WP Risk Management Web
WP Risk Management Web
Contents
Introduction3
Conclusion 22
References23
Author 25
Peer Reviewers 26
Disclaimer
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reviewed work. Although it may be a sponsored publication, it is
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BSI Risk management for medical devices and the new BS EN ISO 14971 3
Introduction
Risk perception in early days In later years, people would apply ‘trial and error’
Risk management has evolved over many methods and use experience from previous
centuries. It started with awareness and the failures to improve their decisions and actions.
recognition that sometimes things go wrong, and The focus was on analysing and learning from
gradually progressed with the application of more previous mistakes and failures and on improving
structured approaches and finally developed into product designs to prevent new failures, but there
a field of science in its own right. Elaborate was less focus on reducing the consequences of
historical reviews of risk management can be the failures. This can be seen as a simple but
found in [8, 9, 10]. In the times of ancient history, effective application of post-production feedback.
people recognized that they could have good luck The industrial revolution of the 19th century
on some days and bad luck on other days. They opened a new era of mechanization. The invention
consulted priests and oracles to learn if the gods of the steam engine enabled the development of
would favour their actions and which would be locomotives and large machines for a wide variety
the right day to build a house or to embark on a of industrial applications. These machines made of
long journey. The advice was often cryptic and iron introduced new risks that were not present
ambiguous, but it provided confidence when their before. The brittleness of cast iron and the power
decisions were based on the advice given. This of pressurized steam frequently resulted in
way of dealing with uncertainty should be seen accidents with severe injuries and often with many
more as an early and limited kind of ‘risk people being injured or killed, which revealed the
awareness’ than as an effective form of risk need to develop safety principles and to perform
management. Failures and damages that reliability engineering. This led to the development
occurred were accepted and regarded as part of of safer designs and better materials (wrought
their unavoidable fate, but there were no iron, steel alloys) and to the implementation of
attempts to understand or even eliminate the protective measures with the machinery.
underlying causes.
The development of statistical methods in the 17th
century by Pascal [11] and later refinements by
Laplace [12] provided a mathematical basis for
probability theory. This theory enabled the
analysis of the probability of occurrence of failures
and deviations from the expected. Statistical
methods came into use by banks and insurance
companies to support decision making and to
manage financial risks. Nevertheless, it was not
until after World War II that more structured
approaches to risk analysis and risk management
came into use for product development. This was
stimulated for a large part by the growth of the
aviation and aerospace industries and the
concerns on the safety of nuclear power plants.
Structured approaches for risk analysis were
developed, such as Fault Tree Analysis (FTA),
Failure Mode and Effects Analysis (FMEA) and
Hazard and Operability Study (HAZOP). Safety
engineering also became an important topic in the
defence sector, where the first edition of the US
military standard MIL-STD-882 on system safety
[13] was published in 1977, and even more
prominently in the aviation sector, where a United
Nations specialized agency for civil aviation safety
[14] was established already in 1944.
BSI Risk management for medical devices and the new BS EN ISO 14971 5
Risk management for medical devices The second edition of ISO 14971 was published in
Performing risk management became an essential 2007 and the third edition in 2019, followed by the
requirement for medical device manufacturers revised companion document ISO/TR 24971 [2] in
with the publication of the European Directives 2020, containing extensive guidance on the
AIMDD [3], MDD [4] and IVDMDD [5]. The risk application of ISO 14971. The requirements in the
management requirements only covered risk third edition of BS EN ISO 14971 [1] are expressed
analysis and were expressed in general, not very more accurately and are elaborated with more
specific terms. Risks needed to be reduced as far detail compared to the second edition. The
as possible while taking account of the generally requirements are in line with the recognized
acknowledged state of the art and maintaining a essential principles of safety and performance of
high level of protection of health and safety. medical devices (see ISO 16142-1 [17]) and in vitro
Similar requirements can be found in the diagnostic medical devices (see ISO 16142-2 [18]).
