By

Sherman Eagles
This document provides answers to questions that have been asked to notified bodies regarding using EN 62304 for regulatory purposes in the EU. FAQ 62304
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The debate over ISO 14971 continues between industry and the European Commission. The joint ISO & IEC working group responsible for ISO 14971 met and determined that ISO 14971 still represents the state of the art for medical device risk management and that no changes were needed, despite the position of the EC that ISO...
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IEC SC 62A has agreed that the 2nd edition of 62304 will be expanded to cover all Health Software, not just medical devices. In the interim, an amendment will be issued to clarify current safety classification as well as application of 62304 for legacy software (this was originally intended to be done as part of...
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AAMI and FDA held a two day event Oct 2-3, 2012, as a summit on interoperability. 260 people attended. AAMI has authorized widespread distribution of the proceedings document from this event (see the link provided). Interoperability Summit 2012
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The GHTF is ending and will be replaced by a regulator-only organization, the International Medical Device Regulators Forum (IMDRF). This is the closing statement by the GHTF: GHTF-Closing-Statement.
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AAMI/CDV-1 62366:2007/A1 (IEC/SC62A/826/CDV) — Medical devices – Application of usability engineering to medical devices, Amendment 1. This amendment is out for comment and addresses legacy user interfaces and 62366 conformance for User Interfaces of Unknown Provenance (UOUP). The 62366 amendment draft can now downloaded free from AAMI. Go to the AAMI web site at the...
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The first committee draft of the second edition of “IEC 62304 Medical device software life cycle processes” has been circulated internally for comment. Major changes include a revision of how software safety class is determined, which could reduce the tendency towards most software being Class C; clear requirements for legacy software that explain how conformance...
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Presentations made at the AAMI/FDA Interoperability Summit on October 1-2, 2012, can be found at the link provided. http://www.aami.org/interoperability/presentations
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See the attached press release from AAMI and UL regarding their collaboration to produce a series of interoperability standards. AAMI UL Interoperability Press Release
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AAMI has published “AAMI TIR45: 2012 Guidance on the use of AGILE practices in the development of medical device software.” FDA staff was involved in development of this guidance for compliant use of Agile methods. The document can be ordered from AAMI.org.
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The final version of “ANSI/AAMI SW 87:2012 Application of quality management system concepts to medical device data systems” has been published. FDA initiated and participated in this work. Sherman Eagles, Sandy Hedberg, and Molly Ray of SoftwareCPR were on the working group and Alan Kusinitz of SoftwareCPR was a reviewer. SoftwareCPR can provide MDDS developers...
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Medical Device Interoperability Coordinating Council draft concept paper is at the link provided. This group is being facilitated by the FDA to encourage interoperability between medical devices. MDICC Draft Concept
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A proposal has been made for a fast-track amendment to IEC 62366 related to use with legacy products. Application of “62366 Medical devices – Application of usability engineering to medical devices” to legacy devices has been inconsistent and problematic; this proposal is for a fast track amendment to address what is called User Interface of...
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The European Commission has issued a final guidance on standalone software entitled: “GUIDELINES ON THE QUALIFICATION AND CLASSIFICATION OF STAND ALONE SOFTWARE USED IN HEALTHCARE WITHIN THE REGULATORY FRAMEWORK OF MEDICAL DEVICES.”  Updated in 2015.
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The UL 1998 revision comment period ends March 5, 2012. The suggested revisions include: Reducing ambiguity in the applicability of the requirements for Negative Condition Branch failure mode and stress testing Revision of requirements to address the effects of power supply voltage variations Revised formating of Table A2.1 to clarify acceptable measures for each requirement...
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This content is only available to our Standards Navigators subscribers.  See our Subscribe page for information on subscriptions. Read the Swedish formal objection to the harmonization of ISO 13485. Sweden Formal Objection ISO13485 Medical Devices
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This content is only available to Standards Navigators subscribers.  See our Subscribe page for information on subscriptions. The Industry response to the Swedish objection to ISO 13485 can be found at the following link:   Industryresponseto13485objection I had previously posted regarding the Swedish objection at this link:  Swedish objection to ISO13485 Harmonization
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This content is only available to Standards Navigators subscribers.  See our Subscribe page for information on subscriptions. The link provides the formal objection to the harmonization of ISO 14971 from the European Commission.   EN Deharmonization of Cen-Standards 2010-11
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This content is only available to Standards Navigators subscribers.  See our Subscribe page for information on subscriptions. The link provides the response from ISO TC 210 to the EC objections to ISO 14971.  ISO TC210 Comments on deharmonization of EN14971
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The AAMI Human Factors committee has proposed a work item to develop a new standard: “AAMI/HE N245R2, Human factors engineering design processes for medical device software not considered a medical device”.The current proposal is the scope would be Heath IT user interface engineering for software not considered part of a medical device.
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This content is only available to Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. A new work item and draft technical report for guidance in implementing IEC 80001-1:2010. This TR provides practical guidance for doing risk management for hospital networks.The report is at the link provided until the review period ends on 24-Feb-2011. IEC...
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This content is only available to Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. A new work item and draft technical report for guidance in implementing IEC 80001-1:2010. This TR provides a framework for a dialogue between a medical device manufacturer and a hospital regarding system and data security controls. The report is at...
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This content is only available to Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. A new work item and draft technical report for guidance in implementing IEC 80001-1:2010. This TR provides guidance for considering risk when using wireless communications in a hospital.  The report is at the link provided until the review period ends...
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The pdf at the link provided is a list of detectable flaws which a manufacturer could be expected to identify and remove. This was provided to the 62304 working group by the FDA for consideration during the work on the second edition of 62304.
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The pdf at the link provided is a reprint of an article entitled An Introduction to IEC 80001: Aiming for Patient Safety in the Networked Healthcare Environment” authored by Sherman Eagles, Partner at SoftwareCPR. This is reprinted with permission from the Association for the Advancement of Medical Instrumentation (AAMI), www.aami.org. The article first appeared in...
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The new version of IEC 60601-1 (3rd edition, 2005) replaces IEC 60601-1-4, not just ISO 14971. IEC 60601-1-4 includes both risk management requirements and PEMS development process requirements. IEC 60601-1-4 remains a harmonized standard in the EU to meet the essential requirement of the MDD on PEMS, if the 2nd edition of IEC 60601-1 is...
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Sherman Eagles, a Medtronic Standards representative and co-chair of the AAMI software committee, gave a presentation on changes and new developments in software standards at the Nov 2006 Advamed conference. This presentation is at the link provided. It addresses the withdrawal of ISO/IEC 60601-1-4 and the incorporation of Programmable Electronic Medical Systems (PEMS) into the...
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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.

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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.

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