July 29, 2021 FDA’s 21 CFR §820.72 Metrology Requirements vs. Test Method / Process Validation My experience has been that FDA views a test method as a process that produces an output. And if such output can’t be fully verified, then it must be validated. Since FDA’s 21 CFR §820.72 is not generally related […]
<h1 class="entry-title">Category: ISO QMS</h1>
ISO 13485 QMS Planning vs. Quality Plans
July 19, 2021 ISO 13485 QMS Planning vs. Quality Plans I think it’s important to remember that the general quality management system planning and set-up called for by ISO 13485 clause 5.4.2(a) is fundamentally distinct from clause 7.1’s product/project/object/output-oriented planning. If they were the same, then ISO TC/210 would not have separated and distinguished […]
Risks from an Inadequate Development Process for Software
July 19, 2021 Risks from an Inadequate Development Process for Software The most fundamental reason for medical device design and development controls (e.g., ISO 13485 clause 7.3; the U.S. FDA’s 21 CFR 820.30, etc.) is to control risks that come from an inadequate development process. That fact is unequivocally true and stands in stark contrast to […]
ISO 14971 Estimating Probability of Occurrence of Harm
July 13, 2021 ISO 14971 Estimating Probability of Occurrence of Harm Based on the aforesaid flexibility (see my earlier blog post) allowed by ISO 14971 (e.g., see the third paragraph of ISO/TR 24971 section 5.5.2) for how to estimate probability of occurrence of harm, one might employ a variety of probability expressions. For example, […]
ISO 14971 Probability of Occurrence of Harm
July 12, 2021 ISO 14971 Probability of Occurrence of Harm When tackling the estimation of probability of occurrence of harm during medical device risk management, I think it is important to remember that there is no one-size-fits-all approach. Instead, each manufacturer’s approach needs to be derived and appropriate based on the nature and complexity […]
FDA & ISO DMR/MDF vs. “Design Output”
April 1, 2019 FDA & ISO DMR/MDF vs. “Design Output” Remember that the DMR is intrinsically linked to the design control process. The DMR is by formal definition a design output (see my preceding blog post). It unequivocally lives and breathes in direct relationship to the design control process. A properly-maintained DMR never becomes decoupled […]