Quality Manual: Revised August 28, 2018
Quality Manual: Revised August 28, 2018
Quality Manual
Revised August 28, 2018
2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014 Fluke Corporation, All rights reserved. Printed in U.S.A.
All product names are trademarks of their respective companies
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Site Roles: Calibration, Distribution, Service, and Repair of electronic test and measuring equipment, software,
radiation detection instruments, and their accessories
www.flukebiomedical.com
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Table of Contents
Section 1: Quality Policy ................................................................................................................. 1-1
1.1 Company Mission Statement ........................................................................................... 1-1
1.2 Company Background ..................................................................................................... 1-1
Section 2: Amendment Record ....................................................................................................... 2-1
2.1 Amendment Record ......................................................................................................... 2-1
2.2 Controlled Circulation List ................................................................................................ 2-2
Section 3: Glossary .......................................................................................................................... 3-1
3.1 Glossary ........................................................................................................................... 3-1
Section 4: Management Responsibility ......................................................................................... 4-1
4.1 Management Responsibility ............................................................................................. 4-1
4.2 Quality System ................................................................................................................. 4-2
4.3 Contract Review ............................................................................................................... 4-3
4.4 Design Control ................................................................................................................. 4-4
4.5 Document and Data Control ............................................................................................ 4-6
4.6 Purchasing ....................................................................................................................... 4-7
4.7 Control of Customer-Supplied Product ............................................................................ 4-8
4.8 Product Identification and Traceability ............................................................................. 4-8
4.9 Process Control/ Validation .............................................................................................. 4-9
4.10 Inspection and Testing ................................................................................................... 4-10
4.11 Control of Inspection, Measuring and Test Equipment .................................................. 4-11
4.12 Inspection, Test and Operating Status........................................................................... 4-13
4.13 Control of Nonconforming Product ................................................................................. 4-13
4.14 Corrective and Preventive Action ................................................................................... 4-14
4.15 Handling, Storage, Labeling, Packaging, Preservation and Delivery ............................ 4-16
4.16 Control of Quality Records ............................................................................................. 4-17
4.17 Quality Audits ................................................................................................................. 4-17
4.18 Training .......................................................................................................................... 4-18
4.19 Servicing ........................................................................................................................ 4-19
4.20 Statistical Techniques .................................................................................................... 4-19
Appendix A: Fluke Biomedical Organization ................................................................................... A-1
Appendix B: Documentation Structure ............................................................................................. B-1
Appendix C : Quality Management System Flow Charts……………………………………………….C-1
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Section 1
Quality Policy Statement
1.1 Company Mission Statement
Company Mission Statement
To continue as the market leader in providing equipment to clinical engineers, radiation physicists, and
oncologists, while expanding our range of solutions to a broader range of health and safety professionals.
Quality Policy Statement
The personnel of Fluke Biomedical are committed to achieving quality through the following objectives:
• Focusing on the customer by applying innovation and flexibility to meet their needs
• Fostering a controlled atmosphere for continuous improvement and problem prevention
• Identifying the need for, and providing appropriate training to ensure the development and
qualification of our personnel
• Communicating the mission and objectives to our personnel and customers
• Developing relationships with our customers that emphasize continuous improvement in product
quality, service and support
• Promoting a supportive work environment that facilitates the delivery of a quality product on a
consistent basis
• Working in a manner consistent with our documented quality-management system to ensure our
products and services are safe and effective for their intended use
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Section 2
Amendment Record
2.1 Amendment Record
The Amendment Record will be maintained in Master Control in the Notes Section.
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Section 3
Glossary
PO – Purchase Order
MR – Management Representative
Standards/Requirements – ISO 9001: 20XX, FDA Quality System Regulations for Medical Devices 21
CFR part 820, Energy Regulations 10 CFR part 50 Appendix B, ISO 13485: 20XX; ISO 14971 20XX, and
QM – Quality Manual
Medical Device (ISO 13485)- Any instrument, apparatus, appliance, material or other article, whether
used alone or in combination, including the software necessary for its proper application, intended by the
manufacturer to be used for human beings for the purpose of:
• diagnosis, prevention, monitoring, treatment, or alleviation of disease
• diagnosis, monitoring, treatment alleviation of, or compensation for, an injury or handicap
• investigation, replacement or modification of the anatomy or of a physiological process
• control of conception, and which does not achieve its principal intended action in or on the human
body by pharmacological, immunological, or metabolic means, but which may be assisted in its
function by such means.
