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Residual risks vs side effects

  • 1.  Residual risks vs side effects

    This message was posted by a user wishing to remain anonymous
    Posted 28-Aug-2023 09:05
    This message was posted by a user wishing to remain anonymous

    Hi,

    Could someone clarify the difference between Residual risks and side effects in the context of the MDR ? or do they mean the same ?

    thanks



  • 2.  RE: Residual risks vs side effects

    Posted 28-Aug-2023 09:21

    Residual risks come from EN ISO 14971:2019/A11:2021. They are the risks remaining after implementing the risk control measures.

    Side effects are unintended results of using the device. Side effects are residual risks, but not all residual risks are side effects.

    Because of the EU-MDR I recommend that in the risk management hazard analysis include a column for both residual risks and side effects. While side effects are residual risks, it is more convenient to break them out separately.

    Under the EU-MDR, disclose all residual risks (including side effects) in the limitations, contra-indications, precautions, or warnings section of the information supplied by the manufacturer.

    Use the information on side effects in the Article 88 Trend reporting.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: Residual risks vs side effects

    Posted 29-Aug-2023 04:51

    Good day Anon,

    Concur with Dan that side effects are residual risks, but not all residual risks are side effects.  Definitely either put a "notation" of a residual risk being a side effect or potential side effect or keep a separate list somewhere in the risk summary report of side effects.  Think of residual risks as something that could happen if something was done wrong or the hazardous situation decided to pop its head up.  Whereas a side effect is usually something which can often happen with a quite small percent of the population, i.e. a good example is an allergic reaction to some material.  Also keep in mind, most medical devices do not have side effects (such as in the pharmaceutical world), though many medical devices have residual risks.



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    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Vice President Global Regulatory Affairs
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  • 4.  RE: Residual risks vs side effects

    Posted 30-Aug-2023 17:09

    Dan,

    if you are using 14971 in any form, you are doing a Risk Analysis  there is no Hazard Analysis in 14971 (ANSI/AAMI/ISO,  EN ISO, or ISO)

    We analyze the Risk in 14971not the Hazard.  I guess in the heat of the responding we may fall back on older terminology  but, for compliance with 14971, use the right terms  



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    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    elb@edwinbillsconsultant.com
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  • 5.  RE: Residual risks vs side effects

    This message was posted by a user wishing to remain anonymous
    Posted 31-Aug-2023 09:08
    This message was posted by a user wishing to remain anonymous

    Hi all,

    Thanks for your feedback. So, the side effects can be considered transient ? And if there are long term complications or serious injury resulting from user error or pre-existing patient conditions , these would be considered as residual risks ?




  • 6.  RE: Residual risks vs side effects

    Posted 31-Aug-2023 09:40

    When the effect is transient or long-term does not enter into determining either some thing is a residual risk or part of the side-effect subset of residual risk.

    A residual risk is a risk remaining after implementing the risk control measures. I often use the office copier as an example of residual risk. Inside is a hot fuser which is necessary for the copier to work. If you touch it, you will get a burn.

    The typical risk control measures are protective measures (an interlocked cover to shut down the power) and information for safety (a label about a hot surface). However, it takes time for the fuser to cool, so there is a residual risk of a burn. Whether the burn is long-term or transient doesn't matter.

    Residual risks are identified in the medical device risk management process.

    A side-effect could, for example, trigger an allergy. The allergic reaction could be short term (an inflammation that passes quickly). The allergic reaction could be long term such as change in the immune system but makes a person more susceptible to allergic reactions.

    There may not be a risk control measure for these kinds of side-effects, so they are also residual risks.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 7.  RE: Residual risks vs side effects

    This message was posted by a user wishing to remain anonymous
    Posted 14-Sep-2023 09:16
    This message was posted by a user wishing to remain anonymous

    In the risk assessment , what would be the verification of implementation and verification of effectiveness for the residual risks /side effects ?




  • 8.  RE: Residual risks vs side effects

    Posted 14-Sep-2023 12:34

    Remember that per EN ISO 14971 (as amended), we verify implementation and effectiveness of risk controls, not of the risks or side effects. The risk controls generally correspond to design and development inputs and the corresponding outputs. Accordingly, verification of the implementation and effectiveness of those risk controls (i.e. of the corresponding design and development input and outputs) happens via the corresponding design and development verification and/or validation processes.



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    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
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  • 9.  RE: Residual risks vs side effects

    Posted 15-Sep-2023 08:16

    Implementation verification and effectiveness verification don't apply to residual risks /side effects. They apply to the risk control measures.

