Quality System Basics Awareness of the Quality Policy, Manual, and QMS. ENT Version 2.0
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1 Quality System Basics Awareness of the Quality Policy, Manual, and QMS ENT Version 2.0
2 In this module you will learn MDT Quality Policy Location of the Quality Manual and Quality Documents Definition of the Quality Management System (QMS) Regulations and Standards we must follow Difference between a Paying vs. Permitting Customer Common Quality Acronyms Impact of Not Following Procedures 2 MDT Confidential
3 Quality Policy The policy is displayed in various locations around the facility and on specific badge cards. 3 MDT Confidential
4 Quality Manual and QMS The Quality Manual describes the Quality Management System (QMS), including quality procedures and quality related activities used by Medtronic Xomed, employees, operations, products and facilities located in Jacksonville, Florida and Mystic, Connecticut. The QMS is a process based system that takes system inputs from customers that are used for product development, manufacturing, distribution and servicing, and then monitors and analyzes feedback from customers as improvement input into the QMS and/or product. 4 MDT Confidential
5 Regulations and Standards The QMS provides activities that meet the requirements of the following laws, regulations and/or industry standards: U.S. FDA Quality Systems Regulations (QSR) European Communities Directive 93/42/EEC Medical Devices Canadian Medical Device Regulations ISO 14971:2007 Medical Devices - Application of Risk Management to Medical Devices. Japanese Quality Management System Ordinance (MHLW Ministerial Ordinance No. 169) Medtronic Corporate Policies and other applicable quality system regulations or standards. Specific Regulations and Standards 21CFR Part 820 Code of Federal Regulations (Sec. 820.XX) U.S. Law that governs Medical Devices Also referred to as Good Manufacturing Practices (GMPs) ISO International Standard Rules to sell and produce in Europe. Governs Medical We must follow all laws, regulations, and/or industry standards! 5 MDT Confidential
6 Paying vs. Permitting Customer When we think about our overall types of customers, we have two types: The paying customer (e.g. Doctors, Patients) Buy and pay for products Keep us in business The permitting customer (e.g. FDA) Certify our products and processes Allow (permit) us to do business 6 MDT Confidential
7 Quality Acronyms SOP Standard Operating Procedure This is just a short list of the numerous acronyms used around the organization! SSOP Sector Standard Operating Procedure QCFM Quality Controlled Form FDA Food and Drug Administration Additional Mystic Acronyms: PR Product Specification LS Label Specification MS Material Specification CFR Code of Federal Regulations (21 CRF 820) ISO International Organization for Standardization (ISO 13485) TM Test Method PS Process Specification GMP Good Manufacturing Practices 7 MDT Confidential
8 Where can I find SOPs SSOPs QCFMs PRs, TMs, LSs, MSs Quality Manual and Policy Agile: 8 MDT Confidential
9 Impact of Not Following Procedures (NFP) We have procedures (i.e. SOPs) in place for many important reasons. One reason is to ensure quality and consistency in the products we design, manufacture, and deliver to the customer. When procedures are not followed (and in the order they are designed too) we can cause harm to the company and most importantly to our patients. The cost to society for people not following procedures is enormous. Personal and Financial Information Exposed Safety, Injury, and/or Death The cost to a company for an individual not following procedures can be extremely high. FDA Fines Production Stopped Facility Closure 9 MDT Confidential
10 What can I do? FOLLOW THE PROCEDURE Compare the procedure to the work actually being performed Notify your supervisor if there are differences. It s Everyone s Responsibility! 10 MDT Confidential
11 What if I don t follow the procedure? Process for Violations Compliance is Mandatory Adherence to the Quality Management System (QMS) is a condition of employment for all Jacksonville and Mystic employees Violations will be handled promptly 11 MDT Confidential
12 Factual Determination/Investigation Process Failure to follow Procedure Investigation Quality System Training Resources If there is a suspected violation, the Department Manager and Human Resources will conduct an investigation to determine the root cause. The investigation will review the Quality System, Training, Resources, and/or Personal Responsibility (e.g. employee chose not to follow the procedure) as the possible cause. Depending on the outcome, the disciplinary process may be initiated. Personal Responsibility Disciplinary Process 12 MDT Confidential
13 Factual Determination/Investigation The goal is to find and correct system issues. The investigation seeks to identify: General facts Employee s explanation Employee s awareness of QMS requirements Factors outside the employee s control Was violation willful or inadvertent? Did violation increase risk or patient safety? Did violation increase regulatory or legal risks? Does employee have history of prior violations? Investigation team determines if violation occurred. If so, disciplinary action is taken 13 MDT Confidential
14 Suspected Violation Disciplinary Actions: As determined to be appropriate, an employee who is found to have violated the QMS may be subject to any of the disciplinary actions outlined below, up to and including immediate termination: Verbal Warning/Coaching First violation appears to be inadvertent and is determined not to have given rise to a risk to patient safety or material legal or regulatory risk for Medtronic. Not documented. Written Warning gave rise to a risk to patient safety or material legal or regulatory risk for Medtronic, second warning within past 24 months; and is determined to have been a knowing or willful violation. Suspension is preceded at any time by a written warning for any prior violation within past 24 months; resulted in a substantial risk to patient safety or substantial legal or regulatory risk for Medtronic, is determined to have been a knowing or willful violation. Termination is preceded at any time by a suspension; gave rise to a severe risk to patient safety or serious legal or regulatory risk for Medtronic; is determined to have been a knowing or willful violation. 14 MDT Confidential
15 Summary The Quality Management System is in place to meet the requirements of particular laws, regulations, and/or industry standards (such as QSR and ISO). The Quality Manual, Policy, and Documents (e.g. SOPs and QCFMs) can be found on the Agile Portal. Not following procedures can have a large negative impact on society and the company. All employees should be aware and follow the Quality Policy are responsible for following established procedures and notifying management of any differences must adhere to the Quality Management System (QMS) For more information: Review the Quality Manual Contact your manager, Human Resources, and/or Compliance Dept. 15 MDT Confidential
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