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Does ISO 9001:2015 require CSV

Discussion in 'ISO 9001:2015 - Quality Management Systems' started by Praveen Gunasekaran, Aug 10, 2022.

  1. Praveen Gunasekaran

    Praveen Gunasekaran New Member

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    Hi my organization is a ISO 13485 and ISO 9001 certified, we have certain product lines that are fully under ISO 13485. Some products line are completely Non-Medical and are under ISO 9001, these products do not share any processes, equipment, and procedures with medical device products. These softwares are not uploaded into any machine, it checks if the product can perform basic operation like move to certain X, Y and Z location to perform certain tasks.

    As these tasks are covered in my manufacturing test plan, I believe doing validation for each computer is overkill.

    So my question.
    1) Is CSV an ISO 9001 requirement.
    2) When I point that software validation is not part of ISO 9001 the quality team's counterargument is that 8.5.1 f control of production service provision states the requirement for validation.

    Requesting for expert opinion.
     
  2. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Welcome. Can you tell us more about the software?
     
  3. yodon

    yodon Well-Known Member

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    Standards aside, since you're making quality decisions based on the software, how do you have assurance that the software is operating correctly?
     
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  4. BradM

    BradM Moderator Staff Member

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    Excellent (as usual).

    Yes... there may be "formal" steps and activities related to applicable standards, but what activities do you need to do to assure it's working properly on all the different workstations where it's going to be used?
     
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  5. Praveen Gunasekaran

    Praveen Gunasekaran New Member

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    Hi, Thanks for replying, and this is my first joining a forum and raising a question, So bit excited. Maybe I will split my question in 3 separate questions. 1) Is it a general practice to perform CSV for ISO 9001 certified product lines, 2) If not what is recommended method to control software in a ISO 9001 production line, 3) Specific to my case what should be my approach?


    So to explain the background of the software I use,

    1) We build robotic products which are controlled by our company software installed to a laptop or desktop, no inbuilt memory system in the product.

    2) Using Software, I teach and train the robot to execute predefined protocols (which is the QC checkpoint). Product expectation is to execute all required protocols and once executed they produce intended results like delivery of 1ul of liquid, moving to x for 200 mm, y for 100 mm etc. Again these indented results are verified using either visual, mechanical or analytical and are recorded.

    3) Once the product reaches the customer, they again teach and create new protocols as per their requirement, even integrate third party software to my software and execute either medical or nonmedical environment.

    4) Our software is not validated for medical devices, and it is up to customer to run validation of it for their needs.

    5) The revision upgrades,
    a) done by R&D software team (in US) targets certain customer requirement which we don't test at manufacturing (in Singapore). R&D team verify the software by running either customer test cases or their own test cases.
    b) does not affect the core performance (manufacturing test protocols) and in case certain features are added we have separate change management process where we test, verify, record and approve those changes.

    6) CSV expectation from quality team is whenever there is an up rev every computer should be validated with master validation plan multiple validation report.
     
  6. BradM

    BradM Moderator Staff Member

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    So the mfg. builds robotic products. You state the products have no inbuilt memory. How does it retain the "learned" movements/ activities?
    A computer is used for programming. Will the robotic product operate in production environment separate of the computer? Or will the computer always have to be attached?

    I guess I'm wondering this... are the computers used merely to program information into the robotic product and then is not used again; or is the robotic product continuously dependent on the computer?
     
  7. Praveen Gunasekaran

    Praveen Gunasekaran New Member

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    Hi Brad,
    The Robotic product continuously requires a computer. The teach point is saved in each computer as profile. If I connect with a new computer, I need to reteach and recreate the profiles.

    regards,
    GP
     
  8. Andy Nichols

    Andy Nichols Moderator Staff Member

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    The situation you describe is similar to most tools used to "set" products up - assemblies or similar. There should be no need for anything other than control (like information controls) over the program so that you know which version is being run and removing any previous versions which may be resident on the pc/controller. If the positions the robot is instructed to go to can be verified, then having done it once, the program version control should take care of the rest.
     
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  9. BradM

    BradM Moderator Staff Member

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    So... sorry for all the questions. :) To clarify... the robotic product in question has no impact/association/ etc. with any patient, their safety or anything like that?
    Would... incorrect operation of the robotic product lead to a quality failure?
     
  10. BradM

    BradM Moderator Staff Member

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    I'm leaning this way, Andy. However... I'm not sure what the product is going to be used for. If there is no quality/ safety risk, then yes, establish like you list. But if there is something else... it would need to be addressed.
     
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