R-023-001_005 Change control
Description
- Change name: Changes to QMS processes due to MDR transition
- Change description: Adaptation of the Quality Management System (QMS) to comply with the new requirements established by the Medical Device Regulation (EU) 2017/745 (MDR). This includes modifications to product development processes, design and development documentation, software validation processes, and risk management documentation to ensure full compliance with MDR requirements during the transition from MDD to MDR.
- Source of change: Regulatory change (MDR 2017/745 transition).
Impact analysis
- Regulatory impact: is the change classified as significant?
- Yes (it requires notification to Regulatory Authorities): BSI (Notified Body) was notified as part of the MDR certification process.
- No (it does not require notification to Regulatory Authorities)
- Risk analysis impact: Risk management documentation was updated to comply with ISO 14971:2019 and MDR Annex I requirements. Risk-benefit analysis was enhanced according to MDR requirements.
- Quality documentation impact:
GP-012 Design and development- Enhanced documentation requirements per MDR Annex IIGP-028 Post-market surveillance- New procedure created to comply with MDR Articles 83-86GP-029 Clinical evaluation- New procedure created to comply with MDR Annex XIVGP-030 Vigilance- Updated to align with MDR Article 87-92 vigilance requirements- Technical documentation structure updated per MDR Annex II and Annex III
Approval
The change is approved.
Plan
- Update
GP-012 Design and developmentto comply with MDR Annex II technical documentation requirements. - Create
GP-028 Post-market surveillanceprocedure to comply with MDR Articles 83-86 and Annex III. - Create
GP-029 Clinical evaluationprocedure to comply with MDR Annex XIV requirements. - Update
GP-030 Vigilanceto align with MDR Article 87-92 and serious incident reporting requirements. - Restructure technical documentation according to MDR Annex II and Annex III.
Implementation
Implementation date: 2025-06-30
Status
QMS changes implemented. Currently under review by BSI (Notified Body). Pending confirmation and CE marking under MDR.
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 Design & Development Manager, JD-004 Quality Manager & PRRC
- Approver: JD-001 General Manager