Medical Device (FDA 21CFR)- An instrument, apparatus, implement, machine, contrivance, implant, in
vitro reagent, or other similar or related articles, including any component, part or accessory, which is:
• Recognized by the National Formulary, or the United States Pharmacopoeia, or any supplement to
them.
• Intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment,
or prevention of disease, in man or other animals.
• Intended to affect the structure or any function of the body of man or other animals, and which does
not achieve any of its principal intended purposes through chemical action within or on the body of
man or other animals and which is not dependent upon being metabolized for the achievement of its
principal intended uses.
Medical Device (CMDR) – A device within the meaning of the Act (Food and Drugs Act, Canadian
Medical Device Regulation), but does not include any device that is intended for use in relation to
animals. (Currently Fluke Biomedical does not market any medical devices in Canada. The CMDR and
MDSAP will be addressed if the company decides to sell medical devices in Canada)
Design History File (DHF) – Means a compilation of records which describes the design history of a
finished device.
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Design input – Means the physical and performance requirements of a device that are used as a basis
for device design
Design output – Means the results of a design effort at each design phase and at the end of the total
design effort. The finished design output is the basis for the device master record. The total finished
design output consists of the device, its packaging and labeling, and the device master record
Device History Record (DHR) – Means a compilation of records containing the production history of a
finish device
Device Master Record (DMR) – Means a compilation of records containing the procedures and
specifications for a finished device
Finished device – Means any device or accessory to any device that is suitable for use or capable of
functioning, whether or not it is packaged, labeled, or sterilized
Harm – Physical injury or damage to the health of people, or damage to property or the environment
Hazardous situation – Circumstance in which people, property, or the environment are exposed to one
or more hazard(s)
Intended use – Intended purpose use for which a product, process or service is intended according to
the specifications, instructions, and information provided by the manufacturer
Life-cycle – All phases in the life of a medical device, from the initial conception to final decommissioning
and disposal
Lot or batch – Means one or more components or finished devices that consist of a single type, model,
class, size, composition, or software version that are manufactured under essentially the same conditions
and that are intended to have uniform characteristics and quality within specified limits
Management with executive responsibility – Means those senior employees of a manufacturer who
have the authority to establish or make change to the manufacturer’s quality policy and quality system.
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Manufacturer – Natural or legal person with responsibility for the design, manufacture, packaging, or
labeling of a medical device, assembling a system, or adapting a medical device before it is placed on the
market or put into service, regardless of whether these operations are carried out by that person or on
that person's behalf by a third party
NOTE 1 Attention is drawn to the fact that the provisions of national or regional regulations can apply to the definition
of manufacturer.
Post-production – Part of the life-cycle of the product after the design has been completed and the
medical device has been manufactured
EXAMPLES: transportation, storage, installation, product use, maintenance, repair, product changes,
decommissioning, and disposal.
Process – Set of interrelated or interacting activities which transforms inputs into outputs
Product – Means components, manufacturing materials, in-process device, finished devices, and
returned devices
Quality – Means the totality of features and characteristics that bear on the ability of a device to satisfy
fitness-for –use, including safety and performance.
Quality audit – Means a systematic, independent examination of a manufacturer’s quality system that is
performed at defined intervals and at sufficient frequency to determine whether both quality system
activities and the results of such actives comply with quality system procedures are suitable to achieve
quality system objectives.
Quality policy – Means the overall intentions and direction of an organization with respect to quality, as
established by management with executive responsibility
Quality system – Means the organizational structure, responsibilities, processes, and resources for
implementing quality management.
Residual risk – Risk remaining after risk control measures have been taken
NOTE 1 Adapted from ISO/IEC Guide 51:1999, definition 3.9.
NOTE 2 ISO/IEC Guide 51:1999, definition 3.9 uses the term “protective measures” rather than “risk control
measures.” However, in the context of this International Standard, “protective measures” are only one option for
controlling risk as described in 6.2.
Rework – Means action taken on nonconforming product so that it will fulfill the specified DMR
requirements before it is released for distribution
Risk – Combination of the probability of occurrence of harm and the severity of that harm
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Risk analysis – Systematic use of available information to identify hazards and to estimate the risk
NOTE Risk analysis includes examination of different sequences of events that can produce hazardous situations
and harm.
