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Risk Management within Medical Devices
MScSED - Module: MCT626
Researcher: Niamh St John Lynch
Advisor: Dr Owen Molloy
Date: 04 May 2016
Experience
Qualifications / Experience
Quality Manager
 J&J, Boston Scientific, Beckman
Coulter / Danaher, Merit Medical,
Bioniche / Mylan, Phardiag /
Menarini Group
20 Years in IT, Pharmaceutical
and Medical Devices
BSc Cognitive Science (Hons)
MSc Neuropharmacology
Certified to ISO 14971:2016
Certified to ISO 13485:2016
Certified to GMP/GDP/RP
Niamh Lynch (nee St John)
Contents
Background
Definitions
Introduction
Problem Overview
Research Question
Literature Review
Research Methodology
Conclusion
Requirements Relevance?
Background
Risk management is
central to all Medical
Device manufacturers and
with the changes to ISO
14971:2012 and more
recently ISO 13485:2016
All Medical Device
companies need to
review their approach
ISO 14971 Risk Management
Risk Plan
Risk
Analysis
Risk
Evaluation
Risk
Control
Effectivene
ss
Monitoring
Risk
Acceptabilit
y
Risk Report
Risk Benefit
Analysis
ISO
14971:2012
Risk Plan
Risk
Analysis
Risk
Evaluation
Risk
Control
Effectivene
ss
monitoring
of controls
Risk Report
ISO
14971:2007/20
09
Risk
Analysis
Risk
Evaluation
Risk
Control
ISO
14971:2001
Risk
Assessment
Only
ISO 14971-
1:1998
21 CFR Part
820 required
for device
modification
includes
Design
Control and
Validation
including
labelling and
packaging
QSR 1996
Medical
Device
Amendment
Class III
medical
devices to
go through
PMA
FDA GMP
1976
Definition of Risk
“the combination of the probability of
occurrence of harm and the severity
of that harm” Q9 (2006)
Definition of Risk Management
“the systematic application of quality
management policies, procedures, and
practices to the tasks of assessing,
controlling, communicating, and reviewing
risk”, Q9 (2006).
Why Perform Risk Management?
Reduce Risk to Patients
Reduce Risk to Business reduce cost
Risk management attempts to identify, measure,
mitigate or control risks, which as we defined above,
are the opportunity for loss or injury in order to
protect the public from harm arising from new
medical devices or changes to existing medical
devices
What is a Medical Device?
 Medical Device - “Any instrument, apparatus, implement, machine,
appliance, implant, in vitro reagent or calibrator, software, material or
other similar or related article, intended by the manufacturer to be
used, alone or in combination for human beings for one or more of
the specific purpose(s) of the following:
 Diagnosis, prevention, monitoring, treatment or alleviation of
disease;
 Diagnosis, monitoring, treatment, alleviation of or compensation for
an injury;
 Investigation, replacement, modification, or support of the anatomy
or of a physiological process;
 Supporting or sustaining life
 Control of conception
 Disinfection of medical devices
 Providing information for medical purposes by means of in vitro
examination of specimens derived from the human body; and which
does not achieve its primary intended action or on the human body
by pharmacological, immunological or metabolic means, but which
Problem Overview
 Patient Harm, Injury and Death continue to
occur
 Product Recalls and Failures continue
 Risk Management System Requirements
require ‘robust’ risk techniques
 Risk Management Systems continue to be
difficult to maintain
 Risk Management Systems are for the most
part, not integrated within it’s QMS
 FMEA is main tool used in Medical Devices –
not robust enough to identify all risk
Literature Review
Lit Review Demonstrates:
FMEA is the tool of choice for
manufacturing, manufacturing services and
suppliers to the industry.
Ref. Dumbrique, R. (2010). Implementation of
Risk Management in the Medical Device
Industry. Master’s Theses Paper 3855. San
Jose State University. SJSU Scholar Works
Research Question
Two key questions :
Do Medical Device companies continue to rely
heavily on Failure Modes and Effects Analysis
(FMEA) as the primary tool for risk assessment
(ref. Lopez, et al (2010), Kamm (2005) and Lu Gan (2012)?
Does the FMEA adequately support Risk
Management throughout the full lifecycle of the
Product Development Process to meet relevant
Medical Device standards, ISO 13485:2016 and
ISO 14971:2012?
Failure Modes Effects Analysis
FMEA Limitations
Some of the limitations of the FMEA listed by McDowall
(2005 and Gan, 2011) include:
Components can be tedious and difficult to analyze
when part of complex systems
Compound failure effects cannot be analyzed
Cost and time consuming, unless carefully controlled
Successful completion requires expertise, experience
and good team skills
Incorporating all possible factors influencing the
system, such as human errors can result in lengthy
analysis, difficult to manage.
Data redundancies can be a problem and is time
consuming
How Can Technology Help?
A software risk management tool is
proposed to overcome these significant
problems within the industry.
The aim for the software tool suggested is
to streamline the process, create
efficiencies within the Quality
Management System (QMS), reduce real
risk to the business and ensure
compliance to the relevant regulatory
standards and authorities.
Research Methodology
A combination of methodologies are required
to conduct this research:
Content Analysis
Literature Review
Data Surveys for current status
Experimental Research & Development relevant
architectural design
Useful Websites
 ASQ: http://www.asq.org
 FDA: http://www.fda.gov ; http://www.21cfrpart11.com
 ICH: http://www.ich.org
 IEE: http://www.iee.org
 ISPE: http://www.ispe.org/gamp/
 BSI: http://www.bsi-global.com
 NIST: http://csrc.nist.gov/publications/nistpubs/index.html
 WHO: http://www.WHO.org
 EU: http://ec.europa.eu
 GHTF: http://ghtf.org now http://www.imdrf.org
Q&A
Go Raith Maith Agat
Thank You

