Medical Device Risk Management
ISO 14971
Dan OLeary
President
Ombu Enterprises, LLC
Dan@[Link]
[Link]
OMBU
ENTERPRISES, LLC
Risk Management - ISO 14971
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Speaker Biography
Dan OLeary
Dan OLeary is President of Ombu Enterprises, LLC, an education,
training, and consulting company focusing on Operational Excellence
using analytical skills and a systems approach to operations
management.
Dan has more than 30 years experience in quality, operations, and
program management in regulated industries including aviation,
defense, medical devices, and clinical labs.
He holds a Masters Degree in Mathematics; is an ASQ certified
Biomedical Auditor, Quality Auditor, Quality Engineer, Reliability
Engineer, and Six Sigma Black Belt; and is certified by APICS in
Resource Management.
Ombu Enterprises, LLC
Ombu works with small manufacturing companies, offering training and
execution in Operational Excellence. Focusing on the analytic skills and
systems approach of operations management, Ombu helps companies
achieve efficient, effective process and regulatory compliance.
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Outline
Status of ISO 14971:2007
Links to regulatory requirements (QSR & ISO 13485)
Overview of ISO 14971:2007
Q&A session
Summary and Conclusions
Questions
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Our Class
Our approach is casual
Write your name on a table tent
Turn off your cell phones during the class
Ask lots of questions
Bring examples from your experience
Participate
Have fun!
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Participant Introduction
Your Name
Your company
Your job title
Something about the Risk and Hazard Assessment for
Medical Devices issues you face in your company
Something about Risk and Hazard Assessment for
Medical Devices that you want to know
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Dan OLearys Biography
Dan has more than 30 years experience in quality,
operations, and program management in regulated
industries including aviation, defense, medical devices,
and clinical labs.
Dan earned a Masters Degree in Mathematics
Dan is an ASQ certified Biomedical Auditor, Quality
Engineer, Reliability Engineer, and Six Sigma Black
Belt. He is certified by APICS in Resource
Management.
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The Current Status of
ISO 14971:2007
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ISO 14971:2007 Development
ISO 14971:2007 is the second edition
It replaces the year 2000 edition (ISO 14971:2000)
It also replaces amendment 1 to the 2000 edition
(ISO 14971:2000/Amd 1:2003)
The second edition was published on March 1,
2007
ISO 14971 is managed by ISO TC 210 Quality
management and corresponding general
aspects for medical devices
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FDA Recognition Status
The FDA recognized the current version on Sep. 12,
2007.
Their recognition extends to the whole standard
A declaration of conformity means that
(1) a process appropriate for medical devices and their
accessories, including in vitro diagnostic devices, has been used
to identify hazards and hazardous situations, estimate and
evaluate the risks, control those risks including overall residual
risk, and monitor the effectiveness of the controls, and
(2) criteria based upon applicable national or regional
regulations, relevant international Standards, information such
as the generally accepted state of the art, and known
stakeholder concerns was used to determine risk acceptability.
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EN ISO 14971 Status
EN ISO 14971:2009
The current version is EN ISO 14971:2009
Medical devices - Application of risk
management to medical devices (ISO
14971:2007, Corrected version 2007-10-01)
Conformity to EN ISO 14971:2007 expired on
March 21, 2010
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EN ISO 14971 Versions
Many EN standards start with an ISO version
Various standards bodies may adopt them, add
information, and renumber them.
ISO 14971:2007
EN ISO 14971:2007
EN ISO 14971:2009
CEN doesnt sell standards; purchase them through national standards
bodies. As a result, the standards are renumbered (again).
I.S. EN ISO 14971:2009
BSI EN ISO 14971:2009
DIN EN ISO 14971:2009
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Links to Regulatory
Requirements
(QSR & ISO 13485)
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QSR Requirements for Risk
Analysis
The FDA requires risk assessment as part of
design validation. (820.30(g))
Design validation means establishing by
objective evidence that device specifications
conform with user needs and intended use(s).
(820.3(z)(2))
Since medical devices need to both safe and
effective, risk management, starting in the
design phase, is a natural approach.
