By

Alan Kusinitz
/Docs/PlasmaInspections7342002bld-SCPRcomputerhighlights.pdf
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The following question was asked during the “Ask the FDA” session (326-QE) on 10/25/04 at the AABB Annual Meeting held in Baltimore, MD as reported by SoftwareCPR Partner Molly Ray: When blood establishment computer software manufacturers distribute their device (software) for beta testing, they are required to label the software in accordance with the IDE...
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While FDA regulates Blood Establishment Computer Systems (BECS) as medical devices as well as regulating the blood establishments themselves, many other countries take a different approach. In Canada the blood establishment is regulated. Computer systems used in donor establishments are not considered medical devices and are regulated through the establishment licensing process. Unlike with the...
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A final ballot version of the AAMI Software Risk Management Technical Information Report was issued to the AAMI Software Committee. Balloting will end on Sept. 24, 2004. Members of the committee can obtain a copy directly from AAMI.
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Company: John Sjoding AB Date: 6/29/2004 Product: dental endosseous implants and attachments Failure to have changes in documents reviewed and approved by an individual in the same function or organization that performed the original review and approval, as required by 21 CFR 820.40(b). For example, on October 16, 2003, the K.A. Rasmussen as. Document Number...
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The pdf at the link provided is a reprint of an article entitled “Understanding CAPA Requirements in a Software Context” authored by Alan Kusinitz, Managing Partner of SoftwareCPR, for the AAMI Biomedical Instrumentation and Technology journal published in the Spring of 2004. AAMI – AKusinitz CAPA – article 0504
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/docs/CancelCellDetectionDeviceGuidance0904-Doc1531.pdf
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This is one of the FDA recognized software standards.
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Recipient:Cordis Corporation Product: Sirolimus-Eluting Coronary Stent Date: 4/1/2004 Failure to validate with a high degree of assurance, processes, including changed processes, that cannot be fully verified by subsequent investigation and test, as required by 21 CFR 820.75(a) & (c). For example: The automated [redacted] data acquisition system, used to ensure the integrity of the analytical...
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The AAMI Software Risk Management Technical Information Report draft comment period ended March 1, 2004. Comments were generally positive.The next step is a working group meeting May 11-12, 2004 to resolve comments and do a final edit to prepare the document for formal ballot. Contact one of the co-chairs if you are not a member...
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FDA has been investigating putting together information on hazards of various types of devices as an aide to both FDA and industry. Sandy Weininger at CDRH has established a forum for dissemination of information on this project. If you are interested in participating or receiving updates on this effort send email to office@softwarecpr.com or directly...
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The AAMI software committee is preparing comments on the “FDA Guidance for the Content of Premarket submissions for Software Contained in Medical Devices” in the interest of providing FDA input for future revision of this and related guidances. If you are not a member of the AAMI software committee and would like SoftwareCPR (a member...
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The AAMI Software Risk Management Technical Information Report working group has a full draft out for formal comment as of Jan 5, 2004. The comment period ends March 1, 2004. Contact one of the co-chairs if you are not a member of the AAMI committee and would like a copy for comment: Alan Kusinitz Managing...
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The AAMI Software Risk Management Technical Information Report working group has completed a full draft for committee and public comment. Contact one of the co-chairs if you are not a member of the AAMI committee and would like a copy for comment: Alan Kusinitz Managing Partner of SoftwareCPR at alan@softwarecpr.com or Paul Jones of FDA...
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On 10/23/03, Alan gave a presentation on risk based approaches to Part 11 as recommended in the final FDA guidance.  A copy of the slides are at the link provided. Also available on the site are the slides from Joe Famulare (FDA’s Part 11 lead) presented at this conference. scpred_AKusinitz-Part11AdvamedRiskslides102303
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Guidance for Industry and FDA Staff Providing Regulatory Submissions in Electronic Format — General Considerations.  Document dated Oct 22, 2003. This guidance focuses on use of pdf files. It provides many specific requests in construction of the pdf for suitability for electronic submissions. These include resolutions, pagination, preference for digital instead of scanned source documents....
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While FDA regulates Blood Establishment Computer Systems (BECS) as medical devices as well as regulating the blood establishments themselves, many other countries take a different approach. According to the Danish Competent Authorities the European Union (EU) approach is that equipment for blood banks including transfusion and information systems with clinical data about the donors, blood...
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/Docs/BloodBankingComputerValidationguidelines-ISBT-1202.pdf
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The pdf at the link provided is a reprint of an article entitled “Software Test Coverage” authored by Alan Kusinitz, Managing Partner of SoftwareCPR, for the AAMI Biomedical Instrumentation and Technology journal and published in the Spring of 2003. AAMI-BIT-Software-Test-Coverage Article
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An article in the August 22, 2003, Los Angeles Times by Charles Ornstein and Tracy Weber, Times Staff Writers, describes an incident where “two patients die after alarms fail”. Read article:  LATimesarticle822
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The AAMI Software Risk Management Technical Information Report working group has issued a draft for comment to those interested in providing early informal feedback. Contact one of the co-chairs for more information: Alan Kusinitz Managing Partner of SoftwareCPR at alan@softwarecpr.com or Paul Jones of FDA at pxj@fdadr.cdrh.gov.
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On February 20, 2003, a final security rule 45 CFR Part 142 was issued. A copy is at this link: HIPAA Final Security Rule 2003-02. Medical Device manufacturers that produce devices that will maintain patient data should be aware of HIPAA privacy and security requirements to assure appropriate features are incorporated in their devices to...
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A presentation of a proposal for EU software regulation at the ISPRA meeting on Medical Device Software May 13, 2003, is at the link provided. Some of the suggestions are based on FDA guidance documents. ISPRA Meeting on SW This presentation was provided by Poul Schmidt-Andersen of Copenhagen Medical Devices, which is an affiliate of SoftwareCPR....
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A white paper at the link provided gives an overview of the status of European Union medical device software regulation and provides suggestions on software validation. Some of the suggestions are based on FDA guidance documents. CMD Swartikel This paper was provided by Poul Schmidt-Andersen of Copenhagen Medical Devices which is an affiliate of SoftwareCPR.
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. The attached document is a reprint of a chapter from an AABB book. The book is titled “Information Technology in Infusion Medicine”.  The chapter is on 21 CFR Part 11 Electronic Records;Electronic Signatures and was authored by Alan Kusinitz,...
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. SoftwareCPR has prepared an audit checklist for assessing compliance with 21 CFR Part 11 Electronic Records and Electronic Signatures regulation.  The checklist is intended for use by expert assessors knowledgeable in the regulation, its preamble, history, and current enforcement...
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/docs/MurrayPart11PresentationFoodSafetySummitMarch2003.PDF
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. At AAMI’s International Standards Conference on March 11 2003 FDA’s CDRH Software Compliance and Part 11 Representative (John Murray) gave the first presentation on FDA’s changes in its approach to Part 11.  The slides from this presentation can be...
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This content is only available to Premium Level or higher subscribers.  See our Subscribe page for information on subscriptions. At AAMI’s International Standards Conference on March 11 2003 FDA’s CDRH Software Compliance Expert and AAMI Software Committee co-chair (John Murray) gave a presentation on FDA’s software message and the role standards can play to benefit industry and...
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. The document at the link provided is a SoftwareCPR training aide on Part 11. It provides information and explanation of the Feb 2003 FDA redirection of its Part 11 regulation. It includes a summary of the areas of Part...
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. A one page memory jogger for key sections of the Part 11 rule is at the link provided.  This is a SoftwareCPR training and auditing aide. This was updated Feb 2003 to highlight items for which FDA is changing...
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http://www.ispe.org/page.ww?name=Welcome+to+the+ISPE+GAMP+COP§ion=GAMP+COP
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