130 - QMSR Changes to Traceability/Reporting, Independent Reviewer & Risk Management, Learning New Regulations and MDSAP with Aaron Snyder
Aaron Snyder, VP of Quality Assurance at Allotex and AAMI Faculty member, explains the FDA's Quality Management System Regulation (QMSR) and its incorporation of ISO 13485. He details specific changes to traceability, including the requirement to meet 21 CFR Part 821 (Medical Device Tracking) and Part 830 (UDI) in addition to ISO requirements, and new FDA-specific controls for records, packaging, and labeling. Snyder contrasts FDA inspection techniques, which focus on finding non-compliance through deep dives into complaint and service records, with ISO surveillance audits that verify conformity. He also discusses the impact of QMSR on MDSAP companies, noting that while harmonization simplifies compliance for large firms, smaller US-only companies face more work to adopt the process approach and explicit risk management.