thread : 

    Note 1 : ISO 13485:2016, § 7.3.3 (b) states that Design and Development shall include applicable regulatory requirements and standards. 

    Note 2 : indeed, the different terminologies used do not necessarily help clarify the issue. I prefer to use as much as possible the terminology from international standards and/or FDA regulations and guidance documents rather than proprietary or legacy terms such as "User Requirements Specifications" or "Product Requirements Specifications". Personally, I already have an issue with the term "Specification", which for me means something that is specified with sufficient detail for someone "skilled-in-the art" to understand it. In this approach, the term "Specification" may be used in relation to Inputs as well as to Outputs. E.g., SRS = Software Requirements Specification means that the software inputs are documented with sufficient detail for the programmer to unambiguously perform his programming tasks. And, e.g., Design Output Specifications contain a detailed enough description for production staff to unambiguously understand what product they have to build (and for the sake of clarity I would always use the term "Design Output Specifications" rather than "Design Specifications").

     

    With kindest regards,



    ------------------------------
    Ary Saaman
    Director, Regulatory Affairs
    Lausanne
    Switzerland
    ------------------------------



  • 13.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 22-Oct-2019 14:32
    Agree about the terminology.  It's a mess.  And yes, as Arthur notes, almost certainly US-based.

    As for 7.3.3., yet another good reason to resist replacing the QSR with the standard, IMO. 

    PS. Is there a certain irony here, with the standard calling for inclusion of regulatory requirements, while the regulation does not?

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 14.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 23-Oct-2019 08:33
    Edited by Ary Saaman 23-Oct-2019 09:43

    I think it is more a matter of history than of irony … . 

    The Quality System Regulation was published in October 1996 and does not contain verbiage explicitly requesting that "regulatory requirements" be part of Design Input. Nor did EN 46001:1996 contain such verbiage.

    ISO 13485:2003 § 7.3.2 states that Design and Development Inputs shall include applicable statutory and regulatory requirements.
    And as said previously, ISO 13485:2016 § 7.3.3 requires that Design and Development Inputs shall include applicable regulatory requirements and standards.

    All of this probably reflects the increased reliance on the use of International Standards (as published or as adopted/adapted as Consensus Standards by FDA or Harmonized Standards by the EU) for demonstrating safety and performance of medical devices to the regulators. Also FDA's ASCA (pilot) program fits within this scheme of increased reliance on International Standards. 

    On a side note : the Quality System Regulation does have a definition of "specification" as per 820.3(y) : Specification means any requirement with which a product, process, service, or other activity must conform. 

    Enough for today … with kindest regards,



    ------------------------------
    Ary Saaman
    Director, Regulatory Affairs
    Lausanne
    Switzerland
    ------------------------------



  • 15.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 23-Oct-2019 09:45
    Thanks, Ary. 

    I agree, it is likely that it reflected an increased use of harmonized standards, coupled with a denial of the fact that conformance to harmonized standards are rarely required by regulators.  They are convenient for various parties, not the least of which are auditors who would otherwise have no clue as to how to determine compliance to the regulation and even less understand a justification (see Clarisa's experience).  They are also more convenient for medical device companies, for similar reasons.

    Irony stands alone. It may be a result of history, but if it's ironic, it's ironic.  What I find most ironic about harmonization at this point, is that the EU seems to be trying to mimic FDA ("equivalence") and the FDA seems to be trying to mimic the EU (standards), while the 510(k) doesn't seemed to have served FDA well (eg, purge at the top, the Bleeding Edge), while the EU has felt the need to throw out its entire regulation and start over.  Reminds me of the schoolkid who copies someone else's answers on a test, and gets caught because the other kid didn't know either, so they were the only two in the class with identical (wrong) answers.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 16.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 24-Oct-2019 10:44
    You guys are hitting one of my pet topics here, so feel free to just skip, but I can't help saying my piece.

    This is EXACTLY what happens when a bunch of regulators and QA/RA professionals try to integrate systems engineering and robust design practices into standards in regulations. You get a bunch of the principles sort of right and then jumble the jargon to confuse even those who do understand the concepts. Then you promulgate it such that everyone thinks it is a "regulatory requirement" and not an actual attempt to help design good practices.

