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November 13, 2007
Our file number: 07-126340-821
To: All Stakeholders
Re: GD207: Guidance on the Content of ISO 13485 Quality Management System Certificates Issued by Health Canada Recognized Registrars
Health Canada is pleased to announce the release of the revised guidance document GD207: Guidance on the Content of ISO 13485 Quality Management System Certificates Issued by Health Canada Recognized Registrars. This guidance document supersedes the February 18, 2002 version (GD207/Rev0-MDB) of the same document. By way of transition, Rev0 will coexist with Rev1 until January 2, 2008 the date that Rev1 becomes effective.
GD207 provides guidance to Manufacturers of Class II, III or IV medical devices and Registrars recognized by Health Canada on the essential information that Health Canada requires to be displayed on ISO 13485:2003 quality management system (QMS) certificates. This document has been revised to reflect CAN/CSA-ISO 13485:03, Medical devices - Quality management systems - Requirements for regulatory purposes, and other new or updated international standards. The most significant changes include:
Please direct any questions or comments regarding the content of this guidance document to the following:
Quality Systems Section
Medical Devices Bureau
150 Tunney's Pasture Driveway
Main Statistics Canada Building, Room 1605
Address Locator: 0301H1
Ottawa, Ontario K1A 0K9
Phone: (613) 952-8250
Fax: (613) 946-6758
E-mail: ISO13485_CMDCAS_SCECIM@hc-sc.gc.ca
Guidance documents are meant to provide assistance to industry and health care professionals on how to comply with governing statutes and regulations. Guidance documents also provide assistance to staff on how Health Canada mandates and objectives should be implemented in a manner that is fair, consistent and effective.
Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.
As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in this document, in order to allow the Department to adequately assess the safety, efficacy or quality of a therapeutic product. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.
This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidance documents.
Document Number: GD207/Rev1-MDB
Replaces: GD207/Rev0-MDB
File name: cmdcas_scecim_ certi13485_2_e.wpd
Replaces: cmdcas_scecim_ certi13485_e.wpd
Version: 1
Replaces: 0
Date: 2002-02-18
Date: 2002-02-18
| Change | Location (section, paragraph) | Nature of and/or Reason for Change |
|---|---|---|
| 1 | Overall document | "quality system" replaced with "quality management system" (QMS) |
| 2 | Overall document | References to ISO 13485:2003 added. References to 13485:1996/8 removed. |
| 3 | Overall document | Most references to CMDCAS recognized/qualified Registrar changed to Health Canada recognized Registrar. |
| 4 | 1.3 Supporting documents | New section added. References several related and supporting documents. |
| 5 | 1.7 Revised certificates | New section added to address revised certificates. |
| 6 | 1.8 Terms, definitions, acronyms | Definitions section renamed, revised, and expanded. |
| 7 | 1.9 Implementation | New section added to specify the effective date of this guidance. |
| 8 | 2.1 Unique Identification Code | "Certificate number" renamed for consistency with ISO 17021:2006. |
| 9 | 2.2 Certificate dates | Effective date and term of registration has been clarified. |
| 10 | 2.3 Manufacturer's name. | Revised and expanded to address more complex situations. |
| 11 | 2.4 Manufacturer's address | Clarifications have been made. |
| 12 | 2.5 Multi-site QMS | New guidance added to address multi-site quality management systems. |
| 13 | 2.6 Scope statement | Guidance has been clarified and expanded. |
| 14 | 2.12 Format | New section added to address hard and electronic copy submission. |
| 15 | 2.13 Language | New section added to address official languages and multi-lingual certificates. |
| 16 | Appendix 1 | Certificate scope statement templates added to facilitate their construction. |
| 17 | Appendix 2 | Example certificate scope statements added to facilitate their construction. |
The purpose of this document is to provide guidance to
on the essential information that Health Canada requires to be displayed on ISO 13485:2003 quality management system (QMS) certificates.
The scope of this guidance document is limited to the essential information and format Health Canada requires displayed on a QMS certificate.