regulations of other countries. European standard They are also aligned with the general safety and
EN 1441 [15] provided a procedure for performance requirements of the European
manufacturers to investigate the safety of medical Regulations, MDR [6] and IVDR [7]. In view of the
devices by identifying hazards and estimating risks improved and more detailed risk management
based on available information. The scope of this requirements in these regulations compared to the
standard was restricted to risk analysis because it European Directives [3, 4, 5], it is more accurate to
was intended for conformity assessment purposes, say that the general safety and performance
i.e. to support demonstrating conformity with the requirements in [6, 7] have been aligned with the
essential requirements related to risk analysis in globally accepted risk management framework
the European medical device directives. and principles that have evolved over the past
Unfortunately, the directives provide little guidance decades. As result of this alignment, there are no
on further steps in the risk management process content deviations between the risk management
and on the acceptability of residual risks. requirements of the European MDR and IVDR and
those in the third edition of BS EN ISO 14971.
ISO Technical Committee 210 (Quality
management and corresponding general aspects
for medical devices) and IEC Subcommittee 62A
(Common aspects of electrical equipment used in
medical practice) recognized the need to develop
an international standard for risk management of
medical devices and established their Joint Working
Group 1. EN 1441 [15] was taken as a starting point
and was converted with minimal editing to BS EN
ISO 14971-1 [16] in 1998, which thus also covered
risk analysis. BS EN ISO 14971-1 was intended to
be the first part in a series of standards. It was
decided later that, instead of publishing separate
parts, it would be better to publish one document
covering all elements of the risk management
process. This effort led to the first edition of BS EN
ISO 14971 [1] in 2000, in which the principles of
risk management for medical devices were
elaborated further and the entire risk management
process was described. This standard provided a
complete framework for risk management
including monitoring risks in the post-production
phase. The standard was amended with a rationale
in 2003.
BSI Risk management for medical devices and the new BS EN ISO 14971 6
Figure 1 – The six process steps in the risk management process of BS EN ISO 14971 [1].
A selection of important definitions in BS EN ISO further noted that the numbering of the clauses
14971 [1] is given in Table 1. These defined terms has changed in the third edition of BS EN ISO
are frequently used in this paper. The definitions 14971, because a clause on normative references
for benefit and reasonably foreseeable misuse are has been inserted following requirements by the
new in the third edition of the standard. It is ISO/IEC Directives.
Term Definition
Benefit Positive impact or desirable outcome of the use of a medical device on the
health of an individual, or a positive impact on patient management or public
health
Note: Benefits can include positive impact on clinical outcome, the patient’s
quality of life, outcomes related to diagnosis, positive impact from diagnostic
devices on clinical outcomes, or positive impact on public health
Harm Injury or damage to the health of people, or damage to property or the
environment
Hazardous situation Circumstance in which people, property or the environment is/are exposed to
one or more hazards
Intended use Use for which a product, process or service is intended according to the
specifications, instructions and information provided by the manufacturer
Note: The intended medical indication, patient population, part of the body or
type of tissue interacted with, user profile, use environment and operating
principle are typical elements of the intended use
Reasonably foreseeable Use of a product or system in a way not intended by the manufacturer, but
misuse which can result from readily predictable human behaviour
Note: Readily predictable human behaviour includes the behaviour of all types
of users, e.g. lay and professional users. Reasonably foreseeable misuse can be
intentional or unintentional
Residual risk Risk remaining after risk control measures have been implemented
Risk Combination of the probability of occurrence of harm and the severity of that
harm
Risk control Process in which decisions are made and measures implemented by which
risks are reduced to, or maintained within, specified levels
Top management responsibilities Top management also needs to define the policy
The commitment of top management is on how to establish the criteria for risk
indispensable for proper risk management. Large acceptability. These criteria need to be based on
corporations can consist of separate entities (such relevant international standards and the
as divisions or business units), where each entity regulations of the countries or regions where the
can have its own risk management process and its medical devices are intended to be marketed.