    As even a semi-trained systems engineer can tell you, there are a variety of "Voices" [aka User Requirements] including Voice of the Customer, Voice of the Business and what my original business called "Voice of the Application." [others call this different names and sometimes split it differently]

    Voice of Customer is exactly what it says - what is it the customer wants/requires that you are designing the product to deliver. Usually not everything a customer might possibly want, but what is within the realm of the product you can deliver.

    Voice of the Application - this consists of things you must do but you can't control. Follow laws that apply. Deal with conditions in the use environment in which the product will be used etc. Generally true "regulations" and laws sit in this bucket.

    Voice of the Business - this is a huge box and often broken down into things like Voice of Manufacturing, Voice of Service, Voice of Regulatory etc. In its purest form, standards should sit here - they are voluntary requirements that can make some aspect of the business, including the regulatory process, easier.

    Thus, "must have a cleared 510(k)" is a legal or VoA requirement, while "must meet ISO 10993" is a business requirement. However, I know a lot of MedTech companies actually treat standards as either their own bucket, or roll it into VoA, simply because they are so pervasive across our industry, and while you CAN legally do things other ways, most often the hassle isn't worth it.

    In robust design, all of these "Voices" get translated into requirements. Usually there are tools that also help you weight these requirements, so that when conflicts arise, designers know which ones take precedence. The requirements then get deconstructed to lower level requirements, and in complex products, assigned to one or more specific subsystems. The requirements around the relationships between the subsystems are captured in interface documents that then feed lower level requirements. Additional lower level requirements may also enter as design decisions are made [think - hey we decided to ETO sterilize, rather than some other type of sterilization, so now all the ETO standards become requirements]

    In the end, all these requirements drive a specification (functional, dimensional etc), manufacturing process requirement etc. Then one verifies that all these specifications meet the requirements, across the various levels. However, a good systems engineer knows that "verification does NOT equal test" - yes, sometimes statistical testing is the best way to verify a requirement is met, but other times simple inspection by a trained person is sufficient. Still other times that verification may be inspections of ongoing materials.

    And finally, you validate that the top level requirements and/or the "voices" were met. One could argue a top level VoA requirement of "must have cleared 510(k)" is validated by the actual clearance.

    All this is well established best practices in systems engineering, as are many other robust practices like how to actually write a good requirement and capture the "voices" appropriately. I am positive this best practice is what the original design controls intended to capture. But since obviously few of those authors were trained in the practices, and even those had to take "public comment" along the way from people who had no understanding of it, we instead end up with a bunch of differing and sometimes conflicting terminology, that leads an entire generation of med tech employees to think of these a "quality systems" or "regulatory requirements," rather than robust design practices; which in turn leads to regression to the mean (or worse) in many engineering departments and does as much to hurt the implementation of robust design practices as it helps. And finally leads auditors who clearly are not trained in robust design practices to ask nonsensical questions such as the finding which started this thread....

    OK, done ranting....

    ------------------------------
    Ginger Glaser RAC
    Chief Technology Officer
    MN
    ------------------------------



  • 17.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 24-Oct-2019 10:55
    Thank you for that excellent rant, Ginger!

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 18.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 24-Oct-2019 22:59
    Edited by Julie Omohundro 24-Oct-2019 23:03

    "...such that everyone thinks it is a "regulatory requirement" and not an actual attempt to help design good practices."

    I'm sorry to say I think that, in most cases, this is because it is not an attempt to help design good practices, but to impose practices that are convenient, cheap, easy, and, above all, self-serving for a number of players, including the regulators.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 19.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 25-Oct-2019 08:50
    Love it Ginger!

    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
    ------------------------------



  • 20.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    This message was posted by a user wishing to remain anonymous
    Posted 07-Nov-2019 13:43
    This message was posted by a user wishing to remain anonymous

    Joining the party a little late.

    I was a design engineer before moving to regulatory, so I have been involved in this question from both sides. I have always included a regulatory section (high level requirements) in my design requirements (inputs) document; also markets for release. These two items and the data needed to support compliance in the identified markets are critical to know in the early stages of product design. If I don't know the types of data required to support the safety and efficacy of my device in various markets, I may have to redesign my device or conduct additional testing that could have been addressed at an earlier juncture.

