RMBI - Experts in FDA Compliance and Regulatory Affairs

            QSIT & FDA "483" Observations

The FDA in early 1998 proposed and ultimately adopted a new process for performing quality system inspections at medical device manufacturing facilities. The new method is called Quality System Inspection Technique (QSIT.)  QSIT uses a "top down" approach making the management of the quality system the central theme of of facility inspections. The intent is to help investigators to concentrate on manufacturing and quality areas, increase compliance to the quality system regulation, and move the FDA inspection techniques in line with Global harmonization efforts.

The QSIT approach assumes that there are seven sub-systems in the quality system regulation (21 CFR, Part 820). Four are considered primary areas and these four; Management Controls, Design Controls, Corrective and Preventive Actions (CAPA) and Production and Process Controls are the main focus during an inspection. The remaining three subsystems; Material Controls, Records, Documents, and Changes, Equipment and Facilities are covered as links associated with the four primary subsystems.

The FDA in early 1998 proposed and ultimately adopted a new process for performing quality system inspections at medical device manufacturing facilities. The new method is called Quality System Inspection Technique (QSIT.)  QSIT uses a "top down" approach making the management of the quality system the central theme of of facility inspections. The intent is to help investigators to concentrate on manufacturing and quality areas, increase compliance to the quality system regulation, and move the FDA inspection techniques in line with Global harmonization efforts.

The QSIT approach assumes that there are seven sub-systems in the quality system regulation (21 CFR, Part 820). Four are considered primary areas and these four; Management Controls, Design Controls, Corrective and Preventive Actions (CAPA) and Production and Process Controls are the main focus during an inspection. The remaining three subsystems; Material Controls, Records, Documents, and Changes, Equipment and Facilities are covered as links associated with the four primary subsystems

This chart, compiled after the introduction of QSIT from a sampling of  "483" observations, shows the percentage of problems reported for each of the four major quality system subsystems

Establishing an effective and appropriate quality system and managing regulatory compliance is often complex, constantly changing, and demands diligence and training to assure that all company operations are performed within regulatory requirements. It can be a daunting and often stressful task that can become overwhelming.

If you are setting up a regulatory compliance program or improving your existing system, we can help. At R. M. Baldwin, Inc. we provide cost effective regulatory compliance programs, tools, and training that can save time and money.

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