Q
Quality Queen
As a contract manufacturer, one of our clients has requested that we be FDA registered. Does registration require compliance to the QSR?
In a word, yes. If you are registering, you manufacture a medical device. If you are manufacturing a medical device for import into the US, you must meet the requirements of the QSR.Quality Queen said:As a contract manufacturer, one of our clients has requested that we be FDA registered. Does registration require compliance to the QSR?
Quality Queen said:Contract manufacturers are not required to include a products list, or get approval on the products (that is the responsibility of their customer) and it is only when you apply for a 510(k) that you would be subject to an FDA inspection.
I suspected that this was the case since there is no fee for the establishment registration and the form was so simple.
I can echo this in a small way. When I was with a high tech contract manufacturer (machining), we held an FDA certificate for ten years. The FDA never showed up on our doorstep in ten years even though the local office was only fifteen minutes away. We only sold to other FDA-registered organizations who designed the products we made for them (bone screws, dental instruments, housings for electronics.) We also made stuff for aerospace. All our aerospace component contracts from FAA-certified manufacturers stipulated the FAA could inspect us at any time although we were not certified by the FAA. We never had a visit from the FAA, either, and they were also only 15 minutes away.ISO GUY said:Also, if you have an FDA registration number you are fair game for them to inspect. Now depending on what you are doing will dicate how often they will be knocking on your door.
Just to let you know we have thre seperate registration numbers 1 building has seen the FDA shop up 3 times within a 1 1/2 year period, the other two have never been visited.
Quality Queen said:
Thanks for your help everyone! It looks like we're going to try to implement some changes to our quality system to encorporate the QSR. Thankfully, we're already registered to ISO13485 so we've got a good start on it. No doubt I'll be searching posts for guidance with it since my first attempt with FDA!
One more question: If the FDA decides to inspect us, what kind of costs should we expect? (i.e. do we have to pay for the inspection, travel costs for the inspector, etc. as we do with ISO certification?)