17. Quality Systems Audits
Results and Corrective Actions
Policy/Procedure for Quality System Audit
Quality System Audit Procedure
Vendor Survey Form
Section 820.20 outlines the quality system requirements of the Quality System (QS) regulation. As discussed in Chapter 2, every quality system should include: management policies; objectives; an organization; documentation; performance of tasks according to policies; monitoring of the system (feedback) and corrective action as indicated by the feedback. Section 820.22 requires that the quality system be monitored through audits. The analysis and use of feedback data from product acceptance, audits, complaints, repairs, and other sources are necessary parts of a self correcting quality system. Thus, the audit of a quality system is one of the most important GMP requirements. The quality system first implemented by a new manufacturer will change as the manufacturer grows and as the company=s products, operations and employees change. Therefore, a quality system should change with the company. Quality system audits are the primary tool for assuring that the quality system changes are correct and are correctly implemented.
A quality audit is a documented independent inspection and review of a quality system. The audit is performed on a periodic basis in accordance with written procedures. The objective is to verify, by examination and evaluation of objective evidence, the actual degree of compliance with those elements of the quality system under review. These audits are an essential part of every medical device manufacturer's effort to assure safe and effective devices. Regardless of how well a quality system is planned, monitoring of the system is required if the quality system program is to be effective in assuring that finished devices meet specifications. FDA analysis of factory inspections has shown that manufacturers who do not have an adequate quality audit system usually do not have an adequate quality system. An evaluation of approximately 2400 manufacturers that had received GMP inspections by FDA showed that manufacturers with an adequate quality audit system were in compliance with approximately 96 percent of the GMP requirements, while those that did not have an adequate audit system were in compliance with approximately 70 percent of the requirements.
If conducted properly, a quality audit can detect quality system defects. Isolation of unsatisfactory trends and correction of factors that cause defective products prevent the production of unsafe or nonconforming devices. Without an effective quality audit function, the quality system program is incomplete -- there is no assurance that a manufacturer is consistently in a state-of-control. In addition, the proper implementationof a quality audit system can result in cost savings by identifying and correcting problem areas. Without an audit, the quality system becomes an open loop without feedback to management and without corrective action. Without overt management support, the quality system program will eventually become ineffective and, as history has shown, ignored.
The QS regulation requires that planned and periodic audits of the quality system shall be performed to verify compliance with the quality system requirements. The audits are to be performed in accordance with written procedures by appropriately trained individuals who do not have direct responsibility for the matters being audited. Audit results shall be documented in written audit reports, which shall be reviewed by management personnel, who have responsibility for the matters audited, and by other involved parties. Follow-up corrective action, including re-audit of deficient matters, shall be taken when indicated. Upon request of a designated FDA employee, an employee in management with executive responsibility shall certify in writing that the audits have been performed and documented, the dates on which they were performed, and that any required corrective action has been undertaken.
To assure that company quality goals will be routinely met and to comply with the QS regulation, quality system audits should:
- measure the effectiveness of the quality system;
- provide objective evidence that adequate controls are in place; and
- assure that products and processes conform with specifications.
Where practical, manufacturers should include audits of their suppliers, calibration laboratories, and contractors as part of a quality system audit. Manufacturers should audit suppliers where needed, to assure that they have adequate quality system controls for raw materials and components shipped to and received by the manufacturers under supplier certification or certificate of compliance with specifications. An example of a detailed supplier (vendor) survey (audit checklist) form is in the Exhibits.
All manufacturers should have a written quality audit procedure, although the details will vary with the manufacturer size and nature of the manufacturing operations. An audit procedure should include:
- an objective,
- audit scope,
- an audit schedule,
- assignment of responsibilities,
- evaluation criteria,
- management review of results, and
- corrective action policies, schedules, etc.
Before writing their audit procedure, some manufacturers may find it helpful to rearrange the key GMP requirements for an audit in a structured format as shown below:
- Who? Designee(s)
- What? Quality system
- When? X months
- How? Per checklist
- Results? Report/review
- Actions? Corrective
This structured format helps lead auditors into covering key requirements in the audit procedure and "getting straight to the point when writing procedures." Thus, this format tends to reduce the length and increase the clarity of audit procedures.
