ISO 13485 2003 Gap Analysis Tool

The following material will introduce our Plain English Gap Analysis Tool.
However, we will not present the complete product. Instead, we will show
you how our Gap Analysis Tool is organized and how it is used. In addition,
we will show you some examples of our approach. Once you've examined
our approach, we hope you'll consider purchasing our complete
ISO 13485 2003 Plain English Gap Analysis Tool (Title 46).

If you need to comply with the ISO 13485 2003 standard or want to
improve the performance of your quality management system (QMS),
you need our Gap Analysis Tool. Our tool will help you to identify the
gaps that exist between the standard and your organization's actual
processes. Once you know exactly where your gaps are, you can take
steps to fill them. By using this approach, you will not only comply with
the standard, but you will also improve the performance of your QMS.

Use our Gap Analysis Tool either to develop a brand new quality
management system or to upgrade your existing system. If you're
currently ISO 13485:1996 or ISO 13488:1996 certified, you can
use our Gap Analysis Tool to upgrade your quality management
system to the new ISO 13485 2003 standard. And if you're currently
ISO 9001, 9002, or 9003 certified you can use our Gap Analysis Tool
to ensure that your quality management system complies with
the ISO 13485 2003 medical device standard.

Our Plain English Gap Analysis Tool is easy to understand and
ready to use. It is focused, detailed, and complete. We guarantee it!

Our Plain English Gap Analysis Tool has two phases.
The following material will introduce these two phases.

Phase One: Identify Gaps

Phase One asks you to identify gaps by performing a Gap Analysis.
Use our five Gap Analysis Questionnaires (4 to 8) to carry out your
analysis. These five questionnaires list the five sets of requirements
that make up the ISO 13485 2003 standard. But, instead of listing ISO's
requirements in the form of statements, they are listed as questions.

Each Gap Analysis question has either two or three possible answers.
Whenever a question refers to a requirement that must be met in order
to comply with the standard, we offer two possible answers: Yes and
No. A Yes answer means that you have already met one of ISO's
requirements while a No answer points to a gap that must be filled.

However, whenever a requirement may be excluded or ignored, we
offer a third option: N/A. Select N/A if the requirement is not applicable
in your situation. The N/A option is added to every section 7 question
because you may exclude or ignore any section 7 requirement if you
can justify doing so. You can exclude any section 7 requirement if it is
not applicable in your situation because of the nature of your products.

You can also exclude subsection 7.3 design and development
requirements if official regulations allow you to do so and if you
have made other arrangements that comply with these regulations.

Occasionally, throughout the standard, ISO uses the phrases
“if appropriate” or “where appropriate”. Whenever a requirement
uses one of these phrases, you may ignore or exclude it if the
requirement is not appropriate in your situation.

No answers reveal gaps that exist between the ISO 13485 standard
and your organization's processes. Whenever you answer No to a
question, you are stating that at least one process fails to meet an
ISO 13485 requirement. A No answer tells you that at least one
process needs some work. It tells you that at least one of your
processes needs to be developed, modified, or improved. So
whenever you answer No to a question, you must consider
your processes, and decide which ones need to be changed.

Phase Two: Fill Gaps

Once you've identified all of your gaps, you can begin to fill them.
In general, you fill your gaps by preparing and implementing Process
Development Plans using the following Process Development Forms:

Quality Management Process Development Form
Resource Management Process Development Form
Regulatory Research Process Development Form
Market Research Process Development Form
Product Design Process Development Form
Purchasing Process Development Form
Production Process Development Form
Service Provision Process Development Form
Product Protection Process Development Form
Customer Needs Assessment Process Development Form
Customer Communications Process Development Form
Internal Communications Process Development Form
Document Control Process Development Form
Record Keeping Process Development Form
Planning Process Development Form
Training Process Development Form
Internal Audit Process Development Form
Management Review Process Development Form
Monitoring and Measuring Process Development Form
Nonconformance Management Process Development Form
General Systemic Process Development Form

Use these Process Development Forms to prepare your Process
Development Plans. Each Form is used to list the remedial actions
that should be taken to fill your gaps.

