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This content is only available to Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. A SoftwareCPR example for software release note and revision history.  Software Revision Level History Example
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Advanced Botanical Consulting & Testing Inc dba ABC Testing Product: Drugs Date: 6/11/19 CMS Number: 572991 The U.S. Food and Drug Administration (FDA) inspected your contract testing laboratory, Advanced Botanical Consulting and Testing Inc. dba ABC Testing (FEI 3003693795) at 1169 Warner Ave, Tustin, California, from November 1 to 13, 2018. This warning letter summarizes...
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COURSE DATES: June 4 – 6, 2019 TRAINING LOCATION: Boston, MA USA COST: 3 Full Days for $2,495.00 (Registration closes 5/30/2019) Get 24% off for 4 or more from same company registering with same payment! Registration link: https://events.eventzilla.net/e/62304-and-emerging-software-standards-training-course-2138720953 This three-day course provides a clear understanding of the 62304 standard for medical device software, FDA expectations...
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This 62304 Conformance Checklist Tool is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. 62304 can provide an excellent framework from which to design a software process for medical device, medical mobile app, and/or HealthIT software.  62304 was created specifically for this type of software – it was not...
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John F. Murray, Jr, will be teaching at our June 4-6, 2019, FDA and 62304 Software course in Boston. Our course is designed to gain an understanding of how 62304 and other standards can be implemented efficiently and effectively while meeting FDA expectations as well.
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Special download page for job aids, checklists, and other tools.   Aid Link Checklist: Qualifying for Real-Time PMA Supplement Checklist to Qualify for a Real-Time PMA Supplement Sample 62304 Amendment 1 Checklist for audits and review of software development process 62304SoftwareCPR-Checklist_Am1-Sample-20190415 Checklist: 62304 Conformance 62304 Conformance Checklist Tool Training Aid: 62304 & 82304 Comparison 62304-82304...
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Our March 2019 Newsletter has been published.  Learn of significant regulatory and standards related activity associated medical device software, medical mobile apps, and HealthIT software.  Also you can find dates for upcoming training opportunities.
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What does one need to know about IEC 62304? In our 3-day 62304 Training course, we flow through the software development lifecycle drawing attention to requirements of the standard as well as related standards and always current FDA expectations from our experience.  The topics we plan to cover in our 2019 course are below. Topics: Regulatory...
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FDA issued a version of its “Refuse to Accept Policy for 510(k)s” dated 21-Feb-2019. This supersedes the prior 30-Jan-2018 version.  As FDA guidance goes, this a short period of time between updates.  It focuses on explaining the initial 15 day administrative completeness check, review initial questions, provision of a checklist for this administrative review which...
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On Jan 14, 2019, FDA recognized ANSI AAMI SW91:2018 Classification of defects in health software.  The FDA recognition statement for this standard does not indicate any specific use in premarket submissions or relevant FDA guidances. It simply states it supports existing policies.  This standard is lengthy and technical in terms of its approach to defect...
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Through blog posts and downloadable content, Alan Kusinitz, Sherman Eagles, Brian Pate, and other SoftwareCPR® experts keep you informed of new developments in FDA Software Regulation, enforcement actions, ISO standards related to medical devices, and also gain access to a wide variety of training aides, document templates, and checklists! Download the attached form to learn more about the different SoftwareCPR® subscriptions...
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“[W]e have received a very nice letter from the FDA indicating that they have ‘determined the device substantially equivalent to the legally marketed device…’. Needless to say we are very happy with that. Thanks so much for you help and insight. You’ve made a great difference for us.” Yves Theriault Project Manager / Gestionnaire de...
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FDA is entering the test phase of its Digital Health Precertification (Pre-Cert) Pilot Program. General information on this program can be found at: https://www.fda.gov/MedicalDevices/DigitalHealth/DigitalHealthPreCertProgram/default.htm including FAQs at: https://www.fda.gov/MedicalDevices/DigitalHealth/DigitalHealthPreCertProgram/ucm577330.htm Milestones and next steps can be found at: https://www.fda.gov/MedicalDevices/DigitalHealth/DigitalHealthPreCertProgram/ucm584020.htm Generally, this program is for some of what FDA refers to as Software as a Medical Device (SaMD). ...
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(January 7, 2019)— John F. Murray, Jr, of Mount Airy, MD USA, has joined Crisis Prevention and Recovery LLC (DBA SoftwareCPR ®) as a partner. John retired from the US Food and Drug Administration in December 2018 after 32 years of federal service. For 25 years at FDA, John focused on FDA regulated software and...
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Stay up to date and informed of new developments in FDA software regulation, enforcement actions, all the new and emerging standards activities, and gain access to a variety of training aides, document templates, and checklists.  These standards drafts are restricted to our Standards Navigators and Standards Navigator PLUS subscribers.  Items are listed newest to oldest.  If you have trouble finding an...
