Your Guide to the February 2024 FDA QMSR Ruling

By ETQ on March 13, 2024

Finally, An Update! Your Guide to the FDA’s QMSR Ruling

A ruling has been made! After a long wait, the Food and Drug Administration (FDA) finally published its Quality Management System Regulation (QMSR) in February. While not effective until February 2026, the ruling ensures regulatory consistency for medical device manufacturers.

Background on QMSR

When lives are on the line, producing medical equipment that meets safety and performance standards is not optional. From product design and production to testing, packaging      and labeling, manufacturers must implement quality controls that meet rigorous expectations.

Until now, U.S. medical device makers relied on the FDA’s guidance. More specifically, the current medical device good manufacturing practices (CGMP). It gave them a quality system (QS) baseline of expectations to meet for their operation. Things like:

  • Maintaining inventory and production records for auditing quality assurance
  • Keeping your facility clean
  • Following workplace safety requirements
  • Conducting regular product testing
  • Doing consistent quality control checks

You get the idea! That is, until February 2, 2024, when the FDA finalized QMSR. The long-awaited ruling provides a new medical device quality control framework while helping standardize regulatory expectations to governing bodies worldwide.

Overview of the Final Rule

Before covering the general details of the ruling, we should first explain the purposes behind its creation. First, put yourself in the shoes of a medical and pharmaceutical manufacturer. There’s plenty of demand for your products; they save and improve lives. Many rely on you for quality devices — the stakes are as high as they get.

It’s why governing bodies popped up worldwide — to regulate quality standards for medical devices and ensure they meet expectations. The challenge was uniformity. Standardizing your operations is tricky when material differences exist in how your facility must operate, test and label products, etc. It also gets costly.

Hence, the International Organization for Standardization (ISO) established standard 13485:2016. It included baseline quality management guidelines that many governing bodies could use for quality control regulation. It became the most widely recognized framework in the world.

Unfortunately, the FDA had played by slightly different rules and wasn’t quite in line with the international standards. That was due to unique audit requirements, priorities, etc.

Summarizing QMSR

QMSR amended the FDA’s CGMP guidelines to align with ISO 13485:2016. Traditionally, ISO was merely a standard for quality management systems audited internally by third parties to certify excellence. CGMP, on the other hand, was an actual compliance requirement enforced by the FDA that focused on manufacturing processes for product safety. Failure to comply resulted in legal issues and potential fines.

With QMSR, however, the two now go hand in hand. The FDA outlines ISO quality management system (QMS) requirements as “taken in totality, substantially similar to the requirements of the [FDA] QS regulation.” In other words, if you comply with ISO, you meet the agency’s regulatory expectations.

Impact on Manufacturers

In most industries, a new compliance ruling means additional headaches and costs to the operation. Not in this case. The goal of QMSR is to achieve greater harmony with the global consensus standard for devices. It aims to do this by aligning the Quality Management System (QMS) requirements with those used by regulatory authorities in other jurisdictions.

More simply, that means U.S. requirements will be the same (or similar) to other countries. That’s excellent news for manufacturers. Why?

  • Saves on costs: The FDA estimates that the medical device manufacturing industry will save nearly $532 – $561 million annually due to QMS standardization.
  • Provides more distribution power for life-saving devices: Manufacturers won’t be slowed down in their production due to altered quality control systems. It’ll keep production lines moving and provide customers access to newly developed devices — ensuring a higher quality of life.
  • Simplifies compliance management: Manufacturers don’t have to change systems or audit requirements for different plants. They can use the same processes in the U.S. as in other countries.

Like preparing for any regulatory change, manufacturers should work with legal and compliance experts to fully understand the QMSR guidelines. You should also run a gap analysis to see where to take corrective action for QMS. Then, develop a roadmap to compliance before the effective date.

Transition Period

If you’re stressing about the FDA’s ruling, there’s good news: You have a two-year transition period. That’s right; QMSR doesn’t go into effect until February 2, 2026. So, you have plenty of time for preparation:

  • Learning and understanding the requirements
  • Evaluating where in your manufacturing facilities you need to make any changes
  • Notifying stakeholders of the new requirements
  • Planning on when and how you’ll make those QMS changes (new technology, processes, etc.)
  • Auditing QS controls per new requirements

Don’t let procrastination get in the way of progress. Use the two years to your advantage and get ahead of the curve so you’re not hit with regulatory fines.

Compliance and Implementation Challenges

While the long-term looks promising for medical device manufacturers who fall under QMSR, there’s no question you’ll hit some roadblocks on your journey to compliance:

  • A high initial cost of implementation: You may have to purchase new technology, invest in employee training, and change some processes to meet QMSR risk management requirements.
  • Reliance on supply chain partners: If you buy materials from other manufacturers, you must coordinate to ensure their products meet the FDA’s safety and QMS standards.
  • Confusion about the new requirements: The amendments to CGMP are long and complex. It gets tricky because it includes new QMS requirements and confirming edits to the current FDA guidance.
  • Operational impacts: If you invest in new technology, you could find your operation stopping or slowing down for installation. New processes also generally require a learning curve that could cause rifts in production.

People and technology are the keys to overcoming these challenges. Work with compliance professionals who make a living tracking regulatory updates, understanding the legal ins and outs, and assisting with change management.

You should also invest in electronic quality management software (EQMS) built for medical device manufacturers. These tools meet ISO 13485 standards, make audit reporting and QMS validation a breeze, and help automate many quality assurance processes. The result: Faster speed to market for your new products and assurance the FDA can’t fine you for non-compliance.

QMSR: The Harmonization of QMS Regulation

Once you overcome the initial roadblocks, QMSR will offer substantial opportunities for medical advice manufacturers to grow and achieve enterprise success. With a two-year transition period, start your planning now. Maintain quality assurance and compliance by investing in specialists and technology, like EQMS, that support ISO 13485 and the new FDA ruling.