Author name: Clara Fication

Clara Fication has spent more than three decades helping medical device companies navigate the ever-shifting landscape of FDA regulation — from the original QSR to the freshly minted QMSR. Clara writes about FDA requirements the way a good mentor explains them: clearly, honestly, and without the panic that comes from reading the Federal Register cold. She believes that compliance is not the enemy of innovation — it's the thing that makes innovation trustworthy. When she's not translating regulatory Latin into plain English, Clara enjoys criticizing science fiction shows, maintains that a well-written SOP is a form of kindness, and considers coffee a critical component of any compliant quality system.

Quality Audit 2024 presentation on compliance, non-conformance, and improvement
FDA 21 CFR 820 QMSR, ISO 13485, ISO 42001, Management Systems

The Three-Week Panic Is Now Part of the Evidence

For twenty years you could cram for an FDA inspection, because the evidence of the cramming was invisible. The QMSR dropped the §820.180(c) exemptions and FDA retired QSIT — so your internal audit program isn’t just what prepares you for the inspection, it’s one of the things being inspected. Here’s what audit-ready on an ordinary Tuesday actually looks like.

Woman on phone wearing hats labeled CEO and multiple business roles
FDA 21 CFR 820 QMSR, ISO 13485, Management Systems

Congratulations, You’re the Whole Quality Department. Now Go Audit Yourself.

The regulation doesn’t have a headcount exemption — ISO 13485 §8.2.4 asks the same thing of a team of one that it asks of a team of thirty. Here’s what breaks first when the quality department is a single person, what you can fix in-house, and what outsourcing an audit program really means (you can contract the auditing; you cannot contract the responsibility).

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