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MDSAP - the ultimate guide to the medical device single audit program

By

Bethaney Lentz

September 20, 2021

4 min read

This article is an excerpt from The ultimate guide to the medical device single audit program (MDSAP) ebook.

Table of contents

What is MDSAP?

The Medical Device Single Audit Program (MDSAP) was designed and developed to allow a single audit of a medical device manufacturer to be applied to all country markets whose regulatory authorities are members of the program. The MDSAP provides efficient and thorough coverage of the standard requirements for medical device manufacturer quality management systems, and requirements for regulatory purposes (ISO 13485:2016). In addition, there are specific requirements of each medical device regulatory authority participating in the MDSAP that must be met:

  • Conformity Assessment Procedures of the Australian Therapeutic Goods (Medical Devices) Regulations (TG(MD)R Sch3)
  • Brazilian Good Manufacturing Practices (RDC ANVISA 16)
  • Medical Device Regulations of Health Canada (ISO 13485:2003)
  • Japan Ordinance on Standards for Manufacturing Control and Quality Control of Medical Devices and In Vitro Diagnostic Reagents (MHLW Ministerial Ordinance No 169)
  • Quality System Regulation (21 CFR Part 820), and specific requirements of medical device regulatory authorities participating in the MDSAP program.

This means that a report from a single MDSAP audit of a medical device manufacturer would be accepted as a substitute for routine inspections by all the member Regulatory Authorities (RAs) across the world. There are currently five participating Regulatory Authorities (RA) representing the following countries: Australia, Brazil, Canada, Japan and the USA.

In April, 2021, the RAs released an “Audit Approach” document (MDSAP AU P0002.006) that combines the formerly separate MDSAP Audit Model and Process Companion documents into a single guidance document. It includes guidance for assessing the conformity of each process and includes an audit sequence, instructions for auditing each specific process, and identifies links that highlight the interactions between the processes.

History of MDSAP

In March 2012 the US FDA announced that they had approved a final pilot guidance document “Guidance for Industry, Third Parties and Food and Drug Administration Staff: Medical Device ISO 13485:2003 Voluntary Audit Report Submission Pilot Program.” This allowed the owner or operator of a medical device manufacturing facility to be removed from FDA’s routine inspection work plan for 1 year upon completing a ISO 13485:2003 audit. This guidance document went into effect in June 2012, and was intended as an interim measure while a single audit program was being developed.

This pilot program was not very successful and few companies signed up because they did not see any advantage in participating. The manufacturer had to pay for a third party to inspect their facilities, generate a report, and share the inspection results back to the FDA. Many companies were reluctant to contract “someone else” to perform their inspection when they could easily wait for the FDA to conduct an inspection for free.

During its inaugural meeting in Singapore in 2012, the International Medical Device Regulators Forum (IMDRF) appointed a working group to develop a set of documents for a harmonized third-party auditor system. Hence, the “Medical Device Single Audit Program” (MDSAP) was formed. The concept was similar to the FDA’s original idea of creating a third-party auditor to help reduce their workload of performing regulatory audits of medical device manufacturers’ quality management systems. This new approach would consist of a single audit that would review regulatory QMS compliance, conducted by a third-party, who would later be called an Auditing Organization (AO).

From January 2014 to December 2016, five countries participated in a Medical Device Single Audit Program Pilot. In June 2017, a report was generated summarizing the outcomes of prospective “proof- of-concept” criteria established to confirm the success of the program. The outcomes are documented in the final MDSAP Pilot Report and recommended that the program become fully active and open to any manufacturer who requested this type of audit.

2012 Jan: Initiation of the pre-pilot project
2014 Jan: Announcement of the MDSAP Pilot project
Aug: Mid-Pilot Report
2015 Nov: 1st GMP Certificate delivered by ANVISA, using MDSAP audit report
Dec: Health Canada publish transition plan to replace CMDCAS by MDSAP
2016 Jan: 1st Canadian device license supported by an MDSAP certificate
Dec: Review of MDSAP Pilot project
2017 Jan: Auditing Organizations other than CMDCAS registrars can apply
July: Final Pilot Report concludes that the plan objectives met performance targets
2019 Jan: MDSAP replaces CMDCAS
2020 Implementation

Who is responsible for the MDSAP?

