13485cert

Management Representative

In Elsmar Cove, ISO, ISO 13485, Management Representative, Management Responsibility, QA, Quality, Quality Management Systems on January 18, 2011 at 5:05 pm

The video music selection for this week was a tune I heard at a restaurant called “1776” in Crystal Lake, IL. The restaurant played Chris Isaak recordings for the entire meal. Maybe the satellite radio station was stuck on the letter “I”.

 The idea for this posting was from a thread I found on Elsmar Cove:

http://elsmar.com/Forums/showthread.php?t=45658

One person posted a question about the requirement for the Management Representative (MR) to be a member of the organization’s management (see section 5.5.2 of ISO 9001:2008). Companies that are seeking initial certification sometimes struggle with this requirement. Some struggle because they do not have anyone in-house that is sufficiently trained to be the MR. Other companies struggle, because they are very small and outsource their QA functions to a consultant. The following blog is targeted at helping these companies.

     I audit companies to the ISO 13485 (medical QMS) & 9001 (QMS) Standards. The intent of both Standards was always to have the MR be part of management, but some companies did not interpret the Standards in this way. With the 2008 revision of 9001, the possibility of misinterpreting the meaning is much less likely. The companies that receive findings during the Stage 1 or Stage 2 audit for this requirement usually fall into one of two categories. Category #1: our company is small and the only person that really knows enough about ISO requirements is not a member of management. Category #2: our company is small and we outsource QA functions.

   The good news is that any manager can be assigned the responsibility of being MR. One of my clients assigned this responsibility to the VP of Sales. Another company assigned this responsibility to the Director of R&D. Both of these individuals had to put in the time to learn about Quality Management Systems, but both have embraced the challenge and I have learned a lot from them. They have a different perspective and bring a lot of value to the MR role.

    The bad news is: whomever you assign has to learn enough to be competent in the role.

   The definition of “Management” is typically a stumbling block. Most people think of managers requiring that they have other people reporting to them. This is not an absolute. The MR should report directly to a top manager such as the President or CEO to prevent conflicts of interest. As a manager, they should not require a lot of direct supervision and the President or CEO should not be overly burdened by adding one person to their list of direct reports.

   Some auditors like to see a “deputy MR” identified. My advice is to have the CEO or President sufficiently trained that they can be the “back-up” when the MR is on vacation. Every manager should know enough about their subordinate’s job duties that they can “fill in.”

   MR’s should be involved in senior staff meetings too, but not necessarily at the same frequency as every other senior staff manager. Typically operations and sales have the most frequent meetings with the CEO–often weekly. Finance is typically monthly. HR and the MR might be bi-monthly or Quarterly. Communication of the status of Quality Objectives should be regular reports to all senior staff, but you don’t have to have a Management Review to communicate the status. If the company is small enough to have only one QA person, there probably isn’t a need for more than one or two management review meetings per year.

   If your company has a finding against clause 5.5.2, I recommend the following actions:

1. Assign a person that is already a member of your senior staff as MR

2. Document the responsibility in the person’s job description

3. Document the responsibility in the org chart

4. Assign the person’s direct supervisor (typically the CEO or President) as a “deputy MR”

5. Find a good webinar on ISO training for the new MR and their boss (ideally one with a quiz and a certificate)

6. Have the new MR develop a 45 minute presentation for the senior staff on the topic of Management Responsibilities. This training should cover all of section 5 in the Standard.

7. Give the senior staff a 15 minute multiple choice quiz to evaluate effectiveness of the training.

8. Have the new MR discuss delegation of various management review inputs (see section 5.6.2) with their boss. Quality should be a shared responsibility and Management Reviews will be more effective if everyone takes part.

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