Risk assessment – Overall process comprising a risk analysis and a risk evaluation
Risk control – Process in which decisions are made and measures implemented by which risks are
reduced to, or maintained within, specified levels
Risk estimation – Process used to assign values to the probability of occurrence of harm and the
severity of that harm
Risk evaluation – Process of comparing the estimated risk against given risk criteria to determine the
acceptability of the risk
Risk management – Systematic application of management policies, procedures, and practices to the
tasks of analyzing, evaluating, controlling, and monitoring risk
Risk management file – Set of records and other documents that are produced by risk management
Top management – Person or group of people who direct(s) and control(s) a manufacturer at the highest
level
Use error – Act or omission of an act that results in a different medical device response than intended by
the manufacturer or expected by the user
NOTE 1 Use error includes slips, lapses, and mistakes.
NOTE 3 An unexpected physiological response of the patient is not by itself considered use error.
Validation – Means confirmation by examination and provision of object evidence that the particular
requirement for a specific intended use can be consistently fulfilled
Process Validation – Means confirmation by examination and provision of object evidence that a
process consistently produces a result or a product meeting its predetermined specifications.
Design Validation – Means confirmation by examination and provision of object evidence that device
specification conform to user need and intended use(s)
Verification – Confirmation, through the provision of objective evidence, that specified requirements have
been fulfilled
NOTE 1 The term “verified” is used to designate the corresponding status.
NOTE 2 Confirmation can comprise activities such as:
⎯ performing alternative calculations;
⎯ comparing a new design specification with a similar proven design specification;
⎯ undertaking tests and demonstrations;
Note 3 When :20XX is referenced within the procedures, it means the current revision year to the standard
referenced.
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Section 4
Management Responsibility
4.1 Management Responsibility
4.1.1 Scope and Purpose
The quality system described in this section of the QAM complies with the requirements of the
standard(s): ISO 9001:20XX, 21 CFR 820.20, 10 CFR 50 App. B part I, ISO 13485:20XX, ISO 17025, and
CMDR.
4.1.2 Responsibility and Authority (R&A)
The President, Vice Presidents, Directors, and Managers have the responsibility and authority for the
overall administration and management of the quality system activities at Fluke Biomedical. The
company’s personnel have the responsibility and have been given the authority and freedom to carry out
activities relating to its quality policy, quality system documentation and customer requirements. Director
of regulatory and quality is the management representative at Fluke Biomedical and has the responsibility
to ensure requirements of quality management systems are established and executed.
4.1.3 Quality System Requirements
Internal Communication- Fluke Biomedical has established as a means of internal communication,
regarding the effectiveness of the Quality Management System the following processes: QDIP, Policy
Deployment, Key Process Indicators, Management Review meetings and others as deemed appropriate
by management.
Quality Policy –Fluke Biomedical has established a quality policy that identifies quality system goals and
objectives. This policy is relevant to the company’s goal and the expectations and needs of its customers.
This policy has been communicated to the employees and is maintained as the highest priority within the
company; each associate understands their role.
Responsibility and Authority - The quality system documentation, responsibility matrix, and job
descriptions define the R&A and necessary interrelations for all activities.
Resources - The resources required to complete quality system activities are defined in both the quality
system documentation and job descriptions. Fluke Biomedical has identified and provides for the
resources needed to meet the ISO, QMS, QSR, CMDR and Nuclear System requirements including the
assignment of trained personnel for management, performance of work and verification activities
including internal quality audits.
Management Representative (MR) - The President or General Manager of Fluke Biomedical has
appointed a MR for the establishment, implementation, maintenance and reporting of quality assurance
system activities. The MR is the Director of Regulatory Affairs/Quality Assurance. The deputy MR is the
Quality Manager or the highest-ranking RA/QA personnel at the site designated by RA/QA Director.
Management Review - The MR carries out scheduled Management Review meetings with the
management team at defined intervals. These reviews determine the effectiveness, adequacy and
suitability of the implemented quality system requirements. Minutes of these review meetings are
maintained. The reviews include information on audit results, customer feedback, process performance
and product conformity, status of corrective and preventive actions, follow-up actions from previous
management reviews, changes that could affect the quality management system, promoting regulatory
awareness, new or revised regulatory requirements, decision to report an adverse event to regulatory
authorities and/or customers, and recommendations for improvement. Outputs from the reviews include
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any decision and actions related to improvement of the effectiveness of the system and its processes,
product improvements related to customer requirements, and resource needs.
4.1.4 Related and Support Documentation
QSP- NN Quality system procedures
QSP-102 Responsibility and Authority Matrix
QSP-201 Procedure for Management Review of the Quality System
Appendix A Organization Structure
Job Descriptions
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The Quality System Procedures are consistent with the requirements of the sited ISO and EN standards,
the QSR Regulation, the Nuclear System requirements and the company’s Quality Policy. The range and
detail of these procedures is dependent on the complexity of the work, the methods used, and the skills
and training needed by the associates involved. The procedures may make reference to other device
master records/work instructions that define how an activity is performed.
