Reliability in Medical Domain VIT Training Copyright © 2018 HCL Technologies Limited | www.hcltech.com Agenda HCL Reliability capabilities – Medical Domain Stages of Medical device life span Medical device classifications Risk Management PMS 2 Copyright © 2018 HCL Technologies Limited | www.hcltech.com HCL Reliability Capabilities – Medical Domain • • • • • • Reliability Plan & Approach Reliability Allocation Reliability Prediction / Physics of failure Preliminary Hazard Analysis(PHA) Fault Tree Analysis (FTA) FMEA / FMECA • • • • Design FMEA Functional FMEA Process FMEA Application FMEA • Reliability Estimation from Failure Data • Warranty Analysis • Statistical Analysis Support • Cp & Cpk Study • Gage R&R Study • DoE Studies Reliable & Safe Design • Environmental Test Compliance to reliability and safety requirements for certification • Reliability Testing - Reliability Growth Testing, ESS, ALT, HALT SW 3 Relex (FMEA, FTA, Prediction), Reliasoft (Bolcksim, Weibull++7, Alta Pro, MPC3), Cafta Copyright © 2018 HCL Technologies Limited | www.hcltech.com Global Harmonization Task Force Medical Device Definition “Medical device” means any instrument, apparatus, implement, machine, appliance, implant, in vitro reagent or calibrator, software, material or other similar or related article, intended by the manufacturer to be used, alone or in combination, for human beings for one or more of the specific purposes of: diagnosis, prevention, monitoring, treatment or alleviation of disease diagnosis, monitoring, treatment, alleviation of or compensation for an injury investigation, replacement, modification, or support of the anatomy or of a physiological process supporting or sustaining life control of conception disinfection of medical devices providing information for medical purposes by means of in vitro examination of specimens derived from the human body and which does not achieve its primary intended action in or on the human body by pharmacological, immunological or metabolic means, but which may be assisted in its function by such means. 4 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical Devices Life Span Major phases in the life span of a medical device Stages of a medical device life span (WHO, 2003) 5 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Ideal conditions for ensuring the safety and performance of medical devices 6 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Common framework for medical device regulations 7 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Tools and general requirements of the five members of the GHTF 8 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Quality system standards used by different authorities 9 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical Device Regulatory Authority 10 Country Name of Regulatory Authority USA Food and Drug Administration (FDA) UK Medicines and Healthcare Products Regulatory Agency (MHRA) Australia Therapeutic Goods Administration (TGA) India Central Drug Standard Control Organization (CDSCO) Canada Health Canada Europe European Medicines Agency (EMEA) Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical device regulatory requirements FDA’s QSRs: Title 21 CFR Part 820, esp. 820.30 European Union’s MDD 93/42/EEC ISO 13485 Medical Devices – Quality Management Systems – Requirements for Regulatory Purposes ISO 9000, Quality management systems — Fundamentals and vocabulary ISO 14971 Medical Devices – Application of Risk Management to Medical Devices ISO/TR 14969, Medical devices — Quality management systems — Guidance on the application of ISO 13485:2003 IEC 60601-1, Medical electrical equipment — Part 1: General requirements for basic safety and essential performance IEC 62304:2006 Medical Device Software – Software Life Cycle processes IEC 62366:2007 Medical Devices – Application of Usability Engineering to Medical Devices Copyright © 2018 HCL Technologies Limited | www.hcltech.com 11 Medical Device Classification - FDA 12 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Device Classification / Risk Levels 13 Device classification Risk Level Class III High Class II Moderate Class I Low Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical Device Classification in USA Medical devices are classified based on the risks associated with the use of the device. Devices are classified as Class I, Class II, or Class III, with Class I being the lowest risk and Class III the highest risk. Class I – These are devices that present minimal potential for harm to the user. Examples include enema kits and elastic bandages. 35% of medical device types are Class I and and 93% of these are exempt from pre-market review. Class II –These are devices that generally present a moderate risk of harm to the user. Examples of Class II devices include powered wheelchairs and some pregnancy test kits. 53% of device types are Class II, most of which require FDA review through premarket notification (510(k)). Class III – These are devices that sustain or support life, are implanted, or present potential high risk of illness or injury. Examples of Class III devices include implantable pacemakers and breast implants. 9% of device types are Class III and require FDA review through premarket approval (PMA) or humanitarian device exemption (HDE). Unclassified/Not classified – These are device types that FDA has not yet classified. 3% of device types are unclassified/not classified.. 14 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical Devices Regulated in the United States Premarket Notification [510(k)] – submission required to demonstrate that the device is substantially equivalent to a device already placed into one of the three device classifications before it is marketed. Premarket Approval (PMA) – application required to demonstrate that the device is safe and effective when used. It is the most stringent type of device marketing application and is required for Class III devices. Humanitarian Device Exemption (HDE) – a marketing application for a Humanitarian Use Device (HUD). An HUD is a medical device that is intended to benefit patients in the treatment or diagnosis of a disease or condition that affects, or is manifested in not more than 8,000 individuals in the United States per year. 15 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Medical Device Classification across the globe Risk Level India Australia Canada EU Japan USA Low A I I I General I Low-Moderate B IIa II IIa Controlled II Moderate-High C IIb III IIb High III IV III Highly Controlled III 16 D Copyright © 2018 HCL Technologies Limited | www.hcltech.com Design Strategy – Waterfall model FEASIBILITY PHASE Specification DESIGN & DEVELOPMENT Feasibility SW & HW Detail Design PRODUCTION IN-SERVICE Prototype Development Production Field Use Figure 1 – Application of Design Controls to Waterfall Design Process (figure used with permission of Medical Devices Bureau, Health Canada) 17 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Why Risk Management? 