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62304 Training Course Overview Our flagship three-day 62304 training course provides a clear understanding of the 62304 standard for medical device software and much more.  With this training, participants will compare and contrast 62304 with FDA expectations.  Ample time is provided for discussing approaches for alignment between 62304 and FDA expectations.  Additionally, participants will learn...
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Certainly everyone with any connection to information technology and networked devices is concerned with cybersecurity. However, often we just miss the basics – we do not practice good cyber hygiene. While not intended to be comprehensive or state-of-the-art, here are some security basics (or as some call it, “cyber hygiene”) that one should consider when developing...
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Glanced through the latest FDA warning letters today.  From the FDA Medical Device & Radiological Health Operations West/Division 3 I see the inspector pointing out “This design validation also fails to include software validation [emphasis mine] to assure software will perform as intended and will not prevent safe operation by the user.”   Of course this is...
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Stay up to date and informed of new developments in FDA software regulation, enforcement actions, all the new and emerging standards activities, and gain access to a variety of training aides, document templates, and checklists.  The items below are restricted to our Premium subscribers and Standards Navigators subscribers.  Items are listed newest to oldest.  If you...
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This content is only available to Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. Questionnaire asking the national bodies to choose which approach to risk management should be used in the second edition of IEC 62304. 62304 Edition 2 Questionnaire
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Timely, insightful, and relevant thoughts, opinions, and discussion on FDA software validation, 62304 compliance, medical device software standards, updates impacting medical device and HealthIT software development, and sundry subjects from our Partners and staff.
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Feature Premium Standards Navigator A periodic email newsletter listing new items on the site and occasional analysis of selected items. X X Checklists, Templates, Articles, Presentations, etc. X X Emailed bulletins providing updates related to FDA software regulation and standards. X X Searchable access to recent software warning letter and recall excerpts. X X Announcements of new medical device and...
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SoftwareCPR®, experts in FDA and standards compliance, have an extensive network of industry-leading affiliates that work on our larger projects and/or provide special expertise.
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Instructors for internal FDA software validation training and lead instructors for public AAMI/FDA Software Regulation Training courses, Alan Kusinitz, SoftwareCPR®’s Founder and Brian Pate develop and coordinate SoftwareCPR® training courses on IEC 62304/FDA Software Process, Quality System Software (CSV, QS, Manf/process, Engineering Tools), Quality System Regulation, Design Control, Software Regulation and international medical device, Usability, and...
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We provide full-service regulatory compliance and premarket submissions support for Medical Device Manufacturers including IEC 62304 SDLC assessments (SiMD, SaMD, and HealthIT), ISO 14971 risk management process assessments, IEC 82304 SaMD assessments, general quality systems development, risk management, as well as hands-on quality system automation and medical device validation services for Pharmaceutical and Medical Device companies. We...
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Crisis Prevention and Recovery LLC does business as SoftwareCPR®.   SoftwareCPR® consists of several partners who are experts in FDA regulation (and ISO standards) in general, and medical device software in particular.  Most of our partners and affiliates are former practitioners – they were in the trenches at one time developing and/or qualifying medical devices and the software associated...
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FDA has posted their FY 2019 Proposed Guidance Development list with priorities. A link is provided below but here is the “A” list items: Final Guidance Topics Consideration of Uncertainty in Making Benefit-Risk Determinations in Medical Device Premarket Approvals, De Novo Classifications, and Humanitarian Device Exemptions Unique Device Identification: Policy Regarding Compliance Dates for Class...
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Join the SoftwareCPR® mailing list! … we will send you occasional emails notifying you of significant software related regulatory, standards activities, and upcoming training events. We respect your privacy and will not voluntarily distribute your information to others. Check out our annual subscription for access to our newsletter, training material, sample documents, and other services....
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Ron Baerg, of Seminole, FL USA, is now a partner at Crisis Prevention and Recovery LLC (DBA SoftwareCPR ®), a full service medical device compliance and premarket submissions consultancy. Ron has over twenty three years experience in medical device software development and management. His experience has been primarily focused on large, complex medical device systems...
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This content is only available to Premium level and Standards Navigator subscribers.  See our Subscribe page for information on subscriptions. SoftwareCPR has prepared a collection of production and process validation material suitable for training in Production and Quality Systems 820.70(i) Validation including Part 11.  Portions could be made into handouts or provided electronically.  Download the manual...
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The International Medical Device Forum, which FDA participates in, released a draft for comment entitled, “Essential Principles of Safety and Performance of Medical Devices and IVD Medical Devices.“  This guidance document describes fundamental design and manufacturing requirements, referred to as “Essential Principles of Safety and Performance” that, when met, indicate a medical device is safe and...