Formal procedures should start with an objective. In this case, the audit objective was discussed in the opening paragraphs of this chapter -- to monitor the quality system and take any needed corrective action. The audit scope should include all functions that impact on whether devices will meet specifications. These functions include personnel training, facilities, environment, design controls, device master and history records, equipment calibration, suppliers, label control, process controls and validation, complaint files, data feedback, preparation for FDA GMP inspections, etc. Manufacturers that have a total quality system composed of a design quality system and a manufacturing quality system should audit the entire system; otherwise, it is no longer a total quality system! Audits should cover all buildings and operations as necessary to make certain that the desired or required quality system is properly implemented.
The quality system audit required by the QS regulation is not intended to be a product audit. However, the adequacy of procedures used to determine product acceptability should be audited periodically. Product audits and review of the device master record are desirable as independent evaluations of product quality to determine the product's fitness for use and conformance to specification and, these may be acceptable in satisfying most quality audit requirements when product and process are very simple and the operation is small. As products and processes become more complex, evidence from inspection and testing of products no longer provides full assurance that the manufacturing system will consistently produce quality products. Instead, full quality system audits are required to make certain that:
- the established quality system is adequate for producing devices that consistently meet the device master record requirements,
- all system requirements are being met, and
- the system will continue to function when new products are introduced, changes are made, the workforce is understaffed, and the manager is on vacation.
Manufacturers are responsible for deciding the frequency of audits. The frequency should depend upon previous audit findings, any indications of problems, and known stability of the manufacturing process. If an audit reveals no problems, the audit intervals could be lengthened -- if problems are identified, audits may need to be conducted more often. Audits are usually conducted every 6 to 12 months, but should not exceed 12 months. Some companies split their audit into parts, and perform one or more parts per month or quarter, or audit one or more operations per month or quarter. This approach is valuable because it tends to direct attention toward problems that can be resolved within reasonable time limits and existing budgets. However, such segmented audits may fail to identify company-wide problems. Thus, reviewers of segmented audit reports should look for indications of company-wide problems.
The QS regulation (820.22) requires that quality system audits be conducted by individuals not having direct responsibility for the matters being audited. This requirement may be satisfied by an audit team consisting of persons representing product development and manufacturing. Then, when the product development area is being audited, the manufacturing persons should have the lead responsibility and vice versa. For any element of the quality system being audited, at least one member of the team should not have direct responsibility for the element being audited. Management should designate one member as the team leader for a given audit in order to support consistency, timeliness, completeness, and uniform response. Of course, a consultant, corporate, or other independent auditor may be used.
The requirement for an independent audit should generally be met; however, if a very small manufacturer, particularly one in which everyone is directly involved in daily design and production activities, concludes that independent audits would be unduly burdensome or impractical, the requirement for independence may be waived. However, if FDA finds, as a result of inspection or other means, this waiver has compromised the quality system, FDA may require an independent audit, increase the frequency of FDA GMP inspections, or take other appropriate regulatory action.
Individual(s) responsible for conducting audits should be sufficiently trained and experienced to detect variations and problems in the quality system [820.20(b), 820.22]. An auditor is expected to objectively compare existing employee training, design controls, manufacturing processes, facilities, environmental control, records, test/inspection activities, label control systems, feedback, etc., against what they should be. To do this, the individual(s) should have a working knowledge of:
- how products are developed and validated,
- how the device(s) is made,
- the manufacturing processes and process controls,
- how changes are controlled,
- quality assurance principles that apply, and
- the human relations aspect of auditing.
As with any GMP training, a record shall be maintained of the audit training given each employee.
Because the quality system requires a written audit report, auditors should have sufficient writing skills to effectively communicate findings and recommendations. The effectiveness of the audit begins with the planning. The manufacturer should start by defining the purpose and scope of their audit keeping in mind their quality systems requirements. An audit team leader and the other members of this team should be identified early in the planning process. The members of this team should possess skill and knowledge of quality system principles. Preparing an audit checklist will enable the team to properly cover the quality system requirements. Review of previous audits and their resulting reports is an excellent way for the audit team to correctly evaluate their quality system audit program. The background preparation should also include becoming familiar with company policies, operations, and products. The audit team should notify the parties they will audit and also hold a pre-audit conference among the audit team members to clarify exactly what the audit will include and what the objective(s) of their audit will be. Thus, preparing for an audit should include elements such as:
- selecting a knowledgeable audit team,
- preparing an audit checklist,
- developing a planned and systematic procedure,
- structuring the audit to determine both positive and negative trends, and
- structuring the audit and report to promote follow-up actions.
