The International Medical Device Regulators Forum (IMDRF) established a working group to develop a standard set of requirements for auditing organisations (Certification Bodies) performing regulatory audits of Medical Device manufacturers’ quality management systems. Termed the Medical Device Single Audit Program (MDSAP), the requirements are applicable to regulatory authorities, as well as third-party organisations that conduct such audits.
The objective of the MDSAP is to develop, manage, and oversee a single audit program that will allow a single regulatory audit of a Medical Device manufacturer, conducted by an MDSAP recognised auditing organisation, to satisfy the needs of multiple regulatory jurisdictions.
The participating regulatory authorities hope to achieve more consistency among the auditing organisations.
By following the MDSAP Audit Model:
Australian Therapeutic Goods Administration (TGA)
TGA will use an MDSAP audit report as part of the evidence that is assessed in compliance with Medical Device market authorisation requirements, unless the Medical Device is otherwise excluded or exempted from these requirements, or if current policy restricts the use of MDSAP audit reports.
The Brazilian National Health Surveillance Agency ANVISA
(Agência Nacional de Vigilância Sanitária)
ANVISA will utilise the outcomes of the program, including the reports, to constitute an important input on ANVISA’s pre-market and post-market assessment procedures, providing, when applicable, key information that are expected to support the regulatory technical evaluation on these issues.
Health Canada (HC)
Health Canada's intent is to implement the MDSAP as the mechanism to assess regulatory compliance for quality management system requirements in Canada. Health Canada will operate the current Canadian Medical device Conformity Assessment System (CMDCAS) program and the MDSAP in parallel. Beginning with January 1, 2019, Health Canada will only accept MDSAP certificates for the purpose of Medical Device License application or maintenance.
US Food and Drug Administration, Center for Devices and Radiological Health (CDRH)
FDA will accept the MDSAP audit reports as a substitute for FDA routine inspections. Inspections conducted “for cause” or “compliance follow-up” by FDA will not be affected by this program. Moreover, MDSAP will not apply to any necessary pre-approval or post-approval inspections for the Pre Market Approval or PMA applications.
Japan Ministry of Health, Labor and Welfare
Japan’s Ministry of Health, Labour and Welfare (MHLW) and Pharmaceuticals and Medical Devices Agency (PMDA) will use the MDSAP audit report as a trial:
1) To exempt a manufacturing site etc.* from on-site inspection, and/or
2) To allow a Marketing Authorization Holder (MAH) to substitute considerable part of documents required for the inspection with the report.
The MDSAP program was officially implemented in January 2017, following the completion of the pilot program.
Health Canada requires all license holders to change from CMDCAS to MDSAP by December 31, 2018.
Health Canada will terminate the CMDCAS program on December 31, 2018. After this date, Health Canada will only accept MDSAP certificates from manufacturers with their device applications or renewals. To facilitate uninterrupted market access, TÜV SÜD will no longer be conducting CMDCAS audits as of September 30, 2017.
Achieve access to multiple markets with a single audit through the MDSAP. If you are interested in the program, please contact Georg Bauer in Europe or Dawn Tibodeau in the US.
Note: Regulators will be witnessing some audits. This will be for the evaluation of the Auditing Organisation, not the manufacturer.
TÜV SÜD is authorised to work with clients who would like to participate in the MDSAP. If you are interested in the audit program, please contact Georg Bauer in Europe or Dawn Tibodeau in the US.
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