Just so we can be sure there’s no confusion over what we’re discussing, let’s go with the definition of a QMS most easily found on the internet which is:
“A quality management system is a collection of business processes focused on consistently meeting customer requirements and enhancing their satisfaction.”
Of course, that is a very general and generic explanation of what a quality management system is, and it is used for a variety of products in a variety of industries. If we narrow the definition down to just the medical device industry, the reason behind a QMS becomes:
“Quality System requirements for medical devices have been internationally recognized as a way to assure product safety and efficacy.”
As we are well aware, when developing a medical device, the goals are to successfully get to market first, but also to ensure quality devices and components ultimately reach patients. This is why the QMS standard for medical devices is so stringent. These devices could very well end up inside a human body, helping them live a better life while dealing with a medical condition.
Given the important nature of medical devices, there are at least two sets of industry standards that require a QMS to be in place. They are:
- ISO 13485 standards
- US FDA 21 CFR 820 regulations
The FDA provides a lot of guidance for manufacturers to determine their own QMS and how extensive it can be, but let’s look a little closer at what they require.
The FDA’s 7 subsystems of a QMS for medical devices
The Food and Drug Administration requires that a medical device manufacturer have a quality management system. Many of the requirements are based on the complexity of the device, the complexity of the manufacturing process and even the size of the manufacturer itself. Regardless, a manufacturer needs to have a QMS which incorporates the following sub-systems:
- Management controls
- Design controls
- Production and process controls
- Corrective and preventative actions
- Material controls
- Records, documents, and change controls
- Facilities and equipment controls
The FDA’s requirements for each of the subsystems are explained on their website, but each subsystem comes into play as the device is designed, developed, and then constructed. Management, undertaking regular audits, should oversee each subsystem to ensure they are operating properly and effectively.