Each manufacturer shall determine the criteria to be used for conducting the audit. In general, medium to large manufacturers will need extensive documentation outlining the areas to be audited and the acceptable criteria for each of these areas. The GMP requirements are a baseline for the evaluation criteria; however, because the QS regulation is broad, each manufacturer shall tailor the criteria to the design and manufacturing operations they are actually performing. Small manufacturers may need only minimal documentation, and this may consist of an audit checklist with appropriate ancillary instructions to assure that all aspects of the quality system are covered.
An audit checklist may be a series of questions, phrases, trigger words, or any combination of these that will prompt auditors to cover the entire quality system. Checklists should cover requirements of the QS regulation applicable to company products, operations, and other areas company management has decided are included in their total quality system. If operations or devices change, evaluation criteria and checklists shall be appropriately updated.
Results and Corrective Actions
A quality system audit program that has been established in accordance with the QS regulation and implemented in sufficient depth can detect undesirable variations and trends in operating procedures. Management awareness of these undesirable variations should lead to corrections and help prevent the design and production of unsafe, unreliable, or ineffective devices.
The QS regulation requires follow-up corrective action, including re-audit. When indicated, audit results shall be given to individuals responsible for each of the operations audited, especially if deficiencies are found. Audit results shall be reviewed by all key management personnel, especially those responsible for the matters audited.
An audit should never be used as a disciplinary tool. This use will lead to ineffective audits because employees may become reluctant to reveal any possible problems for fear of retribution.
Under 704(e) of the FD and C Act FDA has authority to review and copy all records required by the QS regulation; however, FDA has elected not to review audit reports. The exception [820.180(c)] to FDA's policy of not seeking access to reports of audits of quality systems is that FDA may seek production of these reports in litigation under applicable procedural rules, along with other confidential documents. Thus, a copy of the current audit report should be maintained by the manufacturer. FDA policy was established because the agency does not wish to prejudice audits by having auditors concerned that their comments will be reviewed by FDA investigators. Although FDA investigators do not have routine access to audit reports, they can request manufacturers to certify that audits have been conducted and the results documented; however, investigators do not routinely request certification. If requested, an employee in management with executive responsibility should certify, in writing, that the manufacturer has complied with the audit requirements of the QS regulation.
Investigators usually will ask questions regarding the audit report such as:
- who prepared the report;
- what does the quality system audit include;
- when was the report written;
- using the checklist how should the audit be conducted;
- who reviewed the information and wrote the report; and
- were corrective action and re-audit(s) taken based on the audit result.
If investigators suspect audits are not being conducted, questions to determine consistency in answers may be addressed to those individuals who should have reviewed these reports. FDA investigators will routinely review audit procedures and audit checklists.
Two examples of audit procedures with checklists are included in this chapter. These may be modified to match individual operations as appropriate or used as guidances.
Policy/Procedure for Quality System Audit
In response to requests by small manufacturers, DSMA developed this procedure as an example of a minimum procedure for quality system audits. Following the procedure are comments to aid small manufacturers in completing the procedure and developing a checklist that should be used with it.
No details are given for the format of the audit "report" because the format generally is not important for the small manufacturer -- employees of small manufacturers communicate daily with each other. In fact, the "report" may be the list of findings neatly noted on the audit checklist. As noted in the procedure, however, summaries of the audit findings and corrective actions are recommended. The format Who, When, etc. discussed in the text, was used to develop this example procedure. The first three items in this format are reflected in item 1 of the example and the remaining three are reflected in items 2, 3 and 4 of the example. The scope encompasses the entire quality system.
Quality System Audit Procedure
Quality System Audit Procedure is an audit procedure that can be used by a medium to large manufacturer. In comparison to the small company, there are more people on the audit team, more audits per year, and the reports are distributed to more managers, some of which may be at corporate headquarters. Therefore, this procedure contains more details than the one suggested for the small company. For example, the procedure dictates the format of the audit report for the benefit of the managers, who may review reports for many different operations per year.
Vendor Survey Form
The vendor survey form is applicable to a vendor or contractor or may be modified and used as an internal audit checklist. This survey form is divided into areas of concern such as raw material and component control, manufacturing, quality control/assurance, etc. Also, it is a more conventional checklist with places to check off answers to the questions. This form includes a header with space for manufacturer name, address, date prepared, etc., and general information about the manufacturer such as, annual sales, years in business, other plant locations, etc. Your manufacturers can look at these two styles of checklists and decide to use one or the other, a combination of both, or a totally different format.
Sheet 1 of 6
Title: POLICY/PROCEDURE FOR QUALITY SYSTEM AUDIT No. _____ Rev. ______
1. A general audit of the entire quality system shall be performed by________________________ every_______ months (an audit team may be used).
