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  • 1.  MDSAP Auditing Organization List

    Posted 22-May-2018 15:58
    The list of MDSAP AOs is available at https://www.fda.gov/downloads/MedicalDevices/InternationalPrograms/MDSAPPilot/UCM429978.pdf

    The table has a column entitled "Authorized to Conduct MDSAP Audits" that has entries of Yes/No.

    The column to the right has the title "Recognition" that has entries of Yes/No.

    How does an AO achieve a Yes in the Recognition column? In particular, if an AO has a Yes in the authorized column and a No in recognition column, does this impact the validity of any MDSAP certificate the AO issues?

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    Dan O'Leary
    Swanzey NH
    United States
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  • 2.  RE: MDSAP Auditing Organization List

    Posted 22-May-2018 16:06
    AOs pursue recognition. Authorization is the first step (which enables them to perform audits). Recognition is the next steps, and involves some actions, including a number of audits. In principle there's no problem if an Ao is authorized but still not recognized.

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    Marcelo Antunes
    Regulatory Strategy Consultant
    São Paulo
    Brazil
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  • 3.  RE: MDSAP Auditing Organization List

    Posted 23-May-2018 06:44
    That was confusing to me as well because they have all this documentation on the FDA website, but there is no information for description of this form with the two columns that mean something.  And could mean something significant for manufacturers selecting an AO.  Marcelo is correct there are stages that an AO must go through, but they do not use the same terminology in their own procedures like P0005 or P0016.

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    Richard Vincins RAC
    Vice President Regulatory Affairs
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  • 4.  RE: MDSAP Auditing Organization List

    Posted 23-May-2018 08:58
    Hi Dan,

    As Marcelo states, in principle there is no problem with a certificate that is issued by an authorized AO before they are recognized. Understand the processes for MDSAP are formally issued through IMDRF and one in particular you may want to view is the recently updated document: "Requirements for Medical Device Auditing Organizations for Regulatory Authority Recognition" (link below). Keep in mind that each AO will need to have the requisite number of witnessed audits and auditors competence as part of recognition. If your audit is witnessed, you will have a representative from at least one regulator, but they cannot participate in the audit, they are there to watch the auditor and review the AO performance.
    http://www.imdrf.org/docs/imdrf/final/technical/imdrf-tech-160324-requirements-auditing-orar.pdf

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    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE ASQ, MBA
    Becker MN
    United States
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  • 5.  RE: MDSAP Auditing Organization List

    Posted 23-May-2018 11:08
    Mark,

    Thank you. This helps clear up my confusion.

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    Dan O'Leary
    Swanzey NH
    United States
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  • 6.  RE: MDSAP Auditing Organization List

    Posted 27-May-2018 16:34
    Dan & All,

    To confuse things a little more, make sure you clients pick the appropriate AO for their needs (do they need EU NB, Brazil, other countries) as that may limit who they can go to (of the already limited list) or hopefully they are already using the proper registrar/certifier for their needs.  The reason I add this proviso is the list that ANVISA has for MDSAP AO's is not identical to the one on the FDA website.  On the ANVISA site right above the list of Audit Bodies (yes, a different term but equivalent meaning to Audit OIrganization) it says "...list of Audit Bodies evaluated and approved through the MDSAP Program that have already been recognized by Anvisa and its recognition resolution."

    Best,


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    Leonard (Leo) Eisner, P.E.
    The "IEC 60601 Guy"
    Principal Consultant, Eisner Safety Consultants
    Phone: (503) 244-6151
    Mobile: (503) 709-8328
    Email: Leo@EisnerSafety.com
    Website: www.EisnerSafety.com
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