Several medical device
directive (MDD) and active implantable medical device (AIMD) changes took place
in 2010. This impacted multiple functions (e.g., Regulatory, risk management,
technical communications) and had an effect on legacy, ongoing, and future
products. For example, the crux of the MDD changes included:
- Designing and manufacturing medical devices in such a
way that when used under the conditions and for the purposes intended,
they will not compromise the clinical condition or the safety of patients,
or the safety and health of users.
- Reducing the risk of use error due to the ergonomic
features of the device and the environment in which the device is intended
to be used.
- Considering the technical knowledge, experience, education and training and where applicable the medical and physical conditions of intended users.
So, what is EN
62366?
- This is a ‘process standard’, that tells a manufacturer
the process to analyze, specify, design, verify and validate
usability, as it relates to the safety of a medical device.
- The standard focuses on the need to provide adequate
usability such that the “risks resulting from normal use and use error are
acceptable”.
- The standard focuses on identifying and mitigating
design-induced use error.
- The standard discusses the need to validate primary
operating functions.
- Overall, this standard emphasizes a more formal human
factors process that combines analytical and empirical methods to detect
as well as mitigate use error.
- The standard also requires the maintenance of a usability engineering file and associated documentation that human factors work was done. However, the process is scalable.
In
2011, FDA published a draft guidance on “Applying Human Factors and Usability
Engineering to Optimize Medical Device Design” for comment
purposes. The comment period is complete but the effectivity date for the
guidance is still TBD. Overall the FDA draft guidance is very similar to
EN62366. However, some key differences exist:
- The FDA draft guidance focuses on using analytical and
empirical methods very early in the project lifecycle to identify and
mitigate sources of use error.
- There are clear expectations for handling, documenting,
and resolving use errors.
- The guidance discusses a human factors engineering
summary report, which is very elaborate and prescriptive.
As a human factors
advocate, I believe that irrespective of the regulatory driven requirements,
human factors should be an integral part of the product development lifecycle
in medical device industries (or any industry) so as to create products that are not only safe
but also improve user workflow and efficiency.




