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Quality systems · QMSR Mike Reo

QMSR Vocabulary: Old 820 Terms vs ISO 13485 and EU MDR

The QMSR retired DHF, DMR, DHR and "management with executive responsibility." A crosswalk to ISO 13485 and EU MDR, and why the label matters less than the content.

MLR Associates | Quality systems

The QMSR took effect on February 2, 2026.

Part 820 now incorporates ISO 13485:2016 by reference, and most of the old Quality System Regulation text is gone.

Most of its vocabulary went with it.

DHF, DMR, DHR and "management with executive responsibility" no longer appear in the regulation.

Teams are now renaming their SOPs and templates to match.

Some of that is worth doing.

Most of it does not change what an inspector looks for.

The Word Is a Label. The Content Is What Counts.

An inspector does not clear a file because the folder says Design and Development File instead of Design History File.

They follow the evidence of the work:

A DHF that shows all of that passes under any name.

A relabeled file that cannot show it fails.

Renaming has a real cost when it becomes the project.

Teams spend months reissuing documents to swap terms.

Meanwhile the gaps that draw findings stay put: missing traceability, and risk controls that never became requirements.

Fix the content first.

Update the labels at the next normal revision of each document.

Put a one-page crosswalk in the Quality Manual so anyone can map an old term to its new one.

Auditors use it. So do new hires.

A few terms did change meaning.

Top management is a narrower group than management with executive responsibility.

The Medical Device File covers more than the old DMR.

Management review, internal audit and supplier audit reports are no longer protected from FDA inspection the way they were under the old 820.180(c).

Where the substance changed, update the procedure along with the label.

Everywhere else, the rename is housekeeping.

Vocabulary Crosswalk: Old 820 vs ISO 13485 and EU MDR

Legacy terms come from 21 CFR Part 820 as it stood before February 2, 2026.

ISO 13485:2016 supplies the new terms, since the QMSR incorporates it by reference.

The EU MDR column shows where the same content sits in Regulation (EU) 2017/745.

N/A means the MDR has no single named equivalent, and the requirement sits inside the manufacturer's quality management system under Article 10(9).

Old 820 term (QSR)Old sectionISO 13485:2016 termClauseEU MDR 2017/745
Quality System Regulation / quality systemPart 820 / 820.5Quality management system4.1Quality management system, Art. 10(9)
Quality system record820.186Quality manual / QMS documentation4.2.1, 4.2.2N/A
Management with executive responsibility820.3(n), 820.20Top management5.1 (ISO 9000 3.1.1)N/A
Quality policy820.20(a)Quality policy5.3N/A
Quality plan820.20(d)Quality planning / planning of product realization5.4.2, 7.1N/A
Management representative820.20(b)(3)Management representative5.5.2Person responsible for regulatory compliance, Art. 15. A different role, often confused with it
Management review820.20(c)Management review5.6N/A
Personnel / training820.25Human resources / competence, training and awareness6.2N/A
Quality audit820.22Internal audit8.2.4N/A
Design and development planning820.30(b)Design and development planning7.3.2N/A
Design input820.30(c)Design and development inputs7.3.3General Safety and Performance Requirements, Annex I
Design output820.30(d)Design and development outputs7.3.4Design and manufacturing information, Annex II §3
Design review820.30(e)Design and development review7.3.5N/A
Design verification820.30(f)Design and development verification7.3.6Product verification and validation, Annex II §6
Design validation820.30(g)Design and development validation7.3.7Annex II §6 / clinical evaluation, Art. 61 and Annex XIV
Design transfer820.30(h)Design and development transfer7.3.8N/A
Design changes820.30(i)Control of design and development changes7.3.9N/A
Design History File, DHF820.30(j)Design and development file7.3.10Technical documentation, Annex II
Device Master Record, DMR820.181Medical device file4.2.3Technical documentation, Annexes II and III
Device History Record, DHR820.184Record for each medical device or batch7.5.1N/A
Document controls820.40Control of documents4.2.4N/A
Records, general requirements820.180Control of records4.2.5, plus retained 820.35N/A
Purchasing controls820.50Purchasing / evaluation of suppliers7.4Suppliers and subcontractors, Annex II §3
Identification / traceability820.60, 820.65Identification / traceability / implantable devices7.5.8, 7.5.9Unique Device Identification, Art. 27
Production and process controls820.70Control of production and service provision7.5.1N/A
Inspection, measuring and test equipment820.72Control of monitoring and measuring equipment7.6N/A
Process validation820.75Validation of processes for production and service provision7.5.6, 7.5.7N/A
Acceptance activities / acceptance status820.80, 820.86Monitoring and measurement of product8.2.6N/A
Nonconforming product820.90Control of nonconforming product8.3N/A
Corrective and preventive action, CAPA820.100Corrective action / preventive action8.5.2, 8.5.3N/A
Labeling and packaging control820.120, 820.130Control of production and service provision / preservation7.5.1, 7.5.11, plus retained 820.45Information supplied by the manufacturer, Annex I Ch. III and Annex II §2
Handling / storage / distribution820.140 to 820.160Preservation of product7.5.11N/A
Installation820.170Installation activities7.5.3N/A
Complaint files820.198Complaint handling / reporting to regulatory authorities8.2.2, 8.2.3, plus retained 820.35Post-market surveillance, Art. 83 and Annex III / vigilance, Art. 87
Servicing820.200Servicing activities7.5.4N/A
Statistical techniques820.250Analysis of data8.1, 8.4N/A

What the FDA Kept

Part 820 still carries a few US requirements that an ISO 13485 certificate does not cover.

The Bottom Line

Build the crosswalk once and publish it in the Quality Manual.

Then spend the effort where an inspector or notified body reviewer will look: traceability from user need to evidence, and a risk file tied to the design.

Call the file whatever you like.

Make sure it holds up.

References

Questions or feedback: mike@mlreoconsulting.com

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