Quality Planning activities are carried out to ensure that processes are established and continually
improved to enhance customer satisfaction and to meet the objectives of the Fluke Biomedical quality
management system. The integrity of the system is maintained when changes are planned and
implemented. Quality planning is also done to plan and develop the processes needed for product
realization including the definition and documentation of how specified requirements have been or will be
addressed and met. Quality System Documentation controls the processes and methods used to meet
these requirements. Quality planning methods and practices identify and control the following:
▪ Acquisition of equipment, fixtures, resources and skills needed
▪ Ensuring design, process, installation, servicing and inspection compatibility with the applicable
documentation
▪ Risk management throughout realization through documented procedures
▪ Quality objectives and requirements for the products
▪ Updating of QC inspection and testing techniques
▪ Identification of measurement requirements
▪ Identification of suitable verification activities
▪ Standards of acceptability
▪ Identification and preparation of quality records
For each type/model of medical device, a file is established and maintained that contains or references
the location of a document that defines the product specifications and quality system requirements for
processing and quality assurance of the device. This technical file, or device master record, includes
specifications for the complete manufacturing of each product and its installation and servicing, if
appropriate.
4.2.5 Related and Support Documentation
QSP-NN Quality System Procedures
QSP-202 Procedure for Quality Planning
Structure of Documentation- Appendix B
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contract review activities so that customer requirements are determined and met. The Director of
Engineering or Engineering Manager is responsible for reviewing contract requirements when the
contract requires design activities related to nonstandard specifications. The President or Designee
reserves the right to review contracts which involve a significant or unusual amount of revenue or
resources. The business partners have the responsibility and have been given the authority and freedom
to carry out activities in accordance with the quality policy, quality system documentation and specified
requirements of QSR, QMS, CMDR and 17025
4.3.3 Contract Review Requirements
Contract Review - Procedures exist to control the methods and practices used to complete customer
contract reviews and contract amendments. Contracts (verbal and written) are reviewed to ensure that
they adequately define the specified requirements; that differences between the contract and tender are
resolved; and that the company is capable of meeting the contract or order requirements in order to
enhance customer satisfaction.
Amendments – The amendments to contracts are defined, documented and communicated to affected
functional groups.
Records of contract reviews and amendments are maintained. Channels for communication and
interfaces with the customer’s organization in these contract matters are established.
4.3.4 Related and Support Documentation
QSP-203 Procedure for Contract Review
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Design Input - the project group interfaces with the sales/marketing and regulatory functions in order to
ensure a complete understanding of the customer(s) and other requirements (industry and
governmental). The input takes into consideration the results of contract review activities. For medical
devices, requirements that are related to the safety of the device are identified and included as design
inputs and the outputs of risk management.
The design inputs are then documented and reviewed for adequacy. Incomplete, ambiguous or conflicting
requirements are resolved with those responsible for imposing these requirements.
Design Output – The output of the design process is documented in various forms. The design output
must be expressed in terms that can be verified and, where necessary, validated against the design
inputs using suitable methods. The design output must meet the specified design input requirements, and
contain or make reference to the appropriate acceptance criteria. In addition, those characteristics that
are crucial to the safe and proper functioning of the product such as operation, storage, handling etc.
must be identified. Prior to release, the results of design output activities are reviewed by objective design
review committee personnel.
Design Review - At appropriate stages of the design, formal, structured and documented design reviews
activities are held; these reviews are carried out to determine if all specified requirements for the phase
being reviewed have been addressed. Representatives from the functional groups concerned with the
design phase being reviewed, as well as other specialist personnel are asked to participate. Records of
these reviews are maintained with the design history file for the project.
Design Verification –At appropriate stages of design, design verification is performed to ensure that the
design stage output meets the design stage input requirements. The design verification measures are
recorded and maintained with the design history file. Design verification may include tests to compare
new designs to proven designs. Alternate experiments, tests and demonstrations and a review of design
documents before their release are also conducted. For items subject to the requirements of 10CFR 50
Appendix B, where a test program is used to verify the adequacy of a specific design feature in place of
other verifying or checking processes, it must include suitable qualification testing of the prototype unit
under the most adverse conditions. Independent design verification, performed by someone independent
of the design or activity being verified, is to be performed when needed to meet regulatory or customer
requirements. All design verification activities for medical devices are documented and maintained,
including those where clinical investigation was involved.
