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  • 1.  Medical Device_Change in number of employees_Impact on Quality system

    Posted 20-Nov-2018 10:58
    ​​Hi RA folks,

    My question is with reference to change to Quality system for a medical device manufacturer. One of the change that falls underneath the Quality system change umbrella is - Change in number of employees. Does this mean like large changes in the number of employees?  How to evaluate if a change in number of employees substantially impacts the quality system or not?

    Any guidance is highly appreciated!

    Thanks,
    Meenakshi

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    Meenakshi Verma
    Regulatory Affairs Professional - Medical Devices
    Ontario
    Canada
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  • 2.  RE: Medical Device_Change in number of employees_Impact on Quality system

    Posted 21-Nov-2018 02:41
    Where are you getting this reference to change in number of employees?  From the ISO 13485 Handbook or another source?  I am not aware of a specific requirement that number of employee needs to be considered as part of changes assessed in the quality management system.  With that said, I can understand the intent.  This goes back to Section 5.1(e) ensuring availability of resources and Section 6.1 to determine and provide the resources.  If there are insufficient resources, number of people, the activities in the quality system do not get done, delays are found, corrective actions not closed, documents not approved, etc.  It could also mean that if there are not the right employees in the proper position either through qualification or experience or just missing the right person.  I have seen companies where the management representative left and the quality system fell apart for 6 months until they hired another person and took months to get it back to normal.  But I would argue that it is not change in number of employees, but more generally change in employees as losing individuals in certain positions can be detrimental to the effectiveness of the quality system.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 3.  RE: Medical Device_Change in number of employees_Impact on Quality system

    Posted 21-Nov-2018 15:14

    Meenakshi

    Lacking specifics in your query I am making some assumptions, such as this matter has been raised by your Notified Body/ Registrar, since there is no specific requirement from the ISO 13485 : 2016 Standard or Handbook, as Richard has pointed out.

    Notified Bodies/ Registrars require to be notified of 'significant' / 'substantial' changes in an organization that may impact the Quality System, so in my opinion your query is related to the "employee count" that could affect, for example, the duration of an audit. Examples of such substantial changes in number of employees that require notification could include a new facility added to the Quality System (multi-site organization), relocation of an existing facility, considerable increase in product range, mergers or acquisitions, etc. So to directly address your query, yes, this would apply only when there are 'large changes in the number of employees'.

    See:

    https://lne-america.com/library/news/notification-of-changes-how-what-and-when-to-communicate-with-your-notified-body

    https://www.iaf.nu/upFiles/IAFMD5QMSEMSAuditDurationIssue311062015.pdf

    Hope this helps.



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    Homi Dalal RAC
    Regulatory Affairs Leader
    Christchurch
    New Zealand
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  • 4.  RE: Medical Device_Change in number of employees_Impact on Quality system

    Posted 22-Nov-2018 08:00
    As RIchard said, a change in the number of employees in itself does not affect the QS, but it can raise concerns regarding training/competency and adequate provision of physical resources.  However, the number of employees is one factor that Notified Bodies incorporate into their pricing schemes so while it is not necessarily a QS issue, the NB wants to know how many employees and the working structure (admin, professional, production, shifts, etc.) with regards to the fee they will extract from you.  Sorry to say, but this factor ranks right up there with number of devices and class that they are to certify.

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    James Bonds
    Director Regulatory Affairs
    Atlanta GA
    United States
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  • 5.  RE: Medical Device_Change in number of employees_Impact on Quality system

    Posted 22-Nov-2018 09:15
    ​Thank you so much for the guidance guys!!!! It was very helpful!

    Kind regards,
    Meenakshi

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    Meenakshi Verma
    Regulatory Affairs Professional - Medical Devices
    Ontario
    Canada
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