own quality management system. In such cases, Considerations of the generally acknowledged
top management refers to those individuals who state of the art and known stakeholder concerns
direct and control that entity. need to be taken into account as well. Local
regulations can impose that risks must be reduced
Top management is responsible for the provision as far as possible or as low as reasonably
of adequate resources and the assignment of practicable (i.e. technically feasible in practice). A
competent personnel. This means that personnel well-known concept for exposure to ionizing
need to have appropriate training and also the radiation is that the resulting radiation dose to any
tools and the time to perform the risk person must be as low as reasonably achievable
management tasks assigned to them. Top (the ALARA principle, see [19, 20]). Where
management is further responsible for the applicable, these concepts need to be incorporated
continued effectiveness of the risk management in the criteria for risk acceptability. This means that
process and, therefore, needs to regularly review the criteria need to provide guidelines on how far
its suitability at planned intervals. Information the risks shall be reduced. The end points for risk
from the post-production phase can be valuable reduction ‘as far as possible’ can be determined
input for this review. based on international standards that provide
specific state-of-the-art technical solutions or on
local regulations that have specific requirements or
limits. These concepts and the end points for risk
reduction should be described in the policy.
Frequent
Probable
Occasional
Remote
Improbable
A risk chart or risk matrix shown in Figure 2 can be The severity levels need to be described in relation
useful in supporting the estimation and evaluation to the possible harm (injury to people, or damage
of residual risk, especially those risks for which no to property or the environment). These levels can
requirements and no technical solutions exist in distinguish between life-threatening injuries,
international standards or local regulations. In serious injuries that are not life-threatening but
such cases, the criteria can require risk reduction needing immediate medical attention, major
as far as possible where the end point is based on injuries that can result in permanent damage or
the combination of the probability of occurrence of impairment, minor injuries that are transient or
harm and the severity of possible harm, as reversible, minor injuries needing limited medical
indicated in a risk chart. However, it is emphasized care, pain and discomfort. Concerning damage to
that the criteria for risk acceptability need to take property or the environment, the severity levels
the applicable regulations and standards into can distinguish between leakage of radioactive
account and need to be more comprehensive than substances, leakage of or contact with hazardous
only a risk chart, and that a risk chart by itself is chemicals, contamination with blood or other
not the criteria. It is further noted that the bodily fluids (possible infection with blood-borne
descriptors of the severity and probability levels in viruses or bacteria), loss of x-ray images (where
Figure 2 are just examples, and that more or fewer retaking adds radiation dose), loss of other images,
levels and different descriptors can be chosen (e.g. loss of data, unauthorized access to data,
Negligible, Moderate, Significant, Serious, destruction of the medical device or repairable
Catastrophic for the severity levels and damage to the medical device. The probability
Inconceivable, Unlikely, Rare, Possible, Often for range can be divided into discrete levels based on
the probability levels). ISO/TR 24971 [2] provides the probability of occurrence of harm per use, per
guidance on defining the policy and on procedure, per device, per hour of use or within a
establishing the criteria for risk acceptability. population. The choice can depend on the type of
medical device.
BSI Risk management for medical devices and the new BS EN ISO 14971 10
Term Definition
Abnormal use Conscious, intentional act or intentional omission of an act that is counter to
or violates normal use and is also beyond any further reasonable means of
user interface-related risk control by the manufacturer
Normal use Operation, including routine inspection and adjustments by any user, and
stand-by, according to the instructions for use or in accordance with generally
accepted practice for those medical devices provided without instructions for
use
Note: Normal use should not be confused with intended use. While both
include the concept of use as intended by the manufacturer, intended use
focuses on the medical purpose while normal use incorporates not only the
medical purpose, but maintenance, transport, etc. as well
Use error User action or lack of user action while using the medical device that leads to
a different result than that intended by the manufacturer or expected by the
user
Note: User error includes the inability of the user to complete a task. Use
errors can result from a mismatch between the characteristics of the user,
user interface, task or use environment. Users might be aware or unaware
that a use error has occurred. An unexpected physiological response of the
patient is not by itself considered use error. A malfunction of a medical device
that causes an unexpected result is not considered a use error
User Person interacting with (i.e. operating or handling) the medical device
User interface Means by which the user and the medical device interact
Note:User interface includes all the elements of the medical device with which
the user interacts, including the physical aspects of the medical device as well
as visual, auditory, tactile displays and is not limited to a software interface
BSI Risk management for medical devices and the new BS EN ISO 14971 12
Figure 3 – Different kinds of use and misuse of a medical device considered in usability
engineering and risk management
Abnormal use
(part of reasonably foreseeable misuse)
BSI Risk management for medical devices and the new BS EN ISO 14971 13
Some forms of misuse can be foreseen based on sometimes called ‘off-label use’. Other intentional
readily predictable human behaviour and are acts like sabotage cannot be foreseen by any
called reasonably foreseeable misuse in BS EN ISO reasonable means and are also part of abnormal
14971 [1] (see Table 1). The manufacturer needs to use. Those acts can be outside the scope of risk
document the reasonably foreseeable misuse and management and are usually not included in the
consider it in the risk management process as well. reasonably foreseeable misuse. But this is not a
Such misuse can be a use error which is performed fixed rule, because breaches of data and systems
unintentionally. However, use error can also arise security by hackers can be regarded acts of
from an intentional action, for example when the sabotage but can also be reasonably foreseen.
