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Inspection Program

Overview

Health Canada's inspection program involves on-site visits to manufacturers, importers, and distributors of medical devices. Inspections verify compliance with the Medical Devices Regulations and the QMS requirements for establishment licence holders.

Types of inspections

Routine inspections

Scheduled inspections of MDEL holders, typically on a risk-based cycle (e.g., every 2–5 years depending on risk level). Routine inspections are announced in advance.

Surveillance inspections

Targeted inspections triggered by:

  • Mandatory problem reports or recall activities
  • Complaints received by Health Canada
  • Intelligence from other regulatory authorities
  • Post-market testing results

Surveillance inspections may be unannounced.

For cause inspections

Inspections specifically investigating a suspected compliance issue. These are typically unannounced or at very short notice.

What inspectors look for

For manufacturers, inspectors typically review:

  • QMS documentation (quality manual, procedures, records)
  • MDSAP or ISO 13485 audit certificate validity
  • Device Licence maintenance (amendments filed when required)
  • Post-market surveillance and complaint handling records
  • Mandatory problem reporting records
  • Recall procedures and records
  • Labelling compliance

For importers and distributors, inspectors typically review:

  • MDEL validity and currency
  • QMS elements (complaint handling, distribution records, recall procedures)
  • Distribution records (lot-level traceability)
  • Mandatory problem reporting records
  • Evidence that all distributed devices hold valid Device Licences

Preparing for an inspection

Best practices for inspection readiness: • Maintain your Quality Management System in a continuously inspection-ready state • Conduct periodic internal audits (at least annually) to identify gaps before Health Canada inspections • Ensure all QMS documentation is current, accessible, and accurately indexed • Provide regular training to all relevant staff on their QMS roles and responsibilities • Keep records of training completion and document all corrective actions taken • Maintain a log of any changes made to the device, manufacturing process, or QMS since the last inspection

Inspection outcomes

After an inspection, Health Canada issues an inspection report classifying the findings:

  • Satisfactory — no significant deficiencies
  • Acceptable with deficiencies — minor deficiencies identified, corrective actions required
  • Non-compliant — significant deficiencies; corrective action plan required with follow-up inspection possible
  • Unsatisfactory — serious non-compliance; may trigger immediate enforcement action

Legislative source: Food and Drugs Act, ss 22–23; Medical Devices Regulations, SOR/98-282

Health Canada typically establishes inspection cycles based on device risk classification and compliance history. Class III and IV devices generally receive more frequent inspections than Class I and II devices.