GP-022 Document translation
Procedure flowchart
Purpose
Define the methodology for the translation of documentation related to the manufacturing of medical devices and provision of the services that we carry out.
Scope
Documents pertaining to the QMS and documents related to the device, especially those documents whose innaccurate translation may affect how the device is used and therefore potentially compromise its safety and performance.
As a general rule, it will apply to translations from Spanish to English, or vice versa. The same procedure applies in case of need of translation to other languages.
Responsibilities
JD-001
Provide the organization and its members with the necessary resources to carry out their obligations in the most efficient way possible.
Directly supervise potential outsourced translation activities.
JD-003
Review the translations carried out by the JD-004
, either by their own means, or with the support of third parties specialized in this regard.
JD-004
Carry out the required translations, or delegate to third parties, of the required documents.
JD-005
Review the translations carried out by the JD-004
, either by their own means, or with the support of third parties specialized in this regard.
Inputs
Documents that need translation, including the technical documentation and the documents included in the QMS.
Outputs
The translated documentation that can be presented in dual mode or in the language to be translated only. In other words: you may find some documents that include more than one language at once.
Development
Translation process
We identify two available translation methods:
- Translation by a team member: when the person in charge of the translation has proven proficiency in the language (native knowledge or at least a B2 level). The language competence, when not native, will be recognized by certification of a language school or equivalent certificate.
- Translation by external translators: outsourcing the translation to a specialized translation company is applied when the translation cannot be performed internally or requires a certified translation. In case of external translation, the translation company will be assessed and evaluated according to the procedure
GP-010 Purchases and suppliers evaluation
.
You can use professional commercial translation tools as an aid, but the result of that translation will never be considered approved without a proper review of it.
When there is a need for translation, JD-004
will initiate and coordinate the translation process by identifying the suitable translation method according to the required language.
For the translation of Instructions for Use (IFU), JD-004
shall review the language requirements available in the MDR - language requirements for manufacturers
document (published by the European Commission) to start the translation process and be compliant with Article 10(11), Article 41 of MDR 2017/745
and Article 5(11) of Regulation (EU) 2021/2226
on electronic IFU.
Languages requirements shall be reviewed before placing the medical device into Member States market: once the countries where the medical device is planned to be sold are defined and the languages requirements are identified, the traslation process can start.
Everytime there is a sales opportunity on a new market of one of the Member States, the JD-004
shall be informed to evaluate the language requirements and availability of translated IFU. In the case the IFU in the required language are not available, JD-004
will start the translation process before making the medical device available to clients.
Translation review process
When the translation is done internally, the translated document requires review.
The minimum level required for document review is C1 (Effective Operational Proficiency). In the event that the person responsible for the review (usually JD-004
) does not have that level, a member of the organization who does, or external personnel, will be contacted to carry out the review.
Once reviewed, the document shall be managed according to teh requirements set ou in GP-001 Documents and records control
.
In special cases, such as for regulatory stipulations, we will hire companies specialized in a specific domain of language, to carry out the appropriate translations for each specific case, as explain in the section above.
Naming standards
When referring to language and countries identification, we follow ISO 20417.
When referring to languages, and specially when naming documents, we follow ISO 639-1. More specifically, we use the Alpha-2
code, which is a two letter lowercase word that represents a language.
For example, Spanish is expressed as es
, while English is called en
.
When we require to be more specific regarding a dialect or geographical localisation, we use ISO 3166-1, that defines codes for the names of countries, dependent territories, and special areas of geographical interest, and we append the ISO 3166-1 Alpha-2
code to the ISO 639-1 Alpha-2
code.
Examples
ISO 639-1 code | ISO 3166-1 code | Result | Meaning |
---|---|---|---|
es | ES | es_ES | Spanish as spoken in Spain |
es | CO | es_CO | Spanish as spoken in Colombia |
Availability of translated IFU
Once the translated IFU are reviewed and approved, they will be made available in Legit.Health website. There, the users will be able to choose the IFU in the required language.
The IFU of the medical device are also accessible via a URL: when the IFU are displayed, the user can choose between the available languages.
The availability check of the translated IFU in the website and at the IFU URL is part of the IFU validation documented in T-001-006 IFU and label validation
.
Associated documents
GP-001 Documents and records control
Signature meaning
The signatures for the approval process of this document can be found in the verified commits at the repository for the QMS. As a reference, the team members who are expected to participate in this document and their roles in the approval process, as defined in Annex I Responsibility Matrix
of the GP-001
, are:
- Author: Team members involved
- Reviewer: JD-003, JD-004
- Approver: JD-001