The Seven MDSAP Audit Processes
A Manufacturer's Guide to Compliance and Audit Readiness
Overview of the Process-Based Audit Model
The Medical Device Single Audit Program (MDSAP) replaces the traditional clause-by-clause audit of ISO 13485 with a process-based model built around seven defined processes. A single audit conducted by an MDSAP-recognized Auditing Organization (AO) satisfies regulatory requirements across five participating jurisdictions: Australia (TGA), Brazil (ANVISA), Canada (Health Canada), Japan (MHLW/PMDA), and the United States (FDA). MDSAP is mandatory in Canada for any Class II, III, or IV device licensing; in the other four jurisdictions it is voluntary but strongly recognized.
All medical device manufacturers marketing or seeking to market devices in one or more participating countries should comply. This includes finished-device manufacturers, contract manufacturers, sterilization specifiers, and own-brand labelers. Each of the seven processes has defined inputs, outputs, and linkages, and auditors trace records across processes to verify the QMS operates as a connected system rather than in silos.
The Seven Processes at a Glance
| # | Process | Scope and Key Focus |
|---|---|---|
| 1 | Management | Leadership commitment, quality policy and objectives, resource allocation, management review, communication. Audited every cycle. |
| 2 | Measurement, Analysis & Improvement | Internal audits, CAPA, data analysis, monitoring of customer feedback and complaints, statistical techniques. Audited every cycle. |
| 3 | Adverse Events & Advisory Notices Reporting | Country-specific vigilance reporting timelines, field safety corrective actions (FSCA), and recall procedures for all five jurisdictions. |
| 4 | Design & Development | Design controls including planning, inputs, outputs, V&V, design transfer, design changes, and the Design History File (DHF). |
| 5 | Production & Service Controls | Process validation (IQ/OQ/PQ), environmental controls, sterilization, traceability, identification, servicing, and installation. |
| 6 | Purchasing | Supplier qualification and re-evaluation, purchasing data, verification of purchased product, and supplier risk management. |
| 7 | Device Marketing Authorization & Facility Registration | Country-specific licenses, registrations, listings, UDI submissions, and authorized representative arrangements. |
Country-Specific Compliance Guidance
Australia (TGA):
Align with Therapeutic Goods (Medical Devices) Regulations 2002, Schedule 3. Maintain an Australian Sponsor and ensure ARTG inclusion. Report adverse events within 48 hours to 30 days based on severity
Brazil (ANVISA)
Comply with RDC 665/2022 (GMP) and RDC 67/2009 (technovigilance). Hold a Brazilian Registration Holder (BRH) and submit Technovigilance Reports for serious events within 72 hours.
Canada (Health Canada)
MDSAP is mandatory for Class II–IV device licenses under SOR/98-282. Mandatory Problem Reporting required within 10 days (serious) or 30 days (non-serious). Maintain a Canadian Medical Device License (MDL).
Japan (MHLW/PMDA)
Meet MHLW Ministerial Ordinance No. 169 requirements. Appoint a Marketing Authorization Holder (MAH/D-MAH) and report malfunctions within 15 to 30 days under the PMD Act.
United States (FDA)
Comply with 21 CFR Part 820 (QSR) — transitioning to QMSR alignment with ISO 13485 effective February 2026. File MDRs within 30 days (or 5 days for events requiring remedial action).
JJCC Group Services Mock Audit: Preparedness & Readiness
JJCC Group Services offers a comprehensive MDSAP Mock Audit program designed to replicate the certification audit experience and surface findings before a real Auditing Organization arrives. The engagement is delivered by former MDSAP-qualified lead auditors and follows the official MDSAP Audit Approach (AU P0002) and Companion Document (AU P0002.004).Â
Engagement Structure
- Pre-Audit Readiness Assessment (Week 1): Documentation review against MDSAP criteria, identification of high-risk gaps, and a tailored audit plan covering all seven processes.
- On-Site Mock Audit (Weeks 2–3): Three to five days on site replicating the Stage 2 audit including opening meeting, process tracing, record sampling, employee interviews, and closing meeting with simulated findings.
- Findings Report & Grading (Week 4): Each observation is graded on the official 1–5 MDSAP scale with a clear rationale, including identification of any Grade 4 or 5 issues that would trigger regulatory notification.
- Remediation Roadmap & CAPA Coaching (Weeks 5–8): Prioritized corrective action plan, root cause analysis support, and verification of effectiveness before the live audit.
- Final Readiness Verification: A condensed follow-up audit confirms closure of mock findings and validates audit-day readiness, including front-room/back-room logistics and auditor interview coaching.
Deliverables: a graded findings report, process-linkage matrix, CAPA tracker, audit-day playbook, and an executive readiness scorecard. JJCC Group Services guarantees that clients completing the full program enter their certification audit with documented evidence of process maturity across all seven MDSAP processes and clear ownership of every country-specific obligation.Â
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MDSAP Audit Process: Frequently Asked Questions
How JJCC Group Services Helps Medical Device Manufacturers Achieve and Maintain Certification
The Medical Device Single Audit Program (MDSAP) is one of the most consequential quality system audits a medical device manufacturer can undertake. The questions below address the issues most frequently raised by clients preparing for, undergoing, or maintaining MDSAP certification, and explain how JJCC Group Services supports manufacturers at every stage of the journey.
