Post on 29-Nov-2014
description
Complying with ISO 14971: Transition from 2007 to 2009
presented by
John Beasley Owner & Sr. Consultant
MedTech Review
Topics
• Understanding need for Risk Management • Implementing ISO Standards • Outline of ISO 14971 • Key Changes under EN ISO 14971:2009 • Final Comments
Understanding need for Risk Management
Advances in TECHNOLOGY bring increases in RISK to both pa?ents and users
Classic example: Radia?on Treatment for cancer
BENEFIT to pa?ent outweighs RISK to which the pa?ent and the user is exposed
Understanding need for Risk Management
Understanding need for Risk Management 25 MeV Radiotherapy Machine X-‐rays & Electrons
200 rad (e) or 25000 rad(x)
Error on selec?on, SoUware bug, Beam not reset
Pa?ent received 25000 MeV , “malfunc?on 54 displayed “
Technician fired 2 more ?mes
4 Months later pa?ent died
“Captain Kirk forgot to put his phaser on stun”
Implementing ISO Standards
Implementing ISO Standards
• For the EU (and CE Marking) manufacturers have until 31 Mar 2010 to comply before cessation of the 2000 version
• Some Notified Bodies are offering registration certificates to ISO 14971
• EN ISO 14971:2009 identical to ISO 14971:2007 but includes annexes that show how it meets the essential requirements of AIMD, MDD and IVDD
had
Outline of ISO 14971
• Risk Management Objectives • Risk Management Process
– Risk Analysis – Risk Evaluation – Risk Control – Overall Residual Risk – Risk Management Report – Production & Post Production
• Annexes
Risk Management Objectives • Management Policies • Documented Procedures • Tasks
– Analysis – Evaluation – Risk control
Enable medical device manufacturers to iden6fy all foreseeable hazards and hazardous situa6ons relevant to a par6cular device and demonstrate with documented evidence that related risk has been reduced to an acceptable level.
Risk Management Process
• Interactive with design, engineering, production, purchasing, sales, quality assurance and regulatory affairs
• Perpetual process, beginning with design & development and continuing through to the use of devices, where user feedback reveals actual performance
Interactive
• ISO 13485:2003 Medical devices. Quality management systems. Requirements for regulatory purposes
– Paragraph 7.1: Planning of Product Realization – “The organization shall establish documented
requirements for Risk Management throughout product realization. Records arising from Risk Management shall be maintained”
– (See ISO 14971 for guidance related to Risk Management)
Interactive
• ISO 10993-1:2009 Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process – Describes
• general principles • general categorization • Evaluation • identification of gaps • identification of additional data sets • the assessment of the biological safety
Interactive
• BS EN 62366:2008 Medical devices. Application of usability engineering to medical devices – Specifies process to
• Analyze • Specify • Design • Verify • Validate
It can be used to iden6fy, but does not assess or
mi6gate, risks associated with abnormal use.
Perpetual
• Clause 1 – Scope • Clause 2 – Terms & Definitions • Clause 3 – General Requirements for Risk Management • Clause 4 – Risk Analysis • Clause 5 – Risk Evaluation • Clause 6 – Risk Control • Clause 7 – Evaluation of overall residual risks
acceptability • Clause 8 – Risk Management Report • Clause 9 – Production & Post Production Information
Perpetual • Annex A – Rationale for requirements • Annex B – Overview of the risk management process for medical devices • Annex C – Questions that can be used to identify medical device
characteristics that could impact on safety • Annex D – Risk Concepts applied to medical devices • Annex E – Examples of hazards, foreseeable sequences of events and
hazardous situations • Annex F – Risk Management Plan • Annex G – Information of Risk Management Techniques • Annex H – Guidance on risk management for in-vitro diagnostic
medical devices • Annex I – Guidance on risk analysis process for biological hazards • Annex J – Information for safety and information about residual risk • Annex ZA/ZB/ZC – Relationship between the standard and the
Essential Requirements of the MDD / AIMDD / IVD
Management Responsibilities
• Top Management must show its commitment by: – Providing adequate resources – Assigning qualified personnel – Defining & documenting the policy for
determining risk acceptability – Conduct internal audits on risk management
activities
Risk Management Team
• Qualification of Personnel: Personnel must have knowledge and experience – How the device works and its intended use – Knowledge of the technologies involved – How the device is manufactured and
constructed – Familiar in risk management techniques
Records of qualifica?ons must be kept as part of the Risk Management File!
