By

Alan Kusinitz
/docs/FDAPortableInvasiveGlucoseMonitoring-DraftGuidance102406.pdf
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A new work item proposal was approved to begin a draft Risk Management of IT networks incorporating medical devices. Formal work is planned to beginning in January 2007.
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FDA’s Center for Biologics Evaluation and Research issued the following: “Compliance Program Inspection of Human Cells, Tissues, and Cellular and Tissue-Based Products (HCT/Ps) 7341.002” This guide mentions software and computer systems in one paragraph which is provided below: “Computers: The performance of computer software must be validated (if customized) or verified (if used “off-the-shelf”) for...
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FDA announced in the Federal Register (Docket No. 1992S–0251) a central Gateway/single point of entry for electronic submissions for device, drug and biologic applications. It is referred to as the Electronic Submission Gateway (ESG). The announcement describes three secure options for electronic submissions: “The FDA ESG offers two secure communication options for applicants that have...
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http://webstore.iec.ch/webstore/webstore.nsf/$$search?openform
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http://www.fda.gov/cdrh/oivd/presentations/042004-callaghan-software.html#footnote_2
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http://www.fda.gov/ForIndustry/FDAeSubmitter/default.htm
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http://www.fda.gov/ForIndustry/FDAeSubmitter/default.htm
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This report was from an independent panel commissioned by Guidant corporation after Guidant received significant press for failure to take timely corrective action, including lack of clinician notification, of low probably known defects that could and did lead to deaths. This was focused in cardiac rhythm management products such as implantable pacemakers and defibrillators. The...
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/docs/TransfusionSafteyManagementSystems-FDApresentation09-Mar-06.pdf
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The EU is now close to release of a revision of the Medical Device Directive (MDD). The full text with change marks is at the link provided. The MDD has expanded clause 12.1 into an (a) and (b) sub-clause with the latter specifically addressing software and the former being the original 12.1. The text of...
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Larry Pilot, lead attorney on behalf of Utah Medical, recently gave a presentation on this case. His slides are available at the link provided with his permission. In this case FDA cited Utah Medical Products for process and production software validation issues and was seeking an injunction. Utah Medical won in court and FDA decided...
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. This reference manual includes the following documents in a single pdf with bookmarks and a clickable TOC. Be sure to click bookmarks in adobe so you can jump around the document easily. This pdf contains key FDA software guidances...
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http://www.21cfrpart11.com/pages/sol_prov/solution_providers.htm
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The link provided is a pdf of slides on software maintenance presented by Carl Wyrwa of Beckman at the November 2005 ADVAMED FDA Conference. These are provided with his permission. Software Maintenance Presentation Carl Wyrwa 03Nov2005 V9
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The link provided is a pdf of slides on validation of design tools presented by Carl Wyrwa of Beckman at the November 2005 ADVAMED FDA Conference. These are provided with his permission. Validation Of Design Tools Presentation Carl Wyrwa 03Nov2005 V9
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Recipient: Guidant CorpProduct: Insignia Pacemaker Date: 9/22/05 There are no corrective and preventive actions to change design control procedures to identify or prevent memory overflow or similar software programming problems from recurring. Software used as part of production and the quality system has not been fully validated for its intended use according to an established...
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This content is only available to Premium Level and higher subscribers.  See our Subscribe page for information on subscriptions. At a 1-day current regulatory topics session by ASQ held in Needham, MA, on June 16, 2005, Alan Kusinitz, Managing Partner of SoftwareCPR®, gave a presentation on the recent FDA Cybersecurity Guidance and the new revised FDA “Guidance...
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The EU issued proposed new text for the Medical Device Directive (MDD). The document with highlighted revisions, additions, and deletions is at the link provided. The proposed changes include several additions to more explicity address software. These include adding: the word “software” into the definition of a medical device in section 2(a) Annex I 12.1b...
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The EU issued a proposal to modify the MDD. This proposal expresses several suggestions related to software. The full text is at the link provided. EU proposal for revision of MDD
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http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm072331.pdf
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Recipient: Rosenthal Eye and Facial Plastic Surgery.Product: Investigational devices Date: 4/11/05 Our review of the inspection results also noted that you use an electronic medical record (EMR) system to maintain medical and other clinical data for your patients, including study subjects . You told Mr. Steyert that data obtained during study visits are entered directly...
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http://www.fda.gov/ohrms/dockets/dockets/04p0429/04p-0429-let0001-vol1.pdf
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Recipient: General Electric Inc.Product: X-ray and fluoroscopic systems Date: 3/31/05 For example, your firm uses electronic database systems to document, track, and control corrective and preventive actions. The Correct Action/Preventive Action System procedure, _____, does not reference the use of these database systems, nor does it describe the steps necessary to close corrective and preventive...
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AAMI Standards Conference Software Session 2005 including 4 FDA presentations The following are all included in the pdf at the following link: AAMI Standards Conference Software Session 2005 Review of Software in Premarket Submissions (new guidance for CDRH and CBER) – David S. Buckles FDA CDRH ODE Cybersecurity for Networked Medical Device Containing (OTS) Off-the-Shelf Software...
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http://www.fda.gov/cdrh/osel/programareas/software.html
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IEC 62304 and other emerging standards for Medical Device and HealthIT Software

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Being Agile & Yet Compliant (Public or Private)

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