GDP For Medical Devices
GDP For Medical Devices
SPECIFICATION
01 SEPTEMBER 2012
SEPTEMBER 2012
PREFACE
This document sets out the requirements for the Good Distribution Practice for
Medical Devices (GDPMDS).
In the event of any contradiction between the contents of this document and
any written law, the latter shall take precedence.
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1.
INTRODUCTION
1.1.
Purpose
SEPTEMBER 2012
This document specifies the requirements for the Good Distribution Practice
for Medical Devices, including secondary assembly activity.
1.2.
Background
The storage, trade and distribution of medical devices are carried out by
various organisations. The nature of the risks involved may be the same as
those in the manufacturing environment, e.g. mix-ups and contamination.
Hence, certain aspects of a quality system for manufacturing (e.g. storage,
transportation, documentation and record-keeping practices) are applicable to
the distribution of medical devices.
The need for establishment, development, maintenance and control over the
activities involved in the distribution process has, hitherto, generally not been
well-emphasised. The objective of Good Distribution Practice for Medical
Devices (GDPMDS) is to assist in ensuring the quality and integrity of medical
devices throughout the distribution process.
WHO IMPACT Draft Principles and Elements for National Legislation against Counterfeit
Medical Products, endorsed by IMPACT General Meeting in Lisbon, 12 December 2007.
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is the responsibility of the organisation to ensure that they are in compliance with all
applicable laws in force.
NOTE
1.3.
Scope
For organisations that had been certified to ISO 9001 Quality management
systems Requirements, various requirements of GDPMDS are covered
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under ISO 9001. As certain clauses of GDPMDS are covered under ISO
9001, the audit time for companies that have obtained certification to ISO
9001 from Certification Bodies should be reduced in accordance to CT 04:
SAC Criteria for Certification Bodies (Good Distribution Practice for Medical
Devices).
NOTE
ISO 9001 is not equivalent to GDPMDS. The ISO 9001 Certification shall not
be accepted in lieu of GDPMDS Certification for the purpose of obtaining Importers and
Wholesalers Licence(s) from HSA.
1.4.
Application
When the terms where appropriate are used to qualify a requirement in the
GDPMDS, it is deemed to be appropriate unless the organisation can
document a justification otherwise.
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1.5.
Definitions
The terms used to describe the supply chain is in line with ISO 13485:2003
Medical devices Quality management systems Requirements for
regulatory purposes.
ADVERSE EVENT: any event or other occurrence, that reveals any defect in
any medical device or that concerns any adverse effect arising from the use
thereof.
management systems Requirements for regulatory purposes (Terms and definitions 3.4)
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any action regarding the use of the medical device that is taken in
accordance with the advice of its product owner;
the clinical management of any patient who has used the medical device;
any upgrade to any software used with the medical device, including any
such upgrade carried out by remote access;
In assessing the need of the FSCA, the product owner is advised to use the
methodology described in the ISO 14971:2007 Medical devices Application
of risk management to medical devices.
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injury;
physiological process;
control of conception;
and which does not achieve its primary intended action in or on the human
body by pharmacological, immunological or metabolic means, but which may
be assisted in its intended function by such means.
PREMISES:
location that is used for activities dealing with medical devices, including
storage, manufacture, etc.
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supplying the medical device to a person who obtains the medical device
for the purposes of supplying it again to some other person;
supplying the medical device to a person who requires the medical device
for the purpose of enabling him to comply with any requirements made by,
or in pursuance of, any written law with respect to the medical treatment of
persons employed by that person in any business or trade carried out by
that person;
supplying the medical device to a person who requires to use the medical
device, other than by way of administration to one or more persons, for the
purpose of his business or trade;
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2.
2.1.
General Requirements
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Where an organisation chooses to outsource any activities that may affect the
quality of medical devices, the organisation shall ensure control over such
processes.
2.2.
Documentation Requirements
2.2.1. General
The documentation shall include:
the scope of the GDPMDS implemented, including the details of, and
justification for any exclusion and/or non-application,
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no less than two years from the date that the medical device is shipped
from the organisation,
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3.
RESOURCE MANAGEMENT
3.1.
Personnel
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3.1.1. General
Key personnel in charge of warehousing operations shall possess the
necessary competence in terms of education, training, skills and experience,
prior to performing their work.
3.1.2. Training
The organisation shall
ensuring that processes needed for the quality management system are
established, implemented and maintained,
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3.2.
3.2.1. General
The organisation shall ensure that the premises and equipment used are
suitable and adequate to ensure proper conservation and distribution of
medical devices.
3.2.2. Cleanliness
The organisation shall establish documented requirements for cleaning of
premises, including frequency and methods.
4.
4.1.
Receipt Of Stock
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4.2.
Calibration
4.3.
Storage
Medical devices beyond their expiry date or shelf life shall be segregated from
usable stock. They shall be clearly labelled as Not for Sale or in other similar
phrases/words. The expired medical devices shall be disposed of in
accordance to Clause 9.
4.4.
Delivery To Customers
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they do not contaminate, and are not contaminated by, other medical
devices or materials/substances;
they are secure and not subjected to unacceptable degrees of heat, cold,
light, moisture or other adverse influence, or to attack by microorganisms
and pests.
4.5.
4.5.1. Installation
Where the installation of a medical device is a specified requirement, the
organisation shall establish and maintain adequate installation and inspection
instructions, and where appropriate, test procedures.
4.5.2. Servicing
Where servicing is a specified requirement, the organisation shall establish
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and maintain instructions and procedures for performing and verifying that the
servicing meets the specified requirements.
5.
