Guiding clients to effective and efficient compliance and regulatory approvals

This content is only available to our Premium subscribers. See our Subscribe page for information on subscriptions. ISO 14971 was updated and released in 2019.  We previously discussed the internal debate regarding ISO 14917 in this post ISO 14971 versus the EU Commission. There are several items to consider with the new update: Section 10.1 - “The manufacturer...
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Company: Fresenius Medical Care Holdings, Inc. Date of Enforcement Report: 11/18/2020 Class II PRODUCT Liberty Select Cycler Software Version 2.9.0 Model Number 180343 and RTLR180343 Recall Number: Z-0439-2021 REASON The device may detect an incorrect Heater Bag volume which may lead to a ‘Supply Bag Line Blocked’ alarm during treatment. This alarm may cause the...
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Compliance and Agile In a prior blog, we discussed a common hurdle to achieving agile benefits: focusing on isolated software process changes and not considering all four organizational factors. Another common hurdle to agile success is thinking only about making agile “compliant.” You will miss the full power of agile if you do not consider...
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The Food and Drug Administration (FDA or Agency) is announcing the availability of the draft guidance on EMC entitled ‘‘Electromagnetic Compatibility (EMC) of Medical Devices.’’ This new “draft” guidance document is intended to recommend information that should be provided in a premarket submissions to demonstrate electromagnetic compatibility (EMC) for electrically powered medical devices and medical...
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Our General Manager and Partner, Brian Pate, along with our expert affiliate, Mike Russell, will be teaching a one-day training course through Irish Medtech/Ibec (https://www.irishmedtechassoc.ie) for Ireland-based medical device and HealthIT companies on Thursday, November 19, 2020.   The course will be delivered virtually/online.  This course condenses the agile topics covered in our 3-day IEC 62304...
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Company: Siemens Medical Solutions USA, Inc Date of Enforcement Report: 11/11/2020 Class II PRODUCT ARTIS Icono Interventional Fluoroscopic X-Ray system – Product Usage: Intended Use: ARTIS is a family of dedicated angiography systems developed for single and biplane diagnostic imaging and interventional procedures including, but not limited to, pediatric and obese patients. Recall Number: Z-0400-2021...
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Company: Boston Scientific Corporation Date of Enforcement Report: 11/11/2020 Class II PRODUCT Model 3300 LATITUDE Programming System with installed Model 3892 ALTRUA, INSIGNIA I, NEXUS I Software Support Application Recall Number: Z-0319-2021 REASON There is potential when a user changes an EGM trace channel with a Manual Pace Threshold test in progress that the newly...
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At SoftwareCPR today, we honor our consultants that are also veterans who served in our US military! John Murray – US Navy Mike Russell – US Air Force Greg Sandoe – US Marine Corps Jordan Pate – US Army Paul Felten – US Army Thank you for your service!
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Why is a SR or NSR Designation important? The FDA guidance document, “Information Sheet Guidance For IRBs, Clinical Investigators, and Sponsors: Significant Risk and Nonsignificant Risk Medical Device Studies,” sheds some light on the Investigational Device Exemptions (IDE) regulations of 21 CFR 812. The IDE regulations describe significant risk (SR), nonsignificant risk (NSR), and exempt...
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FDA released their CDRH Proposed Guidance Updates that includes a significant amount of “software related” guidance in FY 2021. There are four separate guidance documents listed for publication in FY 2021. IMO that is a fairly large commitment from the agency and I will look forward to reading about the agency’s “current thinking” on these...
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Medical devices are now considered a subtype of Internet of Things (IoT) devices [(2) https://owasp.org/www-pdf-archive/SecureMedicalDeviceDeployment.pdf]. There is a growing need to properly document the physical off-the-shelf (OTS) subsystem components that a medical device contains. Medical devices are often no longer stand-alone devices which contain only proprietary components. Inattention to additional components may lead to a...
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SoftwareCPR® November 2020 Newsletter has been published.  FDA news, regulatory updates, new SoftwareCPR® content, software recalls, and software warning letters.  Click here:  https://mailchi.mp/20c005316272/softwarecpr-nov-2020-newsletter-4560492?e=819caeeb16
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Company: GE Healthcare, LLC Date of Enforcement Report: 11/4/2020 Class II PRODUCT Revolution Apex, Revolution CT with Apex Edition, Model 5995000-5 – Product Usage: The system is intended for head, whole body, cardiac and vascular X-ray Computed Tomography applications. Recall Number: Z-0306-2021 REASON There is a potential for a smudge artifact that could be suspect...
