MDSAP replaces several audits with one, and it widens that one audit. A
recognized auditing organization audits your quality management system once
against ISO 13485:2016 and the regulatory requirements of the participating
markets you supply. The report then goes to the authorities, which use it in
their own procedures.
The audit runs in a fixed order through seven processes: management;
measurement, analysis and improvement; design and development; production and
service controls, with purchasing audited alongside. Two further processes
serve the specific requirements of the participating authorities: device
marketing authorization and facility registration, and adverse event and
advisory notice reporting.
The cycle runs for three years. The initial audit has two stages, a
surveillance audit follows in each of the next two years, and a recertification
audit closes the cycle. The authorities require unannounced audits where high
grade nonconformities have been found; special audits follow, for example, an
extension of scope or a significant complaint.
| Market | Authority | What the MDSAP audit is used for |
|---|
| United States | FDA | substitute for the routine inspection |
| Canada | Health Canada | QMS evidence for class II, III and IV licenses, only MDSAP certificates since January 1, 2019 |
| Brazil | ANVISA | input to ANVISA's assessment procedures; for class III and IV, which need a GMP certificate before registration, it can take the place of ANVISA's own inspection |
| Australia | TGA | auditing organizations assess the QMS on behalf of the TGA under the conformity assessment procedures |
| Japan | MHLW, PMDA | used in the QMS inspection; PMDA can still inspect on site or ask for documents |
For the FDA, the MDSAP report replaces the surveillance inspection, not
every inspection: compliance follow-up, for-cause, specific product risk
assignment and PMA inspections before and after approval remain. How the FDA itself inspects under the QMSR is
set out in our article on compliance program
7382.850.
Every nonconformity is graded from 1 to 5, following GHTF/SG3/N19:2012 as
applied in MDSAP. The grade does not fall when the finding is fixed. After the
audit, a remediation plan is recommended within 15 calendar days and the
evidence for grade 4 and 5 findings within 30; the auditing organization then
submits the complete report package to the authorities.
Outside this page: the certification audit under ISO 13485:2016 alone, the
notified body audit for the CE mark under MDR and IVDR, and the preparation for
an FDA inspection under the QMSR.