This guidance document contains undated references. In these cases, the following documents apply:
CAN-P-10B (ISO/IEC Guide 62:1996) - Criteria for Accreditation of Organizations Registering Quality Systems
CAN-P-16 (ISO 17021:2006) - Conformity assessment -- Requirements for bodies providing audit and certification of management systems
Food and Drugs Act ( R.S., 1985, c. F-27 )
GD013/Rev00-MDB - Guidance on How to Complete the Application for a New Medical Device Licence
Guidance for Industry - Private Label Medical Devices
IAF GD2:2005 - IAF Guidance on the Application of ISO/IEC Guide 62:1996, General Requirements for Bodies Operating Assessment and Certification/registration of Quality Systems, Issue 4
ISO 9000:2005 - Quality management systems - Fundamentals and vocabulary
ISO 13485:2003 (CAN/CSA- ISO 13485-03) Medical Devices -- Quality management systems -- Requirements for regulatory purposes
ISO 15225:2000 Nomenclature -- Specification for a nomenclature system for medical devices for the purpose of regulatory data exchange
ISO 17011:2004 - Conformity assessment -- General requirements for accreditation bodies accrediting conformity assessment bodies
Medical Devices Regulations SOR/98-282 (latest consolidated version)
Q90R0e : 2000-04-19, Policy on the Canadian Medical Devices Conformity Assessment System (CMDCAS)
A Manufacturer will provide a valid certificate to Health Canada:
ISO 17021:2006 states in the introduction, "The form of attestation of conformity of an organization's management system to a specific management system standard or other normative requirements is normally a certification document or a certificate...The overall aim of certification is to give confidence to all parties that a management system fulfils specified requirements."
Only valid certificates (see below) issued by Heath Canada recognized Registrars will be accepted as objective evidence of compliance with sections 32(2)(f), 32(3)(j), 32(4)(p), 34 (in some cases), or 43.1 of the MDR. No other form of documentation will be accepted by Health Canada as a substitute (for example [e.g.,] other certificates types, audit reports, letters, or attestations).
Despite this guidance, any certificate which contains ambiguous or conflicting information may be subject to a request for additional information or may be refused by Health Canada.
The MDR require the QMS under which Class II, III or IV medical devices are designed and/or manufactured satisfy the National Standard of Canada CAN/CSA-ISO 13485:03. There are no regulatory QMS requirements for Class I medical devices. Health Canada considers CAN/CSA-ISO 13485:03 and ISO 13485:2003 to be equivalent.
Organizations that exclusively design, manufacture, and sell Class I medical devices for Canada shall not receive certification under the Canadian Medical Devices Conformity Assessment System (CMDCAS). However, Manufacturers of Class I devices that also design, manufacture and sell Class II, III or IV devices for the Canadian market are eligible for certification under CMDCAS and may voluntarily include Class I devices and other medical devices not sold in Canada in the audit process and in their QMS certificate scope statement.
The MDR do not require importers or distributors of medical devices to have a certified QMS. However, any importer or distributor of a Class II, III or IV devices that choses to become the Manufacturer by labelling and selling the device with their own name, trade-mark, design, trade name or other name or mark owned or controlled by them (see definition of a Manufacturer) shall comply with the QMS sections of the MDR and other applicable sections.
A Manufacturer who will obtain medical device licences exclusively through Health Canada's Private Label process is not required to obtain a QMS certificate. See Health Canada's Website for additional details.
Revised certificates shall be valid and be based on any supplementary audit and approvals by the Health Canada recognized Registrar, as appropriate (ISO 17021:2006 9.5.1, CAN-P-10B 3.5.4). Revised certificates will supercede and be clearly distinguished from any previously issued versions (ISO 17021:2006 8.2.3i)).
As of 2008/01/02, all newly issued and re-issued/revised certificates will be subject to this guidance.
The certificate shall bear a unique identification code (ISO 17021:2006 8.2.3 d)). The code is assigned by the Health Canada recognized Registrar to reference a unique certification/ registration or a unique certificate document. Either practice is acceptable provided that it is consistent and maintains adequate traceability for the users of the certificate.
Health Canada will use this code for administrative purposes. Registrars may choose a format that suits their operational needs, including embedding version control and other information in the code. However, the code is limited to 30 characters (without spaces).
Based on section 32.2 of the MDR, Health Canada requires two dates to be displayed on a certificate:
Registrars may use a date format that suits their needs so long as it is unambiguous and consistent. To meet accreditation requirements (ISO 17021:2006 8.2.3b)), other dates will be displayed, but they must not confuse the dates required by Health Canada.
