Professional Documents
Culture Documents
BRSM Form 009 Qms MDD Hs
BRSM Form 009 Qms MDD Hs
System: QMSMDD ISO 13485 (2003)
Assessment Report/Checklist
Form 009
CLIENT‐ORGANIZATION (NAME): HOMA SYRING KHOZESTAN Co.
No. 3 , Industrial Zone , 8th km of Ahvaz‐Mahshahr
PHYSICAL LOCATION(s):
Road Ahvaz , Iran
Stage II Audit Date(s): 22&23Aug 2016
Stage I Audit Date(s): 3 Aug 2016
NAICS (or NACE) CODE MD0106
EXCLUSIONS:
7.3‐7.5.1.2.2‐7.5.1.2.3‐7.5.3.2.2‐7.5.4‐8.2.4.2
Assessment objectives: Third party assessment of requirements of QMSMDD
ISO 13485 (2003), is met in companies management
system, as well as legal requirements
ASSESSMENT TEAM INFORMATION
Assessment Team Leader, ATL Marjan Azadmanesh
Assessor 2 Yasaman Zehtab
Assessor 3
Assessor 4
Assessor 5
Assessor 6
Note: Adjusting the language within this form to the type of activity and nature of the organization is acceptable.
Clause observation
We pursuit to assure that client‐organization adheres to the protection of communities and consumers. This is to follow the intent to
1 the substitution of the word “identify” to the word “determine” as part of the importance to the processes being capable of achieving
desired outputs (including consumer’s well‐being).
2 Scope of activities: manufacturing of sterile and pyrogen free single‐use (2.5 cc and 5cc) and needle
BRSM requires that the organization’s legal obligations and regulatory are met. Technical
Legal status supervisor is main responsible for executing and monitoring of these regulations
ok
3
Obligatory applicable standard which
organization has to follow
ISIRI 770 , ISIRI 3979 , ISIRI 3980, isiri 3001‐1 , iso 384 , iso 3696 , IMED regulations
4 Quality Management System
sample of organization processes: 'purchument', with process indicator/index:
'conformity of purchased material to procurement data', acceptance level/criteria:
'95%', Owner of the Process: 'training manager', and 'customer surveys' is input to
Quality Management this process. Output from this process is used in 'QC' .next process is
4.1 'PRODUCTION', with process indicator/index: 'on time production', acceptance
Ok
System
Level/criteria: '90%', Owner of the Process: 'production manager’ and 'planning' is
input to this process. Output from this process is used in 'sale' .The structure of the
documentation is compatible with standard requirements regarding size and
complexity of organization. the Quality Manual: P84000QM07 is in place, Quality
Objectives: F541000QM01 and Policy: F53100QM01 backed with documented
Documentation requirements procedures and work instructions/SoPs, control forms and planning records, as well OK
as Regulatory documents , such as; 'ISIRI 770 as main ISIRI requirement' are in
place.
Document control is in place ; Document control procedure was reviewed during
Assessment with Document ID: Control of documents and records, Revision and
Date: 001, 2011 Approved by: P42300QM01. It provides a system to review and
approve documents for adequacy prior to issue. It provides a system to review and
approve documents for adequacy prior to issue and re‐approve and update when in
use. it provides a method of revision status identification and prevention of
Obsolete document to be used. Method of identification: ok and obsolete seal
stamp. , Obsolete documents are kept in QA DRAWING ROOM. Documents are
always available at the point of access as in machinery identification; number of
4.2.3 Control of Documents the last version was available. All sample reviewed documents are Legible and OK
Readily identifiable. Applicable national or local regulations were identified.
Applicable local and national documents were listed in master list. Sample of
applicable local and national documents listed: GMP. External documents were
identified. Applicable external documents were listed in master list. Sample of
external documents listed: GMP. The records related to tested medical device
samples are kept for 3 years. Records of sample device tested, observed: syringe.
tested at: 2016
Clause observation
record control procedure was reviewed during assessment with Document ID:
Control of documents and records, Revision and Date: 001, 2011 Approved by:
P42300QM01. Record control has following features; method of identification: ok
and obsolete seal stamp. Method of defining distribution: distribution table.
Method of retrieving of records: backup of electronic file. Method of disposing of
4.2.4 Control of Records records: when a new record is in place the old one is collected and torn. All samples OK
reviewed records were Legible and Readily identifiable. As evidence records of
syringe test report seen issued at: April 2013 which is kept paper record on
Laboratory as planned.
