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ISO 13485, ISO 9001, FDA 21 CFR 820 Quality Manual
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Food and Drug Administration (FDA)
has established and maintains Part 820 – Quality System
Regulation (QSR), also known as 21 CFR 820 or “Current
good manufacturing practice” (CGMP). This regulation
applies to medical device manufacturers or importers of
devices intended for “human use”. Compliance with this
regulation is expected from any organization that
manufactures or imports such devices into the USA. Among
other requirements, QSR prescribes establishment and
maintenance of a number of documented procedures. A
typical approach to establishing documentation systems
is by means of developing a suitable structure to
include quality policy, quality manual, procedures,
instructions, etc. This approach documents hierarchy and
relationship of documents within the system, allowing
users to easily locate information they need.
While QSR does not specifically require establishment of
a quality manual, Section 820.186 requires a
manufacturer to establish a quality system record that
includes “…or refer to the location of procedures and
the documentation of activities required by [the QSR].”
This definition very closely resembles requirements for
or intent of a quality manual for ISO 13485 compliant
quality management system. Since almost all medical
device manufacturers dealing with the US market comply
with both, FDA QSR and ISO 13485 standard, it is a
good idea to include requirements of both, QSR and ISO
13485 into your
integrated quality manual. This
set includes:
- ISO 13485 / ISO 9001 / QSR Integrated Quality Manual,
- 21 CFR 820 / ISO 13485 Checklist, and
- Quality Policy
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