user consciously presses a button which appears
to be the wrong button. Since errors can normally The second step in the risk analysis is identifying
occur, both use error and correct use are the characteristics of the medical device that can
considered to be part of normal use. Risks related affect its safety. Such characteristics can be related
to use error can be analysed and evaluated using a to the performance or the operating principle of
usability engineering process, such as the one the medical device, its intended use or reasonably
described in IEC 62366-1 [21]. Those risks can often foreseeable misuse. This can concern among
be controlled effectively in the user interface (see others the materials used in parts coming into
definition in Table 2). It has to be recognized, contact with the patient, moving parts, the use of
however, that some risks related to use error radiation for diagnosis or treatment, the accuracy
cannot be reduced sufficiently in this way and may of measurements, the need for calibration or
need further control by other measures outside maintenance, the security of data or the required
the user interface. Therefore, the results of the skills of the user. These characteristics need to be
usability engineering process have to be fed back considered in the risk management process. The
into the risk management process of BS EN ISO characteristics can be qualitative or quantitative
14971. Reasonably foreseeable misuse can also and it may be necessary to establish limits that
include instances of abnormal use, which are not should not be exceeded. An extensive list of
regarded as use error and cannot be controlled in questions that can assist the manufacturer in
the user interface. Abnormal use is a term from identifying the characteristics related to safety is
usability engineering (see Table 2) and concerns, contained in ISO/TR 24971 [2]. It is emphasized
for example, the intentional use of the medical that those questions are examples and the list
device for an application that is unspecified or should not be used as a checklist.
unintended by the manufacturer. This is
BSI Risk management for medical devices and the new BS EN ISO 14971 14
The third step is identifying the hazards associated All hazardous situations and all kinds of harm need
with the medical device and identifying the to be considered, not only the worst-case scenarios
reasonably foreseeable sequences or combinations with the highest severity of harm, because scenarios
of events that can lead to hazardous situations. It with less severe harm could have a higher probability
is important to consider the medical device not of occurrence and could thus lead to a higher risk.
only in its normal condition, but also when a defect
is present or in a fault condition that could occur. Risk evaluation is also part of risk assessment. It is
The intended use, the reasonably foreseeable the step where the estimated risks are evaluated
misuse and the characteristics related to safety are using the criteria for risk acceptability as defined in
important inputs in this step. It has to be the risk management plan. The criteria for risk
emphasized that different sequences of events can acceptability are established based on the policy
lead from one hazard to different hazardous defined by top management and are documented
situations, and that one hazardous situation can in the risk management plan. The criteria can
lead to different kinds and severities of harm incorporate the concept that risks have to be
depending on the circumstances. These situations reduced as far as possible (see earlier section on
need to be considered as separate risks and should top management responsibilities). The conclusions
not be combined and assessed together. of the evaluation are documented in the risk
management file. If the risk is judged acceptable,
The fourth and final step in the risk analysis is the estimated risk becomes the residual risk. If the
estimating the risk for each of the identified risk is not judged acceptable, it is mandatory to
hazardous situations. The severity of any possible perform risk control.