    Residual risks /side effects are the risk remaining after implementing the risk control measures.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 10.  RE: Residual risks vs side effects

    Posted 15-Sep-2023 11:20

    The Risk after the Risk Control has been applied is the Residual Risk. You are trying to show that the Risk Control will do what you ESTIMATE is what the control actually will do.  Until you have exposure during use, it is still an estimate. Until you have statistically valid data to verify, it is still an estimate. The value of Residual Risk that you have estimated in your Risk Analysis is what you are trying to verify in the Verification of Effectiveness.

    So if you estimate that a Risk, when the Control Measure has been applied has a Severity of Harm of "Serious", which is specifically defined in your risk management system, perhaps with a injury requiring medical intervention, and a probability of occurrence of 10-3 after the risk controls is applied, you need to verify that.    



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    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    elb@edwinbillsconsultant.com
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  • 11.  RE: Residual risks vs side effects

    Posted 05-Sep-2023 06:29

    To add what may hopefully a useful differentiator....

    As other replies have said, residual risks are what is left after risk controls have been implemented. 

    Side effects are a sub-set of the residual risks. More often than not, I would argue that side-effects occur in NORMAL conditions rather than FAULT conditions. E.g. a sore-throat or cough after being intubated with a endotracheal tube for a period of time and there has been no failure of the tube during insertion, use or removal. There is also an connection between these side-effects and the residual risks that should be disclosed to the user/patient. i.e. side-effects should (always) be part of the disclosure of residual risks (as in most cases, I think Richard indicated this too in this reply, there will be no risk control measures).

    I will happily hear (and learn from) any exceptions to my quickly written 'rules' that anyone can share. 



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    Ed Ball
    Manager, Intelligence & Innovation
    United Kingdom
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  • 12.  RE: Residual risks vs side effects

    Posted 05-Sep-2023 08:34

    Great points, Ed. And pointing out that Side Effects occur during Normal Condition is a valuable add to the discussion. 



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    Edwin Bills
    Edwin Bills Consultant
    ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
    elb@edwinbillsconsultant.com
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  • 13.  RE: Residual risks vs side effects

    Posted 07-Sep-2023 09:15
    Edited by Richard Jansky 07-Sep-2023 09:18

    Please apologize my poking as I don't want to correct the experts here, but in my understanding, risks can occur from a foreseeable misuse, from failed functionality, or from the device characteristics. Only one of those is based on a failure. All three might need to be mitigated, potentially resulting in residual risks.

    Is then the distinction that a side effect occurs only during a foreseeable misuse or from device characteristics?

    And if so, shouldn't it be listed as a residual risk?



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    Richard Jansky
    Head of RA / RM / QM
    Beringen
    Switzerland
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  • 14.  RE: Residual risks vs side effects

    Posted 07-Sep-2023 10:20

    The process starts with a hazard, which could occur in a normal or in a fault condition. The analysis identifies the initial harm. Risk reduction (not mitigation) reduces the risk to an acceptable level. Risk reduction may not eliminate the risk. The risk remaining after risk reduction is the residual risk.

    Most of the discussion of side effects originates with the EU-MDR which does not have a definition. It also has about five kinds such as undesirable, unexpected, etc.

    All side effects are residual risks, but there are residual risks that are not side effects.

    I think of a side effect as an unintended outcome, but this is squishy.

    Take two examples. The risk of a burn from a toaster is a residual risk, since the toaster must get hot to perform its function. Risk reduction doesn't completely eliminate the possibility of a burn. I would not consider a burn as a side effect.

    I buy a light therapy device to make the hair grow back on the top of my head. I realize, after three months of using the device, that it has caused my IQ to  decrease by 20 points. The IQ decrease is a side-effect. It is also unanticipated and undesirable. I consider this a residual risk as well as a side-effect. The residual risk may not be known initially, but uncovered through post-market surveillance.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 15.  RE: Residual risks vs side effects

    Posted 07-Sep-2023 10:56

    Hi Richard

    I think Dan has confirmed the latter part of your question already, in that side effects are a sub-set of the residual risks. My suggestion was that side-effects would typically only stem from NORMAL USE conditions, which would mean no fault conditions (I would interpret that as the device is manufactured to specification, used as intended and does not fail during use etc). Which is what I think you are meaning by 'device characteristics'. 



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    Ed Ball
    Manager, Intelligence & Innovation
    United Kingdom
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  • 16.  RE: Residual risks vs side effects

    Posted 08-Sep-2023 02:12


    Thank you Dan and Ed for your helpful responses.

    Yes, I didn't mean to say mitigation, but reduction - my bad.

    Also yes, risks from "device characteristics" as "functionality/performance needed to achieve intended use" I see as those associated with the device functioning as specified and used as intended.

    If the distinction is as fuzzy as it seems, is there a need to distinguish between residual risk and side effect?

