Inspection Program
Overview
Health Canada's inspection program involves on-site visits to manufacturers, importers, and distributors of medical devices. Inspections verify compliance with the Medical Devices Regulations and the QMS requirements for establishment licence holders.
Types of inspections
Routine inspections
Scheduled inspections of MDEL holders, typically on a risk-based cycle (e.g., every 2–5 years depending on risk level). Routine inspections are announced in advance.
Surveillance inspections
Targeted inspections triggered by:
- Mandatory problem reports or recall activities
- Complaints received by Health Canada
- Intelligence from other regulatory authorities
- Post-market testing results
Surveillance inspections may be unannounced.
For cause inspections
Inspections specifically investigating a suspected compliance issue. These are typically unannounced or at very short notice.
What inspectors look for
For manufacturers, inspectors typically review:
- QMS documentation (quality manual, procedures, records)
- MDSAP or ISO 13485 audit certificate validity
- Device Licence maintenance (amendments filed when required)
- Post-market surveillance and complaint handling records
- Mandatory problem reporting records
- Recall procedures and records
- Labelling compliance
For importers and distributors, inspectors typically review:
- MDEL validity and currency
- QMS elements (complaint handling, distribution records, recall procedures)
- Distribution records (lot-level traceability)
- Mandatory problem reporting records
- Evidence that all distributed devices hold valid Device Licences
Preparing for an inspection
Best practices:
- Maintain your QMS in a continuously inspection-ready state
- Conduct periodic internal audits to identify gaps before Health Canada does
- Ensure QMS documentation is current, accessible, and accurate
- Train all relevant staff on their roles in the QMS
Inspection outcomes
After an inspection, Health Canada issues an inspection report classifying the findings:
- Satisfactory — no significant deficiencies
- Acceptable with deficiencies — minor deficiencies identified, corrective actions required
- Non-compliant — significant deficiencies; corrective action plan required with follow-up inspection possible
- Unsatisfactory — serious non-compliance; may trigger immediate enforcement action
Legislative source: Food and Drugs Act, ss 22–23; Medical Devices Regulations, SOR/98-282