harm and the probability that this harm occurs
need to be estimated. The probability of Experience shows that there is confusion about
occurrence of harm (P) can be decomposed into estimating risk when a particular risk control
the probability that a hazardous situation occurs measure is always part of the medical device
(P1) and the probability that the hazardous design. In this case it is sufficient to estimate and
situation leads to harm (P2). Such decomposition evaluate the risk after implementation of the risk
(P = P1 × P2) can be helpful but is not mandatory. control measure. It is not useful and therefore
Data and experience with previous or similar discouraged to estimate the (theoretical) risk for a
medical devices on the market can be useful in medical device without the particular risk control
estimating the risks, either qualitatively or measure in place, because it has become an
quantitatively. A risk chart as shown in Figure 2 can integral part of the medical device design.
be useful in risk estimation.
BSI Risk management for medical devices and the new BS EN ISO 14971 15
Risk control (process step 3) The risk control measures selected have to be
The manufacturer has several risk control options implemented, and the implementation verified.
for eliminating or reducing risks to an acceptable This can be done as part of design and
level. Many international standards provide specific development verification in a quality management
technical solutions to address particular risks. system. The effectiveness of the risk control
Those standards should be considered in selecting measures implemented also have to be verified,
the most appropriate options. which can be done as part of design and
development validation in a quality management
• The first and preferred option is to eliminate the system. The results of these verifications are
risk by making the design of the medical device documented in the risk management file.
and its manufacturing process inherently safe.
This ensures that a hazardous situation cannot After implementation of the risk control measures,
occur. This is often related to the operating the residual risk has to be estimated and evaluated
principle of the medical device. Examples include again using the criteria for risk acceptability. If the
designing medical devices for single use such risk is not judged acceptable, it is necessary to
that they cannot be reused, designing medical consider more risk control. These iterations are
electrical equipment such that live parts and indicated in Figure 1 with the arrows back and
high-voltage parts cannot be touched, and forth between risk control and risk assessment. If,
designing surfaces without sharp edges. after careful analysis, it is concluded that further
risk control is not practicable, the manufacturer
• If this is not possible, the second option is to may perform a benefit–risk analysis. Data and
implement protective measures in the design of literature can be gathered and analysed to
the medical device or in the manufacturing determine if the benefits of using the medical
process. Such measures can reduce the device outweigh the residual risk. If this is not the
probability of occurrence of a hazardous case, the manufacturer needs to go back in the
situation or harm and/or the severity of the process and consider to modify the medical device
harm. Examples of such measures include gloves or to restrict the intended use (for example, to
and special clothing to protect against exclude vulnerable patient groups). Otherwise, the
contamination, covers to protect against risk remains unacceptable and the medical device
electrical shock, barriers to prevent collision or development needs to be abandoned.
trapping between moving parts, lead aprons and
screens to protect against radiation. Protective Completeness is an important aspect in risk
measures also include alarms to alert people of a management. Therefore, the manufacturer is
hazardous situation needing immediate attention required to check that all identified hazardous
to avoid any harm from occurring. situations have been addressed and all risk control
activities have been completed. In addition, it has
• If protective measures do not sufficiently reduce to be checked that the selected and implemented
the risk, the third option is to provide information risk control measures do not introduce new risks
for safety to the users of the medical device. The and do not affect other risks.
information for safety can be given in the form of
warnings or contraindications, or as instructions
how to handle and use the medical device. This
information can concern in particular actions that
the user needs to take or to avoid to prevent the
occurrence of a specific hazardous situation or
harm. Some examples are warnings against
reuse of single-use medical devices, warnings for
high voltage, high temperature or radiation,
instructions to use personal protective
equipment, and instructions for calibration and
maintenance of medical devices performing
measurements. Training of users can be an
important means of providing the information
for safety.