The governing body of the MDSAP is the Regulatory Authority Council (RAC), which is composed of two senior managers (and a few other staff members) from each participating RA. They are responsible for executive planning, strategic priorities, setting policy, and making decisions on behalf of the MDSAP International Consortium. The RAC also reviews and approves documents, procedures, work instructions, and more. The mission of the MDSAP International Consortium is to jointly leverage regulatory resources to manage an efficient, effective, and sustainable single audit program focused on the oversight of medical device manufacturers on a global scale.

Other international partners that are involved in the MDSAP include:

MDSAP Observers:

  • European Union (EU)
  • United Kingdom’s Medicines and Healthcare products Regulatory Agency (MHRA)
  • The World Health Organization (WHO) Prequalification of In Vitro Diagnostics (IVDs) Program

MDSAP Affiliate Members:

  • Argentina’s National Administration of Drugs, Foods and Medical Devices (ANMAT)
  • Republic of Korea’s Ministry of Food and Drug Safety
  • Singapore’s Health Sciences Authority (HSA)

The observers and affiliate members are not the same as the participating member RA’s. The observers simply observe and/or contribute to RAC activities. Affiliate members, on the other hand, are interested in engaging in the MDSAP program and are subject to certain rules. They are only given access to a certain level of information about the manufacturers, audit dates, and information in audit reports.

They are also invited to attend sessions that are open to members, observers, and affiliates only.

Audits can also be conducted by MDSAP participating RAs at any time and for various reasons including:

  • "For Cause" due to information obtained by the regulatory authority
  • as a follow up to findings from a previous audit
  • to confirm the effective implementation of the MDSAP requirements

The purpose of audits conducted by the RAs is to ensure appropriate oversight of the AOs MDSAP auditing activities. The AOs are appointed by the RAs and a list of the currently approved AO’s is published on the FDA website. Most AOs offer a broad range of management system certification services, beyond just medical devices. Manufacturers should verify that prospective AOs are clearly trained and perform MDSAP audits of medical devices.

AOs have the final word as to whether a manufacturer has met the requirements for the MDSAP during the execution of the audit and generation of the associated reports summarizing the results. MSDAP RAC participating RAs have the final decision regarding all development, implementation, maintenance, and expansion activities associated with the program.

Although an unannounced visit by an AO is rare, it can happen in circumstances where high-grade nonconformities have been detected.

How does an MDSAP audit work?

To continue reading this eBook including a detailed look at the MDSAP audit process and grading, pros and cons of the approach, and how to get started please register to download the full version.

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Company

Rimsys Launches the Regulatory Execution Engine for MedTech

By

May 5, 2026

4 min read

Spring 2026 embeds submission authoring, AI-powered regulatory monitoring, and configurable impact workflows inside a single RIM platform, the first step toward Rimsys' AI vision for global regulatory operations.

 

PITTSBURGH, PA, May 5, 2026 – Regulatory Information Management (RIM) software was built to store records. That foundation has served its purpose and reached its limit. Today, Rimsys announces the Spring 2026 release: a platform designed not to hold regulatory data, but to execute on it.

Submission volumes are growing. Markets are multiplying. Regulatory change is accelerating. Spring 2026 gives regulatory teams the tools to keep pace: embedded authoring, reusable submission content, configurable impact workflows, and AI-powered intelligence, all inside a single platform.

"Our vision for Rimsys is a platform that makes regulatory expertise go further, companies move faster, and products reach more markets than any team could accomplish alone. Spring 2026 is another meaningful step toward that vision. We are embedding the tools and intelligence that allow regulatory affairs professionals to operate at a different level, doing more strategic work, entering markets faster, and staying ahead of regulatory change rather than reacting to it. What we are building next makes this release the starting line." – James Gianoutsos, CEO

What Spring 2026 Delivers

A brand new website that provides in-depth information about the Rimsys offering and the benefits to MedTech manufacturers, including details on these new products:

Intelligence: AI-Powered Regulatory Monitoring

Rimsys Intelligence provides access to regulations, guidance documents, safety alerts, and legislation across more than 90 countries. AI triage and prioritization surface the updates most relevant to each customer's specific products and markets, eliminating hours of manual surveillance and putting the right information in front of the right people.

When a change requires action, teams can move directly from regulatory signal to impact assessment without a manual handoff. Intelligence represents Rimsys' first production deployment of context-aware AI operating across a customer's live regulatory data, a foundation that will expand significantly in future releases.

