Thursday, May 12, 2016

RISK  ANALYSIS

There seem to be several definitions of risk analysis, left unstated, in many on-line regulatory discussion threads, which can lead to incorrect focus and improper direction.   

The most important from a regulatory standpoint, either US FDA or EU MDD, et al, is product risk to the end user, the patient / clinician. For devices this is ISO 14971, for pharma it could be ICH Q9, which could include the d-, p-, and u-FME[C]A as well as other complementary methods recommended in those standards. 

IN ADDITION, a project leader may want to do risk analysis tied to project success, meeting budget and time deadlines, customer delivery commitments, etc. But those would be business / financial-related risks not the ones regulatory agencies mandate. And as mentioned, the earlier the better.  


So such risk analysis if performed on equipment would still have to trace any failure modes, malfunctions, or even correct functions that could cause problems, through to their effects on the end user / patient / clinician (an omission often cited for the disadvantage of using FME[C]A for patient / user risk analysis, although such can be compensated for by definitions and/or structure of such).

-- John E. Lincoln, jelincoln.com

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