The whole point of this
section ‘Document Controls” are nobody can simply revise and approve any
procedure and documents. All new revision of procedures, documents, protocol,
manufacturing processes must be well thought of and be implemented effectively
throughout the whole organization.
Associates whom have been effectively
trained on the documents can perform a task according to the procedure. Therefore,
a new revision or a new document should have the approved status and effective
status. Approved status is to show the document is only ready pending all the
employees are trained effectively, then the document is changed to a status of ‘effective’
with a date. Then, the document is ready for the whole organization.
Each stage of a document
must be indicated as either ‘DRAFT’, ‘Controlled’ or OBSOLETE’.
Only approved documents can be used. Effective date of each document must be
conspicuously shown on the document or the effective date is easily accessible.
It is not uncommon for careless associate to work on the old revision of a
procedure resulting in a messy deviation. This obsolete document must be marked
‘OBSOLETE” and be removed promptly from being inadvertently used.
Any change to each document
must be performed according to corporate procedure. It is critical to get all
related departments managers involved to ensure the change can be reviewed,
edit, approved and implemented.
A sponsor should have a
document control department to ensure all new documents are initiated, edited
and written properly and present documents revised accordingly. There should
not be any obsolete document floating around.
Because there can be
hundreds of documents in the organization from quality policy, procedures, work
instructions, drawings, training record, verification and validation protocols
and report, manufacturing processes, etc. It is important that medical device
company to have a system to manage all the documents. There are many software
out there to manage all the documents. Master Control is one of them.
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Reference
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Criteria
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ISO 13485 4.2.1
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Does the quality management system documentation
include documents needed by the company to ensure the effective planning,
operation, and control of its processes?
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ISO 13485 4.2.3
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Are the documents required by the quality management
system controlled?
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ISO 13485 4.2.3.a
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Has a documented procedure been established to
define the controls needed to approve documents for adequacy prior to issue?
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ISO 13485 4.2.3.b
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Has a documented procedure been established to
define the controls needed to review, update as necessary and re-approve
documents?
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ISO 13485 4.2.3.c
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Has a documented procedure shall be established to
define the controls needed to ensure that changes and the current revision
status of documents are identified?
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ISO 13485 4.2.3.d
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Has a documented procedure been established to
define the controls needed to ensure that relevant versions of applicable
documents are available at points of use?
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ISO 13485 4.2.3.e
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Has a documented procedure been established to
define the controls needed to ensure that documents remain legible and
readily identifiable?
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ISO 13485 4.2.3.f
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Has a documented procedure been established to
define the controls needed to ensure that documents of external origin are
identified and their distribution controlled?
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ISO 13485 4.2.3.g
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Has a documented procedure been established to
define the controls needed to prevent the unintended use of obsolete
documents, and to apply suitable identification to them if they are retained
for any purpose?
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Disclaimer:
Although
the author had exhaustively researched all sources to ensure the accuracy and
completeness of the information contained in this blog, but no warranty and
fitness is implied. I assumed no responsibility and implied warranty of any
kind for errors, inaccuracies, omission, or any inconsistency herein. No
liability is assumed for incidental or consequential damages in connection with
the use of the information contained herein. Readers should always use their
own judgment and review all related regulatory guidelines. Guidelines can
change over time.
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