2. The latest company approved audit checklist (number) _________shall be used. The audit checklist shall be updated as required and approved by __________________________to reflect our current quality system needs.
3. The completed checklist and audit results summary report shall be reviewed with the following managers, as appropriate, who are responsible for the matters audited: ____________________, _______________________________________and____________________________________ . Minutes of the review meeting, including a list of attendees and desired corrective actions, shall be taken, distributed and filed by__________________________________ . This same procedure shall be used when reviewing the findings of GMP inspections by FDA investigators. (820.20)
4. Corrective actions shall be taken by all affected persons as discussed in the review meeting. ____________________________ will coordinate the corrective actions, re-audits, and keep management informed. A summary report of the status of the corrective actions, as determined by a re-audit of the affected areas or other appropriate means, will be written by _________________________ and filed with the original audit report. The status report shall be updated at least bimonthly if there are any uncompleted corrective actions.
Comments on the Policy/Procedure
A. "Rev." is the revision level of the latest company approved procedure.
B. The above blanks should be completed with employee position titles and, if desired, employee names.
C. An audit checklist may be a detailed series of questions, phrases, trigger words or any combination of these to assure that the auditor covers the entire quality system. The checklist should cover the requirements of the QS regulation applicable to each company's products and operations plus other areas that company management had decided are included in the total quality system. A suggested way to develop a question-type checklist is to refer to the table of contents of the QS regulation and the chapters of this manual. Then generate questions for each topic as applicable to specific products and operations of the manufacturer. If operations or devices change, the checklist should be updated. A small portion of a quality audit checklist follows.
Sheet 2 of 6
A few cites are given. There are more. For example most of the QS regulation applies to labeling -- not just 820.120.
SPECIFICATION CONTROLS (820.30, .40, and .181) YES NO COMMENTS
1. Is an adequate system in place to control
all engineering drawings, specifications
and other related documentation?
2. Does the system require adequate review,
and approval of all new documentation and
changes to documents?
3. Does the system require controlled,
timely distribution of new specifications and specification changes?
4. Are procedures provided and adequately
implemented to assure collection of obsolete documentation?
5. Are all specifications used in production
approved, dated, and current?
Sheet 3 of 6
PROCESS CONTROLS (820.70, .40, .60 and .80, .86) YES NO COMMENTS
1. Are current, approved process specifi-
cations/procedures such as work instruction,
etc., used to define each process?
2. Are process changes made according to a
formal change system and documented?
3. Are process changes communicated in a
4. Do process specifications and procedures
properly reflect the work to be accomplished?
5. Are adequate acceptance and rejection criteria
provided for the output of each process?
6. Are in-process and rejected items adequately
identified and/or segregated to prevent mix-ups?
Sheet 4 of 6
PERSONNEL 820.20(b)(2), 820.25, and 820.70(d) YES NO COMMENTS
1. Are there sufficient personnel having the
necessary education, background, training,
and experience to assure that all design and
manufacturing operations are correctly performed?
2. Are training programs conducted and documented?
Is the program proactive? Do design personnel
have basic training in safety, use of standards,
labeling, and applicable regulations?
3. Are all employees made aware of device
defects which may occur from the improper
performance of their specific jobs?
4. Are all employees including salespersons
made aware that they must report all
complaints received from any source to
the company complaint department?
5. Are quality system personnel made aware of defects
and errors likely to be encountered as
part of their individual quality system function?
6. Are verification/validation personnel made aware
of design errors that may be found?
7. Are personnel in contact with the device or its
Sheet 5 of 6
QUALITY ASSURANCE FUNCTIONS YES NO COMMENTS
1. Does the quality assurance unit or qualified
designee do the following?
a. review customer purchase orders
b. approve or reject components
c. approve or reject manufacturing materials
d. approve or reject in-process materials
e. approve or reject packaging materials
f. approve or reject labeling
g. approve or reject finished devices
h. approve or reject devices manufactured by
i. review production records
j. approve or reject devices processed by
k. approve or reject devices packaged by
l. approve or reject devices held under
contract by another company
m. help provide solutions for quality system problems
n. verify implementation of solutions for
quality system problems
o. assure that all quality system checks are appropriate
p. assure that all quality system checks
are performed correctly
2. Are periodic audits of the quality system conducted
to verify compliance with quality system program
3. Are audits of the quality system program:
a. performed in accordance with written
b. conducted by appropriately trained
c. conducted by individuals who do not have
direct responsibility for matters being audited?
4. Are audit results:
a. documented in written audit reports?