5 Management responsibility
the Top Management, Mohammad fathi has communicated to the organization the
Management importance of meeting customer as well as statutory and regulatory requirements,
5.1,2
Commitment/Customer Focus through policy, objectives and providing resources
5.5 Responsibility, Authority and Communication
Clause observation
Top management has defined responsibilities and authorities which are
Documented and communicated within the organization. Top management has
established the interrelation of all personnel affecting quality, with independence
and authority necessary to perform their tasks. As seen in O‐Chart: F55100HR01, to
5.5.1 Responsibility and Authority
meet IMED regulations Mrs. Darvishpasand has been appointed as Technical
Supervisor. With License number: 117‐بTop Management has appointed
ms.darvishpasandas Management representative. some of the main job duties of
MR are as follows: , Establish and Implement processes needed for the QMS and OK
maintained, Report to top management on the performance of the quality
5.5.2 Management Representative management system and any need for improvement , promotion of awareness of
regulatory and customer requirements throughout the organization., Internal
communications are mostly; verbally, Face to Face, In writing, Via
automation/email, The communication is effective and efficient according to the
5.5.3 Internal Communication complications and size of organization.
5.6 Management review
The latest management review was conducted on 20 July 2016Records of
Management review minute observed, Management review was recorded
5.6.1 Management review in MOM based on procedure P56000QM01. Participants in the latest
Management review session: Mr. Amiri and Mrs. Darvishpasand and Ms.
Pishdar and Mr. Abbacinejad.all inputs to management review were
reviewed such as Customer feedback, product conformity, Status of
preventive and corrective actions, Follow‐up actions from previous OK
5.6.2 Review input
management reviews, changes and improvements and regulatory updates.
following items has been significant outputs of Management review:
training of new personals, Verification and calibration of ETO before end of
2016 on time. Management Review sessions are held every 6 months.
5.6.3 Review output
6 Resource Management
Training and competence of staff affecting quality is directed by Training
Procedure with Document ID of P62200TR01, Version: 01 issued in 2012,
Provision of Resources approved by MD. Records of qualifications and competence needed for
6.1
positions affecting quality observed during audit; training plan/matrix
F62200TR03. Records of trainings conducted for positions affecting quality
observed during audit; training plan F62200TR02. Records of trainings
evaluations for training conducted observed during audit; evaluation
training form F62200TR03. The organization keeps the educational records
of staff affecting quality, Type of Record: Diploma and License. The
organization keeps the Training records of staff affecting quality, Type of
6.2 Human Resources Record: Training Certificates. The organization keeps the Experience and
Skills records of staff affecting quality, Type of Record: Resumes. for sample,
following evidence has been reviewed during HR audit; Name of the staff
profile reviewed ,Ms. Bavi, Position: needle assemble machine . Education
record was in place: bachelors of science. Training planned observed during
Clause observation
audit for training course of injection and assembly machine, Planned in Jan
2016. Records of Training conducted in may 2016, observed during audit
for training course of injection and assembly machine. Records of Training
effectiveness evaluation observed during audit for training course of
injection and assembly machine, evaluation result: Name of the staff profile OK
6.2.1 responsibilities reviewed, Ms. Bavi, Position: needle assemble machine. Education
Record was in place: bachelors of science. Training planned observed during
audit for training course of injection and assembly machine, Planned in Jan
2016. Records of Training conducted in may 2016, observed during audit
for training course of injection and assembly machine. Records of Training
effectiveness evaluation, observed during audit for training course of
injection and assembly machine, evaluation result: Name of the staff profile
reviewed, Mr. Abbacinejad, Position: QC and Lab. Education record was in
place: Master of science of analytical chemistry. Training planned observed
during audit for ISIRI 770, Planned in 2015. Records of Training conducted
in April 2016, observed during audit for ISO 13485:2016.
Records of Training effectiveness evaluation done in April 2016 observed
6.2.2 mcompetence, Awareness, and nduring audit for ISO 13485:2016, evaluation result: ISO 13485:2016.
Training
Changed.
7 Product Realization
The organization has planned and developed the processes needed for
Product realization. Planning of product realization is in consistent with the
requirements of the other processes of the quality management system.
