Firstly I should introduce myself. I am Compliance Officer for *** based in the UK. *** are distributors of medical devices and have a vast range of products acquired from our list of approved suppliers.
We, as an organization have been authorized by our suppliers to ensure that all products meet the MDR standards and, to document and submit these products to the *** website.
What I need to know firstly, is what documentation I need to put together for each product, such as certificate, instructions for use etc….
We as an organization are already ISO 9001 accredited so do not need to undertake another ISO accreditation.
Is there a specific list of documents required for each product? I am taking this is phases, and phase I will be to pull all documentation together. Phase II to establish the class of products and finally Phase III to submit to the website.
According to the MDR 2017/745, Article 14, you as distributor need to prepare and check, the following the documentation for each medical device (or device family):
Declaration of conformity
Instruction of use and labels are on the proper language
The distributor of medical devices needs to have implemented a quality management system (QMS) (in MDR there is no requirement for certification of the quality management system, only that QMS must be implemented). In ISO 13485:2016 in 1. section – Scope – is stated that this International Standard specifies requirements for a quality management system where an organization needs to demonstrate its ability to prove that medical devices and related services meet customer and applicable regulatory requirements. Such an organization can be involved in one or more stages of the medical device life-cycle including design and development, production, storage and distribution, installation, or service.
Further on, in MDR (Article 1, section 2) is stated that all medical device needs to be in compliance with harmonized standards or state-of. the art standards. On the list of harmonized standards, only one standard that is considering the quality management system is ISO 13485:2016. Therefore, it is expected that distributors and importers will also have implemented a quality management system according to the applicable requirements from ISO 13485:2016.