Of course, before you can list your remedial actions, you need
to formulate them. In general, remedial action statements can be
formulated by turning our Gap Analysis questions into simple action
statements. For example, the Product Realization Gap Analysis
question number 409 asks: "Do you protect your monitoring and
measuring devices?" In order to prepare a remedial action statement,
all you have to do is re-write it as follows: "Protect monitoring and
measuring devices". This remedial action statement is then listed on
our Monitoring and Measuring Process Development Form. In most
cases, that's all there is to it. However, in some cases, you may need
to be more specific, or you may need to formulate a slightly different
action statement for several different processes.

Once you’ve done this for all gaps, you will have several Process
Development Plans which, taken together, make up a very detailed
Quality Management System Development Plan that will be unique
to your organization. And once you’ve implemented your Quality
Management System Development Plan, you will have an
ISO 13485 2003 compliant quality management system.

The following example will show you what our Gap
Analysis Tools look like. This example is taken from
7. Product Realization Gap Analysis Questionnaire.

NOTE: ISO 9001 2000 questions use black text,
whereas ISO 13485 2003 questions use blue text.

ISO 13485 2003 GAP ANALYSIS TOOL 7. PRODUCT REALIZATION GAP ANALYSIS QUESTIONNAIRE
7.5.3 IDENTIFY AND TRACK YOUR PRODUCTS
7.5.3.1 DEVELOP PROCEDURES TO IDENTIFY PRODUCTS
1	Have you established procedures to identify your products and to maintain their identity throughout product realization?	YES	NO	N/A
2	Have you documented procedures to identify your products and to maintain their identity throughout product realization?	YES	NO	N/A
3	Do you maintain procedures to identify your products and to maintain their identity throughout product realization?	YES	NO	N/A
4	Do you use your procedures to establish the identity of your organization’s products?	YES	NO	N/A
5	Do you use your procedures to maintain the identity of your products throughout product realization?	YES	NO	N/A
6	Have you established procedures to control what is done with your medical devices when they are returned to your organization?	YES	NO	N/A
7	Do your procedures identify returned medical devices?	YES	NO	N/A
8	Do your procedures distinguish between returned medical devices and conforming products?	YES	NO	N/A
9	Have you documented procedures to control what is done with medical devices when they are returned to your organization?	YES	NO	N/A
10	Have you implemented procedures to control what is done with medical devices when they are returned to your organization?	YES	NO	N/A
11	Do you maintain procedures to control what is done with medical devices when they are returned to your organization?	YES	NO	N/A
7.5.3.2 ESTABLISH PROCEDURES TO TRACK PRODUCTS
7.5.3.2.1 ESTABLISH PRODUCT TRACEABILITY PROCEDURES
12	Have you developed product traceability procedures?	YES	NO	N/A
13	Do your product traceability procedures specify how extensive your traceability process should be?	YES	NO	N/A
14	Do your product traceability procedures describe the records that need to be maintained to support your product traceability process?	YES	NO	N/A
15	Have you documented your traceability procedures?	YES	NO	N/A
16	Have you implemented your traceability procedures?	YES	NO	N/A
17	Do you maintain your traceability procedures?	YES	NO	N/A
18	Do you control the unique identity of your products?	YES	NO	N/A
19	Do you record the unique identity of your products (when traceability is a requirement)?	YES	NO	N/A
7.5.3.2.2 ESTABLISH RECORDS FOR IMPLANTABLE DEVICES
20	Have you established traceability records to support your implantable medical devices?	YES	NO	N/A
21	Have you established traceability records to support active implantable medical devices?	YES	NO	N/A
22	Do your traceability records identify all product components whenever these components could undermine your medical device’s ability to meet specified requirements?	YES	NO	N/A
23	Do your traceability records identify all materials used whenever these materials could undermine your medical device’s ability to meet specified requirements?	YES	NO	N/A
24	Do your traceability records identify all work environment conditions if these conditions could undermine your medical device’s ability to meet specified requirements?	YES	NO	N/A
25	Do your distributors maintain a record of their medical device distribution activities and results?	YES	NO	N/A
26	Do your distributors’ records facilitate product traceability?	YES	NO	N/A
27	Are distributors’ records available for inspection?	YES	NO	N/A
28	Do your agents maintain a record of their medical device distribution activities and results?	YES	NO	N/A
29	Do agents’ distribution records facilitate product traceability?	YES	NO	N/A
30	Are your agents’ records available for inspection?	YES	NO	N/A
31	Do all traceability records specify where medical device packages are shipped to?	YES	NO	N/A
32	Do all traceability records specify who medical device packages are consigned to?	YES	NO	N/A
7.5.3.3 PRESERVE PRODUCT IDENTITY AND STATUS
33	Do you identify the monitoring status of your products?	YES	NO	N/A
34	Do you identify the measurement status of your products?	YES	NO	N/A
35	Do you maintain the identity of your products, including their monitoring and measurement status, throughout the production process?	YES	NO	N/A
36	Do you maintain the identity of your products, including their monitoring and measurement status, during the storage process?	YES	NO	N/A
37	Do you maintain the identity of your products, including their monitoring and measurement status, during the installation process?	YES	NO	N/A
38	Do you maintain the identity of your products, including their monitoring and measurement status, throughout the servicing process?	YES	NO	N/A
39	Are your products dispatched only if they have passed all tests and inspections or have been released under an authorized concession?	YES	NO	N/A
40	Are your products used only if they have passed all tests and inspections or have been released under an authorized concession?	YES	NO	N/A
41	Are your products installed only if they have passed all tests and inspections or have been released under an authorized concession?	YES	NO	N/A
42	*Etcetera ...*

ORGANIZATION:		YOUR LOCATION:
COMPLETED BY:		DATE COMPLETED:
REVIEWED BY:		DATE REVIEWED:

ISO 13485 2003 GAP ANALYSIS TOOL
PART	TITLE 46: TABLE OF CONTENTS	PAGE
1	Profile of Gap Analysis Project	3
2	Introduction to ISO 13485 2003	4
3	Explanation of Gap Analysis Process	13
4	Systemic Gap Analysis Questionnaire	17
5	Management Gap Analysis Questionnaire	26
6	Resource Gap Analysis Questionnaire	36
7	Realization Gap Analysis Questionnaire	44
8	Remedial Gap Analysis Questionnaire	74
9	Quality Management System Development Plan	90
10	Administrative, Legal, and Contact Information	112
JAN 2005	COPYRIGHT © PRAXIOM RESEARCH GROUP LIMITED. ALL RIGHTS RESERVED.	VER 1.0

OVERVIEW OF GAP ANALYSIS PROCESS
	PHASE ONE: IDENTIFY GAPS
	ANSWER EACH GAP ANALYSIS QUESTION
	ANSWER "YES" REQUIREMENT HAS BEEN MET NO ACTION REQUIRED	ANSWER "NO" GAP HAS BEEN IDENTIFIED REMEDIAL ACTION SHOULD BE TAKEN	ANSWER "N/A" REQUIREMENT IS NOT APPLICABLE NO ACTION REQUIRED
	FOR EACH "NO" ANSWER SELECT THE QUALITY PROCESSES THAT NEED FURTHER DEVELOPMENT
	PHASE TWO: FILL GAPS
	PREPARE PROCESS DEVELOPMENT PLANS USING OUR PROCESS DEVELOPMENT FORMS
	IMPLEMENT YOUR PROCESS DEVELOPMENT PLANS AND TRACK IMPLEMENTATION USING OUR PROCESS DEVELOPMENT FORMS

JAN 2005	COPYRIGHT © PRAXIOM RESEARCH GROUP LIMITED. ALL RIGHTS RESERVED.	VER 1.0
PART 7	PRODUCT REALIZATION GAP ANALYSIS TOOL	PAGE 65

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Updated on July 17, 2012. First published on January 6, 2005.
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ISO 13485 2003

GAP ANALYSIS TOOL

Phase One: Identify Gaps

Phase Two: Fill Gaps

ISO 13485 2003 GAP ANALYSIS TOOL