BSI Risk management for medical devices and the new BS EN ISO 14971 16
Evaluation of overall residual risk (process manufacturer could gather data and literature to
step 4) determine if the benefits of using the medical
device would outweigh the overall residual risk. In
When one arrives at this process step, all individual
this approach it was unclear which criteria for risk
risks have been controlled and judged acceptable.
acceptability should be used and if the benefits of
In some cases, a benefit–risk analysis has been
the intended use should or could also be
performed with the conclusion that the benefits
considered in the first evaluation. Further, it was
outweigh a particular risk. Although each risk is
not clear which individual risks should be included
acceptable, it is important to also consider the
in the evaluation of the overall residual risk.
contributions of all risks together (i.e. the overall
residual risk). The reason is that the combination of
The two-step approach is replaced with one
several small risks could pose an unexpected big
evaluation in the third edition of BS EN ISO 14971.
risk. For example, there could be too many risks in
It is required that the contributions of all individual
the yellow area of Figure 2 that were each
residual risks are taken into account, and that the
investigated and for which no further risk
overall residual risk is evaluated in relation to the
reduction is possible. Another example is a
benefits of the intended use of the medical device.
particular risk control measure that is designed to
The manufacturer is required to document the
control two independent risks simultaneously,
evaluation method and the criteria for acceptability
which could be deemed unacceptable.
of the overall residual risk in the risk management
plan. This ensures an objective evaluation. The
The clause on the evaluation of the overall residual
method can include gathering data and literature
risk has undergone considerable change in the
for similar medical devices available on the market
third edition of BS EN ISO 14971 [1]. The second
and judgement by a cross-functional team of
edition provided for a two-step approach, where
experts with knowledge of and experience in
the overall residual risk was first evaluated against
application of the medical device.
the acceptability criteria. Second, if the overall
residual risk was not judged acceptable, the
BSI Risk management for medical devices and the new BS EN ISO 14971 17
ISO/TR 24971 [2] provides further guidance on device in a particular procedure, for example,
possible approaches that can be used in the erythema, that can occur after radiation therapy,
evaluation and on inputs and other considerations patients experiencing blood in their urine after
that can be taken into account. It is explained that lithotripsy of kidney stones and swelling or
the criteria for acceptability of the overall residual inflammation of the eye after ophthalmic surgery.
risk can be different from the criteria for The disclosed information enables the user to
acceptability of individual risks. In any case, these make informed decisions on whether to use this
criteria have to be based on the manufacturer’s medical device in a particular situation or to
policy for acceptable risk. If the overall residual risk choose for a different medical device, taking
is not judged acceptable, the manufacturer needs account of the condition of the individual patient.
to go back in the process and apply additional risk The disclosure of residual risks needs to be
control measures. These iterations are indicated in distinguished from information for safety, which is
Figure 1 with the arrows back and forth between a risk control measure. While the disclosure of
risk control and evaluation of overall residual risk. residual risk is descriptive and provides the user
The manufacturer can also consider to modify the with information on risks inherent to the use of the
medical device or to restrict the intended use (for medical device, information for safety is instructive
example, excluding vulnerable patient groups). and provides the user with information on how to
Otherwise, the overall residual risk remains use the medical device and on actions to take or to
unacceptable and the medical device development avoid to prevent a particular hazardous situation or
needs to be abandoned. harm from occurring. ISO/TR 24971 [2] provides
further guidance on information for safety and the
The manufacturer is instructed to inform users of disclosure of residual risk.
any significant residual risks and to disclose those
risks by providing relevant information in the
accompanying documentation. Since BS EN ISO
14971 [1] focuses on risks related to the design of
the medical device and how the manufacturer can
control them, it is important to disclose the
residual risks inherent to the use of the medical
device after all risk control measures have been
implemented. The residual risks can relate to
side-effects or after-effects of using the medical
BSI Risk management for medical devices and the new BS EN ISO 14971 18
Risk management review (process step 5) level document providing evidence that the risk
As emphasized before, completeness is an management plan has been satisfactorily executed
important aspect of risk management. Therefore, and the objectives have been achieved.
after the design and development of the medical Information from the production and post-
device and before its commercial distribution, BS production phases could reveal the need to adapt
EN ISO 14971 requires the manufacturer to review and improve the medical device during its life cycle
that the risk management plan was properly and thus also to update the risk management
executed and appropriately implemented. It also report.
needs to be ensured and recorded that the overall
residual risk is acceptable. Methods to collect and
review production and post-production
information need to be in place before the medical
device is finally released and placed on the market.
