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Regulatory Compliance
 
Certain classes of medical imaging devices that are sold or manufactured in the USA must be auditable for full compliance to the FDA’s Code of Federal Regulations and, under certain conditions, ISO-9001 Quality Process (guidance). International sales or importation of such devices may require additional approvals & labels, such as a CE mark.

Note: compliance advice provided here is not legally
binding in any way; eMail Don Shave for details.


21CFR-820
 
TITLE 21--FOOD AND DRUGS
CHAPTER I--FDA, DHSS
SUBCHAPTER H--MEDICAL DEVICES
PART 820 QUALITY SYSTEM REGULATION     
 
Subpart A--General Provisions
   § 820.1 - Scope.
   § 820.3 - Definitions.
   § 820.5 - Quality system.
 
Subpart B--Quality System Requirements
   § 820.20 - Management responsibility.
   § 820.22 - Quality audit.
   § 820.25 - Personnel.
 
Subpart C--Design Controls
   § 820.30 - Design controls.
 
Subpart D--Document Controls
   § 820.40 - Document controls.
 
Subpart E--Purchasing Controls
   § 820.50 - Purchasing controls.
 
Subpart F--Identification and Traceability
   § 820.60 - Identification.
   § 820.65 - Traceability.
 
Subpart G--Production and Process Controls
   § 820.70 - Production and process controls.
   § 820.72 - Inspection, measuring, and test equipment.
   § 820.75 - Process validation.
 
Subpart H--Acceptance Activities
   § 820.80 - Receiving, in-process, and finished device acceptance.
   § 820.86 - Acceptance status.
 
Subpart I--Nonconforming Product
   § 820.90 - Nonconforming product.
 
Subpart J--Corrective and Preventive Action
 
Subpart K--Labeling and Packaging Control
   § 820.120 - Device labeling.
   § 820.130 - Device packaging.
 
Subpart L--Handling, Storage, Distribution, and Installation
   § 820.140 - Handling.
   § 820.150 - Storage.
   § 820.160 - Distribution.
   § 820.170 - Installation.
 
Subpart M--Records
   § 820.180 - General requirements.
   § 820.181 - Device master record.
   § 820.184 - Device history record.
   § 820.186 - Quality system record.
   § 820.198 - Complaint files.
 
Subpart N--Servicing
   § 820.200 - Servicing.
 
Subpart O--Statistical Techniques
   § 820.250 - Statistical techniques

FDA provides complete details of 21CFR Part 820 here, a video summary of the FDA's rules here and many, many other learning items here.
Other relevant compliance rules include exportation which may be viewed here, imports which are here, privacy of patient data which is here, software validation which is here, CAPA which is here, and critical data about submssions for a 510(k) here.

QMS
A complete Quality Management System (QMS) is required to both achieve and to maintain full compliance for medical imaging device manufacturers, and is by nature extremely broad in scope.

Such a QMS must be controlled and auditable to demonstrate compliance (download a printable copy of FDA's Quality System Inspectional Technique), as well as coverage from "womb to tomb" for product development -- here is a generalized example of a Quality Manual which would support a QMS.

A summary viewpoint of a QMS is described on a web page that I built several years ago:
http://my.execpc.com/~shaved/definitions.html#Regulatory
 
ISO compliance is the 1st step towards achieving compliance with European regulatory requirements; conformity to EEC rules must be assessed and a CE certificate applied before sales are allowed. Certification of the QMS by a conformity assessment body solves this.
ISO
9001 & ISO13485 are virtually identical:
 
http://en.wikipedia.org/wiki/ISO_13485

A comparison is made here of FDA vs ISO...
 
http://elsmar.com/Forums/showthread.php?t=6160

Conceptually, some kind of Enterprise Resource Planning (ERP) system is required...
 
http://en.wikipedia.org/wiki/Enterprise_resource_planning
List of ERP vendors
 
http://en.wikipedia.org/wiki/List_of_ERP_vendors
 Largest (30%) is SAP AG
    
http://en.wikipedia.org/wiki/SAP_AG
 followed by Oracle (10%)
   
http://en.wikipedia.org/wiki/Oracle_E-Business_Suite
                            Note: these are 2005 #s ...

