About

Credibility supports
the message. It is not
the message.

The message is that unmanaged relationships are the root cause of documentation failure in regulated industries. The framework is the argument. The practitioner is the evidence that it works.

30+ Years of PracticeMedical Device · Life SciencesISO 13485:201621 CFR Part 820 · QMSREU MDR 2017/745ISO 14971:2019IEC 62304ANVISA RDC 665Design ControlsRisk ManagementInspection ReadinessQMS Remediation30+ Years of PracticeMedical Device · Life SciencesISO 13485:201621 CFR Part 820 · QMSREU MDR 2017/745ISO 14971:2019IEC 62304ANVISA RDC 665

Why Lean Documents and
Lean Configuration exist.

LDLC was not developed in response to a regulatory framework. It was developed in response to a recurring observation: organizations with substantial documentation investments consistently failed to demonstrate coherent, traceable relationships between their records during inspections.

The failure was not document quality. The documents were often well-written, thoroughly reviewed, and fully approved. The failure was the relationship between documents — the gap between what the URS said, what the TDR derived from it, what the hazard analysis assumed, what the verification protocol tested, and what the Device Master Record specified.

"The problem is not documents. The problem is unmanaged relationships."

That observation became the foundation of the LDLC framework. Lean Documents addresses the quality and discipline of individual records. Lean Configuration addresses the governed relationships between them. Together they provide the architecture for a documentation system that can explain itself — under inspection, under change, and under the pressure of post-market obligations.

More than three decades of
practice in regulated industries.

30+
Years of Practice
Medical
Device
Primary Domain
6+
Regulatory Frameworks

José Ignacio Mora

Manufacturing engineering and quality systems consultant with more than three decades of experience in medical device and life sciences organizations. His work focuses on the intersection of engineering discipline and quality governance — particularly the application of configuration management principles to documentation systems in regulated industries.

He founded Atzari Enterprises, L.L.C. and developed the Lean Documents and Lean Configuration framework as the organizing architecture for consulting practice. The framework is the result of repeated engagement with a single recurring problem: organizations with well-intentioned, well-maintained documentation systems that failed to demonstrate coherence when it was required.

His consulting practice focuses on organizations preparing for regulatory submission, undergoing inspection remediation, implementing design controls for new products, or restructuring their quality management systems to meet current regulatory expectations.

Representative Experience
QMS Remediation
FDA-regulated manufacturers following inspection findings. Quality Plan 100059, Quality Manual 100060 restructuring, CAPA architecture, design control remediation.
Design Controls
DHF architecture, URS/TDR governance, V&V protocol development (100427/100428), design transfer governance for DMR 100518.
Technical Documentation
EU MDR Technical Documentation structure and maintenance. Section 6 biological safety (100781), Section 9 PMS plan (100782), Notified Body preparation.
Risk Management
ISO 14971:2019 RMF governance. Hazard analysis architecture (100312), risk control traceability, PMS-to-RMF feedback loop design.
Supplier Quality
Critical component governance from material supplier (700021) through polymer resin (900118) to finished device assembly (900374). Incoming inspection SOP and work instruction governance.

The regulatory context
for the framework.

The LDLC framework is regulatory-framework-neutral. The governance architecture applies regardless of which standard or regulation governs the organization.

FDA — United States

21 CFR Part 820 / QMSR

Quality Management System Regulation. Aligns with ISO 13485:2016. Design controls, risk management integration, production and process controls.

ISO — International

ISO 13485:2016

Medical devices — Quality management systems. The primary international QMS standard. Design controls, risk management integration, lifecycle documentation governance.

EU — European Union

EU MDR 2017/745

Medical Device Regulation. Technical Documentation requirements, clinical evaluation, post-market surveillance, PMCF. Applicable to devices marketed in the European Union.

ISO — International

ISO 14971:2019

Medical devices — Application of risk management. Risk management file governance, hazard analysis (100312), risk controls, residual risk, PMS feedback integration.

IEC — International

IEC 62304:2006 / AMD1

Medical device software — Software life cycle processes. Software requirements, architecture, detailed design, unit implementation, verification, and release governance.

ANVISA — Brazil

RDC 665:2022

Brazilian medical device quality system requirements, aligned with ISO 13485:2016. Registration, technical documentation, and post-market surveillance obligations.

MHLW — Japan

Ordinance 169:2004

Japanese Quality Management System Ordinance for medical devices and in vitro diagnostics. Design controls, post-market surveillance, manufacturing controls.

FDA — United States

21 CFR Part 11

Electronic records and electronic signatures. Applicable to eQMS implementation, electronic DHF and DMR records, and software validation in regulated environments.

The framework in practice.

These are not case studies — they are examples of the kinds of governance problems the LDLC framework addresses in practice.

QMS Remediation

Quality System Architecture Rebuild

Led complete restructuring of a Quality Manual (100060) and Quality Plan (100059) for a medical device manufacturer following FDA inspection findings. Reorganized from clause-indexed structure to governance architecture. Result: coherent system demonstrable on demand.

Design Controls

DHF Governance Architecture for Class II Device

Designed and implemented the DHF governance architecture for a new Class II medical device. Established governed derivation chain from URS 401042 through TDR 401087, hazard analysis 100312, V&V protocols 100427/100433, to DMR 100518. All relationships governed under explicit change control architecture.

Technical Documentation

EU MDR Technical Documentation — CE Marking Preparation

Led Technical Documentation (100781, 100782) preparation for EU MDR CE marking. Established governance structure for Section 6 biological safety coherence with RMF 100312, and Section 9 PMS plan connection to post-market surveillance data sources.

Inspection Readiness

Pre-Inspection Coherence Assessment

Conducted LDLC coherence assessments for organizations preparing for FDA and ISO 13485 audits. Assessment protocol: for a given set of regulated outputs, can the organization trace every significant claim to its supporting evidence — on demand, without reconstruction?

ERP / eQMS

eQMS Configuration Governance Architecture

Defined governance architecture for eQMS implementation before system selection. Established document type hierarchy, relationship rules, workflow governance for ECN (401247 / 600247), and CAPA work unit architecture. Prevented automation of pre-existing governance failures.

Supplier Quality

Critical Component Configuration Governance

Established configuration governance chain from material supplier account (700021) through polymer resin specification (900118) to patient-contacting component (900221) to finished device assembly (900374). Incoming inspection SOP (100524) and work instruction (100531) linked to material specification (100519) under explicit change control.

The organization behind
the framework.

Atzari Enterprises, L.L.C. is a consulting firm organized around a single practice area: the governed management of relationships between records, systems, and artifacts in regulated industries. The firm's intellectual property includes the LDLC framework, the LDLC ontology, the Change Propagation model, and the book When Documents Lie.

Consulting engagements are structured as discrete, deliverable-oriented projects with defined governance objectives. The output of every engagement is a documentation system that can demonstrate its own coherence — not a compliance checklist, not a document inventory, and not a process map.

Entity Information
Legal Name
Atzari Enterprises, L.L.C.
Framework
Lean Documents and Lean Configuration
Primary Domain
Medical Device · Life Sciences
Copyright
© 2025 Atzari Enterprises, L.L.C.

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