The results of this review are documented as the
risk management report, which forms a crucial
part of the risk management file. The risk
management report is signed off by persons with
the appropriate authority and serves as the high-
BSI Risk management for medical devices and the new BS EN ISO 14971 19
Other standards and guides for safety and The concepts and definition of risk in BS EN ISO
risk management 14971 are in strong contrast with those in ISO
Guide 73 [28] (risk management vocabulary) and
As a risk management standard, the purpose of BS
BS ISO 31000 [29] (risk management guidelines).
EN ISO 14971 [1] is to assist manufacturers in
Risk in [28, 29] is defined as the effect of
achieving safety (i.e. freedom from unacceptable
uncertainties on (business) objectives. Since these
risks) for the medical devices that they develop and
effects can be positive or negative, the risk in the
place on the market. BS EN ISO 14971 is based on
latter documents can be related to threats as well
ISO/IEC Guides 51 and 63. ISO/IEC Guide 51 [26] is
as opportunities. The guidelines in BS ISO 31000
addressed to writers of international standards for
are expressed in general, high-level language and
all sectors and provides guidelines on how to
are intended for business risk management and
include safety aspects. ISO/IEC Guide 63 [27]
dealing with uncertainties. This makes BS ISO
provides guidelines on how safety aspects should
31000 not suitable for applying safety principles
be included in standards specifically for the
and managing risks in product development.
medical device sector. This guide was developed
Nevertheless, one can recognize the typical
based on ISO/IEC Guide 51 and is addressed to
process steps that are present in any risk
writers of international standards for medical
management process [1, 10, 13, 26, 27]. However,
devices. This was considered necessary in view of
the general guidelines of BS ISO 31000 need to be
the high importance of safety and the strict
‘translated’ carefully to each specific situation and
regulatory requirements in this sector. The two
each specific product being considered. For the
standards expressing the essential principles for
application of risk management to medical devices,
safety and performance of medical devices [17]
this translation has already been performed in ISO/
and in vitro diagnostic medical devices [18] are
IEC Guide 63 [27] and BS EN ISO 14971.
based on BS EN ISO 14971 and ISO/IEC Guides 51
and 63. Risk in all these documents is defined in
terms of the probability of occurrence of harm and
the severity of possible harm. In all safety
standards directly or indirectly derived from ISO/
IEC Guide 51, harm can be injury or damage to the
health of people, but also damage to property or
the environment (see Table 1). Thus, we can say
that the concepts of risk in these documents are
based on well-established safety principles.
BSI Risk management for medical devices and the new BS EN ISO 14971 22
Conclusion
References
10. Aven, T. (2016) Risk assessment and risk 20. Council Directive 2013/59/EURATOM laying
management: Review of recent advances on down basic safety standards for protection
their foundation. European Journal of against the dangers arising from exposure
Operational Research, 253, 1-13. to ionising radiation (2013)
11. Ore, O. (1960) Pascal and the invention of 21. BS EN 62366-1:2015+A1:2020, Medical
probability theory. The American devices – Part 1: Application of usability
Mathematical Monthly, 67, 409-419. engineering to medical devices
BSI Risk management for medical devices and the new BS EN ISO 14971 24
Author
Reviewers
Paul Sim, Medical Devices Knowledge Manager, Eamonn Hoxey, Director, E V Hoxey Ltd
BSI Standards Eamonn is a technical author, trainer and
Paul has worked in the healthcare industry for consultant in a range of life science areas
over 35 years, joining BSI in 2010 to lead the including regulatory compliance, quality
organization in Saudi Arabia where it had been management, sterility assurance and standards
designated as a Conformity Assessment Body. development. He worked for Johnson & Johnson
Later, he managed BSI’s Unannounced Audits for 17 years in positions of increasing
programme. Since October 2015, he has been responsibility for Quality and Regulatory
working with both the Notified Body and Compliance for medical devices, pharmaceuticals
Standards organizations looking at how best to and consumer products, including Vice President
use the knowledge, competencies and expertise of Compliance, Vice President of Market Quality
in both. Previously he held senior RA/QA and leading quality implementation for the EU
leadership positions at Spacelabs Healthcare, medical devices regulation for J&J’s Medical
Teleflex Medical, Smiths Medical and Ohmeda Devices companies. Prior to joining J&J, Eamonn
(formerly BOC Group healthcare business). Paul spent 16 years with the UK Medical Devices
is a member of the Association of British Agency, including six years as Head of Device
Healthcare Industries (ABHI) Technical Policy Technology and Safety. Eamonn is currently chair
Group and Convenor of the ABHI ISO TC 210 of ISO TC 198, Sterilization of Healthcare
Mirror Group. He is Convenor of the BSI products, chair of CEN TC 204 ‘Sterilization of
Committee that monitors all of the work medical devices’ and past chair of ISO TC 210
undertaken by ISO TC 210, and Convenor of the ‘Quality management and related general
BSI Subcommittee dealing with quality systems. aspects for medical devices’. He received the BSI
As UK Delegation Leader to ISO TC 210, he is also Wolfe-Barry medal in 2016 for his contribution to
actively involved in the work of national, standards development.