Design Validation- Design validation is performed to ensure that the product conforms to defined user
needs and/ or requirements. This quality system activity is performed when appropriate and follows
successful design verification. When conducted, it follows defined operating conditions, and normally is
performed using product made in manufacturing which represents the proposed final product. Multiple
validations may be performed if there are different intended uses. Medical devices may require clinical
evaluation as part of the design validation. When performed, records of the evaluation are maintained.
The clinical evaluation may include a compilation of scientific literature and historical evidence that similar
designs and/or materials are clinically safe, or a clinical investigation or trial, to ensure that the device
performs as intended.
Design Transfer- Procedures are in use to ensure that the device design is correctly translated into
production specifications.
Design Changes - Design modifications are identified, documented, reviewed and approved by the
various functional organizations affected by the associated changes. These activities are carried out prior
to design change implementation. These controls apply to design changes regardless of the origin or
ownership of the design. Changes to established products must be handled according to the regular
change/engineering control procedures (see sections 4.5 and 4.14)
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Design History/Technical File- A design history file (DHF) is maintained for each type of device. This file
contains or references the records necessary to demonstrate that the design was developed in
accordance with the approved design plan and the requirements of the standards.
Software Development – As appropriate, the design procedures and requirements for software
development are the same as for other designs.
Documents and records relating to product development/design control requirements are kept in the
design history file.
4.4.4 Related and Support Documentation
QSP-204 Product Development/Design Control Procedure
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information or background is provided upon which to base their review and approval. Where practicable,
the nature of the change is identified in the change request documents or attachments.
4.5.4 Related and Support Documentation
QSP-205 Document and Data Control Procedure
QSP-103 Document/Quality Record Matrix
QSP-05-08 Procedure Index
4.6 Purchasing
4.6.1 Scope and Purpose
The quality system described in this section of the QAM complies with the requirements of the
standard(s): ISO 9001:20XX, 21 CFR 820.20, 10 CFR 50 App. B part IV, VII, ISO 13485:20XX, ISO
14971 20XX, and ISO 17025, CMDR.
4.6.2 Responsibility and Authority (R&A)
The Materials/Purchasing Manager and designated purchasing personnel have the responsibility and
authority for carrying out purchasing activities. The business partners have the responsibility and have
been given the authority and freedom to carry out activities in accordance with the quality policy, quality
system documentation and specified requirements.
4.6.3 Purchasing
Documented procedures are in use to ensure that purchased product and services conform to specified
requirements. The type and extent of control applied to the supplier and the purchased product or service
is dependent on the effect of the product or service on subsequent product realization activities and the
final product.
Vendors, contractors and consultants are evaluated on the basis of their ability to meet the requirements
of the quality system and any specific quality assurance requirements. Records of acceptable vendors,
contractors and consultants are maintained.
The procedures also define the type and extent of control to be exercised over the vendors, contractors
and consultants dependent upon the type of product or service supplied, its impact on the quality of the
final products, and where applicable, the audit reports or performance record of the vendor.
Purchase order (PO) information contains adequate detail to ensure that all specified requirements have
been adequately described. Reviews and approvals of all PO and related information are carried out by
purchasing personnel in advance of the PO being placed with the vendor, to ensure adequacy of the
specified requirements. When appropriate, the purchasing information includes requirements for approval
of the product, procedures, processes and equipment, requirements for qualification of personnel, and
quality management system requirements. Copies of relevant purchasing documents are retained as
needed to the extent required by the particular requirements for traceability discussed in section 6.8 of
this manual.
Activities are conducted to ensure that the purchased product or service meets specified purchase
requirements. When purchased product is to be verified at the vendor’s premises, the verification
arrangements and the method of product release are in the purchasing documents.
When it is a condition of the contract, the customer has the right to verify that the product conforms to
specified requirements on our premises or that of our vendor. Such verification is not used as evidence of
effective control of the subcontractor’s quality system. The verification by the customer does not absolve
Fluke Biomedical of the responsibility to provide acceptable product, nor does it preclude subsequent
rejection by the customer.
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There are also documented procedures for the unique identification of individual products or batches
where traceability is a requirement, as for medical devices. The identification is recorded on the
applicable documents and may enable traceability to certain components used in the product. Traceability
is maintained for the distribution of the devices and ensures that the record of the original consignee for
the device is maintained to facilitate corrective or preventive action if needed.
4.8.4 Related and Support Documentation
QSP-208 Product Identification and Traceability Procedure
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▪ Appropriate procedures for installation when performed, and documentation of such activities.
▪ Use of documented procedures for the validation of the application of computer software used for
process control. The results of the validation are recorded.