Advanced Submissions: A Unified Submission Execution Workflow

Advanced Submissions consolidates everything required to create, manage, and publish a regulatory submission into a single workflow inside Rimsys, eliminating the disconnected tools, manual reformatting, and version fragmentation that have defined submission work for too long. Three capabilities anchor it:

Rimsys Editor

The Rimsys Editor is the cornerstone of Advanced Submissions and the most significant capability in this release. It brings word-compatible authoring and editing natively inside Rimsys, fully compatible with Microsoft Word®, allowing regulatory teams to create, co-author, review, and publish submission content without leaving the platform for the first time.

The Editor supports real-time co-authoring, tracked changes and redlining, rich content including tables and images, document comparison, and PDF publishing with standardized headers, footers, and company branding applied automatically. AI-assisted authoring is available as a configurable option, enabling teams to summarize, refine, expand, and translate content within their workflow. Rimsys AI is human-in-the-loop by design.

Universal Submissions

Universal Submissions enables teams to build from a single universal template (an IMDRF Technical Document) with content automatically mapped into market-specific templates. One master structure, many markets, without rebuilding from scratch.

Reusable Submissions

Reusable Submissions takes a completed submission from one market and uses it as the starting point for a new one. The system automatically maps content into the target market's template, carrying applicable sections forward reducing the content creation time up to 90% and compressing the time required to enter each additional market.

Configurable Impact Surveys: Governed Change Assessment at Scale

Impact Surveys are now fully configurable. Templates can be defined for specific change event types, tied to countries or registrations, and triggered automatically from Rimsys Intelligence findings replacing ad hoc assessments with repeatable, governed workflows. This integration creates a direct line from change event to regulatory scope, with results tracked in a single audit-ready trail.

A Platform Built for What's Next

Spring 2026 establishes more than a set of new capabilities. It establishes the execution infrastructure, structured data model, and embedded AI foundation on which Rimsys' longer-term vision is being built.

That vision: a world where regulatory experts are amplified by intelligence, not constrained by information. Where the knowledge required to enter a new market, interpret a regulatory change, or scope a submission is instantly available to every member of the team. Where regulatory operations scale not by spreading experts thin, but by giving them tools that multiply their impact.

Spring is the first production step in that direction. Every submission authored inside the platform, every intelligence signal triaged by AI, and every impact assessment connected to structured regulatory data deepens the foundation. Future releases will build on it directly, expanding AI capabilities, automating more of the regulatory workflow, and ultimately enabling teams to do work that today requires external expertise to be done inside Rimsys.

Regulatory Execution as a Business Lever

Spring 2026 is built to move metrics that matter: reduced submission cycle time variance, improved approval predictability, lower marginal effort per market, and increased team capacity without proportional headcount growth. For executive leadership, earlier approvals translate directly into faster market access and accelerated revenue recognition.

Availability

Spring 2026 is now Generally Available. Existing customers on the Organizer product will retain access to their current experience.

To learn more about the Spring 2026 release and how Rimsys can accelerate your regulatory operations, visit rimsys.io or contact your Rimsys representative.

About Rimsys

Rimsys is the heart of regulatory operations for the medical device industry and the platform at the center of an AI-driven transformation in how regulated products reach global markets. A living, connected regulatory platform, Rimsys keeps regulatory intelligence, product data, approvals, and change management continuously connected, enabling organizations to expand into global markets with speed, precision, and confidence. Enterprise-ready yet intuitive to use, Rimsys is trusted by 6 of the top 12 global MedTech manufacturers to accelerate time to market and scale regulatory operations worldwide. To learn more, visit rimsys.io.

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MedTech

Nonconformance reporting for medical device manufacturers

By

Wendy Levine

March 30, 2023

4 min read

Defining nonconformance

Very simply, a nonconformance occurs when a specification is not met. The FDA defines a specification in 21 CFR 820.3 as “any requirement with which a product, process, service, or other activity must conform,” and ISO 13485:2016 as a “need or expectation that is stated, generally implied, or obligatory.”

While managing nonconformance starts with fully defining specifications; it is the identification, tracking, and resolution of nonconformance that is a focus of medtech quality and regulatory teams and a requirement of both ISO 13485:2016 and the FDA’s 21 CFR Part 820 quality system regulation.  

