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We are a contract manufacturer of components (PCBA's). We do not manufacture finished medical devices. We are not registered with the FDA. We receive prints from our customers that detail the product and its requirements they are purchasing from us.
We take design and development as an exclusion. Sterilization and UDI are non-applicable items and we do not assemble PCBA's that are used in implantable devices.
Section 7.5.6 states that "The organization shall validate any processes for production and service provision where the resulting output cannot be or is not verified by subsequent monitoring or measurement and as a consequence, deficiencies become apparent only after the product is in use or the service has been delivered". "The organization shall document procedures for the validation of the application of computer software used in production and service provision".
As a contract manufacture, assembling printed circuit boards with material purchased off the shelf, where the outputs are fully verified through our approval process, we do not assemble or sell the finished medical device (sell completed PCBA's to medical device companies that install our PCBA's into the finished medical device), are we required by the ISO 13485:2016 standard to validate computer software such as Microsoft Office, CCAM and software that came preinstalled in equipment used for assembling PCBA's?
We do not write macros or modify software used in the computers/production equipment and the software is controlled by the manufacturer. The software loaded into the equipment used in production is preloaded into the machine by the manufacturer, created specifically for that piece of equipment and controlled by the manufacturer (cannot be modified).
To what extent would we need to validate software to satisfy the ISO 13485:2016 seeing exceptions cannot be taken? Again, our outputs are fully verified through our approval process (visual inspection, AOI inspection, etc.).
Any input regarding computer software validation would be appreciated.
We take design and development as an exclusion. Sterilization and UDI are non-applicable items and we do not assemble PCBA's that are used in implantable devices.
Section 7.5.6 states that "The organization shall validate any processes for production and service provision where the resulting output cannot be or is not verified by subsequent monitoring or measurement and as a consequence, deficiencies become apparent only after the product is in use or the service has been delivered". "The organization shall document procedures for the validation of the application of computer software used in production and service provision".
As a contract manufacture, assembling printed circuit boards with material purchased off the shelf, where the outputs are fully verified through our approval process, we do not assemble or sell the finished medical device (sell completed PCBA's to medical device companies that install our PCBA's into the finished medical device), are we required by the ISO 13485:2016 standard to validate computer software such as Microsoft Office, CCAM and software that came preinstalled in equipment used for assembling PCBA's?
We do not write macros or modify software used in the computers/production equipment and the software is controlled by the manufacturer. The software loaded into the equipment used in production is preloaded into the machine by the manufacturer, created specifically for that piece of equipment and controlled by the manufacturer (cannot be modified).
To what extent would we need to validate software to satisfy the ISO 13485:2016 seeing exceptions cannot be taken? Again, our outputs are fully verified through our approval process (visual inspection, AOI inspection, etc.).
Any input regarding computer software validation would be appreciated.