Section 5:
Quality Systems
Regulation (QSR) and
Good Manufacturing
Practice (GMP) 1
Quality Systems Regulation (QSR)
2
Quality Systems Regulation (QSR) and
Good Manufacturing Practice (GMP)
Sets of checks and balances to assure safe and effective finished products
In QS Regulation, FDA has identified the essential elements that a quality
system shall embody for
design,
production, and
distribution
QS Regulation leaves some leeway to manufacturers as to how to
implement their specific system
The FDA monitors device problem data and inspects the operations and
records of device device developers and manufacturers to determine
compliance with the GMP requirements in the QS regulation
3
Contents of Quality Systems Regulation
Quality Systems (QS) Regulation contained in Title 21 Part 820 CFR
QS Regulation covers:
Quality Management and Organization
Device design
Buildings
Equipment
Purchase and handling of components
Production and process controls
Packaging and labeling control
Device evaluation
Distribution
Installation
Complaint handling
Servicing
Records
4
GMP Regulation and its Requirements
Good Manufacturing Practice (GMP) requirements set forth in QS
Regulation are promulgated under section 520 of the FD&C Act
GMP require that domestic or foreign manufacturers have a quality system
for the
- design - manufacture - packaging
- labeling - storage - installation - servicing
of medical devices intended for commercial distribution in the US
The GMP regulation requires
- that various specifications and controls be established for devices
- that devices be designed under a quality system to meet these
specifications
- that devices be manufactured under a quality system
- that finished devices meet these specifications
- that devices be correctly installed, checked, and serviced
- that quality data be analyzed to identify and correct quality problems
- that complaints be processed
Source: FDA, 2006 5
Types of Establishments subject to the GMP
Remanufacturers
Custom Device Manufacturers
Contract Manufacturers
Contract Testing Labs
Repackagers, Relabelers, and Specification Developers
Manufacturers of Accessories
Initial Distributors
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Example Element of GMP: Design Controls
Under Design Controls
The design needs to be reviewed throughout development to make sure all
requirements are being met.
Manufacturers must
- establish performance requirements for a device before production,
- ensure that device components are compatible with each other,
- select adequate packaging materials, and
- where appropriate do a risk analysis.
Source: FDA, 2006 7
Design Controls Example 1:
Defibrillator for Use in Hospitals and Ambulances
If a manufacturer were planning to design a new defibrillator for use in
hospitals and ambulances to restart the heart in emergencies, designers
would have to consider all aspects of use in both settings, not just in the
hospital:
Storage temperatures in the ambulance
Road shock and vibration
Two-way radio interference
Electrical noise generated by the siren
Others
Under Design Controls, the design needs to be reviewed throughout
development to make sure all requirements are being met
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Design Controls Example 2:
Glucose Monitor for Home Use
If a manufacturer were planning to design a glucose monitor for use by
diabetics to monitor their blood glucose at home, designers would have to
consider special circumstances that might arise, such as
use by diabetics who have diabetic eye disease,
use by other persons in the home and medical personnel
They would also have to consider the effects on the monitor from
- other electrical and electronic products in the home such as computers,
televisions, radios, telephones and other medical devices
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QSR Documentation Requirements
I. General (Non-device-specific)
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Quality System Report Documents
Used for many activities that are essential to operating a manufacturing
establishment; these documents are not specific to any given product
Contain standard operating procedures (SOPs) and standard quality
assurance procedures (QAPs)
Typical documents that can be contained in the general record:
Source: FDA, 2006 11
QSR Documentation Requirements
II. Device-specific
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Device Master Record (DMR)
Device master record (DMR) is the term used for all of the routine
documentation required to manufacture devices that will consistently
meet company requirements
Compilation of records containing the procedures and specifications for a
finished device:
shows and/or tells employees how to perform specific functions related to the
production of a device.
DMR Contents:
Device Specification
Specific documents (drawings, procedures, labels, data forms, etc., for a
specific product or family of products)
(Records for In Vitro Diagnostic Products)
Source: FDA, 2006 13
DMR: A Central Element of the Development and
Production Cycle
DMR: Device Master Record
DHF: Design History File
Source: FDA, 2006 14
Typical Location of Documents in a DMR
Source: FDA, 2006 15
Important Element of DMR: Device Specification
Sample specification excerpt: Performance Characteristics for Defibrillator
Source: FDA, 2006 16
Document and Change Control
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Document and Change Control
Oftentimes, changes or modifications are performed on a device or its
associated processes. Any such change needs to be documented in the
DMR (Change Control)
The burden is on the manufacturer to determine whether the
change/modification significantly changes the safety or effectiveness
profile of a device. In case of a significant change, a 510(k) or PMA
supplement must be submitted to FDA depending on the classification of
the device. Additional submissions are not required for marketing or
convenience changes where safety or effectiveness could not be
significantly affected.
A solid Change Control Process is an essential part of a manufacturers
Quality System !
Source: FDA, 2006 18
Medical Device Reporting
19
Complaint Handling and Medical Device Reporting (MDR)
GMP regulation gives clear advise of
how complaints should be handled ( Complaint Handling System)
how responsibilities should be assigned
how device failure analysis should be performed
what sources of information a manufacturer should use to detect device
problems
In addition to the GMP requirements, device manufacturers need to also
comply with the Medical Device Reporting (MDR) regulation (21 CFR 803)
All manufacturers of medical devices are required to notify FDA when they
become aware of a death or serious injury that may have been caused or
contributed to by one of their marketed devices and/or any malfunction of one of
their devices which, if it were to recur, would be likely to cause or contribute to a
death or serious injury.
Specific time limits for reporting exist (30 calendar days for any report of a
device-related death, serious injury, and malfunction)
Source: FDA, 2006 20
FDAs Quality System & Global ISO Standards
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Relationship between FDAs Quality System Regulation
and global ISO Standards
FDAs Quality System Regulation Part 820 is harmonized with ISO
13485:2003, which is based on ISO 9001:2000
ISO 13485 contains requirements for medical device manufacturers in
addition to the general quality system requirements found in ISO 9001.
FDA harmonized their QSR with the ISO standards, because many other
countries rely on ISO standards in regulating medical devices. Benefit:
Agencies can more readily rely on one anothers inspections and
exchange inspection reports.
Global Harmonization Taskforce actively pursues harmonization
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Useful Resource 1:
FDAs Medical Device Quality Systems Manual
Contents
Foreword ii
Preface iii
Abstract iv
Note to Manufacturers of Medical Devices v
1. The Quality System Regulation 1-1
2. Quality Systems 2-1
3. Design Controls 3-1
4. Process Validation 4-1
5. Personnel 5-1
6. Buildings and Environment 6-1
7. Equipment and Calibration 7-1
8. Device Master Record 8-1
9. Document and Change Control 9-1
10. Purchasing and Acceptance Activities 10-1
11. Labeling 11-1
12. Product Evaluation 12-1
13. Packaging 13-1
14. Storage, Distribution and Installation 14-1
15. Complaints 15-1
16. Servicing 16-1
17. Quality Systems Audits 17-1
18. Factory Inspections 18-1
Appendixes
Quality System Regulation 19-1
Application of the Medical Device GMPs to Computerized Devices
and Manufacturing Processes 19-21
Available for download at: http://www.fda.gov/cdrh/dsma/gmpman.html
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Useful Resource 2:
Global Harmonization Task Force (GHTF) website
www.ghtf.org
Source: GHTF, 2006 24