Another view is the Product Lifecycle Management (PLM) site
 
http://www.product-lifecycle-management.com/

Another QMS tool supplier shares a page that summarizes some of the elements
 
http://www.sundaybizsys.com/

Control of QMS documents is possible using many tools...

> Rational ClearCase SCM (software configuration management) tool provides fully compliant document control
 
http://www-01.ibm.com/software/awdtools/clearcase/

> Editorial sales thread for the Perforce SCM... this is not cheap unless you can permit open-source access
 
http://www.perforce.com/perforce/understanding.html


 

Product Life Cycle

Six-Sigma

An industry-standard and interesting subject, this methodology provides proven approaches to the analysis of issues and proposes ways to improve methods, processes and systems.

Key information is shared below.


The Differences of DMAIC and DMADV

Quoted from "the best" 6-sigma web site:
www.isixsigma.com/library

While these commonly encounterd acronyms share the first three letters, that's where the similarities end... here are some descriptions.

DMAIC
Define
 
Measure
  
Analyze
   
Improve
    
Control
  • Define the project goals and customer (internal and external) deliverables
  • Measure the process to determine current performance
  • Analyze and determine the root cause(s) of the defects
  • Improve the process by eliminating defects
  • Control future process performance

When To Use DMAIC

The DMAIC methodology, instead of the DMADV methodology, should be used when a product or process is in existence at your company but is not meeting customer specification or is not performing adequately


DMADV
Define
 
Measure
  
Analyze
   
Design
    
Verify
  • Define the project goals and customer (internal and external) deliverables
  • Measure and determine customer needs and specifications
  • Analyze the process options to meet the customer needs
  • Design (detailed) the process to meet the customer needs
  • Verify the design performance and ability to meet customer needs

When To Use DMADV
  • A product or process is not in existence at your company and one needs to be developed
  • The existing product or process exists and has been optimized (using either DMAIC or not) and still doesn't meet the level of customer specification or six sigma level

  • "I thought it was DMAIC, but it turned out to be DMADV!"

    Pick yourself up, dust yourself off and re-craft your defined piece of the project so you can begin with a fresh look at the project and solutions.

    Occasionally a project is scoped as a DMAIC for incremental process improvement when it really required a DMADV methodology improvement. And it was a month into the project that you realized this!

    Don't be discouraged about the work you put into the DMAIC because

    1) it's happened to more businesses than just yours,

    2) you understand the process at a much greater detail than you did initially, and

    3) you were able to practice not just DMAIC skills but also DMADV!

Clik to examine a product life-cycle

Examining the life-cycle of a product shows that many elements are required, as shown in this process diagram (click to view in a separate window). Key attribute areas of the process diagram are described below.

Marketing FDA's CDRH requires approval of a 510(k) submission to sell products in the US; click here to view the process.

Design goes from a concept to managing devices in the installed base. The regualtory controls encompass clear, controlled, documented (DHF) and approved requirements for the design and deployment of a product, with special focus on the verification & validation (V&V) of the design. The FDA (as well as other regualatory agencies) has extensive interests in software validation, recently adopting ISO62304, a new ISO process that controls the Software Development Lifeclble process. Other related activities or terms (FMEAs, SPRs, CAPA, PQR/PSR, CSO, etc) can be examined using Google Search

Manufacturing occurs once design is complete and is also controlled by regualtory assesssment; key terms like GMP, supply chain, labeling, DHF or DMR (and others) are searchable using Google

Sales must occur or design and mfg are not much use -- brochures, user manuals, etc are also searchable.
Export rules (see above) are key

Service starts once a manufactured product leaves the factory... Look up these terms:
Installation
Maintenance, PM
Retirement
Customer complaints 

 

 

 

 

 

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