MDSAP is a single regulatory audit of a medical device manufacturer's quality management system that satisfies the requirements of five participating regulators: Australia (TGA), Brazil (ANVISA), Canada (Health Canada), Japan (MHLW/PMDA), and the United States (FDA). Rather than hosting multiple separate inspections, one audit conducted by an MDSAP-recognized Auditing Organization (AO) is accepted by all five jurisdictions. MDSAP is mandatory in Canada for Class II, III, and IV device licensing, substitutes for routine FDA inspections in the United States, and streamlines market access in Australia, Brazil, and Japan. For most manufacturers selling in two or more of these markets, MDSAP delivers significant audit-cost savings and a single, defensible compliance record.
Although MDSAP is built on ISO 13485:2016, the audit is structured around seven defined processes rather than a clause-by-clause walkthrough. Auditors trace records across linked processes — for example, a customer complaint may be followed through CAPA, design change, supplier evaluation, and regulatory reporting — to verify the QMS operates as a connected system. MDSAP also uses a numerical nonconformity grading scale from 1 to 5 instead of major/minor classifications. Grades 4 and 5 trigger immediate notification to the relevant regulators, with potential consequences including license suspension and import holds. The audit also incorporates country-specific regulatory requirements that go beyond ISO 13485, such as FDA 21 CFR Part 820, Health Canada SOR/98-282, and Japan MHLW MO 169.
 MDSAP follows a three-year certification cycle. Year 0 is the initial certification audit, consisting of a Stage 1 documentation review followed by a Stage 2 on-site audit. Years 1 and 2 are shorter annual surveillance audits with a rotating focus on specific processes. Year 3 is a full recertification audit covering all seven processes again. Unannounced audits may also occur, particularly for cause. Audit duration is calculated by a formula based on employee count, site complexity, and device risk, and typically runs longer than a standalone ISO 13485 audit. From the decision to pursue certification through Stage 2 completion, most manufacturers should plan on six to twelve months of preparation.Â
The most frequent issues seen during MDSAP audits include weak process linkages where procedures are written in silos and cannot demonstrate how outputs of one process feed inputs of another; incomplete CAPA records that lack genuine root cause analysis or effectiveness verification; gaps in country-specific vigilance reporting timelines and procedures; insufficient supplier controls, particularly for critical and sterilization suppliers; and unclear management review records that fail to capture all required inputs. Many manufacturers also underestimate the documentation rigor expected for design changes, process validation (IQ/OQ/PQ), and software validation. Grade 4 and 5 findings most often arise when these gaps intersect with patient-safety-relevant processes.Â
JJCC Group Services delivers a structured MDSAP readiness program led by former MDSAP-qualified lead auditors. The engagement begins with a gap analysis against ISO 13485:2016 and the official MDSAP Audit Approach (AU P0002), mapping current procedures to each of the seven processes. We then provide remediation support including procedure rewriting, process-linkage mapping, CAPA coaching, supplier control upgrades, and country-specific procedure development for each jurisdiction the client targets. Training is delivered to internal auditors, process owners, and front-line staff on the MDSAP audit approach, the 1–5 grading scale, and country-specific obligations. The goal is a QMS that demonstrably operates as a connected system on audit day, not just on paper. Â
Our mock audit is designed to replicate the certification audit experience as closely as possible. The four-to-eight-week engagement includes:
- Pre-audit readiness assessment: documentation review and tailored audit plan covering all seven processes.
- On-site mock audit: three to five days replicating the Stage 2 audit, including opening meeting, process tracing, record sampling, employee interviews, and closing meeting.
- Graded findings report: each observation graded on the official 1–5 MDSAP scale with full rationale, including any Grade 4 or 5 issues that would trigger regulatory notification in a live audit.
- Remediation roadmap & CAPA coaching: prioritized corrective action plan with root cause support and verification of effectiveness.
- Final readiness verification: a condensed follow-up audit and audit-day playbook including front-room/back-room logistics and interview coaching.
Because our auditors apply the same MDSAP Companion Document criteria used by recognized AOs, the findings are directly comparable to what a real audit would surface.
Yes. Our regulatory specialists provide jurisdiction-specific support for all five MDSAP countries. For Canada, we help manufacturers establish and maintain the Medical Device License (MDL), implement Mandatory Problem Reporting procedures, and align with SOR/98-282 requirements. For Brazil, we support Brazilian Registration Holder (BRH) coordination, RDC 665/2022 GMP compliance, and Technovigilance Reporting under RDC 67/2009. For Australia, we assist with Australian Sponsor arrangements and ARTG inclusion. For Japan, we coordinate with Marketing Authorization Holders (MAH/D-MAH) and align procedures with MHLW Ministerial Ordinance No. 169 and the PMD Act. For the United States, we help manufacturers transition to the FDA Quality Management System Regulation (QMSR), which aligns 21 CFR Part 820 with ISO 13485 effective February 2026.
Certification is the beginning, not the end. JJCC Group offers post-certification support including annual internal audits aligned to the MDSAP process model, surveillance audit preparation for Years 1 and 2, CAPA effectiveness reviews, supplier audit programs, vigilance reporting oversight, and management review facilitation. We also provide regulatory intelligence updates as participating regulators revise their requirements — for example, the FDA's transition to QMSR, evolving Brazilian technovigilance expectations, and Canadian licensing changes. For manufacturers expanding into additional MDSAP jurisdictions after initial certification, we manage the scope expansion process with the Auditing Organization and ensure country-specific procedures are in place before the next surveillance visit. The objective is a compliance program that strengthens with each audit cycle rather than scrambling to recover from one.
Ready to start your MDSAP journey?
Contact JJCC Group Services to schedule a complimentary readiness consultation. Our team will assess your current MDSAP posture and recommend the right combination of gap analysis, remediation, and mock audit services to achieve certification with confidence. Â