fda-qsr-audit-prep

Imported from borghei/claude-skills (ra-qm-team/audit-prep/fda-qsr-audit-prep/SKILL.md). Install upstream with npx skills add borghei/claude-skills --skill fda-qsr-audit-prep. Copyright stays with the author (MIT + Commons Clause).

FDA QSR / QMSR Audit Prep

Operational playbook for FDA inspection preparation under Quality System Regulation (21 CFR 820) and the transitioning Quality Management System Regulation (QMSR, fully effective 2026, harmonizing with ISO 13485:2016).

When to use this skill vs. fda-consultant-specialist:

• This skill: FDA inspection imminent OR 483/Warning Letter received; need sprint
• fda-consultant-specialist: building / maintaining QMS; multi-quarter

When to use this skill

The audit-prep sprint at a glance

2-week sprint (announced inspection, mature QMS)

Week 1: Inventory, walkthrough rehearsal, gap remediation
Week 2: Inspection week (front room + back room operation)

8-week sprint (gaps identified, scheduled inspection)

Weeks 1-2: Readiness assessment + 483 / WL prior issue review
Weeks 3-6: Gap remediation (DHF, CAPA, complaint records, etc.)
Weeks 7-8: Mock inspection + final remediation + inspection prep

Reactive: 483 / Warning Letter response

- 483: 15 business days to respond (then ongoing)
- Warning Letter: 15 business days to respond (then full corrective action plan)
- Approach: Acknowledge + investigate root cause + corrective action plan + commitment + evidence

QSR / QMSR key audit areas

QMSR transition (effective Feb 2026): Harmonizes 21 CFR 820 with ISO 13485:2016. Adds requirements for risk management (ISO 14971), software lifecycle (IEC 62304), usability (IEC 62366).

Clarify First

Before running the audit-prep, settle the inputs below. When one is missing or vague and would change the result, ask about it; when it wouldn't, use a sensible default and say which one you used.

• Trigger: announced inspection, Form 483 received, Warning Letter, or annual readiness (chooses between the sprint track and the reactive 15-day response track, and sets deadlines).
• Framework: legacy QSR (21 CFR 820) vs QMSR (ISO 13485-harmonized, effective Feb 2026) (changes which requirements and subparts apply).
• QMS maturity and known issues: mature vs gaps, plus prior 483/WL findings (picks the 2-week vs 8-week sprint).

Ask about the two or three inputs that matter most for this request, not the whole list. If the user wants a result straight away, produce it and state your assumptions at the top.

Quick start

1. Run readiness score: python3 scripts/qsr_readiness_score.py --config qsr-controls.yaml
2. Check DHF completeness for in-scope devices: python3 scripts/dhf_completeness_checker.py --dhf device-dhf.yaml
3. Pick sprint length based on score + known issues
4. Execute sprint per references/fda-qsr-pre-inspection-checklist.md

Common FDA inspection findings (highest 483 / Warning Letter trigger)

1. CAPA failures — root cause not addressed, ineffective corrective action
2. Complaint handling — complaints not investigated, MDR (Medical Device Reporting) missed
3. Design controls (Subpart C) — DHF incomplete, V&V gaps, no design reviews
4. Process validation — processes not validated, validation stale
5. Supplier controls — suppliers not qualified, agreements missing, evaluations skipped
6. Document control — old procedures in use, no document approval evidence
7. Management responsibility — no management review, no quality policy, no objectives
8. Records (DHR) — incomplete records, missing lot traceability

See references/483-warning-letter-prevention.md for prevention patterns + response templates.

Inspection-week operations

Front room (where inspector works)

• Designated front room (conference room, not someone's office)
• Front-room lead (often Quality Manager) accompanies inspector all day
• All requests routed through front-room lead
• Inspector requests evidence; front-room asks back-room

Back room (where requests are fulfilled)

• Cross-functional team available
• Document retrieval, witness preparation, technical questions answered
• Inspector requests evidence; back-room delivers (filtered through front-room lead)

Daily debrief

• End of each inspection day: review what was inspected, observations, next-day topics
• Prepare overnight any evidence needed for next day

After inspection

• Form 483 review (if issued): consult with QA Lead + outside counsel
• 15 business days to respond
• Full corrective action plan
• Ongoing engagement with FDA office

Tooling

Scope & Limitations

In Scope:

• FDA inspection prep under 21 CFR 820 (QSR) and the ISO 13485-harmonized QMSR, with 2-week and 8-week sprints and a reactive 483 or Warning Letter track
• Readiness scoring per Subpart, with an overall score and sprint recommendation, from qsr_readiness_score.py
• Design History File completeness checks per 21 CFR 820.30 from dhf_completeness_checker.py
• Inspection-week front room and back room operations, common 483 triggers and response patterns

Out of Scope:

• Building or maintaining a QMS, or preparing 510(k) and PMA submissions (see ra-qm-team/fda-consultant-specialist/)
• ISO 13485 QMS implementation (see ra-qm-team/quality-manager-qms-iso13485/)
• ISO 14971 risk management files (see ra-qm-team/risk-management-specialist/)
• Running the CAPA process itself (see ra-qm-team/capa-officer/)

Important Caveats:

• Both tools read YAML you fill in. They score what you report and check that DHF sections exist; they do not judge the quality of design controls or records.
• A high score does not predict the inspection outcome. The output is not regulatory or legal advice, and a Warning Letter calls for outside FDA counsel, as the skill already notes.
• QMSR dates and requirements are stated as of when the skill was written. Check current FDA guidance before relying on them.

References

• fda-qsr-pre-inspection-checklist.md — full pre-inspection punch list per subpart
• 483-warning-letter-prevention.md — common triggers + prevention + response patterns

Related skills

• ra-qm-team/fda-consultant-specialist — deep FDA program (510k, PMA, QMSR build)
• ra-qm-team/quality-manager-qms-iso13485 — ISO 13485 QMS (QMSR harmonized)
• ra-qm-team/risk-management-specialist — ISO 14971 (required for QMSR)
• ra-qm-team/capa-officer — CAPA process specialist
• ra-qm-team/qms-audit-expert — internal/external QMS audits
• ra-qm-team/audit-prep/compliance-readiness — multi-framework readiness