Regulatory Open Forum

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  • 1.  Risk Management File

    Posted 29-Mar-2017 15:56
    Hello Everyone,

    We are a <g class="gr_ gr_26 gr-alert gr_spell gr_run_anim ContextualSpelling ins-del multiReplace" id="26" data-gr-id="26">relabeler</g>/repackager and I was wondering if we have to keep a risk file/plan for items we relabel/repackage. We do not have any product specifications (i.e. line drawings) from the OEM's, but I wanted to make sure we are in compliance. We do manufacture some items and we do have risk mitigation and risk management files in place, but I cannot locate any guidance for <g class="gr_ gr_251 gr-alert gr_spell gr_run_anim ContextualSpelling ins-del multiReplace" id="251" data-gr-id="251">relabelers</g>/repackagers. Thank you for all of your time!

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    Lauren Combs Viker
    Quality Assurance Manager
    Grover Beach, CA 93433
    USA
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  • 2.  RE: Risk Management File

    Posted 31-Mar-2017 10:27
    I don't know FDA opinion, but if you are certified to ISO 13485 I can tell you that based on my past experience a risk file would be expected. In the past, when we had a certified office that basically a distribution center only - but their NB required them to have risk management files. This file should not attempt to quantify the risk of the entire product, but the risks due to the processes you actually do. So think the risks and controls related to packaging in your case.

    g-

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    Ginger Glaser RAC
    Vice-President, Quality and Regulatory Affairs
    Maplewood MN
    United States
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  • 3.  RE: Risk Management File

    Posted 01-Apr-2017 11:18

    Risk is a word used to mean many things. I infer you mean medical device risk of the type that could result in harm to the patient or user. This excludes risk such as supplier risk, regulatory risk, etc.

     

    As a relabeler/repackager, your company is a manufacturer and therefore subject to QSR; see the definition in 820.3(o). However, these activities are probably not covered by design control in 820.30, which is the source of “risk analysis”. You should exclude 820.30 for your relabeler/repackager activities as allowed by 820.1(a)(1), “If a manufacturer engages in only some operations subject to the requirements in this part, and not in others, that manufacturer need only comply with those requirements applicable to the operations in which it is engaged.”

     

    As a company that manufacturers a finished device, then QSR probably applies; some devices are GMP-exempt. If it does apply, design controls may not apply; some devices are exempt from design control. However, if design control applies, then you will need “risk analysis” under 820.30(g). The common methodology uses ISO 14971:2007.



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    Dan O'Leary
    Swanzey NH
    United States
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