FDA GPSV Traceability Expectations

Going way back to the late 1990’s, FDA had an expectation that safe and effective software would require a well thought out development lifecycle that includes many activities designed to ensure the correctness and robustness of all software that was part of the medical device.  A key guidance document was created known as the General Principles of Software Validation, or GPSV for short.  One method that one will find in the GPSV is the use of traceability analyses for several verification activities.  FDA GPSV traceability expectations include at least twelve traceability analyses.  This could vary depending upon the risk profile of the medical device and other regulatory factors.  Theses trace analyses are illustrated in the diagram below:

FDA GPSV Traceability Expectations Diagram

As you can see, this does not perfectly align with IEC 62304 so one should carefully consider and plan how traceability analysis will be used in the SDLC process for products marketed in the US to better fulfill FDA GPSV traceability expectations.

Traceability analysis can be a powerful tool to help gain confidence in the quality of a software program.  It is just one verification method that one should use.  The V-model diagram illustrates how verification activities essentially trace back to the “flowdown” portion of requirements and specifications.  See our post on the V-model here:  Enhanced V Model Diagram

About the author

Partner and General Manager, Brian Pate is ISO 1385:2016 Lead Auditor certified for Medical Device Quality Management Systems (MD), and ISO 19011:2018 Management Systems Auditing (AU) and Leading Management Systems Audit Teams (TL). Brian started his medical device career in anesthesia clinical research in 1985 and has since worked both academia and industry including many years with Johnson & Johnson, Baxter Healthcare, and GE Medical. Brian’s roles have included software engineering, systems engineering, quality assurance, and regulatory affairs. Brian has served on multiple AAMI TIR working groups, including TIR32-2008 (Application of ISO 14971 Risk Management to Software; now IEC 80002-1) and TIR45-2012 (Guidance on the use of Agile practices in the development of medical device software) and served as a reviewer for the 2nd edition of TIR45. Brian serves on the AAMI Software Committee and as an AAMI instructor for the software, design controls, and agile methods courses. Brian also is a member of the Underwriters’ Laboratories (UL) Standards Technical Panel for UL1998 (Software in Programmable Components) and or UL5500 (Remote Software Updates).

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