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Medical Device Risk Management ISO 14971: Dan O'Leary President Ombu Enterprises, LLC
Medical Device Risk Management ISO 14971: Dan O'Leary President Ombu Enterprises, LLC
ISO 14971
Dan O’Leary
President
Ombu Enterprises, LLC
Dan@OmbuEnterprises.com
www.OmbuEnterprises.com
OMBU
ENTERPRISES, LLC
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Risk Management - ISO 14971 Ombu Enterprises, LLC 3
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Risk
Risk Production
Production & &
Residual
Residual Risk
Risk
Risk
Risk Analysis
Analysis Risk
Risk Evaluation
Evaluation Risk
Risk Control
Control Management
Management Post-production
Post-production
Evaluation
Evaluation
Clause
Clause 44 Clause
Clause 55 Clause
Clause 66 Report
Report Information
Information
Clause
Clause 77 Clause
Clause 88 Clause
Clause 99
Risk assessment
Risk management
Risk
Risk Estimated
Estimated
Risk Option
Option Implementation
Implementation Residual
Residual Risk
Risk New
New
reduction Analysis
Analysis (6.3)
(6.3) Risk
Risk Benefit
Benefit Risks
Risks
required? Yes (6.2)
(6.2) (6.4)
(6.4) (6.5)
(6.5) (6.6)
(6.6)
No
Completeness
Completeness
Check
Check
(6.7)
(6.7)
Overall
Overall
Risk
Risk
(7)
(7)
• In the US it is
– A Class I device
– For infant use, it requires a 510(k)
Clause 2
Hazard
Hazard
Hazardous
Hazardous Severity
Severity of
of
Harm
Harm
Situation
Situation the
the Harm
Harm
Risk
Risk
Probability
Probability of
of
Sequence
Sequence Occurrence
Occurrence
of
of Events
Events of
of the
the Harm
Harm
Discussion
The manufacturer identifies device hazards. The standard creates a potential
2×2 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 Known Foreseeable
• Rupture
Normal
• Improper reuse
Condition
Fault
Condition
Discussion
A hazard is potential, and doesn’t 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 manufacturer’s instructions
• Rupture
• Incorrect seal strength
• Improper reuse
• Reuse of a single use device, contrary to manufacturer’s instructions
Risk Management - ISO 14971 Ombu Enterprises, LLC 33
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
Discussion
When harm occurs, it can have different levels of seriousness. Severity is the
measure of seriousness of the harm.
Example
• Thermal Burn Example
• First degree These instance must be
• Second degree converted to the manufacturer’s
• Third degree description of severity. This is
• Chemical Burn often a qualitative approach.
• Skin
• Eyes
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 Æ Very Low
Thermal burn resulting from use of a “blanket” Æ Low
Thermal burn resulting from a burst package Æ Very Low
Chemical burn resulting from a burst package Æ Very Low
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 Severity of Harm
identify Validation
Validation
Warehouse
Warehouse
• Examples include:
– Reviewer
– Approval authority
– Expert
– Verification specialist
The concept of risk starts with continuous Probability and Severity dividing the
Risk area into regions.
Increasing Probability
Unacceptable
As low as
reasonably
practicable
Acceptable
Increasing Severity
Severity Levels
Negligible Minor Serious Critical Catastrophic
Frequent R2 R2 R3 R3 R3
Probable R2 R2 R2 R2 R3
Probability
Occasional R2 R2 R2 R2 R3
Levels
Remote R1 R1 R2 R2 R3
Improbable R1 R1 R2 R2 R3
Clause 4
Clause 5
Risk
Risk Estimated
Estimated
Risk Option
Option Implementation
Implementation Residual
Residual Risk
Risk New
New
reduction Analysis
Analysis (6.3)
(6.3) Risk
Risk Benefit
Benefit Risks
Risks
required? Yes (6.2)
(6.2) (6.4)
(6.4) (6.5)
(6.5) (6.6)
(6.6)
No
Completeness
Completeness
Check
Check
(6.7)
(6.7)
Overall
Overall
Risk evaluation (Clause 5) Risk
Risk
for each identified hazardous (7)
(7)
situation
Clause 6
No
No
Risk analysis
2nd Phase Identify hazards in normal use or foreseeable misuse
Estimate the for each identified hazard
• 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)
OR
The output event occurs when at least one
of the input events occur