Some of the
key requirements in purchasing controls are always have procedures to evaluate
and select potential suppliers, contractors and consultants. Sponsor are
advised to have an ‘Approved Supplier List’ where the detail of each sponsor
evaluation. How and when it is being evaluated. What is the outcome of each
evaluation? Qualified auditor should physically go to the site to audit
thoroughly the whole site and should also re-audit per schedule. Update the
Approved Supplier List regularly. Should any supplier disqualified, inform all
purchasing department of the sponsor’s status.
Another key
issue is that sponsor must sign a quality agreement with the supplier so that
part/parts must be made accordingly to sponsor specification.
Sponsor must
have a supplier evaluation form to ‘evaluate’ each supplier. Example of items
in the form are: Name, Contact Information, Supplier Quality Certification like
ISO 13485, Job/Part Description, Initiation Date, on-time delivery, evaluation
results etc.
The following
are the exact working I copy from FDA website (1).
Each
manufacturer shall establish and maintain procedures to ensure that all
purchased or otherwise received product and services conform to specified
requirements.
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(a)Evaluation
of suppliers, contractors, and consultants.
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Each
manufacturer shall establish and maintain the requirements, including quality
requirements, that must be met by suppliers, contractors, and consultants.
Each manufacturer shall: (1) Evaluate and select potential suppliers, contractors, and consultants on the basis of their ability to meet specified requirements, including quality requirements. The evaluation shall be documented. (2) Define the type and extent of control to be exercised over the product, services, suppliers, contractors, and consultants, based on the evaluation results. (3) Establish and maintain records of acceptable suppliers, contractors, and consultants. |
(b)Purchasing
data.
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Each
manufacturer shall establish and maintain data that clearly describe or
reference the specified requirements, including quality requirements, for
purchased or otherwise received product and services. Purchasing documents
shall include, where possible, an agreement that the suppliers, contractors,
and consultants agree to notify the manufacturer of changes in the product or
service so that manufacturers may determine whether the changes may affect
the quality of a finished device. Purchasing data shall be approved in
accordance with 820.40.
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1.
–CFR-Code of Federal Regulation Title 21 part 820 Quality
System Regulation, www.fda.gov, page last updated 06/01/2013.
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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