Orcanos Cafe – Recent Regulatory 2013 Updates

Report
‫‪Orcanos Café‬‬
‫עידכונים ודרישות חדשות בתחום התוכנה למיכשור‬
‫רפואי‪ ,‬ובנושא פיתוח תוכנה רפואית ב‪Mobile -‬‬
‫‪Orcanos Dec. 2013‬‬
Software Development and
Validation – Updated Status
Mike Ze’evi
SoftQuest Systems
www.softquest.co.il
email: [email protected]
Copyright SoftQuest Systems 2013
2
Topics





What is the issue?
Standards and guidances
Verification and Validation
SOUP
General and summary
Copyright SoftQuest Systems 2013
3
FDA Annual Report 2011


Software Failures Responsible for 24%
of all Medical Device Recalls
The absence of solid architecture and
"principled engineering practices" in
software development affects a wide
range of medical devices, with
potentially life-threatening
consequences.
Copyright SoftQuest Systems 2013
4
FDA Annual Report 2011


The agency has come under fire in recent years for
not holding manufacturers' accountable for insecure
or poorly written software.
"Manufacturers are responsible for identifying risks
and hazards associated with medical device
software (or) firmware, including risks related to
security, and are responsible for putting appropriate
mitigations in place to address patient safety."
Copyright SoftQuest Systems 2013
5
Software in the Medical Device
Medical Device Software can be
 part of the medical device itself
 an accessory to the medical device
 the medical device itself
Copyright SoftQuest Systems 2013
6
FDA Software Development
Standards

General Principles of Software Validation, FDA,
CDRH, 11/1/02

Guidance for the Content of Premarket Submissions
for Software Contained in Medical Devices, FDA,
CDRH, 11/5/05

Off-The-Shelf Software Use in Medical DevicesFDA,
CDRH, 9/9/99
Copyright SoftQuest Systems 2013
7
62304

Edition 1
– Approved 2006
– FDA approved it as a consensus standard
– CE approved as standard for software development

Edition 2
–
–
–
–
–
–
Should be released Q1/2014
Interim updates for future major release
Advance draft copy available
Adds flow for determining Software Safety Classification
Relates to validation of legacy software
Miscellaneous clarifications and technical changes
Copyright SoftQuest Systems 2013
8
62304 Continued



Capability assessment will become a separate Technical
Report
Assessment TR expected during 2014
Second edition expected 2015/2016
Copyright SoftQuest Systems 2013
9
60601


3rd edition released 2005
Amendment 1 released 7/12
– Known as edition 3.1
– Risk management according to IEC 14971:2007
– Software development lifecycle according to IEC
62304:2006
– Usability engineering according to IEC
62366:2007
Copyright SoftQuest Systems 2013
10
Risk Management Standards




ISO 14971:2007, Second edition, Medical
devices – Application of risk management to
medical devices
EN 2009, EN 2012 updates
ISO/TR 24971:2013, Medical devices Guidance on the application of ISO 14971
OD-2044 Ed. 2.0, Evaluation of Risk
Management in medical electrical equipment
Copyright SoftQuest Systems 2013
11
82304-1

IEC 82304-1 Health Software
– Draft status
– Draft copy available
– Relates to standalone health software (software intended
to be used specifically for maintaining or improving
health of individual persons, or the delivery of care)
– Should be released during 2014
Copyright SoftQuest Systems 2013
12
Medical Device Data Systems MDDS

21 CFR 880.6310, Medical Device Data Systems, FDA
– Hardware or software products that transfer, store, convert
formats, and display medical device data

SW87:2012, Application of quality management
system concepts to medical device data systems
Copyright SoftQuest Systems 2013
13
Agile Software Development

AAMI TIR45:2012, Guidance on the
use of agile practices in the
development of medical device
software
Copyright SoftQuest Systems 2013
14
80002-1

IEC TIR 80002-1:2009 Medical device
software - Part 1: Guidance on the
application of ISO 14971 to medical device
software
– Released in 2009
– Relates to the software risk analysis on the
operational software in the formal risk
management process
Copyright SoftQuest Systems 2013
15
80002-2

IEC/TIR 80002-2, Validation of software for
regulated processes
– Draft, due to be released in 2014
– Current guidance is TIR36:2007
Copyright SoftQuest Systems 2013
16
Mobile Medical Applications