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ISO 13485:2003 & Risk
Management
Clause 7.1 requires, . . . risk management
throughout product realization.
In addition, Records arising from risk management
shall be maintained
The standard recommends ISO 14971 for guidance
related to risk management.
Clause 7.3.2 says that design and development
inputs include risk management outputs.
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An Overview of
ISO 14971:2007
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The Risk Management Flow
Risk
Risk Analysis
Analysis
Clause
Clause 44
Risk
Risk Evaluation
Evaluation
Clause
Clause 55
Risk
Risk Control
Control
Clause
Clause 66
Residual
Residual Risk
Risk
Evaluation
Evaluation
Clause
Clause 77
Risk
Risk
Management
Management
Report
Report
Clause
Clause 88
Production
Production &
&
Post-production
Post-production
Information
Information
Clause
Clause 99
Risk assessment
Risk management
Adapted from ISO 14971:2007 Figure 1
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Risk Management Plan
Risk management activities need an overall
plan
The risk management plan has standard
elements:
Scope (including the life-cycle)
Responsibilities and authority
Review requirements for risk management
Risk acceptability criteria
Risk verification
Production activity data collection and review
Post-production activity data collection and review
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Risk Management File
The documents and quality
records are maintained in the
Risk Management File.
Think of this as a filing cabinet
containing information about
the risk management program
In practice, it is usually a variety of
documents, often in different
formats (text files, spreadsheets,
etc.)
You must be able to readily
retrieve documents and
records of the Risk
Management File.
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Risk Analysis (Clause 4)
Document both the intended use and
foreseeable misuse of the device
Identify known and foreseeable hazards
associated with the device
Estimate the risk for each hazardous
situation
Hazard + Sequence of events Hazardous Situation
Severity Probability Risk
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Risk Evaluation (Clause 5)
The Risk Management Plan defines risk evaluation
criteria for each hazardous situation
Evaluate each hazardous situation, individually, against
the criteria in the Risk Management Plan
If risk reduction is required,
follow clauses 6.2 to 6.6
If risk reduction is not
required, go to clause 6.7
Example
A Risk Management Plan defines five risk levels, 1 to 5, and shows how to
calculate them using severity and probability.
Any risk of level 4 or 5 must be reduced to level 1, 2, or 3.
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Risk Control (Clause 6)
Hazardous
Hazardous
Situation
Situation
Identified
Identified
Risk
Risk Estimated
Estimated
Risk
reduction
required?
Yes
Option
Option
Analysis
Analysis
(6.2)
(6.2)
Implementation
Implementation
(6.3)
(6.3)
Residual
Residual
Risk
Risk
(6.4)
(6.4)
Risk
Risk
Benefit
Benefit
(6.5)
(6.5)
New
New
Risks
Risks
(6.6)
(6.6)
No
Completeness
Completeness
Check
Check
(6.7)
(6.7)
Overall
Overall
Risk
Risk
(7)
(7)
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Residual Risk Evaluation
(Clause 7)
The Risk Management Plan defines risk
evaluation criteria for overall risk
After the risk control measures are
implemented and validated, review the
overall risk
If the overall risk is unacceptable,
determine if the medical benefits outweigh
the overall residual risk
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Risk Management Report
(Clause 8)
Prior to release of the device, you need to review the risk
management process.
The review ensures:
The Risk Management Plan is implemented
Overall residual risk is acceptable
Measures are in place to obtain production and post-production
information
The reviews results become the Risk Management
Report, and is included in the risk management file
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Production & Post-production
Information (Clause 9)
Collect information about your device in the
production phase.
Review acceptance data
Look closely at validated processes and their controls
In the post-production phase review:
Installation and servicing reports
Customer complaints
New or revised standards
Public information, including similar medical devices
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An Example to Keep in Mind
The Neonatal Heel Stick
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The example helps illustrate the
concepts
Neonates (babies under 1 month of age) are
routinely tested for metabolic diseases.
A nurse draws a sample of blood from the
babys heel, places it on filter paper, and allows
it to dry.
The dried blood spot is sent to a laboratory for
testing.
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The Heel Stick
The nurse uses a lancet to draw the blood in a
process called a heel stick.