In planning product realization, the organization has determined the
following: Quality objectives and requirements for the product; processes,
documents, and resources specific to the product; required verification,
validation, monitoring, inspection and test activities specific to the product
and the criteria for product acceptance which is explained further in the
report. The output of this planning is suitable for the organization’s method
of operations. Risk management procedure is the name of the documented
requirement established for risk management throughout product
realization, With Document code/Version; P71000QC01 R0 approved by top
managenment, Date; 2011. Members of the Risk assessment
Clause observation
Team/committee; technical supervisor. according to Risk management
7.1 Planning of product realization Procedure, Risk levels have been considered as follows; Intolerable risk level OK
is: and Acceptable risk level is: bellow30. sample of risks hazards evaluated
by organization: , sample 1, Hazard: Breaking needle while use,
RPN / Risk Level: 50, Control Method: Supplier management, raw material
verification, control of parts during production, RPN / Risk Level after
control: 14, sample 2, Hazard: package torn, microbiological hazard,
infection of patient, RPN / Risk Level: 50, Control Method: Advisory notice
on
labeling, RPN / Risk Level after control: 28, sample 3, Hazard: separation of
the needle from syringe, RPN / Risk Level: 36, Control Method: control of
injection stager / Risk Level after control: 14, sample 5, Hazard: leakage,
RPN / Risk Level: 16, Control Method: leakage test
7.2 Customer‐Related Processes
The company reviews the product requirements through formal
Documented communications with customer. The documented record
observed during assessment for product requirement was; Invoice of selling
120 cartons 2.5 and 100 cartoons of 5 cc syringes, dated may 2016, for
customer: Mahshar hospital, sample of requested product requirements:
syringe 120 cartoons 2.5cc and 5 cc 100 carton, and also The company
reviews the product requirements through informal communications or
Review of requirements verbally with customer. customer can select from items in catalogue and
7.2.2 OK
related to the product/service buys it from the company, company ha production list "F71000PR1R0" such
needle code of product D30130
, Where product requirements are changed, the organization properly
ensures that relevant documents are amended and that relevant personnel
are made aware of the changed requirements.
7.3 Design and Development
Clause observation
Excluded
Design and Development
7.3.1 E
Planning
Excluded
Design and Development
7.3.2 E
Inputs
Design and Development Excluded
7.3.3 E
Outputs
Design and development Excluded
7.3.4 E
review
Excluded
Design and development
7.3.5 E
verification
Excluded
Design and development
7.3.6 E
validation
Excluded
Control of design and
7.3.7 E
development changes
7.4 Purchasing
The organization has established documented procedure to ensure that
Purchased product conforms to specified purchase requirements in;
Purchase and supplier evaluation procedure, with Document ID:
P74100PU01, approved by top management, Date; 2011. The organization
evaluates and selects suppliers based on their ability to supply product in
accordance with the organization’s requirements, the Criteria for selection,
evaluation and re‐evaluation has been established, The organization
evaluates suppliers periodically, for grade: 'all' every 6 months, Latest
suppliers evaluation has been done in 1 may 2016. , Records of suppliers'
evaluation were provided in F74100PU01. Sample of criteria: price ‐ result
7.4.1 Purchasing Process of tests ‐ time delivery ‐ quality of packing ‐ standard of product. Supplier’s OK
acceptance criteria; over 50 points. Sample suppliers evaluation observed
during audit; alvan plastic, results of evaluation for this supplier: Grade: 'A',
93. Sample observed ; chesi, results of evaluation for this supplier: Grade:
'A', 93. Sample observed; Beijing Ou Yuan Sheng Fa Plastic Products Co.,
Ltd., results of evaluation for this supplier: Grade: 'A', 88. Sample
suppliers evaluation observed during audit; Masoom Geranool, results of
evaluation for this supplier: Grade: 'A', 91.