Certificates shall bear an effective date. The field will be labelled "Effective date" and denote the commencement of the certificate's validity period. The effective date shall not precede the date of the certification decision (ISO 17021:2006 8.2.2).
Device licences, licence applications, and applications to amend the name or address on a licence must always be supported by a valid certificate. A certificate whose effective date occurs in the future (post-dated) is not in effect, for the purposes of licensing. Consequently, a certificate received by Health Canada prior to the effective date will not be accepted.
Date of Certification Decision ≤ Effective Date ≤ Date Received by Health Canada
Certificates shall bear an expiry date or a recertification due date (ISO 17021:2006 8.2.3 c)) or both. The field(s) will be labelled "expiry" or "expiry date" or "recertification due date" and will denote the end of the certificate's validity period.
The period specified by the effective date and the expiry or the recertification due date shall not exceed three years (MDR section 32.2). If both expiry and recertification due dates appear on the certificate, the expiry date will be recorded by Health Canada.
The certificate's main page shall identify the name of the Manufacturer to whom the certification applies (ISO 17021:2006 8.2.3 a)). The Manufacturer's name shall be the same as that used on the medical device licence and medical device label. An organization that sells a medical device under their own name, or under a trade-mark, design, trade name or other name or mark owned or controlled by them is defined as the Manufacturer (MDR Section 1)
Health Canada will not accept certificates from a Manufacturer's subcontractor as evidence of compliance to MDR sections 32(2)(f), 32(3)(j), 32(4)(p), 34, or 43.1.
Name on the Certificate = Name on the Licence = Name on the Device Label
Some organizations have a complex structure, with multiple names, sites, and ownership. However, the identified Manufacturer shall bear the responsibility of complying with the MDR.
In all situations, QMS documentation and certification agreements (ISO 17021:2006 5.1.2) between the entity(s) and the Health Canada recognized Registrar shall reflect the name(s) of the Manufacturer.
Health Canada will recognize a portion of a legal entity that is empowered to sign a device application, to be a legal entity for the purposes of obtaining a licence. Therefore, Registrars shall engage such entities, whether they be business units, subsidiaries, or divisions, as distinct legal entities for the purpose of certification under CMDCAS. The applicability of certificates issued to a division shall be limited to that division.
The name and address of parent companies or ownership groups may not appear on certificates, except where necessary to identify the legal name associated with the certified QMS. The following is an acceptable format:
ABC, a division of XYZ - a wholly owned subsidiary of 123
Address
or
Company ABC, Medical Device Division
Address
In a situation where there is a singly defined QMS, associated with two or more names, the certificate may bear the additional names, subject to any verifications and/or certification requirements by the Registrar, including verifying the Manufacturer's intention to use all such names in Canada. The names will be listed in the following manner:
Company X
also trading as Company Y
also trading as Company Z
...etc.
Address
The certificate's main page, beneath the Manufacturer's name, shall identify the address to whom the certification applies (ISO 17021:2006 8.2.3 a); GD013/Rev00-MDB Item 4). The Manufacturer's address shall be the same as that used on the device licence and device label. A complete address would include a street name and number, city, province or state (where applicable), postal or zip code, and country. A post office box number may be added to the complete address.
Address on the Certificate = Address on the Licence = Address on the Device Label
Manufacturers are required to define the scope (extent and boundaries) of the QMS in their quality manual (ISO 13485:2003, 4.2.2 a)). The scope generally includes a description of the physical locations, organizational units, and processes. If more than one physical location is defined within the scope of the QMS, i.e., a multi-site organization, then the names and street addresses of the branch offices shall also be listed and identified as additional sites on the certificate, provided they are covered by the certification (ISO 17021:2006 8.2.3 a)). Additional addresses shall not confuse the main address.
Where certificates display more than one scope statement (see below), Health Canada will record the "global"scope statement for regulatory purposes. The global scope statement shall adequately cover any "site-specific" scope statements and all generic device categories.
NB1: Separate entities, such as subcontractors, that provide product to the Manufacturer's specifications, are not under the direct control of the certified QMS and thus shall not be listed on the certificate.