18 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Evolution of Risk Management 19 Copyright © 2018 HCL Technologies Limited | www.hcltech.com ISO 14971 - Medical devices – Application of risk management to medical devices Scope: Specifies a process for a manufacturer to identify the hazards associated with medical devices, including in vitro diagnostic (IVD) medical devices, to estimate and evaluate the associated risks, to control these risks, and to monitor the effectiveness of the controls. Applicable to all stages of the life-cycle of a medical device. Does not apply to clinical decision making. Does not specify acceptable risk levels. Does not require that the manufacturer have a quality management system in place. However, risk management can be an integral part of a quality management system. 20 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 21 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 22 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 23 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 24 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 25 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 26 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 27 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 28 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Terms and definitions 29 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Management Plan Scope of the plan Responsibilities and authorities Criteria for acceptability Process of collecting post production information Record of changes 30 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Management File Risk Management file shall provide traceability for each identified hazard to: The risk analysis The risk evaluation The implementation and effectiveness of the risk control measures The evaluation of the acceptability of any residual risks 31 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Elements of Risk Management 4 elements of Risk Management are ⎯ risk analysis; ⎯ risk evaluation; ⎯ risk control; ⎯ production and post-production information. Risk Management Process Identify hazards Monitor the effectiveness of the controls Estimate Risk Control Risk Evaluate Risk Conception Disposal Life Cycle 32 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Schematic representation of the risk management process 33 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Hazardous Situation Hazard Hazard Risk Exposure Hazardous Situation 34 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Analysis Process Intended use / Identification of product and functional characteristics related to safety of the medical device. Identification of device related hazards. Estimation of device related to hazards. First Identify the hazard (Potential source of harm). Next, Identify the hazardous situation (Circumstance in which people, property (or) the environment are exposed to one (or) more hazard). With these information, define the foreseeable sequence of events (and their probabilities) that may lead to harm. 35 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Examples of hazards – Annex E (ISO 14971) 36 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Examples of initiating events and circumstances - Annex E (ISO 14971) 37 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Relationship between hazards, foreseeable sequences of events, hazardous situations and the harm that can occur - Annex E (ISO 14971) 38 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Risk = f {P Harm , SHarm } PHarm = Probability of occurrence of Harm SHarm = Severity of that Harm 39 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Qualitative Severity Level 40 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Semi-quantitative analysis 41 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Evaluation & Risk Acceptability International Standard does not specify acceptable risk. Risk Acceptability criteria decided by Manufacturer. Criteria is defined in RM plan. Estimated Risk is low, Risk reduction need not be pursued. Else, Risk reduction shall be performed. 42 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Example of a three-region evaluation matrix 43 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Evaluation 44 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Risk Control – Option Analysis Designing for inherent safety Protective measures in the medical device or manufacturing process Information for safety 45 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Examples of Risk control measures 46 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Overview of risk management activities as applied to medical devices 47 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Post Market Surveillance Data Analysis Challenges: • Failure trend and monitoring between product variants • Money incurred on the products during service and warranty • Minimum inventory level at warehouses at different Geographical locations • Relationship between the product failures and trends (Geos, abnormalities, manufacturing changes, use errors etc.,) • Mapping PMS trends to gage the effectiveness of risk controls • Calibration of product risk thresholds and risk profile Risk Analysis Risk Evaluation Risk Control Risk Estimation Occurrence of Harm (P1) Evaluation of Overall Residual Risk Acceptability Risk Management Report Risk Criteria – Product Threshold Monitor Complaint Trends Product Performance Between Competitors Probability Estimation from Clinical Data Severity Occurrence Product Performance Between Variants Vital Few Contributors PMS Complaints Violations from Specification Limit Severity of Harm (P2) Risk Probability Estimation from Product Complaint Data Production and Post-Production Information Product Performance @ Different Geographical Locations Product Failures @ Different Time period Complaints Violations from Specification Limit Post Market Surveillance Data 48 Copyright © 2018 HCL Technologies Limited | www.hcltech.com Presentation prepared for Example: Aftermarket Reliability Analysis for Insulin Pump Business Need • To study the field performance of insulin pump and reduce the field compliance. Project Scope • To determine the field reliability of Insulin Pump • Identify field failure contributors • Improvement suggestions • Warranty Analysis Output Challenges Weibull plot • Availability of field data • Time to failure. • Limited information on field usage condition for the failed component. Inputs: Shipment Qty • Understand the Field failure trend. Areas of Work: • Field Failure Data Analysis Best Dist • Field returns forecast during warranty duration. • Provide inputs for spares planning. Reliability Metrics • Identification of reliability concern. Weibull Distribution Parameters • Supports rational decision making process for design modifications or preventive Inputs: NEVADA Format Sales Vs returns Field data maintenance Field Data Analysis 49 Determination of Failure Distribution with mathematical analysis Estimation of parameters of distribution Copyright © 2018 HCL Technologies Limited | www.hcltech.com