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Suresh Wadhwani IBM Software, Rational

How to achieve compliance with IEC 62304 for medical device software development

Innovation for a smarter planet


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IEC 62304 Overview

Standards Landscape
Key elements of IEC 62304

IBM Rational solution

Recommendation
Conclusion

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IEC 62304 Overview


IEC 62304:2006 Medical device software Software life cycle processes Software use should not cause any unacceptable risk with respect to safety and effectiveness of the device Focused on software development and maintenance processes for medical devices but does not specify the methodologies, artifacts or life cycle models themselves Derived from ISO/IEC 12207, a general standard for software processes Adoption
FDA Consensus Standard since September 2008 FDA regards complying with IEC62304 as fulfilling Software Development Environment Description section of the Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Normative standard in Europe for conformance marking

Standard available for purchase from ISO website (~$225 USD) 3

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IEC 62304 Structure


Set of interrelated or interacting activities that transforms inputs into outputs

Processes

Activities

Set of interrelated or interacting tasks

Tasks

Single piece of work that needs to be done and results in a deliverable

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What IEC 62304 does not do


Does not cover validation and final release of a medical device
Does not specify an organizational structure
You can do have a hierarchical, matrix, or mixed organization

Does not specify the content of the documentation to be developed


You need to show traceability through all the artifacts but not in some set format

Does not prescribe a specific lifecycle model


Waterfall, Iterative, Evolutionary, it is all up to you

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Standards Landscape
Quality management system RISK MANAGEMENT Software safety classification Software development PROCESS Software development planning Software requirements analysis Software ARCHITECTURAL design Software detailed design

SOFTWARE UNIT implementation and verification


Software integration and integration testing SOFTWARE SYSTEM testing Software release

Software maintenance PROCESS


Software RISK MANAGEMENT PROCESS Software configuration management PROCESS Software problem resolution PROCESS
Source: European Medical Device & Technology, June 2010

Note: ISO 14971 is a Normative standard for Risk Management Process 6

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IEC 62304 Software Development Lifecycle - Model


DEFINITION / DEVELOPMENT System Requirements Phase TEST / VERIFICATION
System & Stakeholder Requirements Definition
Output: System Requirements Doc. (SRD) Traceability for Test Coverage

System Verification Test


Output: System Verification Test Procedure (SVTP) and Results (SVTR)

Software Requirements Phase

Coding Phase

Configuration Management

Risk Management and Safety Assessment Process

Traceability SRS to SRD

System Design & Analysis Software Requirements Def Safety Classification


Output: Software Requirements Spec. (SRS)

Traceability for Test Coverage

H/W - S/W Integration Test


Output: S/W Verification Cases and Procedures (SVCP) and Results (SVR)

Software Design Phase

Planning Process

Traceability SDD to SRS

Software Design Definition


Output: Software Design Description (SDD)

Traceability for Test Coverage

Unit/Integration Testing
Output: S/W Verification Cases and Procedures (SVCP) and Results (SVR)

Traceability SC to SDD

Coding
Output: Source and Object Code

Traceability Test Coverage

Code Review
Output: Source Code Review and Analysis Data

Configuration Management Change Management (Problem Reporting) Quality Assurance Phase

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IEC 62304 Software Risk Management - Process


Analysis of software contributing to hazardous situations Software risk management in addition to ISO 14971 (see also IEC 80002 for specifics) Adds RISK CONTROL measures to Requirements Includes software to control MEDICAL DEVICE RISKS Allows for Design Risk Management (Bottoms

Customer Needs

Develop Concept

Product Definition

Product / System Build

Product / System Deliver

Run / Support / Maintain

Requirements Capture & Analysis Reporting, Version & Change Mgmt Systems Analysis & Design

System Acceptance

(Sub-)System Integration & Test

Up)
Complements Functional Risk Management (Top
SW Design Module Integration & Test

Down)
Risk Management applied recursively throughout product lifecycle Documentation various tools, safety assurance 8 cases
Risk Management File
Implementation & Unit Test Best Practices

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IEC 62304 Risk Management - Approach


Anticipate possible failures of the system Define control measures Inherently safe Preventive Corrective Informative Systematic risk analysis is to anticipate failures Top-down: Function analysis - ISO 14971, FTA o Hazard Analysis Bottom-up: Design/ Process Analysis FMEA o Failure Modes and Effects Analysis Each failure leads to risk control (RCM) measures Each RCM leads to requirements implemented in product hardware, software or documentation Risk Management File documents traceably risk to control measure, to verification of control measure Risk Management Activities continue after release
User Needs System Sub-system Design Implementation Product Function

Hazards Failures
Design RCMs Requirements

Risk Management File


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IEC 62304 Risk Management Traceability, Verification


Document TRACEABILITY of software HAZARDS From hazardous situation to the SOFTWARE ITEM From SOFTWARE ITEM to the specific software cause From the software cause to RISK CONTROL measure From RISK CONTROL measure to VERIFICATION of RISK CONTROL measure
Customer Needs Develop Concept Product Definition Product / System Build Product / System Deliver Run / Support / Maintain

Requirements

Requirements Capture & Analysis

User Needs System Sub-system Design Implementation

Reporting, Version & Change Mgmt Systems Analysis & Design

System Acceptance

(Sub-)System Integration & Test

SW Design

Module Integration & Test

Risk Management File


Safety & Fault Tree Analysis

Implementation & Unit Test

Best Practices

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62304 Safety Classifications

