Quality System Requirements
A quality system is defined as the organizational structure, responsibilities, procedures,
processes, and resources needed to implement quality management. A closely related
term is Good Manufacturing Practices (see Chapter 126).
The international quality system standards for medical devices are ISO13485:1996 and
ISO13488:1996. ISO13485:1996 includes all of the elements of ISO9001:1994 plus a set
of minimum supplementary requirements for medical devices (Simmons, 2003).
ISO13488:1996 is the same as ISO13485:1994 without the design control requirements.
A standard alone ISO13485:2003 is being developed to become the new international
quality standard for medical devices.
Regulatory requirements for quality systems may cover the methods, facilities, and
controls used by the manufacturer in the design, manufacture, packaging, labelling, storage,
installation, and servicing, and post-market of medical devices. Therefore, the influences
of quality system requirements can extend throughout all phases in the life span of
medical devices. Applicable requirements depend upon the risk class of the device and on
the regulatory system of the country. Design control is normally not required for regulatory
scrutiny in medium- to low-risk class devices.
When applied to the manufacturing process, quality-system requirements impose strict
quality control assurance on every aspect of production. The result is a tightly controlled
manufacturing system, commonly known as Good Manufacturing Practices” (GMPs),
which reduces the chance of nonconforming products. This practice ensures consistency
in the quality of the products and provides the basis for a greater reliability on device
safety and performance. Elements of the quality system are periodically subject to audits,
management review, and corrective or preventive actions that will maintain the quality of
the product. The continuous monitoring and corrective action requirements are interrelated
to post-market surveillance described above.
The key advantage regarding quality systems is that they represent a preventive
approach to ensuring medical device quality versus the previous reactive approach by
inspection and rejection at the end of the manufacturing line. Prevention has been proven
to be more efficient and cost-effective in controlling processes and in maintaining medical
device quality.
Because the majority of medical devices are in the medium- to low-risk classes, their
compliance to regulations often depends upon the declarations of manufacturers, and
therefore the question of quality assurance naturally arises. This is why it is important for
manufacturers to conform with quality system standards. Conformity with quality-system
standards is subject to periodic audit by government or third party agencies.