In this application, the chemical pack is a medical
device in the US.
To make the heel stick easier,
the nurse warms the babys heel,
often using a chemical pack.
The technology is a familiar
heat generating chemical pack,
activated by squeezing or mixing.
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Product Description
Early in 2009, the FDA published a note describing problems with
the heel warmer.
The Infant Heel Warmer:
Is an instant chemical heat pack. It increases capillary circulation in an
infants heel to facilitate blood collection by heel stick.
[It is a] nonsterile, single-use, disposable device contain[ing] a nontoxic
material.
Device activation results in an exothermic reaction with a maximum
temperature of around 104F (40C) within the first few minutes before it
gradually diminishes.
In the US it is
A Class I device
For infant use, it requires a 510(k)
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Potential Product Problems
Based on Medical Device Reports (MDRs), the FDA
cited four cases.
Case 1:An infant suffered second to third-degree burns to the
heel requiring treatment.
Case 2:Twins with hyperbilirubinemia were being prepared for a
heel-stick procedure. The heel warmer ruptured, its contents
covered the infants, and they suffered first and second-degree
burns.
Case 3:An infant received a second degree burn when the
device was reused and reheated contrary to labeling
instructions.
Case 4:When the nurse activated the infant heel warmer, it burst
open and splashed her in her eyes. The infant wasnt hurt, but
the nurse required emergency eye wash and ophthalmic
antibiotics.
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Definitions
Clause 2
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The Components of Risk
Hazards, set off by a sequence of events, create Harm.
Severity & Probability combine to measure Risk.
Hazard
Hazard
Hazardous
Hazardous
Situation
Situation
Harm
Harm
Severity
Severity of
of
the
the Harm
Harm
Risk
Risk
Sequence
Sequence
of
of Events
Events
Probability
Probability of
of
Occurrence
Occurrence
of
of the
the Harm
Harm
Adapted from ISO 14971:2007, Annex E
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Definitions Hazard
Hazard - potential source of harm
Discussion
The manufacturer identifies device hazards. The standard creates a potential
22 classification for hazards they could be known or foreseeable; they
could arise in normal or fault condition.
Example
The FDA advice identifies 3 hazards:
Excessive heat
Rupture
Improper reuse
Known
Foreseeable
Normal
Condition
Fault
Condition
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Definitions Hazardous Situation
Hazardous situation circumstance in which people, property, or the
environment are exposed to one or more hazard(s)
Discussion
A hazard is potential, and doesnt arise until set off by a sequence of events.
It then becomes a hazardous situation allowing exposure to the hazard. A
hazardous situation can occur in normal operation or in a fault condition.
Example
Postulated sequences allowing a hazardous situation:
Excessive heat
Chemical mix is incorrect
Use of a blanket, contrary to manufacturers instructions
Rupture
Incorrect seal strength
Improper reuse
Reuse of a single use device, contrary to manufacturers instructions
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Definitions Harm
Harm physical injury or damage to the health of people, or damage to
property or the environment
Discussion
Harm is the actual injury or damage that occurs from a hazardous situation.
Harm arises from a hazardous situation.
Example
Excessive heat
Thermal burn of the skin
Rupture
Thermal burn of the skin
Chemical burn of the skin, eyes, etc.
Improper reuse
See excessive heat
See rupture
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Definitions Severity
Severity measure of the possible consequences of a hazard
Discussion
When harm occurs, it can have different levels of seriousness. Severity is the
measure of seriousness of the harm.
Example
Thermal Burn
First degree
Second degree
Third degree
Chemical Burn
Skin
Eyes
Risk Management - ISO 14971
Example
These instance must be
converted to the manufacturers
description of severity. This is
often a qualitative approach.
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Definitions Probability of Occurrence
Probability of occurrence the likelihood that the harm occurs with the stated
severity
Discussion
Some harms are less likely to occur than others. In addition, harms with
different severity usually have different likelihood of happening.