The software safety classes shall initially be assigned based on severity as follows: Class A: No injury or damage to health is possible Class B: Non-SERIOUS INJURY is possible Class C: Death or SERIOUS INJURY is possible

Class C 100% of 62304 activities apply Class B 93% Class A 43%

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62304: Software Systems, Items, & Safety Classifications


Software Systems are comprised of Software Items Software Systems are assigned a Safety Classification Software Items inherit the Safety Classification of the System If the HAZARD could arise from the failure of the SOFTWARE SYSTEM to behave as specified, the probability of such failure shall be assumed to be 100%

Unless

Higher classification applies unless there is a documented rationale in a Risk Management file to justify lower safety class for software items

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Segregation of Software Items

SOFTWARE SYSTEM

SOFTWARE ITEMS

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Safety, risk, and risk management process


Safety is freedom from unacceptable risk.

Safety is not security!


Security is protection of information and data so that unauthorized people or systems cannot read or modify them , and so that authorized people or systems are not denied access to them.

Risk is a product of severity and probability of occurrence Software Risk Management Process: - identify software items that could contribute to a hazardous situation - identify causes of contribution to a hazardous situation - define risk control measures - verify risk control measures
Document traceability: Hazardous situation to software item to specific software cause to risk control measure to verification of risk control measure

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Hazard and Fault Tree Analysis

Fault Tree Analysis determines what combinations of conditions or events are necessary for a hazard condition to occur

Fault Tree Analysis allows the developer to identify, control and lower the risk to an acceptable level
This is critical in the IEC 62304 standard

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Example Fault Tree Analysis

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Design Redundancy for Safety

The key to safe systems is to analyze the system and to identify the conditions and events that can lead to hazards

Fault Tree Analysis (FTA) determines what logical combination of events and conditions lead to faults
By adding ANDing-redundancy, architectural redundancy can be added

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Recommendations

Determine compliance with IEC 62304 by performing gap analysis


Create a chart that maps IEC 62304 clauses and subclauses to company procedure(s) The mapping chart can be a standalone document, or it can be an appendix to a companys procedure(s).

Address open issues revealed in gap analysis


Establish missing processes Amend deficient processes Deploy appropriate software development tools that execute or enforce your processes

Document updated software development process showing compliance with IEC 62304
Mapping chart should now have 100% coverage of IEC 62304 clauses within your processes

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Some Typical Issues


Reuse of existing documents and data

Risk Analysis
Qualification of requirements
Must have, want to have, nice to have, source, product version etc.

Traceability
Multiple levels required due to the complexity of the systems

Change Control
Who made a change, when the change was made, why the change was made, and analysis of the impact.

Auditable record compliance


Electronic signature and document management

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Import All Your Data & Create Documents


MS-Word
MS-Word

Word Direct Entry Microsoft HTML RTF ASCII


MS-Word

PowerPoint
Excel Outlook

RTF OLE ASCII

Spreadsheet

DOORS
MS-Project

Spreadsheet

MS-Project Tool Integrations*


FrameMaker ReqIF (XML) Print Rational Publishing Engine
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Tool Integrations*
FrameMaker RIF (XML)

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Example DOORS Templates and Pre-Defined Views


Verification and Validation Plan

Risk Assessment View in Design

Risk Management Plan Design and Development Plan

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Some Typical Issues


Reuse of existing documents and data

Risk Analysis
Qualification of requirements
Must have, want to have, nice to have, source, product version etc.

Traceability
Multiple levels required due to the complexity of the systems

Change Control
Who made a change, when the change was made, why the change was made, and analysis of the impact.

Auditable record compliance


Electronic signature and document management

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DOORS Database View


Unlimited hierarchy of Projects/Folders supports scalability

Folders Projects DOORS Documents

Organize Your Projects


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DOORS Document Views


Everything you need in one window!

Spell check

Context

Requirements

OLE

Improves productivity, reduces errors, increases quality


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DOORS views
Change bars and link indicators; instant traceability

See status quickly and concisely


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DOORS views
Attribute columns in a spreadsheet-like view

Rich information; one window


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Unlimited user defined attributes


Unlimited number of attributes in a spreadsheet-like view Values can be calculated for metrics collection Automates your regulatory persons ability to show compliance

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Model Driven Analysis and Design


using Rational Rhapsody and Rational DOORS Visualize requirements and build architecture Integrates requirements, design and implementation Execution validates requirements Facilitates communication across disciplines Impact analysis of changes in requirements or design

Trace requirements to design and implementation

Requirement information generated in code 28 2011 IBM Corporation

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Connecting FTA to Requirements (TraceToReq)

29

2011 IBM Corporation

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Some Typical Issues


Reuse of existing documents and data

Risk Analysis
Qualification of requirements
Must have, want to have, nice to have, source, product version etc.

Traceability
Multiple levels required due to the complexity of the systems

Change Control
Who made a change, when the change was made, why the change was made, and analysis of the impact.