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A draft of a new revision of the NIST Framework for Improving Critical Infrastructure Cybersecurity has been circulated for comment.  This draft (NIST_cybersecurity_framework-v1-1) revision refines, clarifies, and enhances Version 1.0 issued in February 2014.  This is a draft for comment. See copy of draft Framework for Improving Critical Infrastructure Cybersecurity Version 1.1
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FDA regulation of Medical Device Data Systems has changed significantly over the years. This, together with the blurred line between MDDS and general health information technology, interfaces between MDDS and regulated medical devices, the actual criteria for deciding if something is classified as a Medical Device Data System, and different regulatory requirements outside the US...
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The EU has proposed a new regulation on cybersecurity.  While this regulation is not specific to the health sector, health is mentioned as critical infrastructure in the proposal. The proposal would provide a revised mandate, objectives, and tasks for ENISA, the “EU Cybersecurity Agency.”  The new tasks include: Facilitating the establishment and take-up of European...
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I don’t even really like to use the word retrospective
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The firm's quality system does not adequately ensure the accuracy and integrity of data to support the safety, effectiveness, and quality of the drugs manufactured - remediation required
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A short, short time ago, in this very own galaxy some companies were not making blockbusters, but medical devices. Whispers of quicker development times and better testing made the way past the water cooler until it became time to indulge and implement the mythical software development lifecycle. With the changes came weird language and rumors...
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The FDA issued the final guidance entitled “Design Considerations and Pre-market Submission Recommendations for Interoperable Medical Devices.” This guidance addresses medical devices that exchange information; whether wired or wireless, or through the internet. It includes unidirectional exchange, bidirectional, or command and control. The guidance focuses on data exchange not physical connection types. It includes a...
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UL 2900-1 Ed.1 2017 Standard for Software Cybersecurity Network-Connectable Products, Part 1: General Requirements was recognized by FDA on August 21, 2017. See at: FDA Modernization Act of 1997: Modifications to the List of Recognized Standards, Recognition List Number: 047.
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Here are some thoughts from a recent conversation between Sherman Eagles, Brian Pate, and Alan Kusinitz of SoftwareCPR®: Cybersecurity vulnerabilities can have unpredictable effects on safety.  Unpredictable effects … to those who have worked to reduce risks of software failures in medical device software, that phrase may be familiar.  That concept is explained in relation to...
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SoftwareCPR® – Human Factors and Usability Engineering Assessment Does the design of your device promote safe and effective use? Are you ready for an FDA regulatory submission requiring HFE/UE report? Do you maintain a usability engineering file for your products? Is it complete? Do you have a systematic process for identifying and analyzing use error?...
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AAMI Software and IT-related standards working groups include one for interoperability (with 3 standards work items), one for Device Security (with 2 standards work items), one for Wireless, one for SW Defect Classification, and one for AAMI/UL 2800-1 for specification of architecture independent requirements. There is also a separate Health IT Committee with several items...
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Cybersecurity firm Sophos published an article on Medical Device cybersecurity and David Overton of SoftwareCPR® suggested we post this as it may be of interest. David pointed out these statements: A significant percentage of medical devices are not secure. Most medical device manufacturers do not take serious steps to secure their devices for two reasons:...
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The U.S. government established the Office of the National Coordinator for Health Information Technology (ONC) in 2004 and increased its role significantly in 2009 to promote and certify certain aspects of Health IT, including electronic medical record systems. Although a voluntary program, certification is required to access a number of financial incentives. This is entirely...
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This content is only available to Premium and higher subscribers.  See our Subscribe page for information on subscriptions. SoftwareCPR checklist for “IEC 82304-1: Health software – Part 1: General requirements for product safety.”  Download: IEC 82304 SoftwareCPR Checklist SoftwareCPR can provide conformance assessments, training, or expert consultation for efficient use and implementation of 82304 for medical device...
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FACTA Farmaceutici S.p.A Product: drug manufacturing facility Date:1/13/2017 1. Your firm failed to ensure that laboratory records included complete data derived from all tests necessary to assure compliance with established specifications and standards (21 CFR 211.194(a)). For multiple sterile drug product lots, your original data showed failing results, but data you reported showed passing results....
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This document is the result of an industry-led initiative of the European Commission. It is targeted at app developers and its purpose is to foster justified trust among users of mHealth apps which process personal data. Standards Navigator Draft Health Code of Conduct
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/docs/scpred/standardsnavigator/EU_Data_Protection_Regulation.pdf
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The purpose of DTSec is to establish a standard used to provide a high level of assurance that electronic products for the treatment of diabetes deliver the security protections claimed by their developers and required by their users. Diabetes Tech Society Standard
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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:

Register Now

 


 

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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