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  • 1.  Supplier audit of EC Rep - MDR

    This message was posted by a user wishing to remain anonymous
    Posted 09-Jan-2020 10:22
    This message was posted by a user wishing to remain anonymous

    Hi,

    As the EC Rep is a crucial supplier to the manufacturer - my question is what is the best practice for supplier management of EC Rep?
    Does conducting an initial assessment and maintaining the mandate deemed sufficient? or a supplier audit is needed for the EC Rep? Any thoughts?

    Thanks in advance!


  • 2.  RE: Supplier audit of EC Rep - MDR

    Posted 09-Jan-2020 11:03

    The authorized rep is a supplier that provides a service to the manufacturer. The service is an outsourced process.

    Manage the supplier following ISO 13485:2016 Clause 7.4. Also, since this is an outsourced process, follow ISO 13485:2016 Clause 4.1.5. Be very careful with the quality agreement. Read the ISO 13485:2016 Handbook discussion. The mandate is the quality agreement, so you do not need a separate document. Be sure to clarify this point in the supplier file.

    Be careful with classifying suppliers as critical or crucial, since that can trigger NB unannounced audits. There are no standard definitions, so be sure to get your NB's definitions and classify your suppliers.

    ISO 13485:2016 never requires an audit, but in some cases it is useful. You will need to determine the value compared to expense. In my view you do not need an on-site audit. The authorized rep is just an office, and there will be nothing to see.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: Supplier audit of EC Rep - MDR

    Posted 09-Jan-2020 11:08
    While I don't disagree with Dan, I would say that the need for an in person visit/audit is a little dependent on the ability to have clear communication and understanding of the responsibilities and ongoing interactions you will have.  Sometimes - the language barrier can daunting, and there is no substitute for a meet and greet in person to truly obtain joint understanding.

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    Jackie Torfin
    Vice President, Global QA and Regulatory Compliance
    Maple Grove MN
    United States
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  • 4.  RE: Supplier audit of EC Rep - MDR

    Posted 10-Jan-2020 03:18
    I agree with the analysis and approach of Dan. The AR is an important party in the regulatory chain of EU compliance and suitable controls are needed.

    I would like to add that when the activities of the AR are considered to be outsourced processes, these processes should be taken into account in the internal audit program.​ How often and how the audits should be performed is part of the audit program; remote is a possible consideration and also a document review of the associated procedures of the QMS of the AR, etc.. This is why I am very cautious to identify these activities as outsourced processes. One can even extend this discussion to distributors who sell the medical devices on the market on behalf of the manufacturer and consider these activities as outsourced processes....

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    Peter Reijntjes
    Principal Consultant Regulatory & Quality Affairs
    Arnhem
    Netherlands
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  • 5.  RE: Supplier audit of EC Rep - MDR

    Posted 10-Jan-2020 07:57
    An AR should be considered like any other service providing supplier and within your QMS using a risk based approach.  It depends on whether your AR would need a visit or audit, because if your AR is internal to the company, maybe that is not needed.  However, if the AR is truly outsourced third party, it may minimally require a visit, or maybe a formal audit.  This really depends on how your supplier management is set up and all around the control that is needed for the AR.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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