US FDA
21 CFR 820.20 - Management Responsibility (QMSR)
Plain-language explanation, inspection context and common violation patterns.
What it says
Management with executive responsibility must establish and communicate a quality policy and objectives, define organisational structure and authority relationships, provide adequate resources, and conduct periodic management reviews of the quality system's continuing suitability and effectiveness.
Paraphrased for plain-language clarity. Always verify against the current published regulation text.
What it means in practice
- This provision parallels EU GMP Chapter 1's placement of ultimate quality system responsibility on senior management, reflecting a shared underlying principle now more explicitly aligned across drug, device and EU frameworks following QMSR's adoption of ISO 13485:2016.
- Management review is a defined, required activity under this provision specifically, not simply implied by general management oversight, requiring documented evidence that executive management genuinely engaged with quality system performance.
- Adequate resourcing of the quality function is named explicitly as an executive management responsibility, meaning chronic under-resourcing can itself become a citable management responsibility gap, not just a downstream symptom of other problems.
What FDA inspectors look for
- Whether management review meetings occur on schedule and show genuine engagement with quality data, rather than functioning as a reporting formality.
- Whether the quality function is resourced adequately relative to the organisation's actual scale and complexity.
- Whether the documented quality policy and objectives are genuinely understood and referenced by personnel throughout the organisation, not just published without practical integration.
Most common violation
Management review records that document the meeting occurred on schedule but show limited evidence of substantive engagement with the quality data presented, functioning as a compliance formality rather than genuine executive oversight.
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