For thirty years, FDA inspections ran against the Quality System Regulation and ISO 13485 was the voluntary international equivalent. That ended in February. The QMSR now incorporates ISO 13485:2016 by reference, which means the requirements you used to meet by choice are the ones an FDA investigator arrives holding. If your quality system was built to the old Part 820 and never fully reconciled with 13485, that gap is now a compliance gap.
Book a free 30-minute callThirty minutes to work out where your system actually stands against the new regulation, and what closing the distance would take.
The shift is real but narrower than some of the consulting noise suggests. Four things are worth understanding before you spend money on anything.
The FDA requires you to meet the requirements of ISO 13485 as written into Part 820. It does not require you to hold a certificate from a registrar, and a certificate does not exempt you from FDA inspection. Certification is worth pursuing for market access and customer confidence, not because the FDA asks for it.
The QMSR incorporates ISO 13485:2016 specifically. If ISO publishes a later edition, it does not automatically become US law — that would take fresh rulemaking. You are building against a fixed target, which is unusually comfortable ground in this business.
The QMSR is not simply ISO 13485 with a federal cover page. Labeling and packaging controls, unique device identification, certain record and definition provisions, and the FDA's own expectations on complaint and servicing records all sit on top of the standard.
To be clear about something the market often muddles: ISO 13485 is a standalone standard. You do not need ISO 9001 certification first, and no registrar or notified body will ask for it. But the two standards share most of their foundations — document control, purchasing, competence, internal audit, management review, corrective action — and roughly three quarters of the work of building a 13485 system is building a sound quality system, full stop.
That's why my material is structured in two parts. The implementation course builds the quality system itself, clause by clause, with the procedures and forms written out and a completed example of each. The medical device add-on then covers everything ISO 13485 requires that ISO 9001 doesn't: the regulatory reporting obligation, risk management across the product lifecycle, the medical device file, design controls, validation driven by risk, sterile device requirements, and the infrastructure and personnel controls. It also maps the clause numbering, because ISO 13485:2016 kept the older structure — clauses 4 through 8, with management responsibility at 5 and product realization at 7 — rather than adopting the layout ISO 9001 now uses.
Work through the first part and you have a system that would satisfy an ISO 9001 auditor. Add the second and you have one built for the QMSR and a 13485 registrar. Nothing from the first part gets thrown away.
Stripped of the language, the standard asks you to establish how a device gets designed, made and serviced safely, do it that way every time, keep records that prove it, and act on problems in the field. Where it parts company with ISO 9001 is in how much of that has to be written down, and in who you answer to when it goes wrong.
I'm Steve Kent. I've spent over forty years in quality management, most recently as a Quality Director, with roughly twenty of those years working on ISO 9001 and its derivatives — AS9100 in aerospace and ISO 13485 in medical devices.
I've built quality systems from nothing and rebuilt ones that had quietly stopped working. I've prepared companies for registrar audits and I've sat on the other side of the table during them, which matters more than it sounds: knowing what an auditor is looking for is a different thing from knowing what the clause says.
Falcon Quality is a one-person practice by choice. There's no account manager and no junior consultant doing the work under my name. If you engage me, you get me.
I'll also tell you plainly when something is outside what I do. I'm a quality systems specialist, not a regulatory affairs consultant — I can build you a QMS that satisfies ISO 13485 and the QMSR, and I'll tell you when you need a regulatory or notified-body specialist alongside me rather than pretending otherwise.
More about how I work
Four stages, the same shape as any QMS project, with more documentation at every step than an ISO 9001 build. How long it takes depends on how many devices you make, whether you design them, whether you sterilize, and how much of a system already exists. Anyone quoting you a fixed duration before seeing your operation is guessing.
A clause-by-clause review of your current system against ISO 13485 and the QMSR additions, including whatever was built to the old Part 820 and needs reconciling.
Procedures, the medical device file structure, design controls where you design, risk management tied to ISO 14971, and the records to support all of it. Written for how your operation actually runs.
Training, a full internal audit cycle, and management review conducted properly. Registrars and investigators both want proof the system has been operating, not just that the documents exist.
Mock audit, preparation for Stage 1 and Stage 2 if you're certifying, FDA inspection readiness if you're not, and support closing whatever gets raised.
The two courses together are the self-directed path. For medical device work I'd advise adding consulting calls to them — more strongly than I would for ISO 9001. The parts of ISO 13485 with no ISO 9001 equivalent are exactly the parts where a course can only take you so far: which processes need validation and to what depth, how your design history file should be structured for the device you actually make, what your sterilization validation has to demonstrate, and where your risk file and your quality system have to line up. Those answers are specific to your device and your operation, and getting them wrong is expensive to unwind after an auditor finds it. The call is free either way.
Eight modules building the quality system clause by clause, with every procedure and form already written and a completed example of each. This is the three quarters of ISO 13485 that is simply sound quality management.
See what's coveredEverything ISO 13485 requires that ISO 9001 does not — regulatory reporting, lifecycle risk management, the medical device file, design controls, risk-based validation, sterile device requirements, infrastructure and personnel controls — plus the clause mapping between the two structures.
Ask me about the add-onOne-to-one time on the decisions a course can't make for you: validation strategy, design controls for your specific device, sterilization and risk file questions, audit preparation. Blocks of five calls for $600 or ten for $1,000. Most people doing 13485 work want these alongside the courses.
How the calls workBefore any of that, the free gap analysis will give you a reading on the ISO 9001 foundation — the part both standards share. It won't cover design controls, sterilization or the medical device file, so treat it as a temperature check rather than a 13485 audit. Start the assessment
Thirty minutes, no charge, no obligation. Tell me what you make and what state your quality system is in, and I'll tell you what the work actually involves — including whether you need to hire anyone at all.
Sixty-seven questions across every clause of ISO 9001, scored by section. Set aside 30 to 45 minutes. Free, and your answers save as you go.
ISO 9001, AS9100 and ISO 13485 consulting and courses for small and medium manufacturers. A one-person practice — you work with me, not an account manager.
Falcon Quality is an independent consultancy. It is not a certification body, a registrar or an accreditation organization, and it does not issue certificates. ISO 9001, AS9100 and ISO 13485 are the property of their respective standards organizations.