I agree with Dan. I see so many cases where a do over would be better than a patch. This is true for audit/inspection responses on the entire quality system, not just a risk management system.
And though the EN ISO 14971:2019 does not include Z Annxes, if you have a copy of ISO FDIS 14971:2019, you will find purposed Z Annexes that were discarded due to the lack of a Harmonization Request for the new standard. They are useful as a starting point to find the differences between the entire MDR (and not just Annex I). The forthcoming ISO TR 24971:2020 will give you a lot of help in your quest on improving risk management in your company. Until this comes out, I refer you to Annex A of ISO 14971:2019 which is the rationale for the requirements in the standard, and provides necessary background for a deeper understanding of the requirements in the standard and will help you develop a risk management system that meets regulatory requirements and helps in taking safer medical devices to the market.
I like to start product development with the idea that I am going to be the first patient to use the device. This perspective produces better results than just meeting a schedule. You also need to start risk management activities at clinical trials or marketing research and not at design input, that is too late. You should also be sure to incorporate. The use of standards in risk management as outlined in ISO TR 24971:2013 or more importantly ISO TR 24971:2020 when it is released. It will save you time and effort, still providing a state of the art product with excellent risk management.
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Edwin Bills MEd, CQA, RAC, BSc, CQE, ASQ
Principal Consultant
Overland Park KS
United States
elb@edwinbillsconsultant.com------------------------------
Original Message:
Sent: 07-Jan-2020 09:58
From: Dan O'Leary
Subject: ISO 14971:2007 and ISO 14971:2019 gap analysis
My recommendation is not to do a gap analysis.
This is a golden opportunity to start with fresh and create an efficient and effective risk management system.
I work with a lot of companies on risk management and I have never seen a simple or correct implementation following the standard. The propensity is to make the implementation overly complicated. The standard is a simple and straight forward process.
One company put their estimates for the market size and market share in the risk management plan.
One company believed the frequency of occurrence of harm depends on sales volume and included complicated tables to implement it.
Many companies try to calculate P1 and P2, which is impossible.
Another frequent problem is the risk management report. One company recently gave me a 150-page Risk Management Report when two pages would have been sufficient. They had not implemented the change from ISO 14971:2000 to ISO 14971:2007.
EN ISO 14971:2019 supersedes EN ISO 14971:2012, so this is the opportunity to fix all the incorrect things your NB required as they misunderstood the content deviations.
Note however, that EN ISO 14971:2019 does not fully align with the EU-MDR Annex I.
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Dan O'Leary CQA, CQE
Swanzey NH
United States
Original Message:
Sent: 06-Jan-2020 12:53
From: Anonymous Member
Subject: ISO 14971:2007 and ISO 14971:2019 gap analysis
This message was posted by a user wishing to remain anonymous
Hi everyone,
Does anyone have a gap analysis between the two versions of the standard? Thanks.