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  • 1.  Content Deviations of Annex ZA, EN/ISO 14971:2012

    This message was posted by a user wishing to remain anonymous
    Posted 06-Oct-2017 09:26
    This message was posted by a user wishing to remain anonymous

    I am interested in getting feedback on your experience with NB audits, specifically regarding content deviation #4 of the EN standard and how your NB is interpreting this requirement. It states that each individual risk as well as all risks combined require a Risk Benefit Analysis (RBA). In October of 2014, a consensus paper was published by the NB Recommendation Group that seemed to soften this requirement somewhat. It states the following:
    "at the end of the risk management process, the mfr shall perform a RBA for individual risks that are not acceptable according to the criteria explained in content deviation #2 and for which further risk reduction is not possible. In any case, the mfr shall perform an overall RBA considering all individual risks to provide a rationale for overall risk acceptance." ​​
    How do you interpret this and what experience do you have with your NBs?

    Thanks in advance.


  • 2.  RE: Content Deviations of Annex ZA, EN/ISO 14971:2012

    Posted 08-Oct-2017 12:11

    A few comments from my end :

     

    First of all, in direct relation to your question about a Notified Body's position on the clauses of the Z-Annexes of EN ISO 14971:2012 and the NBRG Consensus Paper of two years later (October 2014). From two of our auditors (that I both value very much for their expertise, their intelligent approach to auditing, and (above all) their continuous attention for the safety and performance of medical devices) :

     

    Regarding the publication of EN ISO 14971:2012, I remember one of them stating about the impact of the Z-Annexes : "it means more paper work, but most likely no design changes".

     

    And regarding an evaluation of the overall risk/benefit ratio for one of our devices, another auditor thought we had somewhat over-estimated the residual risk.

     

    For me, this Forum post is pretty much reflecting the debate that seems to be going on for a long time now on how to make the best possible use of Risk Management as a tool to help ensure the responsible use of medical devices, i.e., to ensure they have a favorable Benefit-to-Risk ratio. One the one hand, many of the current (IEC and ISO) standards and (FDA) guidance documents emphasis the notion of "risk management" as a means of contributing to device safety. On the other hand, doubts have been expressed whether Risk Management is a tool that will allow for consistent decision making and whether more Risk Management leads to safer devices or just more paperwork.

     

    To fuel that debate a little bit more :

     

    I recommend reading this AAMI blogpost : https://aamiblog.org/2016/08/23/william-hyman-do-we-know-how-to-evaluate-and-compare-risks-and-benefits/ .

     

    I think the continuous issuance of documents of a regulatory nature demonstrates that we are all still trying to achieve a better consensus and convergence regarding what constitutes useful Risk Management for medical devices:

    • EN 1441 (published in the mid-1990s)
    • ISO 14971:2007 (first published in 1998 as ISO 14971-1, thereafter as ISO 14971:2000)
    • EN ISO 14971:2012 (with its Z-Annexes)
    • ISO 24971:2013 (guidance on ISO 14971:2012)
    • NBRG ("Interim NBMed Consensus Paper"), 2014)
    • AAMI White Paper "Risk Principles and Medical Devices: A Postmarket Perspective", 2015

    And so on … .

     

    Whereas ISO 14971 contains a definition of "risk", it does not contain a definition of "benefit". The absence thereof does not seem helpful, if we want to ensure consistency when performing "benefit-risk-analysis". I have also not found a definition of "benefit" in the GHTF-publications about "Clinical Evidence". The above cited AAMI White Paper is the first publication I came across with an attempted definition of "benefit" by referring to ISO 16439: 2014 « Information and documentation -- Methods and procedures for assessing the impact of libraries" (yes, libraries !). Now the recently published MDR (EU/2017/745) finally contains definitions of "benefit-risk determination" (Article 2, definition 23) and "clinical benefit" (Article 2, definition 53), so let's move forward with those.

     

    And I could easily fuel this debate with more …. . And you ?

     

    Just to end my contribution : all we do must always first and foremost serve the interest of the patient, of the health care professionals caring for the patient, and of public health in general. We also have a legitimate purpose in ensure the good (business) health of the organizations we work for. Filling binders with paper or spreadsheets with numbers that do not serve these interests should have no place in this world.



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    Ary Saaman
    Director, Regulatory Affairs
    Debiotech S.A.
    Lausanne
    Switzerland
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  • 3.  RE: Content Deviations of Annex ZA, EN/ISO 14971:2012

    Posted 10-Oct-2017 03:09
    ​Hi,

    as the new revison came effective, all NBs struggled to handle it during tech file Review and conducting on-site Audits.

    Everything what Ary already mentioned should be seen/ taken as a Basis to build on.

    In my experience with different NBs, still they interpretate the requirements a bit different. Especially when it Comes down to the discussion where to start identifying risks and where to "stop".

    Anyway, the mentioned sources related to guidance documents and for sure showing during an Audit that your Company is aware of the most common ones, helps to demonstrate you are really looking for risk reduction/ elemination as far as possible.

    Coming back to the RBA, which is required for each/ overall risks - that is not easy to answer in my opinion. But as an example you have a device which has couple of remaining risks rated as "unacceptable" you may back up the benefit with scientific data. Meaning to compare and Show what might happen, if the Treatment will not take place. If the result of a Treatment with this mode of Action causes side-effects but still supports at the end the healing efforts, it is reasonable to still use the device.

    I hope that helps a bit.

    Regards, André

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    André Hülsbusch
    Regional QA/RA Specialist, Central Europe

    Germany
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  • 4.  RE: Content Deviations of Annex ZA, EN/ISO 14971:2012

    Posted 11-Oct-2017 06:19
    Those familiar with the current work of ISO TC210/IEC 62A JWG1....are these questions being addressed in the revision currently being worked??

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    Regards,
    Mark Swanson, ASQ CBA, CMQ/OE, CQE MBA
    Becker MN
    United States
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  • 5.  RE: Content Deviations of Annex ZA, EN/ISO 14971:2012

    Posted 12-Oct-2017 22:01
    The question being discussed here is unique to Europe.  EN ISO 14971:2012 is a regional standard and as such has added informative annexes to indicate what additional steps, beyond compliance with the standard, may be necessary to meet regulatory requirements.  The new Medical Device Regulation addresses risk-benefit analysis for the EU and may be a  better source for gaining future European approval for devices.

    ISO 14971:2007 is an international standard and currently requires risk-benefit analysis for risks that are unacceptable after all risk controls are implemented, and additionally for any Overall Residual Risks that are unacceptable.  The one thing currently being discussed for the next version of the international standard is a definition of "benefit", which does not appear in standards, and may be required to clarify risk-benefit analysis.  There seems to be no consensus on what risk-benefit analysis might be, so a definition may help.

    Requirements that are unique to a region or a country, are not typically added to an international standard when other countries have differing requirements.  International standards are consensus standards and are voluntary and are not law or regulation. There is currently no consensus in going beyond the current requirements in the standard to include an atypical regional requirement.

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    Edwin Bills RAC, MA
    Member, ISO TC 210 JWG1, medical device risk
    Edwin Bills Consultant
    Overland Park KS
    United States
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