Auditable record compliance


Electronic signature and document management

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Traceability is the key to compliance


User Needs
1. 820.30(b) Design and Development Planning Each manufacturer shall establish and maintain plans that describe or reference the design and development activities and define responsibility for implementation. The plans shall identify and describe the interfaces with different groups or activities that provide, or result in, input to the design and development process. The plans shall be reviewed as design and development evolves. The plans shall be updated as design and development evolves. The plans shall be approved as design and development evolves. 2. 820.30(c) Design Input 2.1. Each manufacturer shall establish procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the needs of the user and patient. 2.2. Each manufacturer shall maintain procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the needs of the user and patient. 2.3. The procedures shall include a mechanism for addressing incomplete requirements. 2.4. The procedures shall include a mechanism for addressing ambiguous requirements. 2.5. The procedures shall include a mechanism for addressing conflicting requirements. 2.6. The design input requirements shall be documented by a designated individual(s). 2.7. The design input requirements shall be reviewed by a designated individual(s). 2.8. The design input requirements shall be approved by a designated individual(s). 2.9. The approval, including the date and signature of the individual(s) approving the requirements, shall be documented. 2.10. Questions. 2.10.1. Summarize the manufacturer's written procedure(s) for identification and control of design input. 2.10.2. From what sources are design inputs sought? 2.10.3. Do design input procedures cover the relevant aspects, such as: (Mark all that apply and list additional aspects.) 2.10.3.1. intended use 2.10.3.2. user/patient/clinical 2.10.3.3. performance characteristics 2.10.3.4. safety 2.10.3.5. limits and tolerances 2.10.3.6. risk analysis 2.10.3.7. toxicity and biocompatibility 2.10.3.8. electromagnetic compatibility (EMC) 2.10.3.9. compatibility with accessories/auxiliary devices 2.10.3.10. compatibility with the environment of intended use 2.10.3.11. human factors 2.10.3.12. physical/chemical characteristics 2.10.3.13. labeling/packaging 2.10.3.14. reliability 2.10.3.15. statutory and regulatory requirements 2.10.3.16. voluntary standards 2.10.3.17. manufacturing processes 2.10.3.18. sterility 2.10.3.19. MDRs/complaints/failures and other historical data 2.10.3.20. design history files (DHFs) 2.10.4. For the specific design covered, how were the design input requirements identified? 2.10.5. For the specific design covered, how were the design input requirements reviewed for adequacy?

Requirements Specifications
1. 820.30(b) Design and Development Planning Comply with FDA Design Control Guidance GMP Regulation Comply with FDA Design Control Guidance GMP Regulation Each manufacturer shall establish and maintain plans that describe or reference the design Identify impacted elements due to a change in another element 1.1. and development activities 1. Capture design and related informationand define responsibility for implementation. 1. Capture design and related information Traceability Reports: consistency with driving design elements 1.1. Input electronically formatted data 1.1. Input electronically formatted data Impact Reports: other design elements affected information sources The plans shall 1.2. Reference external information sources identify and describe the interfaces with different groups or activities that provide, or result 1.2. Reference external Links to impacted design elements in, input to 1.3. Reference external documentation the design and development process. 1.3. Reference external documentation

Test Cases
1.1. Identify impacted elements due to a change in another element Traceability Reports: consistency with driving design elements Impact Reports: other design elements affected Links to impacted design elements 1.1.1. Create backward traces to design elements within and across any organizational procedure Traceability Reports: Procedure Attribute 1.1.2. Create backward traces to design elements within and across any project milestone Traceability Reports: Milestone Attribute 1.1.3. Create backward traces to design elements within and across Design Control Guidance Elements Traceability Reports: Linked design elements 1.1.4. Create forward impacts to design elements within and across any organizational procedure Impact Reports: Procedure Attribute 1.1.5. Create forward impacts to design elements within and across any project milestone Impact Reports: Milestone Attribute 1.1.6. Create forward impacts to design elements within and across Design Control Guidance Elements Impact Reports: Linked design elements 1.2. Associate changed design elements with related elements Link Change Design Object with affected design element(s) Traceability Links and Reports from affected design element(s) Impact Links and Reports from affected design element(s) 1.2.1. Associate design element changes with decisions, rationale, and approval authority information Change Decision Objects with following Attributes: Disposition Attribute Decision Attribute Rationale Attribute Owner Attribute Management Approval Attribute 1.2.2. Provide associations within and across any organizational procedure Change Design Object Traceability Link on Procedure Attribute Change Design Object Impacts Link on Procedure Attribute 1.2.3. Provide associations within and across any project milestone Change Design Object Traceability Link on Milestone Attribute Change Design Object Impacts Link on Milestone Attribute 1.2.4. Provide associations within and across Design Control Guidance Elements Change Design Object Traceability Link to traced design elements Change Design Object Impacts Link to linked design elements 1.3. Mange the change process Design Change Module Design Change Reports Object History Object History Reports Versions Baselines

1.1.1. Create backward traces to design elements within and across any organizational

2.

3.

4.

5.

6.

