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Qualio+ Newsletter - Q1 2024

Keep up to date with these EXCLUSIVE Qualio+ recommendations and resources curated for our Qualio+ customers.

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Written by Lydia Olu-Harding
Updated over a year ago

Hello and welcome to the January 2024 edition of the Qualio+ newsletter. You’ll find lots of important information throughout this article on what changes have been made to the Qualio+ content, new training that is being provided by the Qualio+ Team, as well as useful snippets from recent webinars and blog posts to answer any quality-related queries you may have. Check out the following video for more information and as always, let the team know if there’s anything we can help you with.

Meet the Qualio+ Team

JERRY ADATSI

Manager, Quality Services

LOLA FURLONG

Senior Quality Specialist

SUMATHA KONDABOLU

Senior Quality Specialist II

MOLLY CALVEY

Senior Quality Specialist

JASON MARCH

Senior Quality Specialist

CASEY WISE

Quality Specialist

Table of Contents:


Updated Qualio+ Content

Review the “Update Details” column for specific updates, or request a strategy session with your Quality Specialist for further information using the Qualio+ Customer Request Form.

Document

Impacted Customer Profile

Update Details

Quality Manual

SaMD & HW

Added section on Person Responsible for Regulatory Compliance to comply with Article 15 of EU MDR (2017/745).

Updated section on Design History File and ISO Technical File to include UK MDR 2002 requirements.

HW only: added new section on Planning of Product Realization to align with ISO 13485:2016 clause 7.2.

General Change Procedure

SaMD & HW & Pharma

Added the following information on Administrative Changes under the Types of Changes section to align with the Quality Manual, where administrative changes are mentioned: Documents needing administrative corrections (e.g. typos, punctuation, etc.) do not need formal review and approval through the change control process and can be updated and approved by the same individual.

Note: Ensure the Signature Matrix Template allows admin changes to be approved by the same individual.

Document Control

SaMD & HW & Pharma

Added the following instructions on how to manage attachments and forms in Qualio: Forms shall be reviewed as part of their parent SOP or WI reviews. Version control will have to be manually checked/updated in the source document.

Control of Quality, Regulatory and Product Records

HW

Added a new section on Control of Quality Documents which discusses the control of procedures, work instructions, policies, the Quality Manual, validation protocols and risk documents. Additional information discussed in this section include the signature matrix, periodic reviews and document storage.

Analysis of Data

SaMD & HW

Added clinical data as another source of data that is recorded, compiled and analyzed to comply with UK MDR 2002 requirements.

Adverse Event, Vigilance and Incident Reporting

SaMD & HW

SOP title revised to Medical Device Reporting, Vigilance and Incident Reporting to align with ISO 13485:2016, MDSAP, EU MDR (2017/745), and UK MDR 2002 terminology.

Added sections on Australian Incident Reporting Requirements to comply with TGA Regulations 2002.

Design Controls

SaMD & HW

Purpose and Procedure sections updated to remove content about the procedure only applying to Class II devices and higher. The SOP also applies to certain Class I devices.

Clarification provided that Phase Reviews are captured in Design Review Records.

Production Identification, Traceability and Unique Device Identification (UDI) Management

SaMD & HW

Added additional context to UDI creation and management for SaMD products and additional content around UDI in the EU, specifically Basic UDI.

Labelling and Packaging

HW & Pharma

HW only:

Added the following specific label requirements for the EU: Where applicable, the label must include an indication that the device contains or incorporates:

  • a medicinal substance, including a human blood or plasma derivative, or

  • tissues or cells, or their derivatives, of human origins, or

  • tissues or cells of animal origin, or their derivatives, as referred to in Regulation (EU) No 722/2012;

Added the following specific label requirements for the UK: The label must indicate that device is for 'single use', 'custom made' or for 'clinical use only' if appropriate;

  • The label must indicate UKCA marking in conformance with the EU MDD and contact information for the UKRP (UK Responsible Person);

  • Under the scope of MDD (Medical Device Directive, 93/42/EEC), the packaging and/or label of the device must distinguish between identical or similar products sold in both sterile and non-sterile condition.

An additional section was added for the labeling translation process in conformance with UK MDR requirements: Under the scope of UK MDR, information contained on a label needs to at least include English and may also include other languages, as needed. If the Instructions For Use (IFU) are not in English, the label must have a clear statement in English indicating the language(s) that the IFU are given in. Self-Test IVD devices must include a translation into the official language of the member State of the Community in which the device reaches the final user.

Pharma only:

SOP was updated in line with the following regulations: FDA 21 CFR 210/211/600/1270/1271, MHRA, TGA (PIC/S GMP Guide), EU (Eudralex Vol 4), Health Canada and GCP.

Out of Specification (OOS)

Pharma

This SOP was updated to align with the MHRA's OOS/OOT presentation which is considered by the FDA and the EMA to be the gold standard for conducting OOS/OOT investigations for medicinal products. The SOP also aligns with the FDA's updated 2022 guidance for industry, Investigating Out-of-Specification (OOS) Test Results for Pharmaceutical Production.

