ISO 13485:2015 Pre-Release News and Discussion

Marcelo

Inactive Registered Visitor
I got a CD version of ISO 13485:2015 in last year. This draft requires how to handle complaint from its sections 8.5.1.1.1 to 8.5.1.1.6.
This June, I get an updated draft from BIS website. This draft removes sections from 8.5.1.1.1 to 8.5.1.1.6 that are required in last CD version.
You mentioned the complaint handling is required in section 8.2.1.2 of DIS version. However, there is no such section in the draft that I get.
Does it mean my version is not the latest draft? In addition, could you please confirm whether the content of 8.2.1.2 in DIS version is the same as 8.5.1.1 in CD version?

Complaint handling was on 8.2.1.2 on the CD from last year. There was only some small modification on this clause on the DIS (removing a link to a subclause, including one or two new wording) But the text is almost the same.

The texto begins with:

8.2.1.2 Complaint handling
The organization shall document procedures for timely complaint handling.
These procedures shall include at a minimum requirements and responsibilities for the following activities:
- Receiving information
- Evaluating information to determine if the feedback constitutes a complaint
- Investigating complaints
- Considering regulatory reporting
- Handling of complaint related goods
- Determining and initiating corrections and/or corrective actions if applicable on the basis of risk.
- Defining requirements for complaint records
- Feedback to review risk management file

And there´s 3 more clauses.

I don´t know which document you have. You might send it tome to take a look and try to help you, otherwise, I don´t know how I could help you.
 
Y

yzl1018

Hello! Marcelo!
I have sent the draft to your hotmail mailbox.
Could you please kindly check?Thank you very much!
 

Marcelo

Inactive Registered Visitor
Hello

I?ve checked, and this document is in fact a very early working draft of the 13485 working group. There?s a lot of differences from the current draft.

You could buy the current draft at the ISO website: DIS ISO 13485

But as we are gonna have a meeting in the beginning of September and will change the draft, it would be better for you to wait anyway.
 
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stevenking

Starting to get Involved
Re: News on the ISO 13485 revision

The problem is really more weird, and, as i've said somewhere else before, even the EU is not really sure of their own arguments (I was with the guy responsible for the formal Eu answer to this problem and he even he wasn't aware what was really happening :))

One example - in New Approach directives, directives have essential (less detailed) requirements, and harmonized standards details that essentials requirements and therefore gives 'presumption of conformity' with the essential requirements they are linked with (annex zx). However, this presumption of conformity is only related to the essential requirements which are given in annex I of the directives. Quality system requirements are not in Annex I, they are only required in the "route" annexes (particularly the annex II route - full quality assurance). So, one of the problems is that ISO 13485 cannot really give presumption of conformity.



Yes, Kim Trautman is a WG 1 member and represents the FDA. From the standpoint of the standard, she didn't seem to have any problems (she mentioned the VARSP program but only to remember that she would prefer the standard to stick to requirements which were already on the regulations) but nothing regarding the EU. As i said, the focus of the discussion obviously was the standard, not the regulations that use them, because it was deemed that a lot of the comments were really problems of the regulations, not the standard.

Update: Just to make things clear here, i didn't imply i know Kim's or FDA's position, what i said is only what I felt during the meeting.
WHAT IS THE VARSP program ? COULD YOU HELP ME UNDERSTAND?
THANKS
 

Marcelo

Inactive Registered Visitor
WHAT IS THE VARSP program ? COULD YOU HELP ME UNDERSTAND?
THANKS

Information on the Voluntary Audit Report Submission Pilot Program can be found on the following link:

(broken link removed)
 

Attachments

  • Medical Devices and Radiation-Emitting Products - Medical Device ISO 13485 2003 Voluntary Audit .pdf
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R

Reg Morrison

What were the objections ?

Who voted NO?Can u give a list?
Thanks!
Not sure if Marcelo would feel comfortable disclosing information that pertains to the ISO TC 210 in a public venue, such as this.

What we do know is that, in the ISO TC 210, there are 35 Participating Countries, and according to the ISO Directive, Part 1, to approve the DIS, the rules require:
2.6.3 An enquiry draft is approved if

a) a two-thirds majority of the votes cast by the P-members of the technical committee or subcommittee are in favour, and

b) not more than one-quarter of the total number of votes cast are negative
If we were to assume that the 26 participating countries that did not vote for approval of the DIS, voted for (there could be abstentions or no votes), it would have been a close call.

Interestingly that, until the next revision of ISO 13485 comes about, we will be using a standard that is over a decade old. I think the TC 210 has a maximum 48 months to complete the revision process of the standard, after it got started.
 
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