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Risk Management Research 2016 ISO 14971:2016

  • 1. Risk Management within Medical Devices MScSED - Module: MCT626 Researcher: Niamh St John Lynch Advisor: Dr Owen Molloy Date: 04 May 2016
  • 2. Experience Qualifications / Experience Quality Manager  J&J, Boston Scientific, Beckman Coulter / Danaher, Merit Medical, Bioniche / Mylan, Phardiag / Menarini Group 20 Years in IT, Pharmaceutical and Medical Devices BSc Cognitive Science (Hons) MSc Neuropharmacology Certified to ISO 14971:2016 Certified to ISO 13485:2016 Certified to GMP/GDP/RP Niamh Lynch (nee St John)
  • 4. Requirements Relevance? Background Risk management is central to all Medical Device manufacturers and with the changes to ISO 14971:2012 and more recently ISO 13485:2016 All Medical Device companies need to review their approach
  • 5. ISO 14971 Risk Management Risk Plan Risk Analysis Risk Evaluation Risk Control Effectivene ss Monitoring Risk Acceptabilit y Risk Report Risk Benefit Analysis ISO 14971:2012 Risk Plan Risk Analysis Risk Evaluation Risk Control Effectivene ss monitoring of controls Risk Report ISO 14971:2007/20 09 Risk Analysis Risk Evaluation Risk Control ISO 14971:2001 Risk Assessment Only ISO 14971- 1:1998 21 CFR Part 820 required for device modification includes Design Control and Validation including labelling and packaging QSR 1996 Medical Device Amendment Class III medical devices to go through PMA FDA GMP 1976
  • 6. Definition of Risk “the combination of the probability of occurrence of harm and the severity of that harm” Q9 (2006)
  • 7. Definition of Risk Management “the systematic application of quality management policies, procedures, and practices to the tasks of assessing, controlling, communicating, and reviewing risk”, Q9 (2006).
  • 8. Why Perform Risk Management? Reduce Risk to Patients Reduce Risk to Business reduce cost Risk management attempts to identify, measure, mitigate or control risks, which as we defined above, are the opportunity for loss or injury in order to protect the public from harm arising from new medical devices or changes to existing medical devices
  • 9. What is a Medical Device?  Medical Device - “Any instrument, apparatus, implement, machine, appliance, implant, in vitro reagent or calibrator, software, material or other similar or related article, intended by the manufacturer to be used, alone or in combination for human beings for one or more of the specific purpose(s) of the following:  Diagnosis, prevention, monitoring, treatment or alleviation of disease;  Diagnosis, monitoring, treatment, alleviation of or compensation for an injury;  Investigation, replacement, modification, or support of the anatomy or of a physiological process;  Supporting or sustaining life  Control of conception  Disinfection of medical devices  Providing information for medical purposes by means of in vitro examination of specimens derived from the human body; and which does not achieve its primary intended action or on the human body by pharmacological, immunological or metabolic means, but which
  • 10. Problem Overview  Patient Harm, Injury and Death continue to occur  Product Recalls and Failures continue  Risk Management System Requirements require ‘robust’ risk techniques  Risk Management Systems continue to be difficult to maintain  Risk Management Systems are for the most part, not integrated within it’s QMS  FMEA is main tool used in Medical Devices – not robust enough to identify all risk
  • 11. Literature Review Lit Review Demonstrates: FMEA is the tool of choice for manufacturing, manufacturing services and suppliers to the industry. Ref. Dumbrique, R. (2010). Implementation of Risk Management in the Medical Device Industry. Master’s Theses Paper 3855. San Jose State University. SJSU Scholar Works
  • 12. Research Question Two key questions : Do Medical Device companies continue to rely heavily on Failure Modes and Effects Analysis (FMEA) as the primary tool for risk assessment (ref. Lopez, et al (2010), Kamm (2005) and Lu Gan (2012)? Does the FMEA adequately support Risk Management throughout the full lifecycle of the Product Development Process to meet relevant Medical Device standards, ISO 13485:2016 and ISO 14971:2012?
  • 14. FMEA Limitations Some of the limitations of the FMEA listed by McDowall (2005 and Gan, 2011) include: Components can be tedious and difficult to analyze when part of complex systems Compound failure effects cannot be analyzed Cost and time consuming, unless carefully controlled Successful completion requires expertise, experience and good team skills Incorporating all possible factors influencing the system, such as human errors can result in lengthy analysis, difficult to manage. Data redundancies can be a problem and is time consuming
  • 15. How Can Technology Help? A software risk management tool is proposed to overcome these significant problems within the industry. The aim for the software tool suggested is to streamline the process, create efficiencies within the Quality Management System (QMS), reduce real risk to the business and ensure compliance to the relevant regulatory standards and authorities.
  • 16. Research Methodology A combination of methodologies are required to conduct this research: Content Analysis Literature Review Data Surveys for current status Experimental Research & Development relevant architectural design
  • 17. Useful Websites  ASQ: http://www.asq.org  FDA: http://www.fda.gov ; http://www.21cfrpart11.com  ICH: http://www.ich.org  IEE: http://www.iee.org  ISPE: http://www.ispe.org/gamp/  BSI: http://www.bsi-global.com  NIST: http://csrc.nist.gov/publications/nistpubs/index.html  WHO: http://www.WHO.org  EU: http://ec.europa.eu  GHTF: http://ghtf.org now http://www.imdrf.org
  • 18. Q&A Go Raith Maith Agat Thank You

Notas do Editor

  1. Luan, J. (2002). Data Mining and Knowledge Management in Higher Education-Potential Applications.