Implementing ISO 13485: Planning the Project
By Guest Blogger, Brigid Glass
Five reasons why ISO 13485 certification may take longer than you expect, as well as tips and planning advice to help avoid pitfalls, are provided.
Your company wants to achieve ISO 13485 certification. How are you going to get there? In a recent blog, I reviewed setting objectives for implementing an ISO 13485 certification project. Once you’re clear on those, then you’re ready to create your first quality plan. The basic elements of any strategy will be:
- Task breakdown (which I will cover in a separate blog)
- Resources (skills and hours available)
Timeframes and Trade-offs of ISO 13485 Certification Planning
The endpoint of planning for the certification project is the certification audit. The earlier you choose your registrar or Notified Body and book the audit, the more choice you will have regarding the date. This should be one of the earliest tasks in the task breakdown. To be able to do that, you need a timeframe as to when you will be ready for the certification audit. How long it takes to implement ISO 13485 and be ready for a certification audit depends upon your starting point and your available resources. If you have no QMS in place, it will take you longer than if you already have a strong, documented QMS that complies with 21 CFR Part 820.
It May Take More Work
If you already have ISO 9001:2008 certification, though you already have a structure in place, the upgrade to ISO 13485 is likely to take more work than you expect because:
- There are fewer procedures required by ISO 9001
- Most of your existing procedures will require revision
- Your employees will need training on the new procedures
- You will need time to generate records using new procedures
- You will need to complete a full quality system audit of the new procedures
Many companies also underestimate the required resources for ISO 13485 certification. If you have a knowledgeable consultant, and people available to write procedures, then ISO 13485 implementation will progress faster than an organization that has little expertise and little time available, so plan accordingly. Ideally, you will determine the length of time each task will take and decide on an endpoint for the project based on that information and available resources. This approach works well if you already have a well-documented, regulated QMS.
6 Months-Reasonable Timeframe?
Six months is my rule of thumb for the time needed to implement a quality system compliant with ISO 13485. If the implementation schedule is longer, organizational enthusiasm may wane. If the timeframe is shorter than six months, it’s difficult to complete all the required tasks. No matter how carefully you plan, you still need to write procedures, train personnel, and implement procedures, so there is adequate time to generate records. Six months is aggressive for most companies, but the objective of achieving certification in six months is reasonable.
You may find it interesting that in Rob Packard’s white paper on ISO 13485 implementation. He also recommends that you allocate six months of one Full-Time Equivalent (FTE). This is a reasonable starting point, but you may want to adjust your resource allocation up or down depending upon the level of experience within the implementation team. Experience has taught me that smaller organizations are more successful at building an effective quality system when effectiveness is achieved in reiterative steps (i.e., – revision 1, revision 2, etc.). This is also the basis of the Deming/Shewhart Plan-Do-Check-Act (PDCA) cycle (http://bit.ly/PDCAcycle). This is also what I meant in a recent blog (http://bit.ly/ImplementationObjectives), where I suggested that you should “throw perfectionism out the window.”
Your understanding of how the quality system links together will grow as you implement each process in your implementation plan. As knowledge grows, you may reconsider some of your procedures. Instead of delaying the certification process (i.e., – revision 1), you may want to implement improvements as a second revision to procedures after the Stage 2 certification audit (i.e., – revision 2). During your Stage 1 and Stage 2 certification audits, your understanding of how the standard is interpreted and audited will build. After you achieve the initial ISO 13485 certification, you will have a much greater understanding of how all the elements of the quality system need to work together. You will also understand what parts of your quality system are easy for an outsider to audit.
After the ISO 13485 Certification Audit
During the initial planning stage, you should also imagine your future state after the certification audit (http://bit.ly/Beginwiththeendinmind). Your boss may assume that once the audit has been and gone, then everything will settle back to “normal” again. The reality is that after you deal with any nonconformities, and you take off a few days like you promised your family, you will have a long list of improvement ideas waiting for you. You will also need to prepare for next year’s surveillance audit. Therefore, I recommend that you manage expectations by adding “Create Quality Plan #2” as the last step of your ISO 13485 certification plan. If your company wants to achieve ISO 13485 certification, you may be interested in our 6-part, “Road to Certification – The Series” (http://bit.ly/roadmapiso) beginning on August 28, 2013 (also available as a recording).
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