While I don't have specific recommendations for in-country representatives, I do have quality agreement recommendations that would apply in that case.
First, note that, except in one case, quality agreements are not a regulatory requirement. Except for the exception, I usually recommend against them. Instead describe the relationship in the "purchasing data" (to use the QSR term).
In ISO 13485:2016, 4.1.5 an outsourced process requires a supplier covered by 7.4 which includes evaluation, selection, and controls. Clause 4.1.5 says that the controls for an outsourced process must include a quality agreement. Unfortunately, the standard doesn't describe or define a quality agreement. However, the handbook does provide some additional information.
To set the stage, you have a process that your QMS requires, but you have decided that a party outside your QMS should provide the output of the process. (See ISO 13485:2016, clause 3.16.)
Your QMS provides process inputs and the outsourced process provides the outputs. The handbook says, "[ISO 13485:2016] requires that there is a written quality agreement that defines the responsibilities of each party."
My recommendation is to start with a SIPOC diagram to help define the inputs and outputs. In this case, your QMS is both the supplier and customer. However, you may decide to identify organizational elements instead of your whole company.
Once done, you know the "responsibilities of each party". They will be in the format "we provide xxx, you apply your process, and provide yyy to us". It is now easy to write the quality agreement. Do not make it complicated. In most cases, if you have more than one page, the quality agreement is too long. You could also incorporate the SIPOC diagram.
I recommend making the quality agreement an attachment to the purchase order or contract, not a separate document.
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Dan O'Leary
Swanzey NH
United States
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Original Message:
Sent: 18-Apr-2018 13:18
From: Maria Vrabie
Subject: MDSAP
Does anyone have recommendations for a resource to consult on quality agreements for in-country representatives? We have an MDSAP audit finding that requires us to improve our quality agreements for MDSAP jurisdictions but would also like these agreements to be applicable for all our global representatives.
Thanks!
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Maria V. Vrabie
Director of Regulatory Affairs
Hu-Friedy Mfg. Co., LLC
Chicago, IL
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