▪ Implementation of release, delivery and post-delivery activities
▪ Supporting services such as transportation and communication
Where the results of processes cannot be fully verified by subsequent monitoring, inspection, measuring
or testing of the product and where, for example, processing deficiencies may become apparent only after
the product is in use, process validation is performed. Validation is performed to demonstrate the ability of
these processes to achieve planned results. The documented validation program includes, where
appropriate, installation qualification, operation qualification, performance qualification and process
validation, software validation, continuous monitoring of processes, and qualification of operators. The
use of specific methods and procedures is defined as applicable. Revalidation is done when needed due
to a design change, new product, and new application for the process or as indicated by process
monitoring or feedback from customers.
The quality records of such validated special processes identify the work instruction or procedure used
the date the special process was performed and the identity of the operator of the special process.
The requirements for any qualification of process operations, including associated equipment and
personnel are specified.
Records are maintained of the process control and validation activities, and for qualified processes,
equipment and personnel.
4.9.4 Related and Support Documentation
QSP-209 Process Control Procedure
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Where incoming material is released for urgent production purposes prior to verification, it is positively
identified and recorded in order to permit immediate recall and replacement in the event it is found to be
nonconforming to specified requirements.
In-process materials and products are inspected and tested as required by documented procedures.
Product is held until the required inspection and/or test has been completed or necessary reports and
records have been received and verified, except when product is released to the next production stage
under positive-recall procedures as described above. Such a conditional release does not preclude the
performance of the in-process inspection and test activities.
Final inspection and testing is carried out in accordance with documented procedures to complete the
evidence of conformance to the specified requirements. The procedures for the final inspection and
testing require that all previously required inspections and tests have been performed and that the results
meet specified requirements. No products are released for distribution until the activities specified in the
documented procedures have been satisfactorily completed and the associated data and documentation
have been approved and accounted for.
Records to demonstrate that the product has been inspected and/or tested are maintained. These
records clearly show whether the product has passed or failed according to defined acceptance criteria.
Where the product fails to pass any inspection and/or test, the procedures for control of nonconforming
product are followed.
The inspection authority responsible for the release of product is identified on the records. Inspection and
test activities are performed by individuals other than those who performed the activity being checked.
4.10.4 Measurement, Analysis and Improvement
Fluke Biomedical has implemented monitoring, measurement, analysis and improvement processes not
only to demonstrate conformity of the product, but also to ensure conformity of the quality management
system and to continually improve the effectiveness of the quality management system. Information
relating to customer perception and satisfaction is monitored by customer service, sales, quality and
marketing, and shared at the Management Review meetings. Internal audits are conducted according to
part 6.17 of this manual. Processes are monitored and measured to demonstrate the ability of the
processes to achieve planned results. When planned results are not achieved, corrective actions are
taken, as appropriate, to ensure conformity of the product.
4.10.5 Related and Support Documentation
QSP-210 Inspection and Testing Procedure
Metrics from Management Review Meetings
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given the authority and freedom to carry out activities in accordance with the quality policy, quality system
documentation and specified requirements.
4.11.3 Inspection, Measuring and Test Equipment (I, M, & TE)
Documented procedures to control, maintain, and calibrate monitoring, inspection, measuring and test
equipment (including test software) are in use to demonstrate the conformance of product to the specified
requirements. Such equipment is used in a manner, which ensures that the measurement uncertainty is
known and is consistent with the required measurement capability.
Where test software or comparative references are used as suitable forms of inspection, they are
checked to prove that they are capable of verifying the acceptability of product, prior to release for use
during production, installation or servicing. Periodic rechecks are done according to a procedure and
records of such checks are maintained. Technical data, pertaining to the inspection, measuring or test
equipment, is made available to a customer when required by their contract or to verify the equipment is
functionally adequate.
In order to ensure the control of the equipment, Fluke Biomedical does the following:
• Selection of I, M & TE is based on analysis and determination of the precision required;
• Equipment affecting quality is identified and handled according to the appropriate procedures
• Procedures are established according to equipment type, frequency of use, and nature of use, and
include acceptance criteria and reference to actions for nonconforming equipment.
• I, M & TE is identified by either a controlled equipment label, calibration sticker or inscribed identifier
number. The calibration status of each piece of equipment is determined by either a calibration sticker
or record of calibration status, based on the equipment identification number;
• Calibration status of equipment is determined by equipment vendor documentation, actual calibration
of equipment by plant maintenance personnel, calibration personnel or QC/QA personnel, or by the
equipment operator when done as part of the work instructions.