Risk Management Plan
• Contents of a Risk Management Plan: – Scope of planned risk activities – Identify & describe the medical device – Define responsibilities & authorities – Requirement for review of risk management
activities – Verification Activities – Define Risk Acceptance Criteria
Manufacturers shall establish and document a risk management plan for a par5cular device
Risk Management Plan
• So how detailed does it need to be? – “commensurate with the level of risk
associated with the medical device” • Annex F for guidance • Forms part of the risk management file
Risk Analysis
• Will people use the device correctly? • Where in the production process might
variations impact the conformity of the device to its intended product specifications?
• Risks are weighted to consider its probability of occurrence and the seriousness of its potential effects.
Iden6fying foreseeable hazardous situa6ons
Risk Analysis Records
• Must include: – description and ID for device analyzed – who conducted the analysis – scope and date
• Forms a part of the Risk Management File
Risk Analysis Methods Events Causes Hazardous
Situa?ons
Accident / Incident / Harm
Primary Cause A
Event 1
Event 2
Primary Cause B Event 3
PHA -‐ Preliminary Hazard Analysis FTA – Fault Tree Analysis
FMEA -‐ Failure Mode and Effects Analysis Ishikawa -‐ Cause and Effect (Fish Bone Diagram)
HACCP -‐ Hazard And Cri?cal Control Point HAZOP -‐ Hazard And Operability Study
Accident / Incident / Harm
Man Machine
Material Method
Risk Evaluation
• Estimated risks are compared to the risk acceptability criteria (Risk Management Plan)
• Comparison determines appropriate level of risk reduction if necessary
• For each hazard determine whether the estimated risk is so low, reduction is not required
Risk Control
• Reducing risk through available control measures.
• Must be consistent with the state-of-the art – a measure that naturally shifts as science progresses
Inherent Safety by Design
(GHTF-‐SG3/N15R8)
Protec?ve Measures in the device or its
manufacture
Provide Informa?on for safety, such as warnings in IFU etc.
Overall Residual Risk
• Risk / Benefit Analysis – If you have any outstanding unacceptable
risks you need to establish if the benefits of the device / therapy outweigh the risks • Reviews • Clinical Evaluation
• Essential Requirements: – 1, 2, 4, 6, 7, 8.6, 9.2, 9.3, 11.2, 11.3, 11.4,
11.5, 12.1,12.5, 12.6, 12.7, 12.8, 13.5
Risk Management Report
• “Prior to release for commercial distribution the manufacturer shall carry out a review of the risk management process”: – the RMP has been implemented – the overall residual risk is acceptable – appropriate methods are in place to gather
production & post production data • Results of the review must be recorded in the
RM Report • Person with appropriate authority shall
conduct the review
Production & Post Production
• Must ensure that appropriate methods are in place to gather: – Production Data – Inspection Data – Design Changes – Post Production Data
Production & Post Production
• Production Experience – Non-conformance (rejects, re-work etc) – Scale up issues
• Design Changes – Drawings, Materials, Methods, Packaging,
Sterilization, optimization studies • Post Market Surveillance
– Active surveillance – Complaints
• CAPA
Maintaining Risk Management File
• Continue to monitor throughout entire lifecycle – Risks continue to remain acceptable – See if any new hazards or risks are identified -
especially CAPA – Verify or review assumptions & scoring values – Effect of State of the Art advances – Competitor products experience
Key Changes of EN ISO 14971:2009
• Phase of the Life Cycle – 7.1 and 7.3.2 address the need to examine
different stages of the product, including manufacture, product release, in-use errors and disposal
Example – HDR Brachytherapy • HDR Ir 192 inserted into catheters • Wire broke in one of catheters • Catheter disposed of in 4 days • 6 Days in storage • Detected at medical waste incinerator
More than 90 people accidently irradiated
Key Changes of EN ISO 14971:2009
• Type of Hazard – This version of the standard distinguishes
between hazard (potential source of harm) and hazardous situation (circumstances in which people, property, or the environment are exposed to one or more hazards).
– The risks must be estimated for both.
Key Changes of EN ISO 14971:2009
• Confirmation of Standard Applicability – This standard is now applicable to all medical
devices, including In Vitro Diagnostic Devices (IVDs), for which a specific annex (H) was added about the identification of hazards. • No direct risk - indirect risks
– The extent to which the diagnosis relies on the analytical result (i.e., contribution to the medical decision)
Final Comments
• FMEA, whether Design (DFMEA), Process (PFMEA) or Use (UFMEA) is a risk management technique mentioned by the standard but it does not alone address all the requirements of EN ISO 14971
• Documentation is often missing to demonstrate compliance to EN ISO 14971
• Start by performing a Gap Analysis
Thank You
John Beasley Owner & Sr. Consultant MedTech Review, LLC
www.medtechreview.com Email: john@medtechreview.com
SKYPE: medtechreview