Best practice on documents turning into records, test and validation plan

P

Peterseb

Hi,
thanks for a wonderful source of information! Sorry for writing a very long post.

I work with a medical device company that has a paper-based quality management system that will complies with the requirements of ISO 13485 (and most likely 21 CFR 820 later).

I would like to know what best practices are in terms of handling documents that turn into records, more specifically, test plans or validation plans that first is a document/specification and when filled in turns to records. This is how we do today:

A Document control SOP dictates templates, review and approvals, doc ID, etc. Documents are generally given a number based on initials and date, for example jdo20091228-1 (SOPs and drawings have their own numbering schemes). A test or validation plan would fall into this category. A test engineer would issue the document with a number like above, specify requirements to be tested, acceptance criteria, test method, environment, equipment etc. On the last pages, he/she would create tables or similar appropriate for filling in test results.

The document would be reviewed, approved, signed and dated.

Records are handled according to a Control of records SOP which dictates templates, doc ID etc. All record types are identified in a record master list, for example Change requests, non-conformities, receiving inspection records, management review records, design review records. Each record type has its own acronym, such as CR for Change Request and NC for Non-Conformity. Each record type also has its own ledger, from which they are given a unique identifier based on the acronym, such as CR-002, or NC-095.

When testing, the approved document jdo20091228-1 would be copied, and the test results filled in. When completed a number would be taken from the test engineer from the Verification record ledger, VR-005. The number would be written on the top right corner of the record (which still contains the header from being a document with issued by, reviewed by, approved by fields).

The completed verification record would be filed in a binder with the other verification records.

Please give me feedback the approach above is appropriate? If there are other easier/better ways? What is the typical set up for this that would be recognized by auditors?

Thanks in advance,
Peter
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
Welcome to the Cove Peter! :bigwave: I am sorry this question didn't get a response earlier. :(

Does anyone have unput for this question? If so, maybe we should contact him personally with it, lest he think we're ignoring him.
 
D

DrM2u

Well, here's my :2cents::

Do not forget to change the procedure(s) for document and record control if and when you change your methods/process.

I have seen a couple of practices where there are electronic blank templates for the documents/forms used for product/process testing & validation. The completed documents (now records) are then stored in an electronic Product Master File along with part prints, control plans, PPAP or First Article records, change records, etc. If the records are hard copies then they can be scanned and stored electronically for easier retrieval and back-up. I am not sure if this is the best practice but it seemed to work just fine where I observed it.

Hope this helps. Good luck!
 

sagai

Quite Involved in Discussions
Hi Peter,
based on these information it is looks like okay for me. It is really good to have a corresponding SOPs on board.
Only one thing I miss based on your description, how the traceability aspect of the executed test cases back to system and user level requirement handled, but it may be solved also.
If it is paper based, than it is, when there is not a huge operation behind, may not be necessary to have electronic document system, it depends on your organisation needs and cost sensitivity.
Regards
Sz.
 
P

Peterseb

Thanks for you reply and for confirming that I am on the right way. The traceability would be taken care of in a master validation plan (for process validation) and a requirement traceability matrix/verification summary table. For the verification, there would be column with the test specification document number, when the test specification has been used, it is given its record number and listed in Design output column. I am thinking that this way, the same test spec may be copied let's say three times to be used on three test objects (or for re-verification purposes in conjunction with changes in the future). Does it still make sense?
 
P

Peterseb

It is in the change between a blank template and completed record where it is somewhat strange to me. First you treat the document as a specification, with approval according to 4.2.3 of ISO 13485. Then I guess the paper hard copy turns into the record and should be handles according to 4.2.4? Does this also mean that you have a document/specification header on the unused test specification, and when it turns to a record you should stamp it or something with your records header? (Or just write a record number on it).
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
Thanks for you reply and for confirming that I am on the right way. The traceability would be taken care of in a master validation plan (for process validation) and a requirement traceability matrix/verification summary table. For the verification, there would be column with the test specification document number, when the test specification has been used, it is given its record number and listed in Design output column. I am thinking that this way, the same test spec may be copied let's say three times to be used on three test objects (or for re-verification purposes in conjunction with changes in the future). Does it still make sense?
Can you attach an example? I think I understand your description, and it seems good, but I would like to see it in an applied sense to feel sure.
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
It is in the change between a blank template and completed record where it is somewhat strange to me. First you treat the document as a specification, with approval according to 4.2.3 of ISO 13485. Then I guess the paper hard copy turns into the record and should be handles according to 4.2.4? Does this also mean that you have a document/specification header on the unused test specification, and when it turns to a record you should stamp it or something with your records header? (Or just write a record number on it).
You could either stamp or legibly write a records number on it, or whatever else is done to identify what it belongs to. It could be kept hard copy - the FDA wants to keep handwritten records intact - I do not recall if others have said scanned versions of hand written records would be acceptable.
 
A

alex.Kennedy

Hi Peterseb

I see you are a medical device (MD) manufacturer; are you now considering marketing in the USA? If you are you should really sit down with 21 CFR Part 820 and study it. The requirements of 820 are mandatory and you can expect to be audited against them. My initial feelings are your system at present is not defined enough to survive an FDA audit.


You are talking about changing documents between being templates and being results documents. This procedure is acceptable for production records (detailed in 820), but is not acceptable for validation.


In the validation process you must start with the User requirements specification (URS) then work through IQ/OQ/PQ to verify that all the requirements detailed in the URS have been satisfied.


You have in fact two validation expections:
1) That your MD meets its design specification as derived from the URS.
2) That all the processes used in producing/testing/inspecting your MD have been validated to confirm that the product will be consistently produced to the correct standard.

