Why take this course?
Under FDA’s QMSR alignment with ISO 13485:2016, medical device traceability depends on more than maintaining a complete traceability matrix. The underlying product configuration must preserve reliable relationships among user needs, requirements, identified risks, risk controls, design outputs, verification methods, objective evidence, residual-risk evaluations, approved changes, and the product configurations to which those relationships apply throughout the design lifecycle and subsequent product changes.
This webinar examines traceability as an observable property of a maintained configuration rather than a collection of linked documents. Participants will consider how approved states, revisions, applicability, effectivity, and relationship types determine whether traceability is actually correct. The discussion addresses missing, stale, broken, and configuration-wrong relationships, change-impact assessment, and the generation of controlled traceability views from maintained information. The emphasis is on exposing affected objects and evidence before change approval, reducing manual document updates, and supporting inspection readiness as products evolve.
Key Areas Covered
José Mora
José Ignacio Mora brings more than 30 years of medical device and life sciences experience across quality systems, manufacturing and design engineering, process development and validation, configuration control, and controlled-document methodology. His work in engineering leadership, quality systems, and configuration management directly supports the relationship-based traceability and change-control challenges addressed in this webinar.
Commonly Asked Questions About This Subject
How can a traceability record look complete and still fail during an inspection or design review?
A complete set of links provides little assurance if those links connect the wrong revisions, configurations, or evidence. This is where apparently mature traceability systems can become difficult to defend. Every requirement may have a verification reference, yet the referenced test may have been executed against an earlier design configuration.
The problem often surfaces after several design changes. A requirement is revised, a risk control changes, or a design output is replaced, but existing relationships remain untouched because no link appears to be missing. The traceability report still shows 100 percent coverage.
A stronger review asks whether each relationship remains valid for the approved product configuration being assessed. That means checking revision state, applicability, effectivity, change history, and the configuration against which objective evidence was generated.
During inspection, being able to produce a complete matrix quickly is useful. Being able to demonstrate that its relationships accurately represent the product configuration under review carries far more weight.
When does a design change require existing verification evidence to be reconsidered even if the original test remains technically valid?
Existing verification evidence should be reconsidered whenever the change affects the configuration assumptions under which that evidence was generated. A test can remain scientifically sound while no longer proving what the organization needs it to prove for the changed device.
This issue frequently appears with changes that seem localized. A software modification, component substitution, interface change, revised risk control, or altered user requirement may leave the original verification method untouched. The difficult question is whether the previous result still applies to the new configuration.
Change assessment should therefore examine the relationship between the changed object and the evidence, including indirect dependencies. If previous evidence is retained, the record should explain why the tested configuration remains representative and why the change does not invalidate the original conclusion.
Weak justification creates substantial rework later because teams may discover during submission preparation, design review, or inspection that accepted legacy evidence cannot be confidently connected to the current device.
Who should own traceability when requirements, risk controls, design outputs, and verification evidence are maintained by different functions?
Ownership has to extend across functional boundaries because no single department can maintain reliable traceability if each team controls only its own records. Engineering may own requirements, Quality may oversee risk management, V&V may control testing, and Configuration Management may govern product revisions. The relationships between those records still require defined accountability.
Governance breaks down when each source document is correctly controlled but nobody is responsible for determining whether cross-functional relationships remain correct after change. This produces a familiar inspection problem: every department can produce its records, but reconstructing the current product configuration requires several people and considerable interpretation.
Effective ownership defines who establishes relationships, who can modify them, who evaluates affected relationships during change, and who verifies that the resulting configuration remains coherent.
A useful test is simple: after a significant change, can the organization identify affected requirements, risks, outputs, and evidence without relying on institutional memory? If experienced employees have to reconstruct those connections manually, the control model remains fragile.
How should legacy products be handled when years of design history were created without configuration-based traceability?
Trying to rebuild every historical relationship at once usually creates enormous effort without proportional regulatory value. A more practical approach starts with the currently approved product configuration and the information needed to support present design, risk, verification, and change decisions.
Legacy products often contain decades of revisions, superseded specifications, historical test reports, transferred records, and inconsistent identifiers. Attempting to convert all of that history into perfect structured traceability can introduce new errors while consuming resources needed for current controls.
Priority should be given to safety-critical requirements, significant risk controls, current design outputs, essential verification evidence, unresolved issues, and areas likely to be affected by future changes. Gaps discovered during this work should be assessed for their actual quality and regulatory significance rather than treated automatically as documentation remediation.
The transition becomes defensible when its scope, priorities, exclusions, and rationale are documented. Regulators are better served by reliable traceability for the current configuration than by an ambitious reconstruction that creates the appearance of completeness without trustworthy relationships.
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