Australian and Canadian requirements were added to the procedure.

Laboratory Controls

Pharma

Added the following Qualified Person responsibilities to comply with EU/UK requirements: The Qualified Person who certifies a batch for sale should ensure that:

  • All relevant reference and retention samples are stored properly and accessible at all reasonable times.

  • Testing of the batch has been performed in accordance with defined release procedures identified in the manufacturing authorization and GMP requirements.

  • The impact of any change to product testing has been evaluated and any additional checks and tests are complete.

  • All investigations pertaining to the testing of the batch being certified (including out of specification and out of trend investigations) have been completed to a sufficient level to support certification.

The SOP was updated to meet the requirements of Europe, the UK, Australia and Health Canada.

Stability Program

Pharma

Added new section on Clinical Trial Phase Specific Stability Requirements.

Management of Supplier Files in Qualio

SaMD & HW & Pharma

Updated instructions on how to export, archive & unarchive suppliers as well as audit trail entries to align with updates made to the Qualio software tools.

Signature Matrix Template

All

Added the following note under the matrix in line with changes made to the General Change Procedure: per SOP-XX General Change Procedure, administrative corrections (e.g. typos, punctuation, etc.) do not need formal review and approval through the change control process and can be updated and approved by the same individual.

*SaMD = Software as a Medical Device

*HW = Hardware Medical Device

*Pharma = Pharmaceutical Product


New Content

  • New ISO 27001 Content

    • Employee Training and Development Policy

    • Document Management and Control Policy

    • Cryptography and Cryptographic Key Management Policy

    • Network Security Policy

    • Cable Security Policy

    • Good Practice for Digital and Data-Driven Health Technologies SOP

    • Register of Data Processing Activities (GDPR Inventory) Template

Note: the ISO 27001 content was recently revised to align with the 2022 version of the standard.

  • New Clinical Content

    • Trial Master File Management SOP

    • Clinical Data Management SOP

    • Clinical Trial Risk Management SOP

    • Archiving of Clinical Trial Data and Essential Documentation SOP

    • Case Record Form (CRF) Design SOP

    • Trial Closure SOP

    • Preparation of a Study Specific Randomization, Blinding and Emergency Unblinding Procedure SOP

    • Clinical Evaluation Report Template

    • Case Record Form Approval Template

  • New ISO 9001 Content

    • Release of Product and Services SOP

  • New SaMD Content

    • Software Validation Procedure (IQ/OQ/PQ) SOP


Qualio+ Training Sessions

Training on quality-related topics is always beneficial for understanding how to use your Quality Management System in the most efficient way possible. Below is a list of the training currently offered by the Qualio+ Team, with some exciting new additions since the last newsletter was released:

  • NEW - Combination Products: Regulatory Approach and cGMP Requirements

  • NEW - Internal Auditor Training

  • NEW - Complaint Handling

  • NEW - Device Development Pathways

  • NEW - Software Validation

  • Supplier Management

  • Effective SOP Writing

  • cGMP Training - History and Practice

  • Intro to Management Review

  • Corrective and Preventive Action (CAPA)

  • Good Documentation Practices

  • How to Manage Internal and External Audits

  • 12 Pillars of a Quality Management System

  • Audit Preparation

  • Design Controls - Requirements from ISO 13485 and FDA

  • An Overview of ISO 13485 and FDA Requirements

  • Risk Management

  • Supplier Management - Device


Upcoming Webinars

Date

Details

Registration Link

February 27, 2024

Feb ‘24 Launch Train Customer Webinar

March 5, 2024

Risk Management - Ask The Expert with Peter Sebelius

March 19, 2024

Software as a Medical Device (SaMD) - Ask The Expert with Christian Kaestner

*Registration link coming soon*

March 27, 2024

Tips & Tricks: Document Creation Options

Snippets from recent webinars with useful information

  • Interested in knowing the most common mistakes in risk management according to Peter Sebelius? View the snippet below of the risk management webinar held in December highlighting the approach all companies should be taking when performing risk management activities.

  • Ever wonder what systems are usually missed when setting up a pharmaceutical quality system in compliance with ICHQ10? Casey Wise provided an insight during our recent Therapeutic Quality Excellence webinar which will be of great interest to our pharmaceutical customers.

Qualio+ on LinkedIn

Do you have a quality-related topic or query that you’d like the Qualio Plus Team to discuss on the Qualio LinkedIn page? If so, we’d love to hear from you through our Customer Request Form (select LinkedIn Video Topic Suggestion when selecting the desired service form the Qualio+ Team). In the meantime, check out Jason March’s short video on Quality tips for effective supplier management below.


Recent Blog Posts

The Qualio Blog is constantly being updated with new content for our customers. Here are a few of our recent favorites for you to explore:


Regulatory Updates

Updates to regulations, standards and guidance documents happen on a frequent basis. Knowing what’s been updated and when the changes occurred can be a challenge. So we’ve put together a list of useful resources to keep you informed on industry updates.

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