Mobile Medical Applications, FDA, CDRH,
25/9/13
What is a mobile medical application?
– Mobile apps are software programs that run on smartphones and
other mobile communication devices. They can also be
accessories that attach to a smartphone or other mobile
communication devices, or a combination of accessories and
software.
– Mobile medical apps are medical devices that are mobile apps,
meet the definition of a medical device and are an accessory to a
regulated medical device or transform a mobile platform into a
regulated medical device.
Copyright SoftQuest Systems 2013
17
Mobile Medical Applications Continued

The FDA is taking a tailored, risk-based approach
that focuses on the small subset of mobile apps
that meet the regulatory definition of “device” and
that:
– are intended to be used as an accessory to a regulated
medical device, or
– transform a mobile platform into a regulated medical
device.
– Mobile apps span a wide range of health functions. While
many mobile apps carry minimal risk, those that can pose
a greater risk to patients will require FDA review.
Copyright SoftQuest Systems 2013
18
80001






Application of risk management for IT-networks incorporating
medical devices
IEC 80001-1:2010, Part 1: Roles, responsibilities and activities
IEC 80001-2-1:2012, Part 2-1: Step by step risk management
of medical IT-networks - Practical applications and examples
IEC 80001-2-2:2012, Part 2-2: Guidance for the disclosure
and communication of medical device security needs, risks
and controls
IEC 80001-2-3:2012, Part 2-3: Guidance for wireless networks
IEC 80001-2-4:2012, Part 2-4: General implementation
guidance for Healthcare Delivery Organizations
Copyright SoftQuest Systems 2013
19
FDA Guidances



Content of Premarket Submissions for
Management of Cybersecurity in Medical
Devices, draft, 14/6/13
Radio Frequency Wireless Technology in
Medical Devices, 14/8/13
Global Unique Device Identification
Database (GUDID) – draft, 9/13
Copyright SoftQuest Systems 2013
20
Patient-Centric Integrated Clinical
Environment (ICE)

ASTM F2761-09 (2013), Medical Devices and
Medical Systems — Essential safety requirements
for equipment comprising patient-centric integrated
clinical environment (ICE) — Part 1: General
requirements for network control
Copyright SoftQuest Systems 2013
21
Future Software TIRs


AAMI TIR on Guidance on Health Software
Safety and Assurance
AAMI TIR on Classification of defects
contributing to unacceptable risk in health
software
Copyright SoftQuest Systems 2013
22
Software Verification and Validation


Verification – provides objective evidence that the
design outputs of a particular phase of the software
development life cycle meet all of the specified
requirements for that phase; did we build the
software correctly?
Validation – confirmation by examination and
provision of objective evidence that software
specifications conform to user needs and intended
uses, and that the particular requirements
implemented through software can be consistently
fulfilled; did we build the correct software?
Copyright SoftQuest Systems 2013
23
Software Validation Review Model


To ensure that the software validation
regulatory requirement has been met
To ensure that the software validation
is sufficient based upon the complexity
and risk of the software
Copyright SoftQuest Systems 2013
24
Additional Issues







Process and documentation
SOUP
Source code
Security and Cybersecurity
Mobile apps
Internet
...
Copyright SoftQuest Systems 2013
25
SOUP – Software Of Unknown
Provenance




Legacy software in the organization
Software developed for other projects in the
organization
Procured software without source code
Open source software
Copyright SoftQuest Systems 2013
26
FDA Issues – Source Code



The FDA have requested from companies to
submit their source code for review or
submit the SCA Report
The code is reverse engineered to show the
detailed design, which is then reviewed by
the FDA
The code is analyzed using a Static Analysis
tool, which serves as a basis to conclude if
the code is “safe”
Copyright SoftQuest Systems 2013
27
FDA - Static Analysis



There are a number of tools that the FDA uses,
including:
Coverity, Polyspace, Parasoft, PQRA, Klocwork,
Grammatech, Code Sonar
If a recognized static code analysis tools is used in the
project, the report may be submitted instead of the
source code.
According to various sources, the probability of the FDA
requesting the source code for infusion pump software
is high.
Copyright SoftQuest Systems 2013
28
Looking Ahead



Have a good software process defined in a
procedure that is practical and affordable
Even if using sub-contractors, have them
work according to your defined software
procedure, and monitor their work
Software documentation should be correct,
concise, compliant, controlled and complete
Copyright SoftQuest Systems 2013
29
Summary





Software in medical devices should be
related to seriously
Documentation and testing are closely
reviewed
Do it right and don’t overkill
Define the process and work accordingly
Use professionals
Copyright SoftQuest Systems 2013
30

similar documents