7.5 Production and Service Provision
7.5.1 Production and Service Provision
Information that describes the characteristics of the product, are available ,
Documented procedures, documented requirements, work instructions, and
reference materials and reference measurement procedures as necessary
are available, Suitable equipment is in place , for The implementation of
monitoring and measurement please refer to 7.6 and 8.2, The
7.5.1.1 General requirements implementation of release, delivery and post‐delivery activities, is explained OK
further in the report. The labeling record provides data on amount
manufactured and amount distributed. as for needle , amount
manufactured is: 3000 , amount distributed is: 3000 there are work
instruction for operators and QC, Work instructions from W75100QC01
to W75100QC07 has been observed such as W75100QC02 for plunger
7.5.1.2 Control of production and service provision — Specific requirements
Clause observation
According to production process and the nature of the product , product is
Cleaned by the organization prior to sterilization and/or its use, process
agents are to be removed from product during manufacture. As cleaning
and contamination control of the product is part of the production system,
organization requires establishing documented requirements for cleanliness
of the product. The organization has established documented requirements
for Cleanliness of product and contamination control in Control Plan of
environmental factors for cleanness of product, with Document ID:
F71000QM04, approved by technical supervisor, Date; 2011, Sample of
product cleanliness and contamination control requirements; separating the
Waste after injection process by operator, record of microbial test on
Cleanliness of product and surface of machines, ground of floor, observed. Such as: on 10 July 2016,
7.5.1.2.1 CFU for production salon air was 6 and in acceptable range. OK
contamination control
Result of particle count in production salon on (oct 2015) observed. For
Assemble line; class of clean room was 100000 according to standard 209E.
Daily qc of clean room has been done, records of 15 and 16 august for
injection of barrel section and packing saloon has been observed, pressure
was 7 Pa and temperature was 21, Control plan for environmental factors
has been developed on W64000QC12. Records of microbiological
measurements of surfaces have been observed on F64000QC15 for 12 June
2016, result was no growth.
Clause observation
The organization has established documented Procedure for validation of
Sterilization processes: sterility test of Product, sterilization process
instruction, with Document ID: W75220QC02, W75130PR01, Date; 2011,
Sample of records of sterilization process observed in; sterile validation
and qc is done base on ISIRI 3001‐1 such as batch no.: 628 sterilize on 15
Particular requirements for April. Records of sterilization validation observed on form F75100QC02, for
7.5.2.2 microbiological validation, organization uses Soybean Casein Digest Broth OK
sterile medical devices
culturing environment Pyrogen test is done based on L.A.L method result is
no gel appeared for same batch no, records observed on F7522QC07 April
2016 Sterilization processes are validated prior to initial use.
7.5.3 Identification and traceability
The organization has identified the product throughout product realization,
And established documented procedure. Document name: identifying and
traceability, Document code/version: P75300PR01, Approved by: md,
Dated: 2011. The organization identifies products/parts/material by
'Tagging'. The organization ensures that medical devices returned to the
7.5.3.1 Identification NC
organization are identified and distinguished from conforming product. NC
observed, in current method of identification, tagging of sterilized products
has not stability on surface of carton. (Material of label is not as defined)
7.5.3.2 Traceability
The organization has established documented procedures for traceability, it
Defines the extent of product traceability and the records required.
Document name: identifying and traceability, Approved by: top
management. Organization controls and records the unique identification of
7.5.3.2.1 General the product. Sample taken: 'syring 2.5cc , 5cc', batch no.: 628 , 705, Date OK
sterilized: 15
April 2016. Final product is traceable to following items: sterilization series,
dates of production, Purchased Material series, , for the sample taken it is
tracked to
Excluded
Particular requirements for
active implantable medical
7.5.3.2.2 OK
devices and implantable
medical devices
Clause observation
The organization has established documented procedure procedures to
Ensure that monitoring and measurement is carried out in a manner that is
consistent with the monitoring and measurement requirements. Procedure
name: calibration procedure, Procedure code: P76000PM01. Calibration
plan is recorded/planned in: calibration planning, with document code:
F76000PM01. Calibration status is recorded in: label. Devices are identified
for their calibration status. Type of status identification record: Label of ph
Meter has been observed. Name of the tool/device reviewed: tensile device,
device ID: 4A02601. This device is used for measuring tensile, calibration
status: Calibrated. Last date of calibration: 17 Feb. 2016. Planned intervals:
every 12 Months. Next due date of calibration: Feb. 2017. The device is
calibrated externally by Tanzim Khuzestan, Calibration certificate No.94839‐
1. All measuring devices observed have been calibrated in range required by
standard and application. Evidence observed: YES. Calibrations are traceable
to international applicable standards. Measuring devices are safeguarded
from adjustments that would invalidate the measurement results. Evidence
observed: it is in laboratory in its place. Measuring devices are protected
from damage and deterioration during handling, maintenance and storage.
Control of monitoring and Evidence observed: it is in laboratory in its place. When equipment is found
7.6 out of calibration, all previous measurements are called invalid and they get OK
measuring devices
verified again. Evidence observed: there is no record for this article; no
device has been identified out range. The organization takes appropriate
action on the equipment and any product affected by out of calibration
measuring device. The organization confirms and makes sure that any
computer software used in measurements satisfy the intended application
requirements. This has been undertaken prior to initial use. After 3 more
samples taken all were calibrated. Name of the device: digital balance,
Calibration status: Calibrated. Calibration Certification No.: 1479‐95‐1164/M.
‐ Name of the device: incubator, Calibration status: Calibrated. Calibration
Certification No.: AE‐T‐950302. ‐ Name of the device: incubator, Calibration
status: Calibrated. Calibration Certification No.: AE‐T‐950303.
8 Measurement, analysis and improvement
The organization plans and implements the monitoring, measurement,
Analysis and improvement processes needed. Which includes; conformity of
the product, conformity and effectiveness of the quality management
8.1 General system, it also includes of use of analytic statistical techniques. Documented OK
procedures for implementation and control of the application of statistical
techniques are in place.
8.2 Monitoring and measurement
Clause observation
The organization monitors information relating to whether the organization
Has met customer requirements. The organization has established
documented procedure for feedback system Procedure name: customer
survey, Procedure code: P82100SM01R0, Approved by: top management,
Dated: 2011. Source of customer requirements fulfillment monitoring:
customer survey, question are, direct call, customer compliant record, IMED
8.2.1 Feedback OK
reports. Sample evidence observed: Mahshar hospital. About quality of
product, residual volume after injection, were satisfied (95%). National or
local regulations require the organization to gain experience from the post‐
production phase, review of this experience is part of the feedback system.
Excluded
Particular requirement for
active implantable medical
8.2.4.2 E
devices and implantable
medical devices
Clause observation
There is a documented procedure to identify, control and prevent
Unintended use or delivery of non conforming products. Procedure name:
control of None conform product, Procedure code: P83000QC01R0,
Approved by: MD, Dated: 2011. Controls and related responsibilities and
authorities for dealing with nonconforming product have been defined in
procedure. Technical supervisor is authorized to deal with non‐conforming
products. Sample non‐conforming products/records observed: 53 barrels
with batch 7003 has been disposed. Nature of Non‐conformity of the
product is recorded, MODE of injector. The non‐conforming product
observed in: 'Injection saloon'. The non‐conforming are identified by: Red
pallet. The non‐conforming products are properly identified throughout the
process. When nonconforming product is detected after delivery or use has
started, the organization takes actions appropriate to the effects, or
Control of nonconforming
8.3 potential effects, of the nonconformity. Sample records of actions taken: OK
product
There was no case in recent four years. When product needs to be
reworked, the has organization documents the rework process in a work
instruction, with determination of any adverse effects. Re‐work instruction:
There is no rework explained, in all identified cases, syringe shall be milled
and sold out. In case batch 7003, syringes are kept in warehouse, as
Warehouse manager says, they mill non conforming material after being 100
kgs.
8.5 Improvement
Clause observation
The organization has established documented procedures for the issue and
Implementation of advisory notices. Procedure name: consumer brochure
8.5.1 General and labels, Dated: 2011. No need to corrective action as the records suggest OK
that, There were no recall happened since 2010
By exception, we indicate the specific Strengths and weakness of the organization in light of the management system, as we perceive and seen through processes in
reference to requirements of the criteria being ascribed as these apply and relate to the assessment plan and planning of the assessment. This aspect relates to
Accreditation Body as it does to the protection of consumers in the client‐organization’s role within their respective supply – chain.
Disclaimers: (1) herein, we reiterate that any suggestion or opinion that the assessment team expresses does not construe to be a contractual requirement. (2) The
degree of certainty in conclusions increases by the competence of the assessment team as well as the attestation within the assessment protocol, values, mission
and vision under which we operate for the protection of consumers, still remains a certain level of uncertainty.
Strength Weakness
Brand Marketing
action Request Type I Form‐008 – as we indicate and that each of the RA addresses the basic four (4) questions as seen in Form‐008:
action Request Type II Form‐008 – as we indicate and that each of the AR addresses the basic four (4) questions as seen in Form‐008: