Transcript Agile 2009
Moving to Agile in an FDA Environment An Experience Report August 27, 2009 Introduction • Available for download at http://agile2009.agilealliance.org/ • Agile Resources – Agile Manifesto http://www.agilemanifesto.org/ – Agile Alliance http://www.agilealliance.org • Agile Books – http://www.agiletek.com/thoughtleadership/books “Agile Software Development” by Alistair Cockburn “Agile Project Management” by Jim Highsmith An Experience Report Slide 2 Outline • The Abbott Experience • Lessons Learned 1. The least burdensome approach? 2. A Risk Based Approach 3. Control what you don’t know, don’t let it control you 4. Dispense with ceremony • Results An Experience Report Slide 3 The Abbott Experience • Comparing two FDA-regulated medical device projects – One not agile, one agile – Class III devices (most stringent) – Results of agile adoption • • • • • Lower cost Shorter duration Better, less prescriptive test cases Accommodated change Higher quality • See paper “Adopting Agile in an FDA Regulated Environment” An Experience Report Slide 4 Software Development Lifecycle An Experience Report Slide 6 Iteration Model Iteration Model Software Characterization Product Definition Feature Summary Feature Descriptions Software Requirements ... Planning Software Development Plan Software Process Definition Software Engineering Development Practice Software Test Plan Software Configuration Management Plan Software Quality Assurance Plan Software Measurement Plan Capability Allocation Matrix Software Schedule ... High Level Design High Level Design Description Software Architecture Description User Interface Design Document User Interface Framework ... Software Construction Software Confirmation System Test Design Feature Detailed Design Presentation Business Rule Data Access Persistence Regression Analysis Integration Test Acceptance Test Functional Testing ... Test Design ... Stakeholder Review Implementation Application Requirements Feature Descriptions Scenario Descriptions ... Presentation Business Data Access Database Test Cases ... Verification Unit Test Integration Test Code Inspection Design Review ... An Experience Report Slide 7 Software Release Version Description (Release Notes) Traceability Matrix Inputs -> Outputs Validation / Verification Data ... Sample Design Control Documents 1. QSR Ref. 820.30(b) ISO Ref. 7.3.1 2. 820.30(c) 7.3.2 Design Control Element Design and development planning Design input 3. 820.30(d) 7.3.3 Design output 4. 820.30(e) 7.3.4 Design review 5. 6. 820.30(f) 820.30(g) 7.3.5 7.3.6 Design verification Design validation 7. 8. 9. 820.30(h) 820.30(i) 820.30(j) NA 7.3.7 4.2.3-4 Design transfer Design changes Design history file Documents Design and Development Plan System Requirements Specification Safety Risk Analysis System Design Description Source code Drawings/Schematics System review reports Design review reports Verification Test Procedures Validation Test Procedures Test Summary Report Requirements traceability matrix Design transfer procedure Change control procedures Document control procedures Courtesy of: Certified Compliance Solutions, Inc. An Experience Report Slide 8 Lessons Learned Least Burdensome We [FDA] are defining the term “least burdensome” as a successful means of addressing a premarket issue that involves the most appropriate investment of time, effort, and resources on the part of industry and FDA. --The Least Burdensome Provisions of the FDA Modernization Act of 1997: Concept and Principles; Final Guidance for FDA and Industry An Experience Report Slide 10 A Risk Based Approach Courtesy of: Certified Compliance Solutions, Inc. An Experience Report Slide 11 Risk Based Approaches • IEC 62304 section 5.1.1, page 31: Note 1: The software model can identify different activities for different software items according to the safety classification • FDA General Principles of Software Validation, page 7, section 3.1.2: The level of confidence, and therefore the level of software validation, verification, and testing effort needed, will vary depending on the safety risk (hazard) posed by the automated functions of the device. Courtesy of: Certified Compliance Solutions, Inc. An Experience Report Slide 12 FDA Reviewer Guidance 2005 SOFTWARE MINOR MODERATE DOCUMENTATION CONCERN CONCERN Verification and Validation Documentation Software functional test plan, pass / fail criteria, and results. Description of V&V activities at the unit, integration, and system level. System level test protocol, including pass/fail criteria, and tests results. MAJOR CONCERN Description of V&V activities at the unit, integration, and system level. Unit, integration and system level test protocols, including pass/fail criteria, test report, summary, and tests results. Courtesy of: Certified Compliance Solutions, Inc. An Experience Report Slide 13 Control What You Don’t Know, Don’t Let It Control You • What you do know: – A typical medical device is developed over a 3-5 year time horizon – It is a myth that you can predict in detail your end product requirements up-front – Start with a core set of features that you must implement – Implement the core features first – Defer the most volatile features as long as possible • Iterative approach allows the team to: – Manage scope and limit feature creep – Negotiate scope and tradeoffs with key stakeholders • “At time of commercial launch, a number of features, once thought to be essential, were not included. Some were deferred as long as three years. Nonetheless, the product was considered highly successful and trading off nice to have features for three years of sales is an easy choice.” An Experience Report Slide 14 Dispense With Ceremony • If it is not adding value, and it is not required, do not do it • The design history files should contain the minimum set of documentation that satisfies the regulatory requirements • There will be other activities that you will want to document, no need to include in design history file, make sure they add value and do it in a least burdensome way • Avoid doing things because “that’s the way we’ve always done it” • If it feels like you are wasting your time you probably are An Experience Report Slide 15 Results Results • High visibility – Easier to manage and control – Far fewer surprises • Lower cost and shorter duration – Estimated schedule and team size reduction of 20%30% – Estimated cost savings of 35%-50% • Higher quality – Availability of working software facilitated continuous testing instead of back loaded V&V – Resulted in fewer overall defects, especially at the end of the project • Better work life balance and team morale – Project death marches are rarer because the issues are surfaced as you go and are managed accordingly, not all saved up for the end of the project An Experience Report Slide 17 Q&A Thank You Tim Hughes Managing Partner [email protected] 847-699-2260 J.R. Jenks Managing Partner [email protected] 847-699-2250 John Skach Rod Rasmussen Senior Technology Architect [email protected] 847-699-2264 Director, Informatics & Software Systems [email protected] 847-938-3633 An Experience Report Slide 19