The plans Store design and related information shall be reviewed as design and development evolves. 2. Store design and related information procedure The plans shall be updated as elements 2.1. Identify and tag design information as unique design design and development evolves. 2.1. Identify and tag design information as unique design elements Traceability Reports: Procedure Attribute The 2.2. Organize design elements plans shall be approved as design and development evolves. 2.2. Organize design elements 1.1.2. Create backward traces to design elements within and across any project milestone 2.2.1. Organize by Design Control Guidance Element 2.2.1. Organize by Design Control Guidance Element 2. 820.30(c) Traceability Reports: MilestoneOrganize by inter-relationships 2.2.2. Organize by inter-relationships Design Input 2.2.2. Attribute 2.1. Each 2.3. Ensure all design elements are availablemanufacturer shall establish procedures to ensure that the design requirements relating to backward traces to design elements within and are available 2.3. Ensure all design elements across Design Control 1.1.3. Create a device are appropriate and address the intended use of the device, including the needs of the user 2.3.1. Store design elements by Design Control Guidance Element 2.3.1. Store design elements by Design Control Guidance Element Guidance Elements and patient. 2.3.2. Store design elements and their historical values 2.3.2. Store design elements and their historical values Traceability Reports: Linked design elements 2.2. Each manufacturer shall maintain procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the 1.1.4.of the user needs Create forward impacts to design elements within and across any organizational Manage all user needs 3. Manage all user needs and procedure 3.1. Identify the source of the user need patient. 3.1. Identify the source of the user need 2.3. 3.2. Identify all user types (groups) The procedures shall include a mechanism for addressing incomplete requirements. Impact Reports: Procedure Identify all user types (groups) 3.2. Attribute 2.4. The procedures shall include a mechanism for addressing ambiguous requirements. 3.3. Identify the customer (s) 3.3. Identify the customer and 1.1.5. Create forward impacts to design elements within(s) across any project milestone 3.4. Profile the expected patients 2.5. The procedures shall include a mechanism for addressing conflicting requirements. 3.4. Profile the expected patients Impact Reports: Milestone State the intended use of the product (family) 3.5. State the intended use of the 2.6. The design input requirements shall be documented by a designated individual(s). product (family) 3.5. Attribute 2.7. each user input 3.6. Capture the acceptance criteria forThe designneed requirements shall be reviewed by a designated individual(s). 1.1.6. Create forward impacts to design elements within and acrosseach user need 3.6. Capture the acceptance criteria for Design Control 2.8. The design input requirements shall be approved by a designated individual(s). Guidance Elements 2.9. The approval, including the date and signature of the individual(s) approving the requirements, Manage design input requirements 4. Manage design input Impact Reports: Linked design elements requirements shall 4.1. Identify the source of the requirement be documented. 4.1. Identify the source of the 1.2. Associate changed design elements with related elements requirement 2.10. 4.2. Identify the associated user need Questions. 4.2. Identify the associated user need 2.10.1. Summarize the manufacturer's written procedure(s) for identification and control of with affected design element(s) Link Change Design Object 4.3. Capture requirement description and attributes 4.3. Capture requirement description and attributes design input. 4.4. Capture acceptance criteria 4.4. Capture acceptance criteria Traceability Links and Reports from affected design element(s) 2.10.2. From what sources are design inputs sought? 4.5. Assign responsibility for each requirement 4.5. Assign responsibility for each Impact Links and Reports from affected design element(s)requirement 4.6. Manage incomplete requirements2.10.3. Do design input procedures cover the relevant aspects, such as: (Mark all that apply and 4.6. Manage incomplete requirements 1.2.1. Associate design element changes with decisions, rationale, and approval authority list additional aspects.) 4.7. Manage ambiguous requirements 4.7. Manage ambiguous requirements information 2.10.3.1. intended use 4.8. Manage conflicting requirements 4.8. Manage conflicting requirements 2.10.3.2. user/patient/clinical 4.9. Approve all requirements 4.9. Approve all requirements Change Decision Objects with following Attributes: 2.10.3.3. performance characteristics Disposition Attribute 2.10.3.4. safety Manage acceptance 5. Manage acceptance Decision Attribute 2.10.3.5. limits and tolerances 5.1. Ensure the acceptance of every user need 5.1. Ensure the acceptance of every user need 2.10.3.6. risk analysis Rationale Attribute 5.2. Ensure the acceptance of every design input requirement 5.2. Ensure the acceptance of every design input requirement 2.10.3.7. toxicity 5.3. Document the results of every user need acceptance test and biocompatibility 5.3. Document the results of every user need acceptance test Owner Attribute electromagnetic compatibility (EMC) 5.4. Document the results of every design 2.10.3.8. input requirements test 5.4. Document the results of every design input requirements test Management Approval Attribute compatibility with accessories/auxiliary devices 5.5. Make acceptance results available 2.10.3.9. 5.5. Make acceptance results available 1.2.2. Provide associations within and across any organizational procedure 2.10.3.10. compatibility with the environment of intended use 2.10.3.11. human factors Change Design Object Traceability Link on Procedure Attribute Manage change 6. Manage change 2.10.3.12. physical/chemical characteristics 6.1. Maintain history of design element changes 6.1. Maintain on Procedure element changes Change Design Object Impacts Link history of design Attribute 2.10.3.13. labeling/packaging 6.1.1. Make complete change history available 6.1.1. Make complete change history 1.2.3. Provide associations within and across any project milestone available 2.10.3.14. reliability 6.1.2. Maintain history within and across any organizational procedure 6.1.2. Maintain history within and across any organizational procedure on Milestone Attribute Change Design Object Traceability Link history within and across any project milestone 2.10.3.15. statutory and 6.1.3. Maintain history within and across any project milestone regulatory requirements 6.1.3. Maintain 2.10.3.16. voluntary Guidance Change Design Object Impacts Link on Milestone Attribute any Design Control Guidance Elements 6.1.4. Maintain history within and across any Design Control standards Elements 6.1.4. Maintain history within and across 2.10.3.17. 6.2. Capture frequency and nature of element changes manufacturing processes 6.2. Capture frequency Control of element Elements 1.2.4. Provide associations within and across Design and natureGuidance changes 2.10.3.18. sterility 6.2.1. Provide rationale for change 6.2.1. Provide to traced change Change Design Object Traceability Linkrationale for design elements 2.10.3.19. MDRs/complaints/failures and other historical data 6.2.2. Describe decisions made 6.2.2. Describe decisions made 2.10.3.20. design history files (DHFs) Change Design Object Impacts Link to linked design elementschange 6.2.3. Identify approval authority for the change 6.2.3. Identify approval authority for the 2.10.4. For the specific design covered, how were the design input requirementsMange the change process 1.3. identified? 6.2.4. Capture date, time, and signature of approving authority 6.2.4. Capture date, time, and signature of approving authority 2.10.5. For another element 6.3. Identify impacted elements due to a change in the specific design covered, how were the design input requirements reviewed forChange Module 6.3. Identify impacted elements due to a change in another element Design adequacy? 6.3.1. Create backward traces to design elements within and across any organizational procedure 6.3.1. Create backward traces to design elements within and across any organizational procedure Design Change Reports 6.3.2. Create backward traces to design elements within and across any project milestone 6.3.2. Create backward traces to design elements within and across any project milestone

Object History Object History Reports Versions Baselines

Initial user needs should be decomposed to detailed requirements, then to design specification, tests, etc.

Decomposition creates traceability relationships


Relationships define your traceability model Your traceability model is a reflection your process Enforce your traceability model; improve your process
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Traceability: drag-and-drop linking

Drag-and-drop to link within a document . . .

. . . or from document to document


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Traceability view
User Needs
1. 820.30(b) Design and Development Planning Each manufacturer shall establish and maintain plans that describe or reference the design and development activities and define responsibility for implementation. The plans shall identify and describe the interfaces with different groups or activities that provide, or result in, input to the design and development process. The plans shall be reviewed as design and development evolves. The plans shall be updated as design and development evolves. The plans shall be approved as design and development evolves. 2. 820.30(c) Design Input 2.1. Each manufacturer shall establish procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the needs of the user and patient. 2.2. Each manufacturer shall maintain procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the needs of the user and patient. 2.3. The procedures shall include a mechanism for addressing incomplete requirements. 2.4. The procedures shall include a mechanism for addressing ambiguous requirements. 2.5. The procedures shall include a mechanism for addressing conflicting requirements. 2.6. The design input requirements shall be documented by a designated individual(s). 2.7. The design input requirements shall be reviewed by a designated individual(s). 2.8. The design input requirements shall be approved by a designated individual(s). 2.9. The approval, including the date and signature of the individual(s) approving the requirements, shall be documented. 2.10. Questions. 2.10.1. Summarize the manufacturer's written procedure(s) for identification and control of design input. 2.10.2. From what sources are design inputs sought? 2.10.3. Do design input procedures cover the relevant aspects, such as: (Mark all that apply and list additional aspects.) 2.10.3.1. intended use 2.10.3.2. user/patient/clinical 2.10.3.3. performance characteristics 2.10.3.4. safety 2.10.3.5. limits and tolerances 2.10.3.6. risk analysis 2.10.3.7. toxicity and biocompatibility 2.10.3.8. electromagnetic compatibility (EMC) 2.10.3.9. compatibility with accessories/auxiliary devices 2.10.3.10. compatibility with the environment of intended use 2.10.3.11. human factors 2.10.3.12. physical/chemical characteristics 2.10.3.13. labeling/packaging 2.10.3.14. reliability 2.10.3.15. statutory and regulatory requirements 2.10.3.16. voluntary standards 2.10.3.17. manufacturing processes 2.10.3.18. sterility 2.10.3.19. MDRs/complaints/failures and other historical data 2.10.3.20. design history files (DHFs) 2.10.4. For the specific design covered, how were the design input requirements identified? 2.10.5. For the specific design covered, how were the design input requirements reviewed for adequacy?

Requirements

Specifications Test Cases


1.1. Identify impacted elements due to a change in another element Traceability Reports: consistency with driving design elements Impact Reports: other design elements affected Links to impacted design elements 1.1.1.Create backward traces to design elements within and across any organizational procedure Traceability Reports: Procedure Attribute 1.1.2.Create backward traces to design elements within and across any project milestone Traceability Reports: Milestone Attribute 1.1.3.Create backward traces to design elements within and across Design Control Guidance Elements Traceability Reports: Linked design elements 1.1.4.Create forward impacts to design elements within and across any organizational procedure Impact Reports: Procedure Attribute 1.1.5.Create forward impacts to design elements within and across any project milestone Impact Reports: Milestone Attribute 1.1.6.Create forward impacts to design elements within and across Design Control Guidance Elements Impact Reports: Linked design elements 1.2. Associate changed design elements with related elements Link Change Design Object with affected design element(s) Traceability Links and Reports from affected design element(s) Impact Links and Reports from affected design element(s) 1.2.1.Associate design element changes with decisions, rationale, and approval authority information Change Decision Objects with following Attributes: Disposition Attribute Decision Attribute Rationale Attribute Owner Attribute Management Approval Attribute 1.2.2.Provide associations within and across any organizational procedure Change Design Object Traceability Link on Procedure Attribute Change Design Object Impacts Link on Procedure Attribute 1.2.3.Provide associations within and across any project milestone Change Design Object Traceability Link on Milestone Attribute Change Design Object Impacts Link on Milestone Attribute 1.2.4.Provide associations within and across Design Control Guidance Elements Change Design Object Traceability Link to traced design elements Change Design Object Impacts Link to linked design elements 1.3. Mange the change process Design Change Module Design Change Reports Object History Object History Reports Versions Baselines

1. 820.30(b) Design and Development Planning Comply with FDA Design Control Guidance GMP Regulation Comply with FDA Design Control Guidance GMP Regulation Each manufacturer shall establish and maintain plans that describe or reference the design Identify impacted elements due to a change in another element 1.1. and development activities 1. Capture design and related informationand define responsibility for implementation. 1. Capture design and related information Traceability Reports: consistency with driving design elements 1.1. Input electronically formatted data 1.1. Input electronically formatted data The plans shall identify and describe the interfaces with different groups or activities that Impact Reports: other design elements affected information sources provide, or result 1.2. Reference external information sources 1.2. Reference external Links to impacted design elements in, input to 1.3. Reference external documentation the design and development process. 1.3. Reference external documentation

1.1.1.Create backward traces to design elements within and across any organizational

The plans 2. Store design and related information shall be reviewed as design and development evolves. 2. Store design and related information procedure The plans shall be updated as elements 2.1. Identify and tag design information as unique design design and development evolves. 2.1. Identify and tag design information as unique design elements Traceability Reports: Procedure Attribute The 2.2. Organize design elements plans shall be approved as design and development evolves. 2.2. Organize design elements 1.1.2.Create backward traces to design elements within and across any project milestone 2.2.1. Organize by Design Control Guidance Element 2.2.1. Organize by Design Control Guidance Element 2. 820.30(c) Traceability Reports: MilestoneOrganize by inter-relationships 2.2.2. Organize by inter-relationships Design Input 2.2.2. Attribute 2.1. Each 2.3. Ensure all design elements are availablemanufacturer shall establish procedures to ensure that the design requirements relating to backward traces to design elements within and are available 2.3. Ensure all design elements across Design Control 1.1.3.Create a device are appropriate Element 2.3.1. Store design elements by Design Control Guidance and address the intended use of the device, including the needs of the user Elements 2.3.1. Store design elements by Design Control Guidance Element Guidance and patient. 2.3.2. Store design elements and their historical values 2.3.2. Store design elements and their historical values Traceability Reports: Linked design elements 2.2. Each manufacturer shall maintain procedures to ensure that the design requirements relating to a device are appropriate and address the intended use of the device, including the 1.1.4.of the user needs Create forward impacts3.to design elements within and across any organizational 3. Manage all user needs Manage all user needs and procedure 3.1. Identify the source of the user need patient. 3.1. Identify the source of the user need 2.3. 3.2. Identify all user types (groups) The procedures shall include a mechanism for addressing incomplete requirements. Impact Reports: Procedure Identify all user types (groups) 3.2. Attribute 3.3. Identify the customer (s) 2.4. The procedures shall include a mechanism for addressing ambiguous requirements. Create forward impacts to design elements within(s) across any project milestone 3.3. Identify the customer and 1.1.5. 3.4. Profile the expected patients 2.5. The procedures shall include a mechanism for addressing conflicting requirements. 3.4. Profile the expected patients Impact Reports: Milestone State the intended use of the product (family) 3.5. State the intended use of the 2.6. The design input requirements shall be documented by a designated individual(s). product (family) 3.5. Attribute 2.7. each user input 3.6. Capture the acceptance criteria forThe designneed requirements shall be reviewed by a designated individual(s). 1.1.6. Create forward impacts to design elements within and acrosseach user need 3.6. Capture the acceptance criteria for Design Control 2.8. The design input requirements shall be approved by a designated individual(s). Guidance Elements 2.9. The approval, including the date and signature of the individual(s) approving the requirements, 4. Manage design input requirements 4. Manage design input Impact Reports: Linked design elements requirements shall be documented. 4.1. Identify the source of the requirement 4.1. Identify the source of the 1.2. Associate changed design elements with related elements requirement 2.10. Questions. 4.2. Identify the associated user need 4.2. Identify the associated user need 2.10.1. Summarize the manufacturer's written procedure(s) for identification and control of with affected design description Link Change Design Object 4.3. Capture requirementelement(s) and attributes 4.3. Capture requirement description and attributes design input. 4.4. Capture acceptance criteria 4.4. Capture acceptance criteria Traceability Links and Reports from affected design element(s) 2.10.2. 4.5. Assign responsibility for each requirementFrom what sources are design inputs sought? 4.5. Assign responsibility for each Impact Links and Reports from affected design element(s)requirement 4.6. Manage incomplete requirements2.10.3. Do design input procedures cover the relevant aspects, such as: (Mark all that apply and 4.6. Manage incomplete requirements 1.2.1.Associate design element changes with decisions, rationale, and approval authority list additional aspects.) 4.7. Manage ambiguous requirements 4.7. Manage ambiguous requirements information 2.10.3.1. intended use 4.8. Manage conflicting requirements 4.8. Manage conflicting requirements 2.10.3.2. user/patient/clinical 4.9. Approve all requirements 4.9. Approve all requirements Change Decision Objects with following Attributes: 2.10.3.3. performance characteristics Disposition Attribute 2.10.3.4. safety 5. Manage acceptance 5. Manage acceptance Decision Attribute 2.10.3.5. limits and tolerances 5.1. Ensure the acceptance of every user need 5.1. Ensure the acceptance of every user need 2.10.3.6. risk analysis Rationale Attribute 5.2. Ensure the acceptance of every design input requirement 5.2. Ensure the acceptance of every design input requirement 2.10.3.7. toxicity 5.3. Document the results of every user need acceptance test and biocompatibility 5.3. Document the results of every user need acceptance test Owner Attribute electromagnetic compatibility (EMC) 5.4. Document the results of every design 2.10.3.8. input requirements test 5.4. Document the results of every design input requirements test Management Approval Attribute compatibility with accessories/auxiliary devices 5.5. Make acceptance results available 2.10.3.9. 5.5. Make acceptance results available 1.2.2.Provide associations within and across any organizational procedure 2.10.3.10. compatibility with the environment of intended use 2.10.3.11. human factors Change Design Object Traceability Link on Procedure Attribute 6. Manage change 6. Manage change 2.10.3.12. physical/chemical characteristics 6.1. Maintain history of design element changes 6.1. Maintain on Procedure element changes Change Design Object Impacts Link history of design Attribute 2.10.3.13. labeling/packaging 6.1.1. Make complete change history available 6.1.1. Make complete change history 1.2.3.Provide associations within and across any project milestone available 2.10.3.14. reliability 6.1.2. Maintain history within and across any organizational procedure 6.1.2. Maintain history within and across any organizational procedure Change Design Object Traceability Link on Milestone Attribute project milestone 2.10.3.15. statutory and 6.1.3. Maintain history within and across any project milestone regulatory requirements 6.1.3. Maintain history within and across any 2.10.3.16. voluntary standards Elements Change Design Object Impacts Link on Milestone Attribute any Design Control Guidance Elements 6.1.4. Maintain history within and across any Design Control Guidance 6.1.4. Maintain history within and across 2.10.3.17. manufacturing processes 6.2. Capture frequency and nature of element changes 6.2. across Design Control of element Elements 1.2.4.Provide associations within andCapture frequency and natureGuidance changes 2.10.3.18. sterility 6.2.1. Provide rationale for change 6.2.1. Provide to traced change Change Design Object Traceability Linkrationale fordesign elements 2.10.3.19. MDRs/complaints/failures and other historical data 6.2.2. Describe decisions made 6.2.2. Describe decisions made 2.10.3.20. Change Design Object Impacts Link to linked design elementschange 6.2.3. Identify approval authority for the change design history files (DHFs) 6.2.3. Identify approval authority for the 2.10.4. For the specific design 1.3. identified? 6.2.4. Capture date, time, and signature of approving authority covered, how were the design input requirementsMange the change process 6.2.4. Capture date, time, and signature of approving authority 2.10.5. For another element 6.3. Identify impacted elements due to a change in the specific design covered, how were the design input requirements reviewed forChange Module 6.3. Identify impacted elements due to a change in another element Design adequacy? 6.3.1. Create backward traces to design elements within and across any organizational procedure 6.3.1. Create backward traces to design elements within and across any organizational procedure Design Change Reports 6.3.2. Create backward traces to design elements within and across any project milestone 6.3.2. Create backward traces to design elements within and across any project milestone

Object History Object History Reports Versions Baselines

End-to-end visual validation in a single view


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Software and Systems Engineering | Rational

Traceability Verification or Completeness

Increases customer confidence


Detect missing links Creation and deletion of links is recorded in history

Traceability through an Orphan report shows missing links


2011 IBM Corporation

Software and Systems Engineering | Rational

Standard DOORS Traceability Tools

Link Matrix Object Properties Link Popups Traceability Columns

Traceability Explorer

2011 IBM Corporation

Software and Systems Engineering | Rational

Some Typical Issues


Reuse of existing documents and data

Risk Analysis
Qualification of requirements
Must have, want to have, nice to have, source, product version etc.

Traceability
Multiple levels required due to the complexity of the systems

Change Control
Who made a change, when the change was made, why the change was made, and analysis of the impact.

Auditable record compliance


Electronic signature and document management

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Software and Systems Engineering | Rational

What are Suspect Links?

If documents are linked

a change by this user here

shows up as a warning flag to this user here.

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Software and Systems Engineering | Rational

Suspect Links
Suspect links are visible directly in the document as indicators or as a full description

Clear on a right click

Never miss a change again


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Software and Systems Engineering | Rational

History and Baselines


Current Version

Previous Baseline

Change History
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Software and Systems Engineering | Rational

Baseline Compare

Provides a concise list of differences as a single report


2011 IBM Corporation

Software and Systems Engineering | Rational

Differentiating Change Management

Lifecycle Change Management


Rational Change, ClearQuest or Team Concert for multiple, configurable processes Flexible process, user definable states Integrated into full lifecycle change process Multiple approvers

DOORS Change Proposal System - CPS


Providing a built in change process for requirements Predefined process Changes only applied on approval

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Software and Systems Engineering | Rational

Manage Change for Good Manufacturing Practice (GMP) Establish an integrated change process across the lifecycle
Capture customer requests & market driven enhancements Manage Portfolio & Product Priorities

Execute Tests
Testing Eco-system

Collaboration, Process, Workflow


Integrated Change Management

Capture & manage requirements

Configuration Management

Develop Model-Driven System -> Software

Collaborate across Development Disciplines Software Electrical Mechanical


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Integrate Suppliers
2011 IBM Corporation

Software and Systems Engineering | Rational

Some Typical Issues


Reuse of existing documents and data

Risk Analysis
Qualification of requirements
Must have, want to have, nice to have, source, product version etc.

Traceability
Multiple levels required due to the complexity of the systems

Change Control
Who made a change, when the change was made, why the change was made, and analysis of the impact.

Auditable record compliance


Electronic signature and document management

2011 IBM Corporation

Software and Systems Engineering | Rational

Electronic Signature

Electronic signature against baselines directly in DOORS provides:

Accountability
Audit capability Quality procedures Verification of intent Documented consensus and decision making Conformance with FDA 21 CFR part 11
Provides full accountability without external tools
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Software and Systems Engineering | Rational

High Quality, Compliant Documents in minutes


using Rational Publishing Engine
Template driven document generation ensures the output complies with any required formatting standards and contains correct branding and legal information Support for multiple output formats (MS Word, HTML, PDF, XSLFO)

Flexible output

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Software and Systems Engineering | Rational

IBM Rational Software Platform for Systems


Full coverage of the systems engineering lifecycle
Product / System Build Product / System Deliver Run / Support / Maintain

Customer Needs

Develop Concept

Product Definition

Spans the entire systems and software lifecycle Integrates complex systems, embedded software and IT to create innovative products Achieves end-to-end traceability

Requirements Capture & Analysis Reporting, Version & Change Mgmt Systems Analysis & Design

System Acceptance

(Sub-)System Integration & Test

SW Design

Module Integration & Test

Implementation & Unit Test Best Practices

Provides proof of compliance

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2011 IBM Corporation

Software and Systems Engineering | Rational

IBM Rational Solution for Medical Devices


Execute best practices and collaborate through an integrated product lifecycle solution
Deliver medical devices that address market needs through portfolio management Provide clear audit trail across the development lifecycle with requirements management Validate designs early with model driven development Integrate change processes to coordinate development Automate document generation for compliance Drive quality throughout the product lifecycle

Powered by

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2011 IBM Corporation

Software and Systems Engineering | Rational

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2011 IBM Corporation

Software and Systems Engineering | Rational

Learn more at: IBM Rational software IBM Rational Software Delivery Platform Process and portfolio management Change and release management Quality management Architecture management

Rational trial downloads Leading Innovation Web site developerWorks Rational IBM Rational TV IBM Business Partners IBM Rational Case Studies

Copyright IBM Corporation 2008. All rights reserved. The information contained in these materials is provided for informational purposes only, and is provided AS IS without warranty of any kind, express or implied. IBM shall not be responsible for any damages arising out of the use of, or otherwise related to, these materials. Nothing contained in these materials is intended to, nor shall have the effect of, creating any warranties or representations from IBM or its suppliers or licensors, or altering the terms and conditions of the applicable license agreement governing the use of IBM software. References in these materials to IBM products, programs, or services do not imply that they will be available in all countries in which IBM operates. Product release dates and/or capabilities referenced in these materials may change at any time at IBMs sole discretion based on market opportunities or other factors, and are not intended to be a commitment to future product or feature availability in any way. IBM, the IBM logo, Rational, the Rational logo, and other IBM products and services are trademarks of the International Business Machines Corporation, in the United States, other countries or both. Other company, product, or service names may be trademarks or service marks of others.

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Back-up

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Safety-Related Concepts
Accident is a loss of some kind, such as injury, death, or equipment damage Risk is a combination of the likelihood of an accident and its severity: risk = p(a) * s(a) A Hazard is a set of conditions and/or events that leads to an accident.

Hazards are predictable and therefore controllable A safety-relevant system contains two kinds of hazards Intrinsic hazards - due to the inherent job and operational environment of the system Technology hazards - due to the addition of specific technological solutions
A safety control measure is an action or mechanism to improve the safety of the system by either

Reducing the severity of the accident Reducing the likelihood of the accident
A fault is the nonperformance of a system or component and may be either random or systematic Fault Tree Analysis determines what combinations of conditions or events are necessary for a hazard condition to occur

Allows the developer to lower the risk of a Safety violation, critical for IEC 62304
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Software and Systems Engineering | Rational

Safety Metamodel

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Software and Systems Engineering | Rational

Fault Tree Analysis is defined in IEC 61025

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2011 IBM Corporation

Software and Systems Engineering | Rational

Show link to IEC sections

Develop Systems and Software in a Model-Driven way

Visually develop complex systems using a structured approach


Traceability from requirements -> implementation Automate FDA documentation submission Visual modeling manages complexity Generates production quality code Reduce testing time with model-driven testing Leverage existing code for documentation

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2011 IBM Corporation

Software and Systems Engineering | Rational

Show link to IEC sections

Automate Document Generation

Generate the right document at the right time


Increase productivity by allowing engineers to focus on engineering
NOT formatting concerns

Maintain accuracy through quick one-click document generation


Captures last minute changes from data held in different source applications

Enhance documentation quality thru template reuse

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2011 IBM Corporation

Software and Systems Engineering | Rational

Manage Requirements across the Product Lifecycle

Capture, define, analyze, and manage requirements


Improves visibility and collaboration
Accurate documentation for regulatory audits and reviews

Supports FDA CFR21 Part 11 compliant electronic signatures Integrates with:


Portfolio management Modeling change management Quality management solutions

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2011 IBM Corporation

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