Identifying nonconformance occurrences

As part of a compliant quality system, medical device manufacturers should implement procedures to identify and address both major and minor non-conformances. Nonconformances may be identified through processes found in multiple subsystems that are part of an overall quality management system within the organization.

The systems and subsystems in which nonconformances are identified typically include:

  • ERP
  • Regulatory information management (RIM)
  • Product lifecycle management (PLM)
  • Document management
  • Customer service / customer management  
  • Complaint handling
  • Device history records
  • Audit management
  • CAPA
  • Training/learning management  
  • Calibration/preventative maintenance
  • Development change management

Evaluating nonconformance

Once a nonconformance is identified, it should be evaluated in a timely manner, and a determination made as to the disposition of any affected products. Requirements for additional investigation and reporting should also be identified. Based on the severity of the nonconformance and its effect on the safety and efficacy of devices being manufactured or already in the market, a CAPA (corrective/preventative action) record may need to be created. In the U.S., this is defined in the quality regulation 21 CFR Part 820.100.

To disposition a nonconformance, consider the following:

  • Will the existing system detect the nonconformance if it recurs in time for remediation?
  • How likely is it that this issue will recur?
  • What is the impact of the non-conformance (i.e., could it affect patient health)?

Issues that are more severe or are more likely to recur should trigger a more immediate and comprehensive response.

Nonconformances that are escalated and handled under CAPA are based on risk and can include those that have or could have an impact on a product or process that is:

  • Not easily corrected
  • Recurring
  • Severe

In addition, nonconformances that rise to the level of a CAPA require significant resources and typically result in a full project to identify root cause(s), containment, and corrective actions, and monitoring for effectiveness.  

Nonconformances that don’t require a CAPA have simpler resolutions that include documenting actions taken to correct the issue (or justification for no action). If the issue is not recurring, there may be no other action required. For example, a nonconforming material received from a vendor may be a singular issue that was easily identified through existing inspection procedures and is not expected to recur. In this case, the material is returned to the vendor and no additional action is required.

Processes that are out of conformance are often resolved through improved documentation and/or additional user training. However, be sure that the true root cause of the nonconformance is identified as procedural nonconformances can signal additional issues.

Documenting nonconformances

An important part of nonconformance procedures is the nonconformance report (NCR) or other documentation procedures.  Nonconformances are typically documented within the subsystem in which they were identified. Some organizations will have a nonconforming system in which issues originating from all subsystems are documented. Centralized nonconformance systems allow for trending and other analysis across all subsystems, the results of which may generate CAPAs.  

The requirements for documenting a nonconformance may vary by subsystem. In general, however, nonconformance documentation records:

  • The requirement/specification that was not met.
  • The objective evidence supporting the determination.
  • The action that is being taken to address the nonconformity.

Nonconformances are a common point of focus during quality audits by regulatory bodies, including the FDA, and should follow a well-documented process. Auditors will often try to determine if the quality system is functioning effectively by looking at self-identified nonconformances and comparing them to externally reported nonconformances. This is to ensure that nonconforming products were not released, or that the appropriate actions were taken to resolve issues in the field.

The importance of nonconformance reports

Nonconformances related to distributed products of higher risk result in nonconformance reports issued to government authorities through vigilance reporting, medical device reporting, and field action/recall reports. For example, the FDA requires that a medical device report be submitted within 30 days of a serious adverse event (see 21 CFR Part 803 Subpart E). Strong reporting procedures for nonconformances of all types are important in identifying trends, addressing issues before they become critical, and as part of a complete quality management system.

A nonconformance reporting procedure is only part of a strong quality system. Read An overview of 21 CFR part 820 and ISO 13485 overview for more information on establishing quality systems for medtech companies.

Company

Why we developed Rimsys from the ground up

By

Wendy Levine

May 26, 2022

4 min read

Rimsys has had quite a year already! In early December, we closed on $16 million in Series A financing and since then we have been carefully growing the company to better serve our customers and the regulatory affairs community. We have almost doubled our employee count and redesigned the Rimsys system to deliver deeper functionality that is even easier to use. We had our first in-person employee meeting here in Pittsburgh at the end of April where we introduced our new mission statement, and we are all excited to be doing our part to improve global health!

