QMS Requirements Under MedDO/IVDO
Overview
A quality management system (QMS) is required for manufacturers of Class IIa, IIb, III, and implantable Class I devices under MedDO. The QMS must cover all activities relevant to the quality and safety of the device, from design through distribution and post-market surveillance.
When a QMS is Required
| Device Class | QMS Mandatory? | NB QMS Audit? |
|---|---|---|
| Class I (standard, non-implantable) | Strongly recommended, not formally required for conformity assessment | No |
| Class Im, Is, Ir | Recommended | No (NB involvement limited to specific aspect) |
| Class IIa | Yes — full ISO 13485 QMS | Yes (Annex IX Chapter I) |
| Class IIb | Yes — full ISO 13485 QMS | Yes (Annex IX Chapter I) |
| Class III | Yes — full ISO 13485 QMS + design controls | Yes (Annex IX Chapters I and II) |
| IVD List A | Yes | Yes |
| IVD List B / Self-test | Yes | Yes (Chapter I) |
| IVD General | Recommended | No |
QMS Scope Requirements
The QMS scope must cover all processes that affect device quality:
- Design and development controls (required for Class II/III) — see Design Controls & CAPA
- Risk management — ISO 14971 process must be integrated with the QMS
- Purchasing and supplier controls — see Supplier Controls
- Production and process controls — manufacturing process validation, environment controls
- Inspection and testing — incoming inspection, in-process testing, final release
- Nonconforming product controls — process for identifying and managing nonconforming devices
- CAPA — corrective and preventive action system
- Complaint handling — receiving, evaluating, and responding to customer complaints
- Post-market surveillance — PMS data collection and review integrated with the QMS
- Management review — periodic senior management review of QMS performance
MedDO-Specific Elements Beyond Standard ISO 13485
MedDO/MDR conformity assessment requires the QMS to address certain elements that go beyond standard ISO 13485 certification scope:
- GSPR compliance management — processes ensuring all devices placed on the market continue to comply with applicable GSPRs
- Unique Device Identification (UDI) — processes for UDI assignment, labelling, and DAPI registration
- Post-market surveillance integration — active PMS system generating data that feeds back into risk management and GSPR compliance
- PSUR preparation — processes for preparing periodic safety update reports on schedule
- SSCP maintenance — for Class III/implantable devices: processes for updating and validating the SSCP
Official Sources
Disclaimer
AI-assisted navigation aid only. Always verify against official Swissmedic and Fedlex sources. Not legal or regulatory advice.