US FDA
21 CFR 820.50 - Purchasing Controls (QMSR)
Plain-language explanation, inspection context and common violation patterns.
What it says
Manufacturers must establish procedures to evaluate and select suppliers, contractors and consultants based on their ability to meet specified requirements, defining the type and extent of control needed based on the evaluation results, and maintaining records of acceptable suppliers.
Paraphrased for plain-language clarity. Always verify against the current published regulation text.
What it means in practice
- This is the device-side equivalent of drug supplier qualification under 211.84, applying a similar principle: the depth of ongoing control and monitoring should scale with documented supplier risk and performance, not be applied uniformly regardless of supplier history.
- Purchasing data, specifications, quality requirements and applicable device master record information, must be communicated clearly to suppliers, since a supplier cannot be held accountable to requirements it was never actually given.
- An approved supplier list functions as a controlled record under this provision, similar in principle to its drug-side equivalent, requiring the same discipline in keeping it current and QA-controlled.
What FDA inspectors look for
- Whether supplier evaluation and selection is documented with a clear rationale connecting the level of ongoing control applied to the supplier's actual demonstrated risk and performance.
- Whether purchasing documents clearly and completely communicate applicable specifications and quality requirements to suppliers.
- Whether the approved supplier list is maintained as a current, QA-controlled record reflecting actual supplier qualification status.
Most common violation
Purchasing documents sent to suppliers that do not clearly specify applicable quality requirements, leaving ambiguity about what standard the supplier was actually expected to meet.
Want a deeper, interactive breakdown?
GMPify's Regulation Explainer tool gives subscribers an AI-powered analysis of any 21 CFR, EU GMP, USP or ICH reference, with live inspection context.
Try the Regulation Explainer →