Example
Thermal burn resulting from incorrect chemical mix Very Low
Thermal burn resulting from use of a blanket Low
Thermal burn resulting from a burst package Very Low
Chemical burn resulting from a burst package Very Low
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Definitions Risk
Risk combination of the probability of occurrence of harm and the severity of
that harm
Discussion
Risk combines two factors, usually in a qualitative approach. Risk increases
with the severity of the harm. It also increases with the probability of
occurrence of the harm. Risk is often expressed as a specialized
multiplication table.
Example
Burst package results in 3rd
degree (thermal) burn of a nurse.
Severity: Significant
Probability: Low
Risk: Medium
Risk Management - ISO 14971
Severity of Harm
Probability
of
Occurrence
Negligible
Moderate
Significant
High
Medium
Medium
High
Medium
Low
Medium
Medium
Low
Low
Low
Medium
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Developing the Risk
Management Plan
Clause 3.4
Annex F
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Role of the Risk Management Plan
The Risk Management Plan provides the
overarching approach to the managing risk.
It can take a variety of forms
Stand alone document
Integrated into QMS documents
Refer to other documents
The structure and detail should relate to the
medical device risk.
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Scope of the Plan
Design
Design &
&
Development
Development
The scope needs to
identify
the medical device (or
family)
and the life cycle
Process
Process
Validation
Validation
Risk
Assessment
& control
Production
Production
Life Cycle of the
Heel Warmer
Example
Pick,
Pick, Pack
Pack &
&
Ship
Ship
Production
information
Warehouse
Warehouse
The risk management
activities are mapped
to the life cycle
Activate
Activate
Apply
Apply to
to
Neonate
Neonate
Post - production
information
Dispose
Dispose
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Assign Responsibility and Authority
Risk Mgmt. Plan
Assign roles and their responsibilities
Examples include:
Reviewer
Approval authority
Expert
Verification specialist
Follow the roles and responsibilities in the design project to avoid
confusion
The RASI Matrix is a useful tool for tasks
Responsible
Support
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Authority
Inform
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Criteria for Risk Acceptability
Risk Mgmt. Plan
The Risk Management Plan needs two
sets of criteria
One arises from the risk assigned to each
hazardous situation
The other arises from the overall risk
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Concept of Risk
Risk Mgmt. Plan
Increasing Probability
The concept of risk starts with continuous Probability and Severity dividing the
Risk area into regions.
Unacceptable
As low as
reasonably
practicable
Acceptable
Increasing Severity
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But more often becomes a table
Risk Mgmt. Plan
...
Severity Levels
Probability Levels
Term
Description
Term
Description
Catastrophic
Results in death
Frequent
Happens often
Critical
Results in permanent impairment to
life-threatening injury
Results in injury or impairment
requiring medical intervention
Results in injury or impairment not
requiring medical intervention
Inconvenience or temporary
discomfort
Probable
Likely to happen
Occasional
Can happen, but not likely
Remote
Unlikely to happen
Improbable
Highly unlikely to happen
Serious
Minor
Negligible
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. . . that represents risk
Risk Mgmt. Plan
Severity Levels
Probability
Levels
Negligible
Minor
Serious
Critical
Catastrophic
Frequent
R2
R2
R3
R3
R3
Probable
R2
R2
R2
R2
R3
Occasional
R2
R2
R2
R2
R3
Remote
R1
R1
R2
R2
R3
Improbable
R1
R1
R2
R2
R3
R1 Acceptable risk
R2 As Low As Reasonably Practicable
R3 Unacceptable
Risk Management - ISO 14971
Each company must develop its own
risk analysis system.
The risk matrix may differ by product.
For example, a risk matrix for a heel
warmer may not be adequate for an
automatic defibrillator.
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Overall Residual Risk Evaluation
Risk Mgmt. Plan
If each risk is low, then the residual risks should be low.
When residual risk remains, it should be evaluated by
specialists with knowledge of the device.
If the residual risk is too high, it may be offset by the
medical benefit.
X-rays cause damage to tissue, but the diagnostic benefit
outweighs the risk.
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Verification Activities
Risk Mgmt. Plan
The standard says there are two distinct
verification activities
Ensure the risk control measures are implemented in
the final design.
Ensure the implemented risk control measures
actually reduce the risk.
The Risk Management Plan explains how to
conduct these verifications.