    Based on the MDR, it seems that one knows the residual risks prior to going into the Clinical Evaluation. There, one confirms them and determines any undesirable side-effect not thought of, which become subsequently residual risks as well.

    Presently though, I feel it's rather semantics.



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    Richard Jansky
    Head of RA / RM / QM
    Beringen
    Switzerland
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  • 17.  RE: Residual risks vs side effects

    Posted 08-Sep-2023 02:32

    Hi Richard,

    as far as I can see at least one thing where this goes beyond semantics are the vigilance requirements of the MDR.Article 87 (1) a states that you must report "any serious incident involving devices made available on the Union market, except expected side-effects which are clearly documented in the product information and quantified in the technical documentation and are subject to trend reporting pursuant to Article 88;" So here the differentiation would have a real effect.

    The only definition I know of besides the hints in the MDR is in MDCG 2023-3, question 8: "An 'undesirable side-effect' under the MDR should be understood as any unintended and unwanted medical manifestation in the human body, as a consequence of the normal use of a device.Undesirable side-effects are not the result of a malfunction, deterioration in the device's characteristics or performance, or an inadequacy in the information supplied by the
    manufacturer. An unsuccessful treatment (or treatment failure) should not be considered an undesirable side effect."

    Best regards

    Christoph



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    Christoph Kiesselbach
    Reutlingen
    Germany
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  • 18.  RE: Residual risks vs side effects

    Posted 14-Sep-2023 10:39

    The plain language of the EU MDR distinguishes residual risks and side-effects as being different from one another.  And I believe the ultimate fundamentals of EN ISO 14971 (as amended) (hereinafter "14971") and ISO/TR 24971 (as amended) (hereinafter "24971") maintain this distinction also aside from the second-to-last paragraph of 24971 Annex D.3 which convolutes residual risk and side-effects. 

    Ultimately, I suggest that side-effects are 14971 harms (primarily) but could also be 14971 hazards and/or sequences of events that lead to those harms.  We then estimate 14971 individual and overall residual risk based on the associated frequency and severity of the harm.  Thus, side-effects (as with any other harm or triggering hazard/sequence of events) can lead to residual risk; yet aren't the residual risk itself.

    To avoid incoherent risk management policies, procedures, and practices that fall short of 14971's essential fundamentals and undermine the EU MDR's distinction between side-effects and risk, I recommend against equating side-effects (i.e., hazards/events/harms) with the resulting residual risk.

    Here is some supporting background that shows established clarity and precedent or other standardized practice distinguishing side-effects as being events/harms that lead to risk:

    • "…The disclosure of the residual risk can also be useful for the user or the hospital organization to prepare the patient for possible side-effects or harms that can occur…" [24971; emphasis added]

    • "…Residual risks can relate to the possible occurrence of side-effects or after-effects related to the use of a medical device…" [24971; emphasis added]

    • "…an undesirable effect can be understood as any undesirable side-effect related to the device and that is experienced by the patient and/or can be diagnosed and/or measured in the patient…" [MDCG 2019-9; emphasis added]

    • "…some events indicated in the MDR by…'undesirable side-effects'…may…be annotated as 'adverse events' in the scientific literature…" [MDCG 2019-9; emphasis added]

    • "…The definition of risk includes the probability of occurrence of harm. Therefore the information in the SSCP on risks shall also include quantifications. This information can be sourced from the clinical evaluation report where an updated examination of qualitative and quantitative aspects of clinical safety is available, with clear reference to the determination of residual risks and side-effects…" [MDCG 2019-9; emphasis added]

    • "…The threshold proposed as acceptable for any new device will depend on the severity and detectability of side effects [i.e., harm] concerned…" [MEDDEV 2.7/1 revision 4 still relied on by the MDCG; emphasis added]

    • "…In order to evaluate the acceptability of the side-effects of a device...there needs to be clinical data for the evaluation of the nature, severity and frequency of potential undesirable side-effects…" [in alignment with 14971 which requires estimation of the frequency and severity of harm, not of risk] [MEDDEV 2.7/1 revision 4 still relied on by the MDCG; emphasis added]

    • "…Example:...A reasonable probability (80%) of observing at least one event of an undesirable side-effect when 15 subjects are studied requires a side-effect with an actual probability of 10%..." [MEDDEV 2.7/1 revision 4 still relied on by the MDCG; emphasis added]

    • "…Considerations may need to include...if follow-up was frequent enough to detect temporary side effects and complications (such as prolonged wound healing)..." [MEDDEV 2.7/1 revision 4 still relied on by the MDCG; emphasis added]

    These are just some examples of the proper and established practice of distinguishing side-effects from the resulting risk. I don't believe we can stay faithful to the basic fundamentals of 14971 or the EU MDR by equating side-effects with residual risk.



    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------