Transcript Internal Auditor Training

Risk Management
An integral part of the Quality Management System
Instructor:
Angelo Scangas
Quality Support Group, Inc.
[email protected]
978-430-7611
www.qualitysupportgroup.com
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Risks related to product safety
 Integration of risk management into
QMS applies to ALL stages of product’s
life cycle
 Elements of risk management fit well into
several of the quality system elements
(ISO 13485 for example)
 Applicable standard - ISO 14971:2007
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Risk Management
 The requirements that it contains
provide a framework within which
experience, insight and judgement are
applied systematically to manage risks.
 Risk management is a complex subject.
 Each stakeholder places a different
value on the probability of harm
occurring and on the detriment that
might be suffered on exposure to a
hazard.
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Risk Management
 It is accepted that the concept of risk
has two components:
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the probability of the occurrence of harm,
that is, how often the harm may occur;
the consequences of that harm, that is,
how severe it might be.
 The acceptability of a risk to a
stakeholder is influenced by these
components and by the stakeholder’s
perception of the risk.

Stakeholders - medical practitioners, the
organizations providing health care,
governments,
industry, patients and
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members of the public.
Risk Management Flow
 Risk Analysis

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Hazard Identification
Estimation of risks for the consequences of
each hazard
 Risk Evaluation

Acceptability of risks that have been
evaluated
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Risk Management Flow
(cont’d)
 Risk Control

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Process through which decisions are
reached
Protective measures to reduce, eliminate
unacceptable risks
 Post Production Information


Establish new design safety requirements
Baseline for future risk management of
similar designs
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Risk Management File
 A Risk Management File should
exist (or other appropriate files
referred to, e.g., design history
files, technical files, device
master records, process
validation, post market
surveillance/ customer
feedback, etc).
 Document controls should be
applied
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 The overall process specified
Risk Management File
 Std states that it need not physically
contain ALL the documents but at least
references or pointers to required
documentation
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Terminology
 It is very beneficial to list common terms
on hazards and or patient (human)
harms
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Management Responsibilities
 Should begin with top management
 Management can demonstrate
commitment by establishing

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State approach in helping determine what
is an acceptable risk
Provide resources, include trained
personnel
Review the results at defined intervals
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Risk Management
 Risk management applied throughout
product realization
 Spans whole life cycle of product

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Planning of product realization
Customer related processes
Design and development
Purchasing, production, servicing
provisions
Post marketing/ customer feedback
information
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Risk Management cont’d
 Objective is NOT to eliminate ALL risks,
rather to reduce to acceptable level
 Formalized brainstorming session of
predicting potential failure modes and
hazards
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ISO 14971:2007
Risk Management Process
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Identification of hazards
 Information can come from published
data, competitive device information,
simulated tests, clinical evidence (see
4.4 of ISO 14971) experience from
previous designs…
 Appendix A of ISO 14971 can be useful
tool to develop initial checklist
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Intended use and identification
of characteristics related to
safety of device
 List the quantitative and qualitative
characteristics that could affect the
safety of the device
 Formal list of known or foreseeable risks
in both normal and fault conditions
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Risk Estimation
 For each hazard (normal and fault
conditions) the risk should be estimated;
Where they cannot a listing of the
possible consequences of the hazard
shall be prepared
 Any system for qualitative, quantitative of
probability (likelihood) OR severity
estimates shall be recorded
 For estimation of risk (sometimes
referred to as “likelihood”) see section of
4.4 of ISO 14971
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Severity
Ranking
Severity
Level
Severity Definitions (possible actions associated with potential failure)
1
Very Low
Minor nuisance, may effect product appearance, not used in patient; no patient
safety concern, possible performance degradation
E.g. Cannot prep device/system, not used in patient, select another
device/system
2
Low
Degraded performance, may remove and replace device/system, may extend
invasive procedure time; no patient safety concern, degraded performance
E.g. Used in patient, removed due to degraded performance, select another
device/system
3
Moderate
Requires unplanned but not uncommon medical management, with or without
degraded performance; moderate patient safety concern
E.g. Filler remnant in parent artery, additional anticoagulant medication given
E.g. Distal emboli, attempt to retrieve emboli
4
High
5
Very High
Requires unplanned medical intervention with or without prolonged hospital stay
to prevent or mitigate serious injury or death; high safety concern
E.g. Rupture of aneurysm or parent artery
Likely to cause death or serious permanent injury; catastrophic safety-related
effects
E.g. Catastrophic aneurysm rupture with hemorrhagic and/or ischemic stroke
and/or permanent neurological deficit
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Failure mode likelihood levels
1. 1/10,000 or less frequent (10-4)
2. between 1/1000 and 1/10,000
3. between 1/100 and 1/1000
4. from 1/10 to 1/100
5. more frequent than 1/10
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Failure mode detectability
levels
 High detectability

