Quality Systems
ISO 9000 - EN 46000 - CE Mark?
It can be recognized in the worldwide development of regulatory
requirements for medical devices as well as for many other products that the introduction
of quality systems is more and more requested. It is no secret that a suitable quality
system, which is implemented in all relevant stages may be an important factor for
maintaining and improving product safety and performance.
For whatever reasons, a lot of manufacturers persistently believe that a
quality management system according to ISO 9001 is the key to CE-marking. This is simply
wrong. The ISO 9000 series of standards is the most popular way for the proper
organization of a quality management system. And EN 46003 in combination with the guidance
standards EN 724 or EN 50103 -which all include ISO 9001 - are harmonized European
standards. But harmonized standards are not the only way to demonstrate compliance with
the MDD (see next chapter).
The MDD requires that the manufacturer of medical devices keeps a
product-related, adequate and efficacious quality system. The application of the quality
system must ensure that the products conform to the provisions of the MDD. All the
elements, requirements and provisions adopted by the manufacturer for his quality system
must be documented in a systematic and orderly manner in the form of written policies and
procedures such as quality programs, quality plans, quality manuals and quality records.
The MDD gives more flexibility to the device manufacturer in organizing
his company according to size, social environment, culture of countries, and nature of the
devices than the ISO 9000 series of standards. On the other hand even ISO 9001 in
combination with the additional requirements of EN 46003, under consideration of EN 724 or
EN 50103, does not fully cover the requirements of the MDD.
.
Additional aspects to be covered by the quality management system
include:
- the technical documentation
- reference to the essential requirements according to Annex I of the MDD
- information about harmonized standards and medical device regulations
- risk analysis
- labeling and instruction
- different languages
- post-marketing surveillance
- reporting under the vigilance system
- retention of certain documents
It is the task of the Notified Body to understand the culture of the
manufacturer and to evaluate whether or not the quality management system meets the
minimum requirements of the MDD, and to give advice where deficiencies are detected.
In December 2000 the standards ISO 9001/2/3 have been replaced by ISO 9001:2000 with a
transitional period of three years. The almost identical EN 46001/2/3 and EN ISO 13485/88
are still based on the previous standards. The future ISO 13485/88 which is based on the
ISO 9001:2000 will be probably finished in the year 2002. This standard is expected to
have an independent content and may slightly differ from the requirements of the ISO
9001:2000.
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