NB2: Health Canada will not issue a device licence to a branch office. Only the Manufacturer, the "central office" of a multi-site, can obtain a licence.
For regulatory purposes, the certificate's scope statement consists of two components:
It is incumbent upon the Manufacturer to draft the initial scope statement (ISO 17021:2006 9.2.1). The finalized scope statement will be subject to clarifications, audit findings, and the Registrar's certification decision. (ISO 17021:2006 9.2.3.1.1 d))
Manufacturers and Registrars are strongly encouraged to employ the scope templates found in APPENDIX 1.
A Manufacturer of a Class II device complies with MDR section 32(2)(f) by providing to Health Canada "a copy of the quality management system certificate certifying that the quality management system under which the device is manufactured..." A Manufacturer of a Class III or IV device complies with MDR sections 32(3)(j) or 32(4)(p) respectively by providing to Health Canada "a copy of the quality management system certificate certifying that the quality management system under which the device is designed and manufactured..."
Thus, depending on the class of the device(s) involved, the scope statement will contain "manufacture" or "design and manufacture". A certificate which lacks "design" in the scope statement that is submitted in relation to a Class III or IV device will not be accepted by Health Canada. A certificate which lacks "manufacture" in the scope statement, regardless of the device class involved, will not be accepted by Health Canada (see notes below).
Additional QMS processes and services pertaining to the device may also be listed in the scope statement, but in most situations should be limited to QMS processes per ISO 13485:2003 (see ISO 13485:2003, 0.1). All processes listed in the scope statement will be supported by evidence of conformity (ISO 17021:2006 9.2.3.2 a). Any listed processes outside the scope of ISO 13485:2003 shall be auditable and will have been carried out by audit teams possessing the necessary competence (ISO 17021:2006 7.2.7). Additional audit time will have been allocated and justified.
NB1: Health Canada will not accept "development" in place of "design" (ISO 9000:2005 3.4.4). "Design and development" is acceptable.
NB2: Health Canada considers manufacture and production to be interchangeable and thus use of either term is acceptable.
All medical devices that are:
shall be listed in the certificate's scope statement using generic device groups. Despite the use of generic device groups, the device descriptions shall be of sufficient detail such that there can be little to no reasonable doubt that the devices listed in the scope statement refer to the same device(s) in a licence application, renewal or amendment (the term "accessories" is not a generic device group). The templates in Appendix 1 cover a broad range of generic device groups. Other generic device groups may also be listed, such as Class I devices or devices that fall outside of the Food and Drugs Act definition but meet an ISO, or other national, or regional definition.
In addition to being accurate and complete, the scope statement should be robust; that is, it should not have to be modified every time devices are added or removed from the generic device groups covered by the scope, or that a design or manufacturing change is made to one of the specific devices included in the groups. Consequently, the listing of product names, trade names, catalogue numbers, device licence numbers, or device classes in the scope statement is not permitted. Certificates bearing such information will not be accepted by Health Canada.
Separate quality management system certificates for each component or member of a device family, group, group family, system and test kit will not be accepted by Health Canada.
A certificate shall be signed by an officer who is employed and authorized by the Health Canada recognized Registrar to perform that function (ISO 17021:2006, 5.1.3). The authorized person's name and position shall appear below or beside the signature.
The Registrar's name and address shall appear on the certificate and shall be the same as that of the accredited entity (ISO 17021:2006 5.1.1) or the directly recognized entity (MDR section 32.1).
A certificate shall either reference ISO 13485:2003 or CAN/CSA-ISO 13485:03. Additional references to other QMS standards or other normative documents are permitted (ISO 17021:2006 8.2.3 e)) but not recommended. Additional scope statements arising from other standards shall not detract from the information required by Health Canada (see 2.6).
Registrars who are recognized by Health Canada through the accreditation and sector qualification process of the SCC shall make a claim on their certificates that they are CMDCAS recognized. The Registrar could use the phrase, "Canadian Medical Devices Conformity Assessment System recognized Registrar" or "CMDCAS recognized Registrar". The statement of CMDCAS recognition is restricted to certificates intended for current Class II, III, or IV licence holders or Manufacturers intending to obtain licences.
