Risk Management for Forseeable Misuse

Stan Hamilton and Brian Pate of SoftwareCPR offer the following tip.

As risk managers, we often struggle to draw the line for inclusion of foreseeable misuse. We ask questions like what is credible, and how far must you go? When performing risk analysis, we decide if it is credible enough to list as a hazard cause, and to consider adding risk controls. In the case of a recent recall, it causes one to consider those difficult risk management decisions. Would it have been better to be more conservative and add another software risk control for a particular case of misuse? A dangerous modification was made by third party personnel. The unit was able to continue functioning with active energy, and led to an adverse event.

Of course, from the outside looking in, it is only speculation. It does remind us (and we often encourage clients) to add risk controls, even if the initial risk evaluation is extremely low, if they are relatively easy to add. Often, the engineers, if aware early enough in the process, will say that risk controls are easy to add and have very little impact on unit cost or development schedules. So integrate risk management planning very early in your design process and don’t hesitate to add simple risk controls even if you consider the likelihood of the misuse to be low.”

SoftwareCPR Training Courses:

IEC 62304 and other emerging standards for Medical Device and HealthIT Software

Our flagship course for preparing regulatory, quality, engineering, operations, and others for the activities and documentation expected for IEC 62304 conformance and for FDA expectations. The goal is to educate on the intent and purpose so that the participants are able to make informed decisions in the future.  Focus is not simply what the standard says, but what is meant and discuss examples and approaches one might implement to comply.  Special deep discount pricing available to FDA attendees and other regulators.

3-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Brian Pate

Next public offering:  TBD

Email training@softwarecpr.com to request a special pre-registration discount.  Limited number of pre-registration coupons.

Registration Link:

TBD

 


 

Being Agile & Yet Compliant (Public or Private)

Our SoftwareCPR unique approach to incorporating agile and lean engineering to your medical device software process training course is now open for scheduling!

  • Agile principles that align well with medical
  • Backlog management
  • Agile risk management
  • Incremental and iterative software development lifecycle management
  •  Frequent release management
  • And more!

2-days onsite (4 days virtual) with group exercises, quizzes, examples, Q&A.

Instructors: Mike Russell, Ron Baerg

Next public offering: March 7 & 28, 2024

Virtual via Zoom

Registration Link:

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Medical Device Cybersecurity (Public or Private)

This course takes a deep dive into the US FDA expectations for cybersecurity activities in the product development process with central focus on the cybersecurity risk analysis process. Overall approach will be tied to relevant standards and FDA guidance documentation. The course will follow the ISO 14971:2019 framework for overall structure but utilize IEC 62304, IEC 81001-5-1, and AAMI TIR57 for specific details regarding cybersecurity planning, risk characterization, threat modeling, and control strategies.

2-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Dr Peter Rech, 2nd instructor (optional)

Next public offering:  TBD

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