European and international standards’
committees.
BSI Risk management for medical devices and the new BS EN ISO 14971 27
• The growing role of human factors and usability • The impact and potential for 3D printing and
engineering for medical devices: What’s required in bioprinting in the medical devices industry, Kenny
the new regulatory landscape? Bob North Dalgarno
• The differences and similarities between ISO • Sterilization – Regulatory requirements and
9001:2015 and ISO 13485:2016: Can we integrate supporting standards, Eamonn Hoxey
these quality management standards? Mark
Swanson • Medical device clinical investigations – What’s new
under the MDR? Maria Donawa
• Planning for implementation of the European
Union Medical Devices Regulations – Are You • The convergence of the pharmaceutical and
Prepared? Eamonn Hoxey medical devices industries: Navigating the
innovations and regulations, Barbara Nasto and
• Cybersecurity of medical devices: Addressing Jonathan Sutch
patient safety and the security of patient health
information, Richard Piggin • Phthalates and endocrine disruptors – An overview
of their safety requirements and evaluations and
• The European Medical Devices Regulations: What the standards that support them, Benjamin Seery
are the requirements for vigilance reporting and
post-market surveillance? Eamonn Hoxey • European Union Medical Device Regulation and In
Vitro Device Regulation: unique device
• General Safety and Performance Requirements (Annex identification: What is required, and how to
1) in the New Medical Device Regulation: Comparison manage it, Mary Gray
with the Essential Requirements of the Medical Device
Directive and Active Implantable Device Directive, • Person responsible for regulatory compliance
Laurel Macomber and Alexandra Schroeder (PRRC) – MDR/IVDR Article 15: An overview of the
requirements and practical considerations, Anne
• Do you know the requirements and your Jury and Maddalena Pinsi
responsibilities for medical device vigilance
reporting? A detailed review on the requirements of • Guidance on MDCG 2019-9: Summary of Safety
MDSAP participating countries in comparison with and Clinical Performance, Amie Smirthwaite
the European Medical Device Regulation 2017/745,
Cait Gatt and Suzanne Halliday • Clinical evaluation under EU MDR, Amie
Smirthwaite
• Technical Documentation and Medical Device
Regulation: A Guide for Manufacturers to Ensure • Medical device clinical investigations — What’s new
Technical Documentation Complies with EU under the MDR? An update, Maria Donawa
Medical Device Regulation 2017/745, Dr Julianne
Bobela, Dr Benjamin Frisch, Kim Rochat and • Using Standards to Demonstrate conformity with
Michael Maier Regulations, Eamonn Hoxey
• Nanotechnology: What does the future look like for Forthcoming white papers
the medical devices industry? Professor Peter J • Requirements of EU-GDPR and PMCF studies,
Dobson, with Dr Matthew O’Donnell 23 registries and surveys under the MDR (working
title), Richard Holborow
• Developing and maintaining a quality
management system for IVDs, Melissa Finocchio • Performance Evaluation for IVD, Fiona Gould