Case for Quality
Company C
Risk Management
Risk Management
Topics
• Overview of the Risk Management Process and Activities
• Risk Analysis Architecture : Pre- Market Activity
• Process to systematically analyze and control risk
• Risk Analysis (Hazard Analysis)
• Cross functional interaction and timing during Product
development
• Post market Risk Management Overview
• Issue Impact Assessment (HHA) - A Post Market Activity
Risk Management
Product risk management
Systematic application of management policies, procedures and practices
to the tasks of analyzing, evaluating,
controlling and monitoring risk
Process governed by ISO 14971- “Application of Risk Management to
Medical Devices Risk Management Process
PROCESS MAP IN EVERY PROCEDURE
Risk Management
Closed loop Risk management activities/process
Pre-Market Post-Market
Feedback
Risk learning
Management
NCRs
Risk controls driving product Plan and Post-Market Lifetest results
Service Records
requirements Report Surveillance Literature Review
Clinical Trials
Compare and update
Risk assessment
(HHA)
Product
Issues
(Field)
Trending and CAPA
PHO, FCA,
Monitoring decisions
Risk Management
Performing Risk Analysis during development
Risk Analysis must identify known and foreseeable hazards in both normal and
fault conditions. It requires more than Failure Mode Effects Analysis (FMEA)
- Standardized list of Hazards and Harms
- Sources of Hazards/initiating events and their likelihood of occurrence.
- Ex: Design/process FMEAs, Use-error, cyber security analysis
- Risk matrix to categorize/classify the Risk Requirements from ISO 14971
RISK ANALYSIS: ANALYZING HAZARDS TO ESTIMATE RISK
Known/Observe
Intended use of RISK: HARM SEVERITY AND PROBABILITY OF HARM d/Reported Risks
the medical (ex: CAPA, field
product complaints etc.)
Occurrence of Harm
Probability of
Product
characteristics Foreseeable/
impacting safety Potential risks
Severity of harm
Use conditions/use-error but medical
Failure of product design/process
device functions normally
“Fault Condition”
“Normal condition”
Risk Management
Analyze Risk using a Risk Analysis Architecture
Risk Analysis Architecture is a pre-market process to develop a
structured risk analysis approach considering risks from design,
use conditions and manufacturing
• Comprehensive risk analysis - Avoids Silos
• Prevents inconsistent estimation of patient harms- by ensuring
only qualified personnel assess patient harm
• Traceability between different analysis and to product
requirements
• Enforces common understanding & ownership at the various
levels of risk analysis
• Enforces the need to understand system interactions that
impacts risk
• Assists post market risk analysis comparison
• 1 Stop shop to demonstrate compliance
Risk Analysis Architecture Process Steps
Plan Risk Assess Perform
Analysis Hazard Product Risk
Architecture Sources Analysis
Risk Management
Risk analysis architecture process
Risk analysis architecture requirements- Requires more than a FMEA
(FMEA as it is not the Product Risk Analysis but an input to the risk analysis)
Product Risk Analysis Next level /safety hazard from Hazard Source=
(Hazard/Harm Analysis) Hazard in Hazard analysis
Inputs to Product Risk Analysis
Process
(Hazard Sources/Initiatingfailure
Events)
Controls
Process
failureSystem Safety Product Design
Product Controls Characterization Failure Analysis
Requirements
DFMEA Failure
Use-Error Analysis Product Security mode & PFMEA
Analysis Next level Effect
Product Process
Failure Analysis
Captures Product Risks
Captures Sources of Risks
Risk Management
A tongue depressor is a simple device that allows a clinician to hold a patient’s tongue in place to Components of
visualize the throat. A tongue depressor needs to be able to perform that function without Risk Analysis
harming the patient. A shipping/handling issue was identified that could damage the curved edges
(Hazard analysis)
of the depressor.
Hazard sources/Initiating event:
Shipping resulting in an issue + creating
a sharp edge + physician not noticing
Shipping /handling issue damages tongue depressor
Hazard
Sequence of Events
P1: Probability of a physician using the
Sharp edge on tongue depressor sharp edge on a patient considering
before using
the probabilities of:
- Shipping/Handling issue
- Physician not noticing the sharp edge
Hazardous Situation before using it on the patient
Use of a tongue depressor with a sharp edge
by a physician on a patient
P2: Probability of a sharp edge
Harm cutting a patient's tongue
Cut on patient’s tongue
Severity of the Harm Probability of
Minor: Temporary injury or Occurrence of the harm Risk
impairment P1 x P2
Risk Management
Risk Or Hazard analysis form for comprehensive
coverage of risks and controls
Risk Analysis considering Normal/Fault; Known/ Foreseeable per ISO 14971
Risk Control Selection and Traceability to product Requirements/Validation
Risk Management
Risk Controls and Product Requirements
Collaborate with Role: Reduces/eliminates risks using all the 3 Risk Control options in the
Product priority order listed below and traces to product requirements
development
1 2 3
Safety by Design and Protective Information for
Construction Measure Safety
Ex: Adding protective Ex: Providing
Ex: Designing for measures by using information for
inherent safety by visual or acoustic safety by:
- eliminating hazard OR alarms to alert the placing warnings
- reducing the operator to in the labelling of
probability of hazardous the medical device
occurrence of the harm conditions.
• “6.2 of ISO 14971 obliges the manufacturer to "use one or more of the following risk control options in the priority order
listed: (a) inherent safety by design; (b) protective measures in the medical device itself or in the manufacturing process;
(c) information for safety“”
Risk Management
Risk Management during Product Development
A cross functional activity
Cross functional responsibilities are defined in the Risk Management Plan
Roles
Intended use and Risk Control
Risk Controls Selection Implementation
Product Systems safety Risk Control
Development characteristics Verification
Verification of
effectiveness
Preliminary
Risk Mgmt. Plan & Report
Personnel with Hazard Product Risk or Hazard Analysis
Risk Mgmt. Plan
Clinical Analysis
knowledge
Human Factors; Use-Error Analysis;
Cyber Security Security Risks
risk Eng.
Reliability Eng. Device/System fault analysis/FMEA
Manufacturing
Medical device
Eng. Process FMEA
Design Output Process ValidationDesign Verification & Validation
Design Input Phase
Phase Phase Phase
Risk Management
Post market Risk Management
Risk Management
PRODUCTION AND POST PRODUCTION
Production and Post-Production Activities
Risk Assessment
for Product
Changes and Non-
Conformances
Risk Management
Plan Updated Risk
Management Files
Production and Post Product Impact Post Market
Production Conclusion on Risk
Assessment Surveillance Acceptability
Information Report
Trending
• Assessment of Production and Post-Production Information for new hazards or
increased risks from existing hazards
• Evaluation of any new or increased risks
• Control of any new or increased risks not deemed acceptable
• Evaluation of overall residual risk
• Update of Risk Management documentation
Risk Management
Product Impact Assessment (PIA/HHA) form
Product
Issues
(Field)
• Primary tool used to assess the risk of issues impacting
product in the field
– Analyzes and Evaluates the risk of the issue
• Uses ISO 14971 flow for assessing risks to allow comparison against pre-mkt.
• Recommends whether additional actions or controls are
needed, including field corrective actions
– Based on benefit-risk analysis
– Cross-functional approval including clinical expertise
• Determines whether additional updates to risk management
files are needed
Risk Management
Important aspects of assessing field issues (HHA)
Identifying population/sub populations Risk Analysis consistent with ISO
14971/pre-market
Drives actions to mitigate risk in field
based on benefit-risk analysis
Setting a threshold to revisit using Closing the loop-updating Risk
complaint monitoring process mgmt. files
