Understanding Audits: An Introduction To Different Audit Types For Greater Compliance

What is an Audit?

Audits in medical device manufacturing are often challenging, but they play an important role in ensuring compliant quality systems and the production of safe products. Proper preparation is required to reduce the stress and risks associated with audits. Organizations must prioritize the development and implementation of comprehensive quality processes that cover the entire product life cycle, as well as their continuous evaluation and improvement. According to ISO 19011, audits include systematic documentation and independent evaluation of objective evidence to determine compliance with audit criteria. They can be carried out internally, and externally (customer, Notified Body, etc.) and ensure compliance with regulatory and quality system standards. Regardless of the requirements based on device classification, preparation is essential for navigating audits smoothly.

The audits are typically conducted to ensure compliance with regulatory standards and quality management systems specific to the medical device industry, such as ISO 13485:2016. Medical device audits encompass various aspects, including product design and development, manufacturing processes, supplier management, risk management, documentation control, labelling, packaging, sterilization, and post-market surveillance. They also focus on ensuring that devices meet safety, efficacy, and performance requirements while adhering to applicable regulatory requirements in different regions or countries, such as the European Medical Device Regulation (MDR) or the United States Food and Drug Administration (FDA) regulations, etc.

Audits may be conducted by internal teams within the organization or by external regulatory bodies, notified bodies, or third-party auditors. The goal of these audits is to verify that the manufacturer has established and implemented effective quality management systems to ensure the safety, effectiveness, and reliability of their medical devices, thereby safeguarding public health and promoting patient safety. Compliance with audit findings often leads to regulatory approvals, certifications, and continued market access for medical devices.

Type of Audit

• CE Audit: An assessment conducted to ensure compliance with European Conformity (CE) requirements, confirming that products meet safety, health, and environmental protection standards within the European Economic Area.
• ISO 13485:2016 Audit: Evaluation of a company’s quality management systems to verify compliance with ISO 13485:2016, an international standard specific to medical devices, ensuring consistency in design, development, production, and distribution processes.
• Customer Audit: Examination performed by a customer to assess a supplier’s capability to meet specified requirements, often focusing on product quality, delivery timelines, and adherence to contractual agreements.
• Country-specific Regulation Audit: Evaluation of an organization’s practices and processes to ensure compliance with regulations specific to a particular country, addressing legal and regulatory requirements governing products or services within that jurisdiction.
• Internal Quality Audit: An independent review is conducted within an organization to examine the effectiveness of its quality management systems, identifying areas for improvement, ensuring adherence to standards, and maintaining consistency in processes and procedures.

Purpose of the Audit

Audits for medical device manufacturers are designed to ensure compliance with regulatory standards, evaluate the effectiveness of the quality management systems, and verify the safety and efficacy of medical devices. Audits assure stakeholders, including regulatory agencies and consumers, that the manufacturer is committed to producing high-quality, safe products. They also help identify areas for improvement, reduce product quality risks, and drive continuous improvement initiatives. Finally, audits are critical for maintaining industry standards, ensuring market access, and protecting public health.

Tips to get ready for your Audit

Preparing for an audit as a medical device manufacturer requires meticulous planning and attention to detail to ensure compliance with regulatory requirements and standards. Here are some comprehensive tips to help you get ready for your audit:

• Understand Regulatory Requirements: Familiarize yourself with relevant regulations such as ISO 13485, FDA regulations (if applicable), and any other applicable standards specific to medical devices. Ensure that your quality management system (QMS) aligns with these requirements.
• Conduct Internal Audits: Regularly conduct internal audits of your QMS to identify areas of non-compliance or improvement opportunities. Address any findings promptly and implement corrective actions to enhance your QMS effectiveness.
• Document Control: Ensure that all documentation, including procedures, work instructions, records, and reports, is up-to-date, accurate, and readily accessible to auditors. Implement a robust document control system to manage document revisions and ensure compliance with regulatory requirements.
• Train Personnel: Provide comprehensive training to employees involved in the audit process, including training on relevant procedures, documentation requirements, and expectations during the audit. Ensure that personnel are aware of their roles and responsibilities during the audit.
• Prepare Documentation: Compile all necessary documentation required for the audit, including quality manuals, procedures, records, and any other relevant documents. Organize the documentation in a logical manner to facilitate easy access and review by auditors.
• Mock Audits: Conduct mock audits to simulate the actual audit process and identify potential areas for improvement. Mock audits help familiarize personnel with the audit process and provide an opportunity to address any gaps or deficiencies before the actual audit.
• Facility Readiness: Ensure that your facility is clean, organized, and conducive to the audit process. Provide appropriate amenities and accommodations for auditors, such as workspace and access to facilities.
• Review Previous Audit Findings: Review and address any findings or recommendations from previous audits. Demonstrate to auditors that you have taken proactive measures to address identified issues and continuously improve your QMS.
• Pre-Audit Meetings: Schedule pre-audit meetings with key personnel to review audit objectives, expectations, and timelines. Clarify roles and responsibilities, address any concerns, and ensure everyone is prepared for the audit process.
• Stay Calm and Professional: Maintain a calm and professional demeanour throughout the audit process. Respond to auditor inquiries promptly and accurately, and avoid becoming defensive or argumentative. Remember that the audit is an opportunity to showcase your commitment to quality and compliance.

By following these tips and adequately preparing for your audit, you can demonstrate your organization’s commitment to producing safe and effective medical devices while ensuring compliance with regulatory requirements and standards.

Understanding the Auditor’s Conclusion

• Understand the Audit Scope: The first step in preparing for an audit is to understand its scope. What exactly is being audited? Is it regarding compliance with regulatory standards, or something else? Knowing the scope will help you focus your preparation efforts and ensure that you gather all the necessary documentation and information.
• Executive Summary: The audit evaluates medical device manufacturers’ compliance and identifies production monitoring procedures. The findings aim to enhance compliance and resolve any issues, ensuring ongoing regulatory compliance.
• Findings: Auditors look for both compliance and non-compliance with requirements during the audit. Auditors may issue non-conformances if you do not adhere to the standard or management system requirements and can report noncompliance with management system controls.

  An auditor can raise findings in three sections as mentioned below:

  • Major non-conformity: A major nonconformance has a significant impact on the management system’s ability to achieve its objectives, compromising overall effectiveness and regulatory compliance.
  • Minor non-conformity: A minor nonconformance has no impact on the management system’s ability to achieve its intended results, posing a low risk to overall effectiveness and regulatory compliance.
  • Observations/ Opportunities for Improvement: These situations are not classified as non-conformances upon identification. Instead, the Certification body makes recommendations to improve the management system or avoid potential non-conformances. They also identify areas for future development, which is essential for changing systems to meet organisational growth and changing needs.
• Conclusions: During the audit’s closing meeting, the auditor will execute a comprehensive assessment of regulatory compliance. The auditor shall also disclose the certification status of our company’s operations. Furthermore, the Auditor will outline all required follow-up actions, including timelines, to address any identified non-conformances.
• Impact on Certifications: The impact of findings on our current certification status will be assessed with specific requirements for maintaining or renewing certification. The auditor will ensure compliance in order to maintain certification and implement the necessary measures for continuous improvement.
• Corrective and Preventive Actions: The manufacturer shall address non-conformities received during the audit and take corrective measures to prevent recurrence. Set clear implementation timelines and assign responsibilities for each action. This ensures that issues are addressed in a systematic manner while remaining within regulatory guidelines.
• Follow-up Audits: Regular re-audits need to be conducted to validate the effectiveness of corrective actions implemented. Continuous monitoring and improvement processes are in place to ensure long-term compliance and increased operational efficiency. These measures demonstrate commitment to continuous improvement and regulatory compliance throughout the medical device manufacturing process.

Conclusion

In conclusion, preparing for an audit requires careful planning, organization, and communication. By following these tips and taking a proactive approach to preparation, you can ensure a smooth and successful audit experience. Remember to stay focused, stay positive, and keep the lines of communication open with auditors throughout the process. With proper preparation and a cooperative attitude, you’ll be well-equipped to handle whatever the audit process throws your way.