Risk Management (03) – The Regulatory Requirements For Risk Management

Rami.Azulay December 5th, 2019 Posted by Rami Azulay( ) Requirements Management Tool

Pharmaceutical/Medical Device/Automotive Regulatory Requirements

According to regulatory bodies, medical devices, pharmaceutical or automotive manufacturers should be implementing Quality Risk Management (QRM) systems when accessing the risks that come with the production of products that introduce safety issues to the user/operator/technician of the device. In this post, we will be addressing the relevant quality standards and regulatory guidelines.

The United States Food and Drug Administration (FDA)

Below are 5 crucial points from the FDA Guidance for Industry: Quality Systems Approach to mentioned industries cGMP regulations (2006).

21 CFR Part 11 – Scope and Application 2003: This guidance is the documentation of the FDA’s approach for electronic records and signatures. They recommend that for implementation of key requirements of Part 11 they should base the decision on a documented and justified risk assessment. Also, consideration should be given toward the potential of the system to influence product quality, record integrity, and safety. 

  • Additionally, the decision to include audit trails should be based on justified and documented risk assessment.
  • The Orcanos QMS system fully complies with the regulatory requirements and it includes a built-in electronic signature and audit trail according to 21 CFR Part 11. It comes with a complete validation package to assist users to include it in their audit inspection.

 Orcanos Electronic Signature

European Regulations: There is a legal status for Annex 15 to the EU GMPs Validation and Qualification. It utilizes a risk-based process for validation of changes to components, systems, facilities, and equipment. To determine the extent and scope of validation, use a Risk Assessment Approach. It crucial to always evaluate the possible effect of changes in facilities, equipment, and systems on the product. Also, do not forget to include a risk analysis report.

In the Orcanos Design Control module, there are several tools that allow you to conduct the assessment of a change. It gives you tools to raise subspecies indicators which are based on existing traceability between artifacts or to asses risk to newly introduce change as part of the risk assessment process.

Orcanos Suspicious Effect on Change Report

There is a legal status for Annex 11 to the EU GMPs for using computerized systems. It mandates that control for computerized systems be based on a document and justified risk assessment. Likewise, the level of validation and data controls have to be in line with a proper and documented risk assessment.

Orcanos computerized system is a validated system and it comes with a validation package that is complying with the regulatory requirements for both the USA and EU.

International Conference for Harmonisation ICH Q9/ISO 14971/ISO 26262: It is regarded as the most important document when it comes to risk assessment for the pharmaceutical/medical device/automotive correlated sector.  The ICH focuses on how scientific knowledge plays a role in the protection of patients in the life industry and ISO 14971 focuses on the hazardous situation and potential mitigation while the ISO 26262 focus on safety issues related to critical components. These reference documents provides guidance on implementation processes. The three major principles that govern quality risk management are; 

  • Always use scientific knowledge were possible, as a base for evaluating risks to product quality and relate it to patient protection.
  • The extensiveness of the documentation, effort, and formality regarding risk management processes should reflect the level of risk.
  • Learn from the existing market what could go wrong in your device.

It might not always be necessary or appropriate to make use of a formal risk management process. For instance, using a well-known tool for an internal process like a standard operating procedure. Similarly, it is acceptable to use informal risk management processes or standard operating procedures for internal processes.

International Standards Organisation (ISO): The organization has three standards that address risk management. They are;

  • ISO 14971 – Medical Devices
  • ISO 31000 – General purpose risk management projects
  • ISO 31010 –  General purpose risk management projects

 

NOTE: There is a major difference between ISO 31000 and ISO 31010 despite addressing the same risk management problems. ISO 31000 highlights principles and guidelines, while ISO31010 describes risk assessment techniques.

ISO 14971: 2012 (Application of Risk Management to Medical Devices): While this document is for medical devices, the FDA recommends it to the pharmaceutical industry, others recommended it for the automotive as well. In this international standard, there is an outline that manufacturers can follow to identify potential hazards that concern medical devices. Also, it covers in-vitro diagnostic devices (IVD). Using the stipulated process, manufacturers can evaluate, and estimate the level of risk and take actions to control and monitor the risks. Likewise, the manufacturers will have criteria that will help them determine the effectiveness of the controls.

Throughout the lifecycle of any medical device, the requirements in this standard are applicable. However, it does not extend to clinical decision making, neither does it specify what risks levels are acceptable. Finally, the standard does not mandate that manufacturers use a quality management system. Nevertheless, a risk management system is a crucial part of the quality management system.

Reference Links

Risk Management – orcanos FMEA Risk Management Tool
Generate Risk Management File Risk Management (ISO 14971) by Orcanos, based on FDA 2017 Recalls
Orcanos Risk Management – Add Traceability Matrix ALM Requirements Traceability Matrix Tools
10 Reasons why to use EQMS 21 CFR Part 820
Risk Management (01) – Introduction to Quality Risk Management (QRM) Risk MANAGEMENT (02) – THE BENEFITS OF FAILURE MODE AND EFFECT ANALYSIS (FMEA)

 


About the author, Rami Azulay

Rami has over 24 years of experience in various software development and QA roles. Using his extensive knowledge of operations and quality, Rami was a main architect of the Orcanos software back in 2005 and later became Orcanos VP sales & marketing. Rami holds an MSC degree in Computer Sciences.

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