ISO 9001:2015

5 ways to ensure you are a valuable management representative

This article gives you five ways a management representative can demonstrate value to medical device top management teams.

poor management review meetings 5 ways to ensure you are a valuable management representative

Align quality objectives with the company first and the FDA second

A fast way to alienate yourself as a management representative is to begin every conversation with a quote from the FDA regulations. Instead, ensure that quality objectives align with the company’s overall goals. For example:

  • Is your company trying to launch a new product?
  • Is your company trying to reduce scrap?
  • Is your company trying to increase productivity?

Next, reword the company’s goals as quality objectives:

  • Complete the design verification and validation of our new product by August 15.
  • Reduce nonconforming products from the molding process by 50% this year.
  • Increase the number of production lots released each week from four to five lots of 1,000 units per lot.

Next, ensure that your quality objectives are achievable, measurable, and have clear timelines for completion. Quality objectives should not be stretch goals. If you have to initiate a corrective action because you didn’t achieve a quality objective, you just create more work for yourself and the company.

Teach people to focus on the process and not the procedure

The FDA and the ISO 13485 standard require procedures to be established. However, if you focus on the documentation of processes, your company will do stupid things faster. Instead, management representatives need to be able to teach people how to make processes more effective before the processes are documented. Lean manufacturing techniques are not limited to manufacturing. You can apply lean methods to administrative processes too. For example:

  • What information needs to be in a form?
  • What is the correct order of tasks for the process?
  • Is there duplicate or unnecessary information?

A management representative helps identify what to measure

In a management review meeting, the effectiveness of the quality system is reviewed, and improvements are identified. This does not mean the management representative needs to measure or create slides and graphs. As a management representative, you should ask the CEO the most important information they want from each department or member of top management. Once you know what information the CEO wants, please work with the other members of top management to find the most efficient way to get that information and graph it. Help the other managers identify who can generate the graph with the least effort (it’s seldom a manager), and help that person build the reporting of that information into their routine.

A management representative needs to share the spotlight

A management review meeting is only effective if the top management is engaged in the process. Therefore, the management representative should not create 100% of the slides or present 100% of the slides. Everyone should have a piece they are responsible for and can be proud of. When an individual or a team achieves a goal, we can celebrate the achievement in a management review. When an individual or team struggles, we can ask for help in a management review. If other members of top management are not engaged in preparation for a management review, they will not be enthusiastic about listening to the presentation either.

Have a positive attitude as a management representative

Everyone hates to listen to someone that has a negative attitude. As managers, we sometimes need to report bad news. However, we need to develop ideas to solve problems instead of just reporting gloom and doom. We also need to ensure we never miss an opportunity to report good news.

Management representatives should schedule reviews more often

This last section is a bonus (i.e., a sixth way to ensure you are a valuable management representative). Most management review procedures require a management review at least once per year. Unfortunately, there is little point in reviewing quality information from last February during this January. If changes to your quality system are planned or implemented, more frequent reviews are needed. Examples of changes that should prompt you to schedule an extra management review include mergers, new product launches, and employee turnover.

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How to reconcile the conflict between ISO 13485 and ISO 9001

This blog explains how to reconcile the conflict between ISO 13485 and ISO 9001, and discusses whether you should maintain dual certification.

how to reconcile diverging standards How to reconcile the conflict between ISO 13485 and ISO 9001

What is the conflict between ISO 13485 and ISO 9001?

The previous version of ISO 13485 was released in 2003. That standard was written following the same format and structure as the overall quality system standard at the time (i.e., ISO 9001:2000). In 2008, there was an update to the ISO 9001 standard, but the changes were minor, only clarified a few points, and the periodic review of ISO 13485 in 2008 determined there was not a need to update 13485 at that time. Unfortunately, the proposed structure of the ISO 9001 standard was radically different, and this forces companies with dual certification to reconcile the conflict between ISO 13485 and ISO 9001.

On December 1-5, 2014, the working group for the revision of ISO 13485 (i.e., TC 210 WG1), met at AAMI’s Standards week to review the comments and prepare a first Draft International Standard (DIS). We should have some updates on the progress of the DIS later in December, but hopefully, the news will not be delayed in publication until 2016. The following is a summary of the status before last that meeting.

Updated ISO 13485 and ISO 9001 Standards Being Released

In 2015, there will be a new international version of ISO 9001 released. This new version will have dramatic changes to the standard–including the addition of a new section on risk management and the adoption of the new High-Level Structure (HLS) changing from 9 sections to 11. The ISO 13485 standard is also anticipated to have a new international version released in 2015, but the ISO 13485 standard will maintain the current HLS with nine sections. The timing of the ISO 9001:2015 release and the ISO 13485:2015 release will likely be around the same time (Correction: the ISO 13485:2016 standard was released in February 2016). Both standards are expected to have a three-year transition period for implementation. The combination of the three-year transition and lessened requirements in the new version of ISO 9001 for a structured quality manual should allow most manufacturers to wait until the ISO 13485 release before they begin drafting a quality plan for compliance with the new standards. Some of my clients have already indicated that they may drop their ISO 9001 certification when it expires, instead of changing their quality system to comply with the ISO 9001:2015 requirements. However, my clients will not have the ability to allow their ISO 13485 certification to lapse. Will Health Canada be updating GD210 and continue to require ISO 13485 certification for medical device licensing? What should companies do?

Update on the reconciliation of ISO 13485:2016 and ISO 9001:2015 on May 29, 2020:

  • GD210 was never updated, and instead, it was replaced by MDSAP
  • ISO 13485:2016 certification, under the MDSAP program, is required for Canadian Medical Device Licensing
  • Many device companies have dropped the ISO 9001 certification.

Recommendations

From the experience of preparing for the ISO 13485:2016 and ISO 9001:2015 releases, I learned that obtaining draft versions of the standards before publication is invaluable. I was able to use the drafts to help prepare quality plans for the transition. Second, companies need to train their management teams and auditors on the differences between the current and the new standards to enable a gap analysis to be completed. Any manager that is responsible for a procedure required by the current version of a standard should receive training specific to the changes to understand how they will meet the requirements for documented information. Most companies will need to improve their risk management competency (which was updated again in December 2019). I recommend that companies begin drafting their quality plans and enter discussions with their certification body for quality system changes as early as possible. I also recommend that medical device companies maintain a quality manual structure that follows the ISO 13485:2016 standard rather than the ISO 9001:2015 standard. Following ISO 13485:2016 will help everyone locate information faster.

There is also specific text in the introduction of ISO 9001:2015 that states it is not the intent of the standard to imply the need to align your quality management system to the clause structure of the standard. Companies that maintain ISO 9001 certification should consider including cross-references between the two standards in their quality manual.

Historical Note

There are also European National (EN) versions of each standard (e.g., EN ISO 13485:2012). The EN versions are harmonized with the EU directives, but the content of the body or normative sections of the standards are identical. Historically, the differences were explained in Annex ZA, which was the last Annex in the EN version of the standard. In 2009 the harmonization annex for ISO 14971 (i.e., the medical device risk management standard) was split into three parts to match up with the three directives for medical devices (i.e., the MDD, AIMD, and IVDD). The new annexes (i.e., ZA, ZB, and ZC) were moved to the front of the EN version of the standard. The changes to ISO 14971 consisted of a correction and the change to Annex ZA. In 2012, there were new harmonization annexes created for ISO 13485 to follow the same format that was used for the EN ISO 14971 annexes. It is expected that these “zed” annexes will be released with a new EN version of the standard shortly after the international standard is published.

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