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- Can MDSAP RAs void audits by an AO due to inadequate methods? If so, will manufacturers need another audit?
Can MDSAP RAs void audits by an AO due to inadequate methods? If so, will manufacturers need another audit?
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Audits FAQs
- How can a manufacturer participate in the MDSAP?
- Does the MDSAP add requirements for the manufacturer?
- How does the MDSAP ensure medical devices are manufactured in accordance with multiple regulations?
- How does MDSAP ensure effort is not duplicated for manufacturers that sell in multiple jurisdictions?
- Does the audit process include daily review of areas of concern?
- Are MDSAP audits conducted by single or multiple auditors?
- Who assigns a particular auditor?
- Do manufacturers seeking certification need to comply with regulations in a jurisdiction where they do not market?
- Can MDSAP RAs void any audits by an AO due to inadequate audit method?
- If an AO issues a negative final report, can the manufacturer still sell in MDSAP jurisdictions?
- How do manufacturers show they have been successfully audited under the MDSAP?
- If a manufacturing site is already under regulatory action with an MDSAP RA, can they participate in the MDSAP?
- What happens to a manufacturer when the AO recognition is revoked?
- Can non-participating RAs have access to MDSAP audit reports? How can the veracity of certificates be confirmed?
- Is the CE certification included in the outcome of a successful MDSAP audit?
- What is the definition of a "campus" in the context of multi-site QMS audits?
- What is the primary benefit of the "campus" concept for multi-site organizations?
- Do audit tasks have to be repeated during a multi-site audit?
- How should AOs treat organizations with a legal address with no association to the company’s daily operations?
- Should a remote-audited facility be included on the certificate?
- How should AOs treat “virtual” manufacturers?
- How should AOs apply the audit approach when sites are not responsible for all QMS activities?
- When should AOs employ technical experts for audits?
- Under what circumstances would an MDSAP audit be followed by an RA inspection?
- Why have the MDSAP RAs imposed an initial response period of 15 calendar days?
- What are the requirements for transfer of certification for manufacturers?
- How long can an MDSAP certificate reference a jurisdiction where no product is distributed?
- Can the manufacturer exclude a jurisdiction or products from the scope of an MDSAP audit?
- What constitutes a counterfeit medical device or a fraudulent activity requiring notification of RAs?
- What is the expectation for Class I medical device manufacturers participating in the MDSAP?
The MDSAP does not include mechanisms for requiring an audit to be re-done. Nevertheless, if an audit report appears to be unreliable, does not include a participating MDSAP jurisdiction in which the products are distributed, or does not include all the appropriate devices in the audit scope, an MDSAP RA may not be able to utilize the certificate or report as part of their process to grant a marketing authorization. A misleading audit report may also present a risk to public health and could lead the RAs to conduct their own follow-up inspection. Alternatively, an RA may request that an AO conduct a special audit to follow up on an issue. (IMDRF MDSAP WG N3 – clause 9.6.6.)
Manufacturers may forward a complaint with the MDSAP RAs in relation to an audit performed by an AO. The complaint will be processed using the procedure described in MDSAP QMS P0011.