Your Validation Plan should justify, scope and allocate (between the IQ/OQ/PQ) the degree of testing that will be performed during the MA validation procedure and also your manufacturing procedures.
The individual protocols must carry;
1) A rationale for each test/inspection.
2) A test method.
3) A detailed acceptance criteria.
4) The actual test result. (no ticks allowed)

Most of this is detailed in the 820. If you store this data electronically then you must verify (document) whether 21 CFR Part 11 applies.


Alex
 
Last edited by a moderator:
P

Peterseb

Dear Jennifer,
I am planning to do just that, write by hand on what was a document.

FDA will accept scanned documents with signature as far as I know.
I will post an example in a couple of days. Thanks in advance.
Peter
 
Thread starter Similar threads Forum Replies Date
bio_subbu NBOG Publishes revised best practice guidance documents (Nov 2014) EU Medical Device Regulations 1
bio_subbu NBOG?s Best Practice guidance documents to implement the directive 2007/47/EC EU Medical Device Regulations 0
qualprod Best practice to ensure inputting of data in production Lean in Manufacturing and Service Industries 19
DuncanGibbons Best practice for identifying "items" of parts for DFMEA analysis AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 2
R Bill of Materials for a complex product - Industry best practice ISO 13485:2016 - Medical Device Quality Management Systems 2
M Best Practice for setting tolerances on a Drawing Inspection, Prints (Drawings), Testing, Sampling and Related Topics 14
W Audit Protocol Manual which describes best practice Auditing Standards General Auditing Discussions 1
D Number of Internal Auditors Best Practice Quality Manager and Management Related Issues 18
alimary15 Industry best practice about Post-Market Surveillance and Risk Analysis ISO 14971 - Medical Device Risk Management 6
K Is this Best Practice Auditing? General Auditing Discussions 3
I Best Practice in Process Validation ISO 13485:2016 - Medical Device Quality Management Systems 2
Q Medical Device Manufacturing Process Monitoring Best Practice ISO 13485:2016 - Medical Device Quality Management Systems 2
I RoHS vs Non-RoHS - Best Practice for preventing Cross-Contamination? RoHS, REACH, ELV, IMDS and Restricted Substances 1
E SPC Corrective Actions - Best Practice with Process Statistical Analysis Tools, Techniques and SPC 2
V What is best practice to track Quality Teams Effectiveness & Efficiency. Quality Manager and Management Related Issues 4
V The best practice to maintain & link Design and Process FMEAs FMEA and Control Plans 8
A Instructions for Use - Best Practice to meet all International Regulations ISO 13485:2016 - Medical Device Quality Management Systems 6
B Corrective Action Numbering and Indexing Best Practice Nonconformance and Corrective Action 2
B SSOW - Safe Systems of Work - Good examples for best practice needed Occupational Health & Safety Management Standards 9
A Best Practice for Documenting Design Reviews 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 13
J Best Practice - Customer Specific Requirements Customer and Company Specific Requirements 6
R Innovations and Best Practice in Software Testing Software Quality Assurance 5
A Best Practice in Printing Industry - New project to improve the printing process Customer and Company Specific Requirements 7
C What is the best practice to label small tools (small pins) which cannot be scribed? General Measurement Device and Calibration Topics 5
C User Acceptance Testing best practice - conducted on production server or test server Software Quality Assurance 0
Q Seeking Best Practice of Parts Segregation Manufacturing and Related Processes 1
D Section 10: Improvement Best example from auditor perspective ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 6
M Best ISO9001:2015 Auditing Company in Chicagoland? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 21
T What is the best way to record an improvement activity or Kaizen? Lean in Manufacturing and Service Industries 8
R Changing our DMS/ECM to a Wiki. Advice on best practices and changes of paradigm? Document Control Systems, Procedures, Forms and Templates 0
T Management review - how do you do your meeting? to get best response and involvement? and outputs Quality Manager and Management Related Issues 20
K Best automation presentation software Manufacturing and Related Processes 0
K Best Internal Auditor Training Internal Auditing 18
M When is the Best Time to Initiate PFMEA? ISO 13485:2016 - Medical Device Quality Management Systems 11
S Local (country) registration of medical devices - Who does it in best case? Other Medical Device Regulations World-Wide 2
A Class 2b medical device - best pathway to obtain CE mark? (2022, MDR 2017/745) CE Marking (Conformité Européene) / CB Scheme 2
J Best Practices for Choosing In-process Inspection Dimensions & SPC Dimensions Inspection, Prints (Drawings), Testing, Sampling and Related Topics 2
G Seeking reference guides/ documentation /tips on verification best practices Other Medical Device Related Standards 6
D Ultra low freezer thermometers, best practices? ISO 13485:2016 - Medical Device Quality Management Systems 8
S Question: Best alternatives to audits for ensuring compliance Quality Tools, Improvement and Analysis 5
PQ Systems Best Practices In Gage Management Using GAGEpack Software 0
Q Best off presentation of process flows Process Maps, Process Mapping and Turtle Diagrams 16
Q Best country to import medical devices into Europe Other Medical Device and Orthopedic Related Topics 0
M Best accreditation body for AS9100D Lead facility auditor? AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 6
P DFMEA - Machinery Design Best Practices FMEA and Control Plans 0
G Best way to calc uncert for measuring microscope without duplicating repeatability? Measurement Uncertainty (MU) 2
William55401 Distributed By Product - Best Practices for Configuration Management and Purchasing Controls ISO 13485:2016 - Medical Device Quality Management Systems 0
P Best european location to set up for a virtual medical device manufacturer? EU Medical Device Regulations 4
optomist1 Best Optical Comparators General Measurement Device and Calibration Topics 9
M Best profilometer for the money General Measurement Device and Calibration Topics 22

Similar threads

Top Bottom