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GUIDE TO INSPECTIONS OF ELECTROMAGNETIC COMPATIBILITY ASPECTS OF MEDICAL DEVICE QUALITY SYSTEMS 1

TABLE OF CONTENTS

Introduction

Pg 1

Electromagnetic Compatibility

Pg 2

IEC 60601-1-2

Pg 2

EMC in GMP Inspections

Pg 3

Design Controls

Pg 3

Device Labeling Content

Pg 5

Purchasing Controls

Pg 6

Inspection, Measuring & Test Equip

Pg 6

Production/Process Controls

Pg 7

Handling/Storage

Pg 7

Device Master Record

Pg 7

Complaint Files

Pg 7

Servicing

Pg 8

Corrective/Preventive Action

Pg 9

Recalls/Upgrades

Pg 11

Inspection Reports/Observations

Pg 12

Appendix A

Pg 13

Appendix B

Pg 14

Appendix C

Pg 15

Appendix D

Pg 16

Appendix E

Pg 17

 

INTRODUCTION

This guide was prepared by the FDA, Office of Regulatory Affairs, and the Center for Devices and Radiological Health (CDRH), Office of Compliance.

This guide provides FDA investigators with information regarding electromagnetic compatibility (EMC) and how it is likely to be addressed in a medical device firm's Quality System/Good Manufacturing Practices (QS/GMP) (21 CFR Part 820). Terms throughout this document that are in bold typeface are defined in Appendix A.

THIS DOCUMENT APPLIES ONLY TO ELECTRICALLY POWERED (MAINS OR BATTERY) DEVICES. It includes information on the following:

  1. electromagnetic disturbances (EMD), including radiated and conducted emissions, as well as electrostatic discharge (ESD);
  2. electromagnetic interference (EMI), susceptibility and immunity;
  3. international and voluntary EMCstandards, such as IEC 60601-1-2; (these are not FDA performance standards or mandatory requirements.)
  4. areas of the new Quality System regulations where EMC is likely to be addressed;
  5. how the regulations apply to EMCissues in continuing production of existing devices, design and production of new or modified devices, and upgrades and recalls of marketed devices; and
  6. expectations and limitations of the GMP inspection process regarding EMC.

The Center for Devices and Radiological Health (CDRH) is encouraging firms, many of whom have never considered some of these issues, to begin the process of addressing EMC. The goal is to improve the industry norm, not to penalize industry efforts to design EMC into their devices. There are a number of confounding factors in achieving EMC. Manufacturers can design EMCinto their electrical devices for most expected use environments, depending on design options for proper functioning or electrical safety, intensity or variableness of environments, the

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