All of these changes made us think back to the founding of Rimsys and how far we have come. So - I sat down with Rimsys Founder and CEO, James Gianoutsos, to talk about the genesis of the company and how he knew that a new type of system designed for medtech regulatory affairs professionals was needed, and needed to be built from the ground up.

Q: What was the biggest challenge you faced as a regulatory professional that led you to form Rimsys?

James: The biggest challenge I saw while working at Philips for many years was completely understanding the complexity and the nuances around everything regulatory from a product standpoint. This really came to light whenever we acquired products. Just seeing firsthand how inefficient and out of compliance these manufacturers really were, and how hard it was from an administrative standpoint just to get into compliance and then to stay compliant, was striking. 

I was working with a smaller medical device company which had acquired products from Philips. Philips provided the company with a list (a color-coded Excel spreadsheet)  of all of their products that the company had acquired along with the registration status of those products globally. After digging into the spreadsheet for several months, we found that about 50% of it was wrong, incomplete, or just completely missing. The company was trying to keep track of registration information, but the available tools were making it nearly impossible. I realized that this was the challenge, and that there really wasn’t a solution on the market that could solve that problem in an easy manner and in a medtech regulatory-focused way.

Q: There were solutions on the market that were geared more towards the pharmaceutical industry, correct?

James: Yes. So I did what every other regulatory professional did, which was to Google “regulatory software,” and I saw that there just really wasn’t anything on the market that fit our needs. The solutions on the market really were pharma-specific, even those that said they worked with medical devices. The workflows and regulatory requirements for medtech are very specific for each market, depending on the product type and risk class and so many other factors. To use a pharma system that was already on the market  just wasn’t even an option because it was like comparing apples to oranges. It is completely different from the regulatory and workflow side of things.

Q: There are existing tools used by the regulatory community, such as quality management and document management systems. Did you envision the new RIM system integrating with existing tools, replacing them, or a little of both?  

James: I never set out to replace those types of systems, no. In fact, I knew that existing system architecture and infrastructure couldn’t handle the specific medtech regulatory workflows but needed to connect to those systems. There have always been PLM (Product Lifecycle Management) systems that contain a company’s product master data, but those systems were never meant to be workflow-driven based on regulatory requirements. At the same time, they are critical for organizing and maintaining product-specific metadata. Then there are ERP systems, which are really about making sure companies have sales flags (i.e. regulatory blocks) in place, appropriate shipping codes, or selling status linked to product registration status. Regulatory professionals are concerned about answering two questions for ERP users; one, “does the product have a valid and current registration within the country or market,” and two, “if it is registered, are we selling and shipping into that market.”  Lastly, quality/document management systems house critical documentation and records needed for registrations. The problem with these systems is that there are no regulatory workflows and no way to compile technical documentation, leaving the documents and records siloed from the regulatory filings.

To do the things that a regulatory affairs professional, in a critical regulatory department, does for their company, the system really had to be built from the ground up with all of these systems in mind. It had to be product-centric. It had to integrate with all these other sources of information, because there really wasn’t a common connection point between your products, your documentation, and the records that you needed to compile and how that relates to getting products on the market. We had no way to communicate to our other systems that a product is actually available for sale in that market or that it confidently can, or more importantly cannot, ship to that market.

Q: What was the most difficult piece of functionality to implement in Rimsys?  

James: Well, at the time it kind of all seemed difficult! No, really the most difficult part was thinking thoughtfully and strategically about how data was going to be mapped and used in conjunction with other data elements, in order to make the system most helpful from a user perspective. We wanted to single-source information to enhance and streamline regulatory workflows, but then also make sure that it was as user friendly as possible. There are a lot of stakeholders that need information or have input into regulatory workflows. Quality assurance, marketing operations, R&D, engineering, sales - all of those specific stakeholders need to view information in a way that is understandable to them.

We worked hard to bring all that information, streamline complex regulatory workflows, and all of those internal and external data sources together in an understandable and user-friendly way.

Q: How important has the technology itself been in the creation of Rimsys?

James: Technology has been a huge advantage for us from day one. Our team had quality and regulatory backgrounds, so we knew what companies would expect from us. We knew we had to be 21 CFR Part 11 compliant. We knew we had to be ISO 27001 certified. We knew we had to have SOC2 Type 2 reports. We knew we had to integrate with a company’s existing IT infrastructure. We really had to build this thing from the ground up on a GxP compliant platform that we could build upon and expand, without having to go back and reinvent the wheel every time we added new functionality. 