• Calibration status for all I, M & TE is traceable to industry, national or international equipment
standards, whenever possible;
• Methods and practices of calibration are documented and these documents are adhered to in
carrying out calibration activities;
• Documented procedures detail methods and practices to be used for assessing I, M &TE found to be
out of calibration and the actions related to product(s) that were inspected or tested using this
equipment;
• Suitable environmental conditions are maintained to ensure the accurate operation of I, M & TE and
for product that will be inspected in these environmental conditions;
• Methods of handling, preservation and storage exist to ensure that I, M &TE are used in a manner
that will ensure measurement accuracy and fitness for use; and
• Measures have been taken to protect I, M & TE, including software and hardware, from unauthorized
adjustment that may affect the accuracy of the equipment.
4.11.6 Related and Support Documentation
QSP-211 Control of Inspection, Measuring and Test Equipment Procedure
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Responsibility for review and the authority for the disposition are defined. Nonconforming product is
reviewed in accordance with documented procedures to determine the appropriate action to take, which
may include:
• rework or repair to specifications
• re-inspection or retest if there is reason to believe the initial results may be due to operator or
equipment error
• scrapping or recycling,
• acceptance through customer concession (not an option for FDA-regulated product)
• rejection/return to vendor
Rework and repair are carried out in accordance with documented instructions and product is retested
according to the documented procedures. Rework for medical devices is documented in a work
instruction that has undergone the same authorization and approval procedure as the original work
instruction.
For product not regulated by the FDA and where contractually required, Fluke Biomedical reports the
proposed use of nonconforming product to the customer for concession. Descriptions of the accepted
nonconformity are recorded to denote the actual condition. Nonconforming product is accepted for
concession only if regulatory requirements are met. The identity of the person authorizing concession is
recorded.
4.13.4 Related and Support Documentation
QSP-213 Control of Nonconforming Product Procedure
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The procedures for corrective action include methods for documenting and handling customer complaints,
returned product, deviations in production, and reports of product nonconformities. An investigation of the
cause and the associated risk of the nonconformities, relating to the product, process or quality system is
done and the results recorded. The feedback information is investigated, interpreted, collated, and
communicated in accordance with defined procedures by designated personnel.
A record is kept of all customer complaint investigations. When the investigation determines that the
activities at remote premises contributed to the customer complaint, a copy of the report is sent from
Fluke Biomedical to the remote premises. The corrective action needed is then determined and followed
up to ensure the action is implemented and effective. If any customer complaint is not followed by
corrective and/or preventive action, the reason is recorded.
The procedures for preventive action include the use of information from various sources including
internal operation reports, audit results, quality records, service reports and customer complaints to
detect, analyze and eliminate potential causes of nonconformities. These procedures include steps to
deal with problems requiring preventive action, the initiation of such actions and instructions for follow-up
to ensure implementation and effectiveness. Again, such proposed actions are handled according to the
established change control procedures, which include management review.
If a customer alleges that one of our medical device products has caused or contributed to a serious
injury or death, or that it has malfunctioned, and if that malfunction were to recur it could cause or
contribute to a serious injury or death, the Medical Device Reporting regulations are followed as
described in 21CFR 803, the Canadian Medical Device Regulations are followed as described in Sections
59-65 Mandatory Problem Reporting, and the requirements of Regulatory Authorities in other countries as
applicable. Procedures for the notification of such regulatory authorities are established to meet the
reporting criteria.
If a correction or removal of distributed medical devices is needed, then the requirements of the FDA’s
21CFR 806, and those of applicable foreign Regulatory Authorities are followed. Procedures are
established for the issue of such advisory notices or recalls, which can be implemented at any time.
For items subject to regulation by the Nuclear Regulatory Commission or the Atomic Energy Act of 1954,
a defect or nonconformance is deemed to exist if anyone obtains information reasonably indicating that a
basic component, licensed activity or a portion of the facility has a defect or failure that could be
associated with a substantial safety hazard. A notification of failure to comply or existence of a defect
must be made according to 10 CFR part 21.21.
NOTE 1: Risk Management is conducted from Product Development to the Post Market Surveillance.
This may include any Risks or opportunities associated with Non-Conformances, Complaints, and
CAPA’s that may affect product integrity, safety and or any other regulatory requirements.
NOTE 2: The corrective and preventive actions shall be examined to ensure product safety and
effectiveness has not been affected. The need for decision to inform regulatory authorities or customers
are evaluated.
4.14.3.1 "Continual Improvement" in the concept of ISO-9001 (part 10.3). Where
possible and applicable, opportunity for continuous improvement shall be evaluated and
implemented. During the improvement process, it must be established that the safety and
efficacy of the product(s) and intended use will not be affected.