Registrars and Manufacturers shall not use any logos or symbols associated with the Canadian Federal Identity Program on their certificates (or other documentation).
CMDCAS recognized Registrars shall display the SCC's mark of accreditation (ISO 17021:2006 8.2.3 g)). Additional marks from other accreditation bodies may also be displayed, where permitted. The use of such marks shall not be misleading and are subject to applicable laws, standards, agreements, etc.
Registrars that are directly recognized by Health Canada under section 32.1 of the MDR will not display the SCC's mark of accreditation.
Manufacturers may be issued certificates in printed hard copy, faxed or electronic formats. For regulatory submissions, printed hard copy is the default format. Electronic format or fax submission is acceptable where Health Canada has specifically permitted or requested it.
Where a certificate exceeds one North American letter size (8.5 × 11") or ISO A4 (210 × 297mm) page, additional pages may be utilized, but shall display the Registrar's name or logo, and any appropriate traceability information such as the certificate's unique identification code and page numbers.
As a minimum, the information Health Canada requires displayed on or attached to a certificate shall be in English or French. English-French bilingual format is acceptable. Although not recommended, information in languages other than English or French are permitted on the certificate. Multilingual certificates shall not confuse or contradict the essential information required by Health Canada.
The MDR, which applies to all products that meet the definition of a medical device that is found in the Food and Drugs Act (R.S., C. F-27, S.1), categorizes medical devices as either in vitro diagnostic devices or devices other than in vitro diagnostics. There is a template for each type.
The (design and development,) manufacture, (installation, service) of (in-vitro diagnostic analyzers/software, in-vitro diagnostic medical devices, in-vitro diagnostic reagents, in-vitro diagnostic test kits) used in the (diagnosis, management, detection) of (autoimmune status, blood analytes, blood components, blood gases, blood grouping, cancer, cardiac markers, coagulation, compatibility testing, disease status, donor screening, drugs of abuse, endocrine disorders, fertility testing, genetic testing, immune status, pregnancy testing, prenatal screening, protein metabolism, sexually transmissible agents, tissue typing, transmissible agents, immunological typing, therapeutic drug monitoring, other... ) including (home use, near patient/point of care) in-vitro diagnostic devices.
The (design and development,) manufacture, (installation, service) of (anaesthesia systems, anaesthetic and/or breathing adaptors, biliary stents, bone prostheses, breathing circuits, cardiovascular stents, catheters, cochlear implants, computed tomography scanners, condoms, contact lenses, cryosurgical instruments, defibrillators, dental amalgams, dental implants, dental etchants, dermatological lasers, diagnostic ultrasound systems, dilatation catheters, disposable surgical instruments, ECG monitors, ECG leads, EEG recorder, elastomeric pumps, electrosurgical instruments and generators, endoscopes, examination gloves, guide wires, hearing aids, hemodialysis water purification systems, imaging and monitoring workstations, infusion pumps, intraocular lenses, intravenous infusion sets, irrigation/drainage sets, mechanical and tissue heart valves, nebulizers, needles, ophthalmic lasers, orthopaedic implants, pacemakers, patient monitors, Picture Archiving Computer Systems (PACS), powered dental instruments, pulse generators, resorbable material implants, slit lamps, software, surgical gloves, surgical sponges, surgical lasers, surgical trays, sutures, syringes, therapeutic ultrasound devices, tonometers, vascular introducers, ventilators, wound dressings, x-ray equipment, other......) for the area of (anaesthesiology, cardiovascular, dentistry, electrosurgical applications, ENT, gastroenterology, neurology, obstetrics & gynaecology, ophthalmology, orthopaedics, plastic surgery, radiology, urology).
The following are examples of acceptable and unacceptable scopes statements for in vitro diagnostic devices.
Example A1
Manufacturer sells, or intends to sell, hand held chemistry and coagulation analysers.
Unacceptable Scope Statement
The development and commercialization of biosensor-based analytical systems.
Reason for Unacceptability
Design and manufacture are missing and the device description is too broad. "Commercialization" refers to the management of a for-profit entity, which is too generic to be associated with a QMS process.
Acceptable Scope Statement
The design and development, manufacture, service of in vitro diagnostic cartridges, controls, analyzers/software, used in the diagnosis and management of blood analytes, blood components, and coagulation including near patient in vitro diagnostic devices.