Sheet 6 of 6
QUALITY ASSURANCE FUNCTIONS YES NO COMMENTS
b. reviewed by management having
responsibility for the matters audited?
5. Does company have a copy of the last
audit report on file?
6. Is follow-up corrective action, including
re-audit of deficient areas, taken when
QUALITY SYSTEM AUDIT PROCEDURE
Sheet 1 of 3
No._______ Rev._____ Approved___________________________________ Date _____________
ECN History____________________________________________________________________ ___________________________________________________________________________________
POLICY: Periodic and planned audits of systems, training documentation processes, product flow and feedback shall be performed to assure compliance with regulatory and company requirements for current Good Manufacturing Practices (quality system).
SCOPE: All facilities, design activities, manufacturing operations, and product lines.
PROCEDURAL GUIDE: An audit of design activities shall be done annually. Routine quality audits of selected production areas shall be conducted each month. The entire operation shall be covered during a 12-month cycle. An area may be audited more than once. An "Action Audit" for any area or element may be initiated by the Manager of Quality Assurance at any time if a special problem arises.
The teamwork approach shall be used to identify and correct deficiencies.
The audit team shall consist of the Senior Quality Auditor (team leader) plus one or more individuals from other disciplines who have no direct responsibility for the area being audited. A team auditing an Operations unit should include an R&D representative. A team auditing a quality systems unit should include an Operations representative. An audit of design activities shall include a representative from both the regulatory and the manufacturing divisions.
The Manager of Quality Assurance selects the team member in consultation with the Department Managers.
A. AUDIT PREPARATION - The Quality Auditor (team leader) reviews applicable change control records subsequent to a design transfer, any FDA clearance delay information, recall records, standard manufacturing procedures, device histories, complaint history, device labels and inserts, previous audits with results, follow-up audits, plus any other document relative to the audit.
B. AUDIT INITIATION - The Quality Auditor prepares/updates an audit checklist for systematic examination of the area to be audited, informs the Manager of the department being audited at the start of the audit, and reviews observations with the Department Manager.
C. AUDIT ANALYSIS - The Quality Auditor reviews the data gathered, verifies important details, and writes an audit report according to the format delineated in the attached audit report outline.
Sheet 2 of 3
D. ISSUANCE OF AUDIT REPORT - The Quality Auditor issues the written audit report to the President and Department managers within three working days following completion of the audit. If conditions are critical, the Director of Quality Assurance shall verbally brief appropriate staff members within 12 hours following audit completion. Audit reports shall be stamped "Confidential".
E. CORRECTIVE ACTION - The appropriate Management staff member shall be responsible for developing a schedule for correcting deficiencies cited in the audit report and submitting same within five working days to the Quality Assurance Manager. Included in the correction schedule shall be the responsible individual, and the date when corrective action will be completed. The Manager of Quality Assurance shall act as arbiter, if necessary, to judge validity of the deficiency, responsible individual, and reasonable date to complete the corrective action.
F. AUDIT FOLLOW-UP - The Quality Auditor maintains a log listing deficiencies, responsible individual, target date for corrective action, and actual date of correction. If the same deficiency occurs on a second follow-up audit, the President shall be notified in writing by the Quality Assurance Manager.
G. LOG OF AUDITS AND FOLLOW-UP AUDITS - The master log shall be maintained by the Senior Quality Auditor. The audit log file shall include a copy of current audits, list of areas to be audited during the 12-month period, and list of areas audited to date (i.e., part of the Master Log).
H. REPORT NUMBERS - Audit numbers shall be composed of the date followed by the sequential number of the audit being reported (e.g., 98–4 for the 4th audit during 1998).
AUDIT REPORT COVER DATA
Area Audited ____________________________ Audit No._____________ Date: ____________
Audit Team members________________________________________________________________
Sr. Auditor's Signature: ___________________________________________________ (Team Leader)
1. PURPOSE AND AREA DESCRIPTION - Describe initiating factors for the audit, limitations of audit, and area being audited.
2. MAJOR FACTS - Summarize for management review the most undesirable conditions and practices in order of their relative importance.
Sheet 3 of 3
3. OBSERVATIONS AND FACTUAL DETAILS - Give a detailed account of the current practices and the deficiencies listed in four below.
4. DEFICIENCIES - List deficiencies in procedures, standards, documentation, safety, etc., along with identity of relevant regulation, SMP, SOP, etc.
5. FOLLOW-UP - State plans for follow-up review to establish individual responsibilities and completion dates.