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Company: Merge Healthcare, Inc. Date of Enforcement Report: 11/4/2020 Class II PRODUCT Merge LIS Recall Number: Z-0289-2021 REASON A defect in the software resulted in medications that are not associated with the patient (i.e., medications that the patient is not currently taking) appearing on their report. RECALLING FIRM/MANUFACTURER Merge Healthcare, Inc. on 1/23/2017. Voluntary:  Firm...
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Company: Pentax of America Inc Date of Enforcement Report: 11/4/2020 Class II PRODUCT 9372HD Digital Capture (ver. 1.1.0 + w/ 9263 endoPortal), Recall Number: Z-0292-2021 REASON There is an intermittent software issue that could affect the systems, in which an exam video for one patient (Patient A) might be copied to another patient (Patient B)....
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Understanding OTS and SOUP
Understanding OTS and SOUP is very important in every lifecycle stages of medical device and HealthIT software development.  In the late 1990’s, the US FDA first published guidance documentation on the use of Off-The-Shelf (OTS) software in medical devices (or sometimes referred to as “OTSS”).  At that time, OTSS generally accounted for a very small...
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Company: Fujifilm Medical Systems U.S.A., Inc. Date of Enforcement Report: 10/28/2020 Class II PRODUCT Synapse PACS Software Version 5.6.1 – Product Usage: intended for use as a web based application on an off-the shelf PC which meets or exceeds minimum specifications and is networked with a FUJIFILM Synapse PACS server. Recall Number: Z-0282-2021 REASON FUJIFILM...
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The FDA recently announced the addition of 25 new tools to the Catalog of Regulatory Science Tools to help assess medical devices. CDRH catalogues regulatory science tools on this webpage to help improve the development and assessment of emerging medical technologies. Of the 25 tools added, some items of interest are: Laboratory Accuracy Evaluation of...
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Company: Siemens Medical Solutions USA, Inc Date of Enforcement Report: 10/21/2020 Class II PRODUCT Artis zee or Artis Q systems (listed below) Product Usage: for single and biplane diagnostic imaging and interventional procedures. System Name/Material Number: Artis Q BIPLANE 10848282 ARTIS Q CEILING 10848281 Artis Q floor 10848280 ARTIS Q ZEEGO 10848283 ARTIS Q.ZEN BIPLANE...
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Company: Brainlab AG Date of Enforcement Report: 10/14/2020 Class II PRODUCT Ultrasound Navigation Software 1.0 and Ultrasound Integration Software for Cranial/ENT Navigation 3.0.x and 3.1.x Product Usage: intended to be an intra-operative image guided localization system to enable minimally invasive surgery. Recall Number: Z-0056-2021 REASON Brainlab Ultrasound Navigation Software does not support the modification of...
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Our internal cybersecurity expert Gwen contributed the following. The Use of LIS2 In Medical Devices LIS2-A2 is widely used in laboratory devices as a standard practice for Healthcare Delivery Organizations (HDOs). The LIS and LIS2 communication protocol standards published nearly two decades ago have often been used in medical device network systems due to their...
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Company: Devicor Medical Products Inc Date of Enforcement Report: 10/14/2020 Class III PRODUCT Neoprobe GDS Control Unit, Model Number NPCU3 Recall Number: Z-0070-2021 REASON It was discovered during a documentation review that China has the software version as v5.01 approved for use in China. The current software version on devices distributed in China since 2011...
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In 2018, Google Health began a program in Thailand to screen for diabetic retinopathy using artificial intelligence (AI). The AI was designed to analyze photos of diabetic patients’ eyes to detect signs of eye disease. The AI was promising in theory – during testing, it was 90% accurate in detecting diabetic retinopathy in eye scans,...
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Company: Siemens Medical Solutions USA, Inc. Date of Enforcement Report: 10/7/2020 Class II PRODUCT Software versions syngo.CT VB20 or VB20_SP1 in the following systems: SOMATOM Force (Model #10742326) SOMATOM Definition As (Model #8098027) SOMATOM Definition Edge (Model #10590000) SOMATOM Definition Flash (Model #10430603) SOMATOM Drive (Model #10431700) SOMATOM Confidence (Model #10590100) SOMATOM Edge Plus (Model...
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Company: Blood Bank Computer Systems, Inc Date of Enforcement Report: 10/7/2020 Class II PRODUCT ABO QuickPass Web Portal, Version 1.2.0; ABO QuickPass Web Portal 1.1.0; ABO QuickPass Web Portal 1.0.0 Recall Number: B-0697-2020 REASON Blood Bank software, with a defect or glitch, was distributed. RECALLING FIRM/MANUFACTURER Blood Bank Computer Systems, Inc. on 9/16/2020. Voluntary:  Firm...
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Upcoming Training

Agile Methods for Medical Device and Health IT Software

One day course sponsored by the Irish Medtech Association / Ibec, Connected Health Skillnet.  November 19, 2020, 9 am to 6 pm IST.  Read more and registration information:  Agile methods Flyer (19 Nov)

Registration Link:  https://connectedhealthskillnet.ie/IBEC/Events.nsf/

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