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Documented procedures for planning and implementing internal and external quality audits are in use.
Quality audits are carried out to verify that planned and documented procedures, quality and control
plans, and other quality system documentation are in conformance, and to assess their effectiveness.
The internal audits are scheduled based on the departments or regulatory element’s impact on quality
and quality performance, and are carried out against the requirements of the standard(s) that apply to the
operation being audited. External audits are done at intervals consistent with the importance, complexity,
performance history and quantity of the product or services obtained from the vendor. Trained and
qualified personnel who understand the standard(s), auditing requirements, and basic communication
skills, and who are independent of the functional area being assessed, conduct the audits.
The results are documented and are communicated to the personnel having responsibility for the area
audited. The management of the audited area must determine and implement timely corrective action.
Follow-up activities are carried out to verify the implementation and effectiveness of corrective action.
Records of quality audits are maintained.
4.17.4 Related and Support Documentation
QSP-217 Quality Audit Procedure
4.18 Training
4.18.1 Scope and Purpose
The quality system described in this section of the QAM complies with the requirements of the
standard(s): ISO 9001:20XX, 21 CFR 820.20, 10 CFR 50 App. B part II ISO 13485:20XX, ISO 14971
20XX, and ISO 17025, CMDR.
4.18.2 Responsibility and Authority (R&A)
All area Directors and Managers have theresponsibility and authority for carrying out training activities
and to ensure all personnel in their respective areas are trained properly. . The business partners have
the responsibility and have been given the authority and freedom to carry out activities in accordance with
the quality policy, quality system documentation and specified requirements.
4.18.3 Training
The necessary competence for personnel performing work affecting product quality has been determined
through the job descriptions. Documented procedures for identifying training needs are in use. Training,
including Quality System requirements, is provided for personnel performing activities affecting quality.
Personnel who perform specific assigned tasks are qualified on the basis of appropriate education,
training and/or experience, as required. Records of training and qualifications are maintained.
Personnel are made aware of the relevance and importance of their activities and how they contribute to
the achievement of the Fluke Biomedical quality objectives.
Personnel who are required to work under special environmental conditions or who perform special
processes or functions are appropriately trained or supervised by a trained person.
4.18.4 Related and Support Documentation
QSP-218 Training Procedure
4.19 Servicing
4.19.1 Scope and Purpose
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The quality system described in this section of the QAM complies with the requirements of the
standard(s): ISO 9001:20XX, 21 CFR 820.20, and ISO 13485:20XX, ISO 14971 20XX, and ISO 17025,
CMDR.
4.19.2 Responsibility and Authority (R&A)
The Director of the Global Calibration Laboratory, the Calibration Service Manager and the Customer
Service/Repair Manager, have the responsibility and authority for carrying out servicing activities. The
business partners have the responsibility and have been given the authority and freedom to carry out
activities in accordance with the quality policy, quality system documentation and specified requirements.
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4.19.3 Servicing
Where servicing is a specified requirement, documented procedures for scheduling, performing, verifying
and reporting the servicing are in use. These procedures ensure that the servicing activities are done
under controlled conditions, meet the specified requirements for the product and that the servicing
activities are documented. Servicing, like production, is done using correct information for the product,
work instructions (as necessary), suitable equipment, monitoring and measuring devices, measuring and
monitoring of the service itself, and proper release, delivery and post-delivery activities.
4.19.4 Related and Support Documentation
QSP-219 Servicing Procedure
QSP-101 Quality Manual for Calibration Services (Cleveland)
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Appendix A
QSP-100
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Appendix B
QSP-100
FLUKE Biomedical,
Documentation Structure
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Fluke Biomedical
6045 Cochran Road
Cleveland, Ohio 44139
440.498.2564
www.flukebiomedical.com
Appendix C
High Level Quality Management System Flow Chart
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Resource Management
Regulatory Compliance
Customer Requirements
Marketing Competency / Training
QSP-218
International
Marketing Quality Records / Document Controls
QSP-205
Management
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Customer Order
Customer Service
No Shipping picks order Packaging Distribution
check inventory level
No
Destroy
Pass
Pass / Fail
Replace
No
Destroy
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Customer Requirements QSP-203
Sales
Customer
Marketing
Technical Service
Title: Quality Manual
No
Product
QSP-213
Control of
Customer
Satisfaction
Nonconforming
Document Number: QSP-100
Quality Assurance
Yes
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Internal Audits QSP-217
Quality Management System