By Guest Blogger, Brigid Glass
In the best-planned project, with plentiful, skilled resources and diligent monitoring, things can still go awry. We need to be watchful for signs of our plans falling behind schedule, and develop contingency plans to prevent delays.
Walk Around the Mountains
Identify major obstacles early and develop a plan to deal with them. The major obstacles are usually the tasks that take the longest—such as process validation. Specifically, name these tasks in your pitch to management for resources before you start. This approach will ensure that everyone is focused on the biggest challenges.
If your plan to climb over those mountains is failing, work out a route around them. Maybe your R&D Manager can’t yet accept that there will now be design controls. In this case, an alternate path might be to leave design controls for last purposely. If you write a concise procedure and release it as your last procedure, then you have a built-in excuse for why you have very few records to demonstrate an implementation of design controls. You will still need at least one design project plan and training records to demonstrate that the process is implemented.
If this plan is successful, your auditor will write in the report that “design controls are implemented, but there are limited records to demonstrate implementation at this time.” If this plan is unsuccessful, you will need to provide additional design control records before you can be recommended for ISO certification—typically within 90 days.
Another approach is to initiate a CAPA and implement some of the tasks after the audit. For example, you have more suppliers than you can audit before certification. In this case, qualify all your suppliers, and use a risk-based approach to help you prioritize which suppliers need to be audited first. In your plan, identify that you will start by auditing the three highest-risk suppliers. Lower risk suppliers can be scheduled for audits after certification.
Keep a close eye on your project plan. One of the most critical factors for success is keeping the plan and progress against the plan in front of the key players and senior management. Do this in such a way that progress, or the lack of it, is very clearly visible. It’s a basic maxim of Quality that we act on what we measure.
ISO 13485 Implementation: If Your Project Falls Behind Schedule
If you find yourself lagging seriously behind in your project, the following steps will assist you in recovering sufficiently to still be able to attain certification.
- Enlist management support when you need it, especially if you need them to free up resources.
- Prioritize. Before the Stage 1 audit, ensure that those procedures which are required by ISO 13485 are released (there are 19). There’s always room for improvement, but leave some of it for the second revision, instead of delaying certification.
- Ensure that you have at least a few examples of all the required records. Your auditor will be unable to tick off his checklist if a record is absent. Make it easy for the auditor.
- If there is a sizeable gap that you won’t be able to close before certification (i.e., – you have a validation procedure, but validations have not been completed), write a CAPA outlining your action plan to address the gap. During the audit, act confidently when you are questioned about the gap. Many auditors will give you credit for identifying the problem yourself.
- Don’t panic. The worst the auditor can do is to identify a nonconformity you will have to address with a CAPA plan before you can be recommended for certification. At most, this will result in a delay of a few weeks.
- Throughout your certification preparations and during the certification audits, you will identify issues you may not have time to resolve before the certification process is complete. If you are planning to revise procedures and make other corrections, make sure you track these issues as CAPAs or with some other tool (e.g., – an action item list). You want to address each issue prior to the first surveillance audit (no more than 12 months from the date of the Stage 2 audit).
Best wishes for your project. Success is the result of good planning, good communication, and good monitoring.