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."
Original Message:
Sent: 08-Sep-2023 02:12
From: Richard Jansky
Subject: Residual risks vs side effects
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
Original Message:
Sent: 07-Sep-2023 10:55
From: Edward Ball
Subject: Residual risks vs side effects
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'.
------------------------------
Ed Ball
Manager, Intelligence & Innovation
United Kingdom
Original Message:
Sent: 07-Sep-2023 09:15
From: Richard Jansky
Subject: Residual risks vs side effects
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
Original Message:
Sent: 05-Sep-2023 08:34
From: Edwin Bills
Subject: Residual risks vs side effects
Great points, Ed. And pointing out that Side Effects occur during Normal Condition is a valuable add to the discussion.
------------------------------
Edwin Bills
Edwin Bills Consultant
ASQ Fellow CQE, CQA, CQM/OE, RAPS RAC
elb@edwinbillsconsultant.com
Original Message:
Sent: 05-Sep-2023 06:28
From: Edward Ball
Subject: Residual risks vs side effects
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.
------------------------------
Ed Ball
Manager, Intelligence & Innovation
United Kingdom
Original Message:
Sent: 27-Aug-2023 18:53
From: Anonymous Member
Subject: Residual risks vs side effects
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