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Production Activity
Data Collection and Review
Risk Mgmt. Plan
The Plan describes how
you will collect and review
data from production
activities
Some production activities,
if performed incorrectly
could increase risk
Identify them and monitor
process results
Pay particular attention to
processes that must be
validated
Risk Management - ISO 14971
Our example
The chemical mix
determines the
temperature of the heal
warmer. Monitor mix
parameters.
One would expect
destructive testing for seal
strength and temperature
profile. Monitor the results
of these tests.
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Post-production Activity
Data Collection And Review
Risk Mgmt. Plan
The plan describes how you will collect and review post-production
activity
Include the following areas in data collection:
Customer complaints
Installation reports
Servicing reports
FDAs Adverse Event reports
Professional literature
For each item collected, review the hazard, hazardous situation,
and risk
The new information may lead you to update the previous analysis and
conclusion
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Performing Risk Analysis
Clause 4
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Risk Analysis Methodology
This is a systematic approach to determine risk
List every hazard (know or foreseeable)
List the associated hazardous situations
List the chain of events that creates each hazardous
situation
Identify the potential harm(s)
Estimate the severity and probability
Calculate the risk, using the Risk Management Plan
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This approach lends itself to a
spreadsheet
Hazardous
Situation
Potential
Harms
Severity Probability
Risk
* Operator error setting up
sealing machine
* Weak seal
* Nurse agressively mixes
Pouch bursts the pouch
Pouch spills
hot contents
Second degree
thermal burn
Serious Occasional
R2
* Nurse reheats the pouch
* Aggressive mixing breaks
seal
Pouch spills
hot contents
Second degree
thermal burn
Serious
R2
Hazard
Chain of
events
Remote
The spreadsheet could contain many rows.
Notice that a hazard could have more than one chain of events.
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Identifying hazards can be difficult
The standard has a number of helpful aids
Annex C helps identify device characteristics that may
impact safety
Table E.1 provides a list of potential hazards
Table E.2 offers a list of potential initiating events
Table E.3 shows examples of hazards, chain of
events, hazardous situations, and harm
Annex H provides additional information for in vitro
diagnostic devices
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Risk Evaluation
Clause 5
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The Prior Work Simplifies Risk
Evaluation
The Risk Management Plan contains the criteria
for acceptable risk
Risk Analysis determined the risk for each
hazardous situation
Application of the criteria to each hazardous
situation determines the need for risk reduction
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Recall Our Previous Flow Chart
Hazardous
Hazardous
Situation
Situation
Identified
Identified
Risk
Risk Estimated
Estimated
Risk
reduction
required?
Yes
Option
Option
Analysis
Analysis
(6.2)
(6.2)
Implementation
Implementation
(6.3)
(6.3)
Residual
Residual
Risk
Risk
(6.4)
(6.4)
Risk
Risk
Benefit
Benefit
(6.5)
(6.5)
New
New
Risks
Risks
(6.6)
(6.6)
No
Completeness
Completeness
Check
Check
(6.7)
(6.7)
Overall
Overall
Risk
Risk
(7)
(7)
Risk evaluation (Clause 5)
for each identified hazardous
situation
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Risk Control
Clause 6
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Risk Reduction (when required) Clause 6
Option Analysis
(6.2)
Select risk control measures in the specified order:
inherent safety by design protective measures
safety information
Implementation
(6.3)
Implement the selected risk control measures
Verify implementation of each risk control measure
Record the results in the risk management file
Residual Risk
(6.4)
After implementation of risk control measures
Evaluate residual risk by the risk management plan
If necessary, apply further risk control measures
Risk Benefit
(6.5)
Decide if medical benefits outweigh the risk when:
Residual risk is not acceptable
Further risk control is not practicable
New Risks
(6.6)
Determine if risk control introduced any new risks
Check if previously estimated risks are affected
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Risk Control Completeness Check
Clause 6
Completeness
Check (6.7)
Risk Management - ISO 14971
Ensure the risks from all identified hazardous
situations are considered.
