We’re just over a month in to the year and the FDA’s CDRH have published a final version of their guidance “Applying Human Factors and Usability Engineering to Medical Devices”.
The document, published on 3 February, is the result of nearly 5 years of consultation with industry since releasing a draft guidance back in 2011.
Detailed examination of the published guidance is probably a topic for another time (as there’s lots to discuss). For now, I’ll make you aware that it contains some key bits of information about:
- Human Factors Engineering process
- Risk Management and Human Factors
- Design Verification
- Summative Human Factors testing
- Human Factors Engineering Summary report
- Changes to products already on the market
In this and subsequent posts, we’ll look at how they may impact what you’re either already doing, or plan to do. Let’s get started with the first two topics.
Human Factors Engineering process
The expectations of your HFE process have been simplified, harmonising with ISO 62366. They’re closely aligned with how we’ve been supporting our clients’ HFE activities.
It may be that your process for HFE is either too simplistic for what’s required (e.g. just focussing on usability of the device), or sits out of alignment with the agency’s expectations. Take the time now to review what you have in place and identify where changes may be required.
Risk Management and Human Factors
As with last year’s revisions to ISO 62366, there’s now a clear emphasis on Risk Management from the User’s perspective (aligned with ISO 14971: Application of risk management to medical devices), throughout an HFE programme. The concept of a hierarchy for risk elimination or reduction measures by and large remains intact, however there are now 3 levels;
- Inherent safety by design;
- Protective measures in the medical device or the manufacturing process;
- Information for safety.
As you’ll probably be aware, the agency expects risk mitigation measures to start at the top of the hierarchy.
Users and Use Related Hazards are placed front and centre, with the importance of identifying and categorising (for subsequent risk control activities) the Critical Tasks in using your device (or combination product) underlined through extensive discussion in the guidance document. Indeed, this part of the published guidance includes techniques like Task Analysis, Heuristic Analysis and Expert Review as your initial basis for risk identification.
Risk Management activities now play a bigger part in the analysis and reporting of your HF Validation Study. Reporting that must include an examination of residual risks, and an overall Usability risk-benefit analysis conclusion for the developed product.
Perhaps now is a good time to have an independent review of your Risk Management plan, activities and documentation to ensure they are ready to meet the agency’s newly published requirements for Use Related risks.
When is the guidance effective?
You will have some time to assimilate the requirements…
A whole 8 weeks, as they go live on 3 April 2016.
How will these changes will affect your product development?
What impact they will have upon your Human Factors Engineering programme?
Get in touch today to discuss how you can best navigate the changes and emerge with a Human Factors programme that is “just right”.