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  • 1.  IEC 82304 - Health software

    Posted 17-Jul-2018 05:53
    Hi

    I would be very grateful for any help with this query regarding the applicability of  IEC 82304 to one of our products i.e. an Electrical Muscle Stimulator that incorporates an App (Android and iOS).

    The product is FDA cleared as a Class II device and our software development complies with IEC 62304.
    My question is as to whether IEC 82304 is applicable to this product or similar future products.
    One reading of the standard suggests that our App is "software as part of a medical device" and is outside the scope of IEC 82304.
    However as the device is being controlled by an a standalone App on a mobile device it may bring us into the scope of IEC 82304.
    Any help with this is very welcome.

    regards
    Mike



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    Mike Kilkelly
    Quality Manager
    Galway
    Ireland
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  • 2.  RE: IEC 82304 - Health software

    Posted 17-Jul-2018 07:08
    If the app is to control the device (and only does this), it would be outside IEC 82304-1.

    IEC 82304-1 is the product standard for standalone software (including Software as Medical Device). IN the case of your device, the "product safety" standard is IEC 60601.

    Scope of 82304-1is:

    This Part of 82304 applies to the SAFETY and SECURITY of HEALTH SOFTWARE PRODUCTS designed to operate on general computing platforms and intended to be placed on the market without dedicated hardware, and its primary focus is on the requirements for MANUFACTURERS.



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    Marcelo Antunes
    Regulatory Strategy Consultant
    São Paulo
    Brazil
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  • 3.  RE: IEC 82304 - Health software

    Posted 17-Jul-2018 07:53
    Hello Marcelo,
    Thank you so much for your reply. The App is used to control the device primarily, but also sends data to and from the user (of a non-medical nature) to motivate them to use the device and as a marketing tool. Does this have any impact on the applicability of IEC 82304?

    regards
    Mike

    ------------------------------
    Mike Kilkelly
    Quality Manager
    Galway
    Ireland
    ------------------------------



  • 4.  RE: IEC 82304 - Health software

    Posted 17-Jul-2018 12:07
    If it sends data of a non-medical nature, it won't in principle even be a health software. 

    Do you have any need to use 82304-1? If not, I would not bother, and would control everything under 62304 if the case.

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    Marcelo Antunes
    Regulatory Strategy Consultant
    São Paulo
    Brazil
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  • 5.  RE: IEC 82304 - Health software

    Posted 18-Jul-2018 03:25
    Thank you again for your help. Much appreciated.
    regards
    Mike

    ------------------------------
    Mike Kilkelly
    Quality Manager
    Galway
    Ireland
    ------------------------------