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Evaluation of Overall Residual
Risk Acceptability
Clause 7
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This is a Broad View of Risk
Previously we evaluated the risk of each
hazardous situation
If it didnt meet the criteria we reduced the risk
We also cycled through all the hazardous
situations to evaluate impacts
Now we take a broader view to evaluate
the whole device
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Use Expert Opinion to Review
and Decide
Overall residual
risk acceptable?
Yes
No
Medical benefits
outweigh risk?
Yes
No
STOP THE PROJECT
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Disclose overall risk
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Disclosing Overall Risk
Annex J offers guidance on communicating risk
Information for safety is the least preferred method
Recall the priority order: inherent safety by design protective
measures safety information
Identify who receives the information and how
Explain the risk, the consequences of exposure, and
how to prevent the harm
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The GHTF Guidance
Implementation of risk management
principles and activities within a Quality
Management System
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Purpose and Overview
The GHTF Guidance focuses on integrating Risk
Management into the Quality Management
System (QMS).
The scope of ISO 14971 says
This International Standard does not require that the
manufacturer have a quality management system in
place. However, risk management can be an integral
part of a quality management system.
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Phases of Risk
1st Phase
Acceptable levels of risk
A policy or procedure determines risk acceptability criteria
It is derived from experience and research on currently
accepted risk levels
2nd Phase
Risk analysis
Identify hazards in normal use or foreseeable misuse
Estimate the for each identified hazard
3rd Phase
Compare risks to acceptability criteria
Determine the need for risk reduction, if necessary
Determines the appropriate level of required risk reduction
4th Phase
Risk control and monitoring activities
Activities can begin as early as design input, and continues
through manufacturing, distribution, installation, and
servicing. Activities cover the device life cycle.
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The Guidance Covers Areas of the QMS
Management Responsibilities
Outsourcing
Planning
Design and Development
Traceability
Purchasing Control and Acceptance Activities
Production and Process Controls
Servicing
Analysis of Data
Corrective and Preventive Actions (CAPA)
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Two Areas are Worthy of Note
Design and
Development
The guidance covers
each area of design and
development.
Annex B contains a
detailed flowchart placing
risk management
activities in the design
and development
process
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CAPA
The guidance contains a
detailed flowchart integrating
risk management into the
CAPA process.
The flowchart identifies key
quality data points:
Service Reports
Product Complaints
Manufacturing
Nonconformities/Defects
Engineering
Nonconformities/Defects
Quality System
Nonconformities/Defects
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Tools for Risk Management
Failure Modes and Effects Analysis
Fault Tree Analysis
Hazard Analysis and Critical Control Point
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Failure Modes and Effects
Analysis (FMEA)
This is a standard reliability technique adapted
to risk analysis.
In risk analysis, there is a very important
consideration. Hazards and Harms do not
require failure!
Evaluate risk management in normal, single
fault, and multiple fault conditions.
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The Standard Method
A large spreadsheet where each row relates to a hazard.
Typical column entries include:
Function
Hazard
Harm
Mode (Normal, single fault, or multiple fault)
Severity
Occurrence
Detection
Risk Priority Number (Determine by severity, occurrence, &
detection as defined in the Risk Management Plan)
Mitigation
Responsibility
Verification
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Fault Tree Analysis (FTA)
A Fault Tree is a logic diagram showing
the paths to an event
The event under study is called the Top
Event
The causes of the Top Event are
diagramed using standard logic gate
symbols
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Logic Symbols
AND
The output event occurs when all input
events occur at the same time
OR
The output event occurs when at least one
of the input events occur
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A Fault Tree
Pump Failure
Bearing Failure
Motor Failure
Seal Failure
Valve Failure
A coupling failure causes a motor failure
A motor failure causes a pump failure
Coupling Failure
Electrical Failure
A power failure AND battery
exhausted cause an electrical failure
Power Failure
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Fault Tree Analysis (FTA) Steps
Fault Tree Analysis usually involves five steps:
1. Define the undesired event to study, the Top Event
State the undesired event that can cause risk
2. Understand the system
Describe the events that could allow the Top Event to happen. For each event determine the
what would cause it. Continue to analyze the system.
3. Construct the fault tree
After selecting the undesired event and analyzed the system to identify the causal events,
construct the Fault Tree. Describe the events and their relationships using AND and OR
gates. More complex gates are also possible.
