New requirements - Amendment 1 of IEC 60601-1 3rd edition IEC/EN 60601-1 Ed.3.1: Basic Safety and Essential Performance. The IEC 60601-1 is the General Overview document for the IEC 60601 Series. It has been adopted around the world over as the benchmark for the import of medical devices. The General Medical Standard contains requirements concerning basic safety and essential performance that are generally applicable to medical electrical equipment. For certain types of medical electrical equipment, these requirements are either supplemented or modified by the special requirements of a Collateral or Particular Standards. Where Particular standards exist, the General Standard should not be used alone. Amendment 1 to IEC 60601-1:2005/EN 60601-1:2006 was released in July 2012 and immediately got much attention. It is acceptable to use the standard in some markets; many designers and medical device manufacturers of medical electrical equipment should be aware of the changes and also may use the changes to justify alternate solutions for improving their products. *On May 16, 2014 the EU updated EU Official Journal for the Medical Device includes the EN 60601-1 with Amendment 1. Starting with 1 January 2018, customers using the 60601-1 standard as a presumption of conformity will need to use the EN 60601-1:2006/A1:2013. ** On November 25, 2013, OSHA published a notice in the Federal Register proposing acceptance of ANSI/AAMI ES60601-1:2005/(R)2012 Medical electrical equipment, Part 1 including the first amendment. Since 2014 - OSHA NRTL’s approved for AAMI ES 60601-1 3rd edition + Amendment 1 (or edition 3.1). There are some basic statistics for Amendment 1 against 3rd edition (IEC 60601-1:2005): ~260 changes 21 new requirements 63 modifications to requirements/tests 47 cases where risk management was deleted or made optional 19 corrections to requirements or test methods Major issues: Risk management - the general Clause 4.2 defines much clear the use of ISO 14971 for specific technical issues of IEC 60601-1, such as providing technical criteria for a specific test or justifying an alternate solution. Full assessment of ISO 14971 is not required, and post market area is specifically excluded. The standard also clearly states that an audit is not required to determine compliance. Within the standard, the number of references to risk management has been reduced, with some cases of simply reverting back to the original 2nd edition requirements. Essential performance – was adopted some colossal changes. The manufacturer shall declare exact performance limits for each essential performance function. It is not enough to say “blood pump speed” for example – as was in 3rd Edition, 3.1 Edition requires setting specification on: o range: xx-yy mL per minute o accuracy: ±xx % or ±xx mL o arterial pressure: ±xx mmHg o venous pressure -xx~+yy mmHg o fluid temperature: xx-yy °C o etc. The manufacturer should consider separately essential performance in abnormal or fault conditions. For example under a hardware fault condition a blood pump may not be expected to provide flow with 10% accuracy, but it should still confidently stop the blood flow and generate a high priority alarm. Care is needed, as the definition of a single fault condition includes abnormal conditions, and many of these conditions occur at higher frequency than faults and therefore and require a special response. User errors, low batteries, power failure, use outside of specified ranges are all examples where special responses and risk controls may be required that are different to genuine fault condition. For example, even a low risk diagnostic device is expected to stop displaying measurements if the measurement is outside of the rated range or battery is too low for accurate measurement. Essential performance must also be declared in the technical description. This is major change since it forces manufactures to declare essential performance in the commercial world, especially visible since most manufacturers incorporate the technical description in the operation manual. Until now, some manufacturers have declared there is no essential performance, to avoid requirements such as PEMS. But writing “this equipment has no essential performance” would raise the obvious question … what good is the equipment? In Edition 3 of the General Standard, the only test clause which requires essential performance is the defibrillator proof tests. Now, in 3.1 edition, essential performance is mentioned in the compliance criteria many times in Clauses 9 (Protection against MECHANICAL HAZARDS), 11 (Protection against excessive temperatures and other HAZARDS) and 15 (Construction of ME EQUIPMENT). These are stress tests including mechanical tests, spillage, sterilization and cleaning. The good news is that the standard makes it clear that functional tests are only applied if necessary. So, if engineering judgment says that a particular test is unlikely to affect performance, there is no need to actually test performance. New marking requirements - contact information, serial number and date of manufacture are now required on the labeling, aligning with EU requirements. The serial number is of special note, since the marking method is often different to the main label. Accessories are also required to marked with the same details (contact information, serial number, date of manufacturer). This also fits with EU requirements, provided that the accessory is placed on the market as a separate medical device. This may yield an effective differentiation between an “accessory” and a “detachable part” – accessories are detachable parts which are placed on the market separately. Both the instructions for use and the technical description - must have a unique identifier (e.g. revision number, date of issue). For defibrillation tests - any unused connectors must not allow access to defibrillator energy (effectively requires isolation between different parts/ special connectors). Mechanical tests for instability and mobile equipment (rough handling test) were modified. The previous 15W/900J exemption of secondary circuits from fire enclosure/fault testing has been expanded to 100VA/6000J if some special criteria are met (e.g. using PCB with FV1 rating). Since the criteria are easy to meet, it will greatly expand the areas of the equipment that does not need a fire enclosure or flame proof wiring; welcome news considering the huge environmental impact of flame retardants. For PEMS - selected references to IEC 62304 are now mandatory (Clauses 4.3, 5, 7, 8 and 9) I.T.L. has a highly trained team in the medical electrical equipment testing and certification to IEC 60601-1 for all the major markets. ITL is an independent test and certification laboratory, accredited to ISO/IEC 17065 and ISO/IEC 17025. International agencies and institutions that certified ITL include A2LA, Intertek (ETL), TUV, UL, CSA, FCC, DNV, Industry Canada (IC), Nemko, NATA, “Israeli Ministry of Economy” and more. ITL is a certification body and test lab under the IECEx and a CBTL lab under the IECEE CB scheme. ITL is accredited and performs testing, certification and evaluation in the areas of Safety, EMC, Radio, Telecom, Environmental and Explosive Environment based on International and local standards.