TRACEABILITY
Records providing traceability of medical devices from the supplier and to the
customers shall be maintained.
no less than two years from the date that the medical device is shipped
from the organisation,
6.
Any reports of adverse event that meets the regulatory reporting criteria
received by the organisation shall be reported to the regulatory authority.
NOTE
Reporting criteria and specific timelines for reporting of adverse events are
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7.
SEPTEMBER 2012
Records of all actions taken in connection with the FSCA and their approval
by the company and regulatory authority shall be maintained.
8.
All returned medical devices shall be segregated apart from saleable stock to
prevent redistribution until a decision has been reached regarding their
disposal.
9.
If the medical devices have not been immediately sent for disposal, they shall
be kept in a clearly segregated area and identified so that they will not be sold
inadvertently or contaminate other medical devices.
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10.
MEDICAL DEVICES
Any counterfeit, adulterated, unwholesome or tampered medical devices
found in the distribution network shall be physically segregated from other
medical devices to avoid any confusion. They shall be clearly labelled as Not
for Sale or in other similar phrases/words.
The organisation shall inform the regulatory authority, registrant and product
owner immediately.
11.
INTERNAL AUDITS
MANAGEMENT REVIEW
The top management shall review its quality management system at planned
intervals, to ensure its continuing suitability, adequacy and effectiveness. This
review shall include assessing opportunities for improvement and the need for
changes to the quality management system.
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results of audits,
customer feedback,
its processes,
resource needs.
13.
OUTSOURCED ACTIVITIES
Where the organisation outsources any process within the scope of the
GDPMDS, the organisation shall ensure control over such processes.
The organisation shall establish requirements to ensure that the outsourced
activities conform to specified requirements.
The type and extent of control applied to the supplier shall be dependent on
the impact on meeting the requirements of GDPMDS.
The supplier shall be audited as part of the internal audit if the supplier has
not been certified to GDPMDS.
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For outsourced activities under Clause 4 of GDPMDS, the supplier of outsourced storage, warehousing, secondary assembly and distribution services
shall be audited by the certification body as part of the organisation's system,
unless the supplier is already certified to GDPMDS. The scope of the
supplier's certification shall cover the scope of the organisation.
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14.
SEPTEMBER 2012
SECONDARY ASSEMBLY
the implementation of release of medical devices, their delivery and postdelivery activities, and
The organisation shall establish and maintain a record for each batch of
medical devices that provides traceability (see clause 5) and identifies the
amount assembled and the amount approved for distribution. The batch
record shall be verified and approved by qualified personnel.
The assembly shall be made or completed at the time each action is taken
and in such a way that all significant activities concerning the assembly of
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no less than two years from the date that the medical device is shipped
from the organisation,
For each delivery, the incoming medical devices shall be checked for integrity
of package and seal, for correspondence between the delivery note and the
suppliers labels, and for compliance with medical device quality specification.
Medical devices with breached primary package shall not be used for
secondary assembly.
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14.3.2.
Packaging materials
14.3.3.
All original labelling (including instructions for use, label and any other
informational sheet or leaflet, etc) and all original labelling information shall
accompany the repackaged medical device when it is supplied. Additional
secondary package labelling is permitted in accordance to Annex 3.
Special considerations
All medical devices and materials used for assembly shall be checked before
use by a designated person for quantity, identity and conformity with the
packaging instructions. Line clearance shall be performed prior to
commencement of the assembly operation.
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14.4.2.
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Assembly equipment
The organisation shall ensure that the assembly equipment used are suitable
and adequate to ensure proper secondary assembly of medical devices.
The parts that come into contact with the medical devices must not affect the
quality of the medical devices and present any hazard.
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ANNEX 1
(Normative)
Scope of certification
The scope of the certificate shall specify the following:
NOTE
Import
Storage
Installation
Secondary assembly
NOTE
secondary assembly and distribution services should only have the following activities listed in
the scope of their certification:
Storage;
Secondary assembly
The certification shall also cover any special storage and handling conditions,
such as chill room or cold room for cold chain management. Examples of
statements can include (non-exhaustive list):
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NOTE
SEPTEMBER 2012
NOTE
If special storage and handling conditions are not applicable, the scope of the
certificate must indicate that there are no special storage and handling conditions.
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ANNEX 2
(Normative)
Medical device categories for inclusion in scope of certification
The certification is specific for categories of medical devices that are covered
under the audit. Some replication may exist when it comes to classifying the
device. For example, a device may be classified as dental device and single
use device. Therefore, the category selected should be the one that is most
appropriate for that medical device.
NOTE
Category 11: Single-use devices is a generic category that shall be used only
S/N
Term Name
Term definition
Active implantable
devices
Anaesthetic and
respiratory devices
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S/N
Term Name
Term definition
Dental devices
Diagnostic and
therapeutic radiation
devices
Electro mechanical
medical devices
Hospital Hardware
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S/N
Term Name
Term definition
In vitro diagnostic
devices
Non-active
implantable devices
Ophthalmic and
optical devices
Reusable instruments A category that includes devices which are used in surgery or
.
Single-use devices
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S/N
Term Name
Term definition
12
disabled persons
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ANNEX 3
Secondary assembly activities
1.
Example
Restrictions
No assignment of new expiry date, NEW product name and NEW product
owner name to medical device
NOTE:
2.
Any expiry date indicated shall reflect the shortest expiry date in the package.
Example
Restrictions
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NOTE:
The change/addition of brand name and/or new product owner name constitutes
Change in quantity for shipper cartons (example provided below), intended for
shipping and transportation only, is not considered a secondary assembly
activity. It is not deemed a manufacturing activity in the first place.
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Contact Information: