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  • 1.  Combination Products and ISO 13485

    Posted 07-06-2026 12:44 PM

    Hi, Exemplar Community:

    I would like to know how many of you work in the combination product arena and how you establish and implement a monitoring system to ensure that post-market quality surveillance complies with ISO 13485, specifically within a pharmaceutical-industry-centric QMS.

    I spent most of 2025 designing an ISO 13485-compliant sub-QMS process for the combination product and successfully implemented the processes prior to FEB 2026. The system and records have not been inspected by the Health Authority; therefore, I would like to know if your company has already been inspected for the combination product-specific requirements.

    Thank you.

    Ming (Device and Combination Product Quality Oversight)



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    Ming Aquila
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  • 2.  RE: Combination Products and ISO 13485

    Posted 24 days ago

    Thanks for starting this discussion, Ming. This is a great question and a very specialized area that I'm sure others in our Community can learn from.

    I'd especially love to hear from members working in medical devices, pharmaceuticals, or combination products. If you've gone through a Health Authority inspection for combination product requirements or have experience implementing post-market surveillance within an ISO 13485 framework, please share your insights.

    Looking forward to seeing the discussion unfold!



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    Jamie Gravatte
    Community Manager
    Exemplar Global
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  • 3.  RE: Combination Products and ISO 13485

    Posted 23 days ago

    We implemented a similar approach by integrating ISO 13485 requirements into an existing pharmaceutical QMS rather than creating a completely separate system. For post-market surveillance, we aligned complaint handling, CAPA, trend analysis, vigilance, and management review with both device and pharmaceutical requirements, ensuring clear ownership and documented interfaces.

    I'd also be interested to hear from organizations that have already undergone Health Authority inspections focused on combination product-specific ISO 13485 requirements, as practical inspection experiences are extremely valuable.



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    Francisco J. Tapia Guerrero
    ftapia@qualitascertification.com
    www.linkedin.com/in/franktapiaguerrero
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  • 4.  RE: Combination Products and ISO 13485

    Posted 19 days ago

    Hi @Ming Aquila

    One common gap in combination product quality systems is the inadequate application of ISO 14971 risk management throughout the entire product lifecycle. Risk management should not be treated as a one-time activity during development; it must be continuously maintained through post-market surveillance, complaint handling, design changes, CAPA activities, and ongoing risk-benefit evaluations.

    One recommendation for organizations implementing ISO 13485 within a QMS is to start with "ISO 14971, Medical Devices – Application of Risk Management to Medical Devices"

    Best,



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    Frank Higley-Sanchez
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  • 5.  RE: Combination Products and ISO 13485

    Posted 5 days ago

    Ming, I have not taken a combination product through a health authority inspection, so treat this as an auditor view of where these systems usually come apart rather than inspection experience. The weak point is nearly always the interface rather than either system on its own. Complaints, adverse events and device deficiencies arrive through different doors in a pharmaceutical QMS, and unless one person owns the decision on how each incoming signal is classified and routed, the device side of post market surveillance quietly sees only a filtered subset. If I were auditing you I would take real complaints from the pharmaceutical intake and follow them through to whether the device risk file was actually reviewed.

    The second thing I would look for is evidence that post market data changed something, which is the practical version of the ISO 14971 point Frank raised. A trend review that concludes acceptable every quarter in the same wording tells an assessor very little, whereas one clear instance of a post market signal reopening the risk assessment and driving a design or labelling change is worth more than a shelf of procedures.



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    Dilawar Laghari
    Auditor, Consultant and Trainer
    Audit Workshop
    https://auditworkshop.com/
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