| Quality
System Regulation 21 CFR Part 820 (CGMP)
Dating
back to October 1996, CFR Part 820 is the FDA's regulation defining
Current Good Manufacturing Practices for Medical Devices. Some
level of QSR compliance is required for all medical
device manufacturers
dealing with devices of risk classifications other than Class
I exempt. This includes both domestic as well as foreign manufacturers.
For
higher risk devices, the level of compliance is 100%, including
the need for well-documented management, design and manufacturing
controls. Other critical control processes include purchasing,
identification & traceability, acceptance activities, nonconforming
product, CAPA, labelling & packaging, handling-storage-distribution,
records, servicing and statistical techniques.
For domestic and foreign
manufacturers alike, the challenge is often to determine compliance
internally prior to the FDA inspection. When issues arise from
an FDA insepction, the challenge then becomes one of investigation,
root cause analysis and corrective/preventive action. In addition,
recently there has been an increased focus on
risk management within the design and development process
as well as throughout production and post-production phases.
RA/QA International
can be an invaluable resource in enabling you to achieve and
maintain QSR compliance, effectively and efficiently.
Solution:
On-site
training of your key staff members and internal auditors to
ensure thorough understanding of requirements of the QSR and
its harmonization with ISO 13485.
Documentation analysis, on-site gap analysis and facilitation of corrective actions
to ensure a streamlined yet effective quality management system to comply with
21 CFR Part 820. Note: Typically we are also requested to analyze current levels
of compliance to
ISO 13485:2003 and ISO 14971:2000 as well.
Internal auditing of your facility to ensure independence and ongoing compliance
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