Each step of the medical device life cycle is taken into account in the risk management process: Step Main activities Participants Conception Selection of composite Multiwave Imaging electromagnetic properties Selection of particles Selection of solvent Selection of composite weight ratio Selection of pouch material Selection of label material Sealing process Selection of packaging IFU/labeling text Supply-chain Selection of suppliers Multiwave Imaging, (raw materials or suppliers intermediate products) Quality control upon receipt Storage Production Preparation of working Multiwave Imaging environment Pouch preparation Composite insertion into the pouch Leveling process Vacuum process Sealing process Cleaning process Labeling process Quality control before release Conditioning process Supply-chain Storage Multiwave Imaging, (finished products) transportation company Transportation to customers Clinical use MRI scan End-users Storage Cleaning Product Returns (end-of-life Disposal/recycling Multiwave Imaging, end- or defective devices) users
3.6 RISK ANALYSIS
3.6.1 Method used to analyze risk The risk analysis method is based on 4 steps: 1. Identification of safety features, hazards associated with the device, hazardous situations, or possible harm to the patient or users or environment (§4.3). The list of hazards provided in annex E of the standard may be used for hazard identification. 2. Evaluation of the probability of occurrence of each hazardous situation, and the severity of the resulting harm (§4.4 and 4.5) 3. Description of the control options (by design, protective measures, information for safety) (§6.2 and 6.3) 4. Residual risk evaluation and risk/benefit analysis (§6.4, 6.5 and 6.6) The 4 steps are documented in an Excel file TF-520 Risk analysis matrix, allowing the risk project team to follow the entire risk assessment process. Note: one hazardous situation may cause more than one type of harm. The most serious harm is always considered when performing risk evaluation. 3.6.2 Risk control options There are three risk control options used to reduce risk (listed in order of priority): 1. Inherent safety by design; 2. Protective measures in the medical device itself or in the manufacturing process; 3. Information for safety. Evidence must be provided to demonstrate the efficacy of risk control options. According to the EU Directive 93/42/EEC, control measures are put in place in order to reduce the risks as far as possible (i.e. the AFAP method: As Far As Possible). According to the EU Directive 93/42/EEC and Annex ZA 7.c) of the EN ISO 14971:2012 standard, the information given to users does not solely allow for additional risk reduction. If needed, an action plan may be written regarding the application of risk control methods. 3.6.3 Risk quotation criteria Risk is defined as the combination of the severity of possible harms to the patient or user and the probability of occurrence of each harm.
3.6.4 The severity scale
Severity is the measure of the possible consequences (damage, harm or adverse health effect) of a hazard. Here, a ranking scale from 1 to 4 is used to rank the severity of a potential harm. Severity level Description Possible harm to user/patient • Discomfort Reversible alteration without medical 1: Negligible • Dissatisfaction, loss of time care • Infinitesimal local warmth Reversible light alteration requiring • Minor skin injury 2: Moderate medical care • Minor local skin irritation
• Major skin/bone injury
• Allergic skin reaction • Respiratory tract irritation • Other limited health risks due to inhalation/ingestion of harmful 3: Significant Reversible severe alteration chemical component • Viral or bacterial infection • Wrong diagnostic leading to inadequate treatment or unnecessary additional tests
3.6.5 The probability of occurrence scale
The likelihood ranking, also a scale from 1 to 4, indicates the probability of occurrence of a harm. Probability level Qualitative likelihood Quantitative likelihood 1: Improbable An event that is very unlikely to < 1 in 1000 devices happen < 0.1% 2: Rare Unlikely to occur during total Between 1 in 1000 and less than 1 in 100 operational life but may rarely devices occur when considering all 0.1% - 1% devices 3: Probable May occasionally occur when Between 1 in 100 and less than 1 in 10 considering all devices devices 1% - 10%
4: Frequent Likely to occur at least once ≥ 1 in 10 devices