Failure is visually evident and likely to be
noticed by a trained operator
 Medium detectability

Product or process is specifically tested or
monitored for this failure mode
 Low detectability

Failure mode is neither visually evident nor
specifically tested or monitored
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Severity/ Frequency example
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Risk estimation cont’d
 Risk estimation can be qualitative or
quantitative. Annexes E and F in ISO
14971 provide some details on how
 Other techniques for estimation include:

Published standards, scientific data,
reportable incidents on competitive
devices, clinical trial evidence, expert
opinions, etc
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Risk Evaluation
 ISO 14971 states “Risk evaluation, for
each hazard, mfr. decides whether
estimated risk so low risk reduction need
not be pursued.”
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Risk Control
 When risk reduction is necessary the
manufacturer should identify risk control
measures by:
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Providing inherent safety measures by
design
Protective measures on the medical device
itself
Providing information for safety
(instructions for use, labeling, etc.)
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Risk control cont’d
 If it is impracticable to reduce risk with
risk controls a risk/ benefit analysis of
remaining risk should be documented
 All risk control measures should be
verified; ISO 14971 defines verified as
“Confirmation by examination and
provision of objective evidence that
specified requirements have been met”
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Risk control cont’d
 Residual risk evaluation after risk control
measures applied and verified. If
residual risk unacceptable, further risk
controls are necessary (unless
impracticable and then risk/ benefit
statement needed).
 Risk benefit

Review published literature on medical
benefits to see if risk outweighed by
benefits
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Risk control cont’d
 Were other new risks generated with risk
control measures?
 The overall completeness of the risk
evaluation should be assessed
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Risk Management Flow Chart
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Flow chart cont’d
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Post Production information
 A procedure AND PLAN shall exist that requires
a review gained by the device or similar devices
in post production phase that reveals potential:
 Previously unrecognized hazards
 If estimated risk is no longer acceptable
 If original assessment is otherwise
invalidated
 FORGOT TO MENTION DESIGN
CHANGES!!!
 ENGINEERING CHANGE CONTROL AS
WELL!!!
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Purchasing and Acceptance
Criteria
 Risk to patient, consumer could occur
with outsourced processes, services as
well
 Specified purchase requirements
determined with risk control measures
 Selection, evaluation and re-evaluation
of suppliers also based on risk of
identified hazards
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Production Process Control
 Assessments of risks, e.g., process
FMEA, can help
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“Bottoms up approach vs top down
approach”
Starting with individual processes, steps
and assessing their impact on failure of
product
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Production cont’d
 Equipment

Calibration, preventive maintenance
considered?
 Work environment and personnel
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Environmental conditions (humidity, spatial
separation, pest control)
Health, cleanliness
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Gowning procedures, cleaning of the clean room?
 Process Validation
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Servicing
 Repair and maintenance of product
 Lack of controls can adversely affect
product
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CAPA risk management
 An integral part of CAPA to help
determined severity (complaints, service
reports, manufacturing defects, supplier
audits, etc.)
 Facilitates closed loop process to ensure
any previously unrecognized risks are
identified and if risk estimation still
acceptable and valid
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Post Market Surveillance/
Customer Feedback
 A concerted effort to gain knowledge
from post production (literature search,
input from sales/ distributor staff,
competitive information, etc.) that might
have an impact on the risk management
file.
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That’s a wrap.
Questions?
+’s and Δ’s
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