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ISO 13485 · Expert · 15 min lesson

Auditing the MDR QMS (Article 10(9)) and the GSPR (Annex I)

EU MDR 2017/745 Article 10(9), Annex I, Annex II section 4 and Article 15; ISO 19011 audit practice

What you will learn

Key takeaways

Free practice question

Verdane's QMS matrix lists items a) to l) of Article 10(9) with procedure numbers and owners. Item m) monitoring, data analysis and improvement has the entry 'see management review'. No procedure covers complaint trending or nonconformity trending.

What is the best audit conclusion?

Element m) is not shown to be implemented: no procedure or record covers data analysis and trending, which Article 10(9) m) requires.

Correct. Article 10(9) m) requires monitoring, measurement, data analysis and improvement, and a pointer to a meeting is not a process.

No finding, because management review exists under Article 10(9) c).

Not quite. Management review answers element c) and does not by itself analyse complaint or nonconformity data required by Article 10(9) m).

A finding against Annex I section 3, because trending belongs to risk management.

Not quite. Risk management feeds from trending, but the missing process is the data analysis named in Article 10(9) m).

Only advise the company to add a procedure at some point.

Not quite. Advice leaves the Article 10(9) m) gap open; an auditor records the missing element as a finding with evidence.

Key terms

Official sources

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The full lesson has narrated slides, more scenario questions with explained answers and a simulation.

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Illustrative example. Educational only, not legal advice.