Some answers to some questions raised on my webinar on the above subject:
Ques: Examples of FDA HF
guidance documents, etc?:
https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/HumanFactors/ucm119190.htm#guidancehf
As mentioned, use the search box in upper right on FDA web site,
as well as links from the above link.
Ques: HE75?
Ans: The ANSI web site sells both HE75 and IEC
62366-1:2015 together, and states:
"The ANSI/AAMI HE75 and ANSI/AAMI/IEC 62366 Human Factor
Set addresses a broad range of human factors engineering (HFE) topics in a structured format. The material
emphasizes adoption of a user-centered focus throughout the product design and
development process, with the goal of making medical devices easier to use and
less prone to use error. By providing a structured approach to user interface
design, this set documents can help manufacturers develop safe and usable
medical devices.
- The
ANSI/AAMI HE75 and ANSI/AAMI/IEC 62366 Human Factor Set includes
- ANSI/AAMI
HE75:2009 (R2013) (ANSI/AAMI HE 75:2009 (R2013))
- ANSI/AAMI/IEC
62366-1:2015"
http://webstore.ansi.org/RecordDetail.aspx?sku=ANSI%2FAAMI+HE75+and+ANSI%2FAAMI%2FIEC+62366+Human+Factor+Set&source=google&adgroup=ansi-aami&gclid=CjwKEAiA0fnFBRC6g8rgmICvrw0SJADx1_zAwESZsbs9ED83LJflK_Qq0H773imIq4qMb-lGfKA12hoCrbnw_wcB
Not too helpful in my opinion.
The FDA allows you the manufacturer to determine how to address
(and they allow plenty of leeway as long as the requirements are addressed by
your procedures , and you follow your own procedures). For CE-marking,
work with the preferences of your Notified Body, following
the general outline presented in the webinar / standard (the 9 stages, documented in a Usability Engineering File), and and with consideration of the new EU MDR.
I still believe that the new IEC 62366-1:2015 is the documented
process to follow with all current and further UE projects, following and
documenting the 9 stages in the UE File as we discussed in the webinar.
The FDA and ANSI/AAMI HE 75 and others could be used in the actual HF/UE
analysis where appropriate for ideas, but the documented process should follow
IEE 62366-1:2015's 9 stages and the document deliverable in the UE File.
I suspect it will take awhile for some consensus in
implementation to build (with the EU implementation). But I believe that
the "end" result will be similar to what I've outlined above.
-- John E. Lincoln -- jel@jelincoln.com
For the basic UE / HF process to follow (and for the basic format of a UE / HF Product File), use the 9 stages defined in IEC 62366-1, worldwide; for the specific UE / HF techniques to employ, use the various other UE / HF standards and/or guidance documents, as applicable. - JEL 03/27/2024
No comments:
Post a Comment