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MDSAP · Expert · 14 min lesson

Change and transition - QMSR 2026, Audit Approach revisions, RDC 665, MO 169 and keeping a multi-regulation QMS current

FDA QMSR (21 CFR Part 820, effective 2 February 2026), MDSAP AU P0002 revisions 009, 010 and 011, ANVISA RDC 665/2022, MHLW Ministerial Ordinance 169 (2021 amendment), ISO 13485:2016 clauses 4.1.4, 4.2.4, 5.6.2 and 6.2

What you will learn

Key takeaways

Free practice question

Calder's quality manager reads an industry blog saying the QMSR changes everything. She starts rewriting all sixty procedures that afternoon.

What should have happened first?

Rewrite all sixty procedures, because blogs are reliable enough.

Not quite. A blog is secondary; clause 4.1.4 expects evaluation of impact, which a blanket rewrite does not provide.

Read the FDA primary text, confirm the effective date and map the change to affected procedures before rewriting.

Correct. The FDA QMSR page is the primary source, and clause 4.1.4 expects changes to be evaluated before they are made.

Ask the auditing organization to rewrite the procedures.

Not quite. The manufacturer owns its procedures under ISO 13485 clause 4.2.1; the auditing organization only audits them.

Do nothing until the next MDSAP audit is announced.

Not quite. Waiting ignores the change monitoring that ISO 13485 clause 5.6.2 expects to reach management review.

Key terms

Official sources

Go further

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

Open the AcademyWatch on YouTube

Illustrative example. Educational only, not legal advice.