Quality - SOP - Non-Conforming Product

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The process outlined in this document will ensure that your company complies with the relevant clauses of ISO 13485 (8.3), 21 CFR (820.90), and EU MDR/IVDR.

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Purpose of Document

It is critical to ensure that all products which do not meet company specifications or regulatory requirements are prevented from being released or (if already released) are recalled from the market, and that the root cause(s) of the non-conformance are investigated and understood. The purpose of this procedure is to describe the steps to follow to control and investigate non-conforming products, which may be purchased items, in-process, finished or returned products. This process will ensure that your company maintains control over non-conforming products and complies with the ISO 13485, 21 CFR 820, MDR (2017/745), IVDR (2017/746) guidelines and their QMS.

Scope of Document/s

This procedure relates to the control of non-conforming product (suspected or confirmed) which was "manufactured" under the quality management system of your company. Non-conforming product can be identified by any means, e.g. quality control inspections by your company, review of batch records, the receipt of customer complaints (e.g. non-functioning components, incorrect versions, incorrect risk scores, incorrect IVD kit components), or through internal or external audits or inspections.

This procedure describes how to:

  • prevent the use and release of non-conforming product, and
  • manage product returned from the market. Where this relates to software, physical return of "product" will not be relevant.
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