Example A2
Manufacturer sells, or intends to sell, home pregnancy test kits and ovulation detection kits.
Unacceptable Scope Statement
The design and manufacture of IVDD's.
Reason for Unacceptability
The scope statement is too broad and ambiguous and does not specify the type of product or its intended use.
Acceptable Scope Statement
The design and manufacture of in vitro diagnostic test kits, used for the detection of pregnancy and ovulation including home use in vitro diagnostic devices.
Example A3
Manufacturer sells, or intends to sell, the following Class II devices: anti-GBM (Glomerular Basement Membrane), Antibodies (ELISA) kit, Anti-PR3 Antibodies (ELISA) kit (Serine Protease-3), HP-G Screen H Pylori (IgG) Antibodies (ELISA), MPO Antibodies (ELISA) kit (Myelperoxidase).
Unacceptable Scope Statement
The design and development, and manufacture of Class II "We-Test-It" in vitro diagnostic kits, Canadian Licence #'s 134567, 134568, 134569, 134570, 134571 for the detection of infectious and autoimmune disease.
Reason for Unacceptability
Scope statement includes the class of device, its brand name, and Health Canada assigned licence numbers. The scope statement does not include immune response to food tests.
Acceptable Scope Statement
The design and development, and manufacture of in vitro diagnostic kits for the detection of infectious and autoimmune disease, including immune responses to food.
Example A4
The Manufacturer sells, or intends to sell, insulin dosers, lancets, lancing devices, consumer and hospital blood glucose monitoring systems, insulin delivery and blood glucose monitoring systems, control solutions, and test strips.
Unacceptable Scope Statement
Design and development, and manufacture of glucose monitors, test strips, and lancets.
Reason for Unacceptability
Scope statement does not cover all products presently licensed for sale in Canada or that are intended to be licensed for sale in Canada. Scope statement does not specify home and/or point of care use.
Acceptable Scope Statement
Design and development, manufacture and service of in vitro diagnostic devices used in the monitoring of blood glucose including lancets, lancing devices, control solutions and test strips including point of care and home use.
The following are examples of acceptable and unacceptable scopes statements for devices that are not in vitro diagnostic devices.
Example B1
Manufacturer sells, or intends to sell, synthetic surgical mesh, irrigation pumps, carbon dioxide pumps, electrosurgical electrodes, wound dressings, and infusion sets in Canada.
Unacceptable Scope Statement
The design and development and manufacture of electrosurgical electrodes, irrigation sets, infusion devices, and wound dressings.
Reason for Unacceptability
Scope statement does not cover synthetic surgical mesh or pumps
Acceptable Scope Statement
The design and development and manufacture of synthetic surgical mesh, powered irrigation sets, carbon dioxide and irrigation pumps, infusion sets, electrosurgical instruments, hemostatic and wound dressings.
Example B2
Manufacturer sells, or intends to sell, install and service ultrasound systems, probes, Picture Archiving Computer Systems (PACS) , and workstations.
Unacceptable Scope Statement
Design and development, manufacture of ultrasound systems.
Reason for Unacceptability
Scope statement does not cover probes, Picture Archiving Computer Systems (PACS) or workstations.
Acceptable Scope Statement
Design and development, manufacture, installation and service of ultrasound systems, probes, Picture Archiving Computer Systems (PACS), and ultrasound workstations.
Example B3
Manufacturer sells, or intends to sell, sterile surgical gloves.
Unacceptable Scope Statement
The distribution of medical examination gloves.
Reason for Unacceptability
Scope statement does not include "manufacture" and uses incorrect generic device group "medical examination gloves" instead of "sterile surgical gloves".
Acceptable Scope Statement
The manufacture of sterile surgical gloves.
Example B4
Manufacturer is design responsible and sells, or intends to sell in Canada dental surface conditioners, dental cement, varnishes, restoration materials and implants.
Unacceptable Scope Statement
The manufacture of dental restoration materials.
Reason for Unacceptability
Scope does not indicate design and it does not include all generic device groups.
Acceptable Scope Statement
The design and development and manufacture of dental restoration materials, dental implants and materials for restoring and protecting teeth in the area of dentistry.