4. Evaluate the fault tree
Evaluate the Fault Tree. Look for possible improvements that can mitigate, reduce, or
eliminate the events. Identify all possible hazards affecting in a direct or indirect way the
system.
5. Control the hazards identified
After identifying the events and hazards, determine methods to decrease the probability of
occurrence.
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Hazard Analysis and Critical Control
Point (HACCP)
HACCP is a system to prevent problems, rather
than finding them by inspection at the end of the
production process.
HACCP is used by US regulatory agencies (FDA
and USDA) to help protect the food supply
HACCP is based on seven principles described in
the FDAs Hazard Analysis and Critical Control
Point Principles and Application Guidelines
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HACCP Principles
Principle 1: Conduct a hazard analysis
The hazard analysis develops a list of significant hazards that they are
reasonably likely to cause injury or illness if not effectively controlled.
Principle 2: Determine the critical control points (CCPs)
A critical control point is a step at which control can be applied to
prevent or eliminate a hazard or reduce it to an acceptable level.
Principle 3: Establish critical limits
A critical limit is a maximum and/or minimum value to which a
parameter must be controlled at a CCP to prevent, eliminate or reduce
to an acceptable level the occurrence of a hazard. A critical limit is used
to distinguish between safe and unsafe operating conditions at a CCP.
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HACCP Principles (cont.)
Principle 4: Establish monitoring procedures
Monitoring is a planned sequence of observations or
measurements to assess whether a CCP is under control and to
produce an accurate record for future use in verification.
Monitoring serves three main purposes.
Monitoring facilitates tracking of the operation. If monitoring
indicates that there is a trend towards loss of control, then action
can be taken to bring the process back into control before a
deviation from a critical limit occurs.
Monitoring is used to determine when there is loss of control and a
deviation occurs at a CCP, i.e., exceeding or not meeting a critical
limit. When a deviation occurs, an appropriate corrective action
must be taken.
Monitoring provides written documentation for use in verification.
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HACCP Principles (cont.)
Principle 5: Establish corrective actions
The HACCP system identifies hazards and establishes
strategies to prevent, eliminate, or reduce their occurrence.
Deviations from established processes may occur, so if there is
a deviation from established critical limits, corrective actions are
necessary. Specific corrective actions should be developed in
advance for each CCP and included in the HACCP plan
Corrective actions should include the following elements:
(a) determine and correct the cause of non-compliance;
(b) determine the disposition of non-compliant product and
(c) record the corrective actions that have been taken.
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HACCP Principles (cont.)
Principle 6: Establish verification procedures
Verification is defined as those activities, other than monitoring,
that determine the validity of the HACCP plan and that the
system is operating according to the plan.
Principle 7: Establish record-keeping and documentation
procedures
Generally, the records maintained for the HACCP System should
include the following:
A summary of the hazard analysis, including the rationale for
determining hazards and control measures
The HACCP Plan
Support documentation such as validation records
Records that are generated during the operation of the plan
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Summary & Conclusions
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Summary
The standard method for medical device
risk management is ISO 14971:2007
The FDA recognizes it as a consensus
standard
The EU lists it as a harmonized standard to
the MDD, IVD, and AIMD
ISO 13485:2003 recommends ISO 14971 for
risk management
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Summary
ISO 14971 implementation starts with a Risk
Management Plan
The implementation flows through a series of steps
defined in the respective clauses:
4: Risk Analysis
5: Risk Evaluation
6: Risk Control
7: Residual Risk Evaluation
8: Risk Management Report
9: Production & Post-production Information
Maintain of the information in the Risk Management File
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Summary
The Risk Management File is not a static
document
It should include production information
Monitor production processes that contribute to risk
factors
Validated processes are particularly significant
contributors
It include post-production information
Integrate the complaint and post-market surveillance
processes
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Conclusions
ISO 14971:2007 is the de facto standard
for medical device risk management
Regardless of the marketing region (US,
EU, Canada, etc.) ISO 14971 is a valuable
addition to a medical device QMS
ISO 14971 is most effective when it is
integrated into a companys QMS.
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QUESTIONS
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