Sanbor Medical Blog

Managing Change Control to Reduce Medical Device Non-Conformities

Written by Jeff Bowman | Jan 22, 2026 4:41:13 PM

Most non-conformities in medical device manufacturing are not caused by design flaws, but by uncontrolled changes.

Even in validated, stable production environments, small changes to people, equipment, materials, processes, or inspection systems can introduce variability that compromises product quality, regulatory compliance, and patient safety. This is why change control is a foundational requirement under ISO 13485 and FDA Quality System Regulations.

At Sanbor Medical, change is treated as a regulated input. Through a structured, ISO 13485-aligned change management system, every change is formally identified, risk-assessed, approved, validated, and documented. This ensures consistent quality and audit readiness.

What Is a Change Point in Medical Device Manufacturing?

A change point is any alteration that can affect:

  • Product characteristics

  • Process capability

  • Compliance status

  • Inspection results

  • Patient safety risk

Change points are commonly categorized using the 5M1E framework:

  • Man – People and training

  • Machine – Equipment, tooling, and software

  • Material – Components, raw materials, and consumables

  • Method – Processes, work instructions, and inspections

  • Environment – Facility and operating conditions

  • Measurement – Inspection and test systems

When changes occur without proper change control, validation, and documentation, the result is increased non-conformities, rework, scrap, customer complaints, and regulatory exposure.

Sanbor Medical’s Quality Management System is designed to identify and control change points before they become quality failures.

People Changes (Man): Controlling Human-Driven Process Variation

Personnel changes are one of the most common sources of unintended process variation.

Common people-related change points include:

  • New employee onboarding

  • Job rotation or coverage substitutions

  • Return from extended leave

  • Deviation from standard work practices

Sanbor Medical controls personnel changes through:

  • Pre-change risk assessment

  • Documented training and qualification

  • Personnel qualification matrices for critical roles

  • In-process monitoring and post-change verification

This ensures only qualified, trained personnel perform regulated operations. This reduces human-driven variability and protects validated processes.

Equipment, Tooling, and Software Changes (Machine)

Changes to production equipment, tooling, fixtures, automation, or software directly impact process validation and product quality.

Machine-related change points include:

  • Preventive and corrective maintenance

  • Equipment relocation or replacement

  • Mold and fixture changes

  • Software and automation updates

  • Adjustments to critical process parameters

Sanbor Medical applies formal equipment change control and re-validation protocols, including:

  • Change request and risk assessment

  • Controlled implementation

  • First Article Inspection (FAI)

  • Post-change validation and documented release

Any equipment that is repaired, replaced, relocated, or restarted is treated as a new validated condition—protecting process capability and compliance.

Material Changes: A High-Risk Source of Non-Conformities

Material changes are among the highest-risk quality variables in medical device manufacturing.

Common material change points include:

  • New or alternate suppliers

  • New material batches (especially first lots)

  • Engineering specification changes

  • Approved substitute materials

  • Packaging, storage, or logistics changes

Sanbor Medical manages material changes through:

  • Formal change approval and supplier control

  • Enhanced incoming inspection

  • Critical characteristic testing

  • First article and small-lot validation

This prevents batch-to-batch variation from introducing hidden defects that lead to downstream non-conformities.

Method Changes: Protecting Validated Manufacturing Processes

“Method” includes all documented processes, work instructions, inspection methods, and control plans.

Method-related change points include:

  • Process flow changes

  • Parameter updates

  • Step consolidation or splitting

  • Inspection method changes

  • Sampling plan adjustments

Sanbor Medical enforces strict document and method control:

  • No changes without formal approval

  • No implementation without validation

  • No rollout without documented training

This ensures continuous improvement does not compromise regulatory compliance or process predictability.

Environmental Changes: A Critical Quality Input

Environmental conditions directly affect many medical device manufacturing processes.

Environmental change points include:

  • Cleanroom classification changes

  • Temperature and humidity variation

  • Electrostatic discharge (ESD) controls

  • Facility layout changes

  • Utility disruptions

  • Seasonal climate variation

Sanbor Medical actively monitors and controls environmental conditions for critical processes—ensuring environmental inputs remain within validated limits.

Measurement System Changes: Protecting Inspection Accuracy

Changes to inspection and test systems directly affect acceptance decisions and regulatory records.

Measurement-related change points include:

  • New or replaced inspection equipment

  • Calibration deviations

  • Software updates

  • Inspection method changes

  • Acceptance criteria revisions

  • Inspector changes

Sanbor Medical requires Measurement System Analysis (MSA) and validation for all inspection system changes—ensuring data integrity, repeatability, and audit defensibility.

How Sanbor Medical Turns Change Control Into a Competitive Advantage

In regulated manufacturing, uncontrolled change is one of the leading root causes of:

  • Non-conformities

  • Batch failures

  • Regulatory findings

  • Customer complaints

  • Product recalls

Sanbor Medical’s change management system is built on three pillars:

  • Visibility – All changes are identified and documented

  • Control – All changes are risk-assessed, approved, and validated

  • Traceability – Full documentation supports FDA and ISO audits

By embedding change control into daily operations, Sanbor Medical helps OEMs:

  • Maintain validated process stability

  • Reduce non-conformities and quality escapes

  • Support FDA and ISO 13485 compliance

  • Enable controlled continuous improvement

This disciplined approach allows Sanbor Medical to transform operational change from a regulatory risk into a structured, compliant driver of long-term quality and operational excellence.

Contact us to learn more.