    Not knowing you require implantation biocompatibility testing for a non-implanted device until you receive an AI from FDA during 510(k) review will result in your submission being withdrawn (implantation testing takes longer than the 180 days allowed for AI response.) And that is just one example. I have seen companies throw money away on repeated testing because they were unaware of the regulatory requirements and had to repeat numerous tests for compliance. Knowing the requirements early in the design process would have allowed for better planning and execution of testing that could have been conducted once to satisfy all regulatory requirements.

    Many devices have specific consensus standards and those requirements were always identified (reference to the standard and section) in my Design requirements (inputs) document. Knowing the applicable standards and related guidance from regulatory agencies is important to know early on. It is definitely best practices and I have seem many companies conducting remediation to address just such gaps.


  • 21.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 08-Nov-2019 04:44
    Excellent points Anonymous-Design-Engineer-turned-Regulator!

    And just to stir the pot one last time:

    Anyone who thinks ISO 13485 isn't about meeting regulations hasn't read the title.  As I say to my students when teaching this stuff, "It's all in those last three little words"  ISO 9001 is about the customer. For ISO 13485, there's an additional customer - the regulator.

    ------------------------------
    Arthur Brandwood PhD FRAPS
    Director and Principal Consultant
    Brandwood CKC
    Sydney, Australia
    Arthur.brandwood@brandwoodckc.com
    ------------------------------



  • 22.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 11-Nov-2019 18:15
    Edited by Julie Omohundro 11-Nov-2019 19:35
    All this tells you is that whoever wrote the ISO standard intended to establish requirements "for regulatory purposes." Presumably they didn't intend to establish requirements "for quality purposes," or they would have put that in the title, too.

    I don't know if the standard is about"meeting" requirements, but if it is, then it's all about compliance, not quality. (Nor is it about regulatory, either.)  I think they should have just called it "Compliance Management Systems and been done with it.

    If the standard was actually written for the (real?) customer and the regulator (fake customer?), I'd be interested to know what language was included to address the needs of the regulator that would not have been included if it were intended to address only the needs of the "real' customer.  If we compared ISO 9001 to ISO 13485, could we assume that anything included in the latter but not the former was included to meet the needs of "the regulator"?  And that, except for the regulator, the "real" medical device customers would be equally well served if the medical device companies conformed to ISO 9001?

    (I'm thinking the "real" customers are those who buy standards and hire QMS auditors and "fake" customers are those who do not.  When it comes to the fundamental quality principle, many in the industry are inclined to translate "customer" into "whoever pays for it" instead of "whoever uses it.")

    Which regulator is "the regulator"?  Or is the standard based on an assumption that, when it comes regulators, one size fits all?



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 23.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 12-Nov-2019 10:47
    Hi all
    Unfortunately, this is a growing trend in NB and MDSAP audits for an observation.  I have a colleague who just got a non-conformance for inadequate detailed country-by-country regulatory requirements in design inputs.  I think as we move toward #MDRisStillComing and we see the pressures MDR is going to put on the interpretation of "regulatory requirements" in ISO 13485 beyond those already developing under MDSAP, everyone is going to have to get comfortable with demonstrating how and where detailed regulatory requirements were captured as design inputs.  

    While I 100% agree that you should not make changes to your QMS because of an auditors opinion, some auditors have flat out said "do this or you will get a nonconformity"  ​Now more than ever, companies must choose what conversations and battles they want to have with auditors.  As the amount of regulations increase, so too do the endless number of options and interpretations.

    ------------------------------
    Michelle Lott RAC
    Principal & Founder
    michelle@leanraqa.com
    ------------------------------



  • 24.  RE: Regulatory requirements in Design Inputs - Audit Deficiency

    Posted 12-Nov-2019 10:57
    Totally agree Michelle!

    I have a huge honking regulatory assessment for clients, according to a written SOP on what should be in the assessment (minimum regulatory requirements for each market or region).  This is written and updated per product/product family as needed, and integrates with Management Review of new regulations/regulatory requirements.

    And it honestly cannot cover every stinking requirement in each country.   Absurb auditors!

    (But apparently writing detailed standards and auditing to them provides job security, so these will never go away- a large cottage. Industry).

    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
    ------------------------------