It’s continued to pay dividends for us because it was something that we thought about from the beginning and that gave us a lot of flexibility. We already had the system and infrastructure in place that we could then expand upon a lot more quickly than we would have been able to otherwise. It’s like the difference between building a house today and trying to remodel a house that was built in the year 1900. If you break down a wall in the older house, there might be so many hidden issues behind that wall - load bearing issues, knob and tube wiring, asbestos, etc. With new modern infrastructure, it is just night and day in terms of adapting quickly with changing regulations and a fast-paced market.

Q: Was there any specific technology you can talk about that became important to the development of Rimsys?

James: Our choice of technology was driven by our desire to build a system that was user friendly and built on a modern infrastructure that felt familiar to our users. So, we took a lot of the Google framework to build an application that didn’t look like enterprise software, but looked and felt more like a consumer product that is inviting, not overwhelming. 

The other thing is that we built the system from day one to integrate because we knew we had to connect with a lot of different sources of information. We strategically built the system with API’s in mind.

Q: What is Rimsys doing differently than other software companies in the regulatory space?

James: We are creating a holistic solution, which is different from what is out there now. We know that registration management is just one key aspect of what regulatory affairs teams need. In order to create a proper regulatory system, we had to take into account all of the data and dependencies and build a system specifically for medtech regulatory teams and other key consumers of regulatory data. There has to be a single source of truth for this data, because otherwise it becomes a nightmare at the end of the day. Existing software solutions were siloed and purpose-built for other industry needs, such as eQMS, PLM and ERP. None of those systems can do what a holistic RIM platform can do. Because of the complex workflows, the regulatory needs are far too broad and interdependent, that data infrastructure is completely different, data sources are too numerous, and the systems offer limited support to bring everyone and everything together into a cohesive, streamlined, compliant and medtech-specific solution.

Another key component of what we are doing is to institutionalize regulatory knowledge and resources into Rimsys—this is at the heart of who we are and what we do. Having the only purpose-built, holistic RIM platform built by and for regulatory professionals specific for the medtech industry really couldn’t be done without internalizing that experience within our own team.

Q: What are you most proud of when it comes to Rimsys? 

James: I think there are two things that immediately come to mind. Having our Rimsys 5 platform launch is really exciting. This is the fifth iteration of our platform, and we did it by listening to our customers and iterating over and over again to get it right. We had to go back to the drawing board a couple of times, not because what we had written wasn’t working, but because our customers that were using the system every day gave us better ways to do things. Rimsys 5 is a really proud moment because this is the platform that we are taking into the future, that will let us get to the next level where we are truly empowering regulatory professionals to make critical decisions and do the job that they are meant to do. 

The ability for us to listen to our customers, take that feedback and move fast is the second thing I’d mention here. We know that this has to be a validated system, but we are able to make changes and add features in a way that is thoughtful and gets our customers what they need right away. Regulatory professionals are very particular. I know since I am one, and making sure they are comfortable using Rimsys from day 1 is critically important. Being a customer-centric company really makes our experience as a team extremely rewarding.

Q: Where is Rimsys going next?  What are you most excited about?

I think I am most excited about Rimsys being an advocate for the medtech regulatory community and helping them wherever we can. Regulatory has a seat at the table now and it is a great feeling to see that we’re able to help these companies to streamline their workflows, accelerate time to delivery for life-saving products and maintain that compliance to keep those products on the market. Regulatory affairs is a mission critical department that the medtech industry cannot underestimate. It’s empowering because while we are helping our customers, they are helping us and every single one of our other customers through the journey of regulatory uncertainty that everyone is going through right now. It feels like a real partnership between us, our customers, and the industry as a whole and I am excited to see where that will take us.

I am also really excited about where we are going with regulatory intelligence. We are just scratching the surface of this now, but you will see regulatory intelligence data built into Rimsys and providing RA professionals with tools that can really provide a competitive advantage for their company. The release of Rimsys 5 platform (“Phase 1”) provides us that platform that will take us into “Phase 2” of Rimsys, with embedded intelligence that will further empower regulatory professionals to make decisive, correct and confident decisions for their products and their company.

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