The organization can then be issued a warning letter or product recall if they fail to adequately address the noted deficiency. Other areas of misalignment between the FDA and industry regarding the guidance include:. With the issuance of final guidance documents in Octoberthe FDA realized its commitments to Congress by "preserving the basic format and content of the original, " guidance and remained consistent with the draft guidance.
In the final guidance, the FDA expanded on the guiding principles and labeling requirements and added more clarity and examples.
The 10 new "guiding principles" have a significant impact on the process, decisions, and documentation required. They are summarized below in Table 1. Section A: Labeling Changes — and the associated flowchart — represents the most significant change between the final issue and draft guidance and increase the scope.
Usability and over-the-counter clarification questions were also added. The FDA increased the number of labeling examples in Appendix A from eight to 11, addressing industry comments and requests.
The final software guidance primarily follows the draft, with additional clarification and a streamlined flowchart. The FDA considers all software changes to be design changes True Guidance - Vital (V2E) Elements* & Micky Finn - So Good / True Guidance (File definition and added additional emphasis in the final guidance regarding what could significantly affect safety and effectiveness. Table 2 is an example flowchart for organizations to follow and specifies when a software change requires a new k submission.
The following questions lead the assessor to a defensible software change k filing decision. Note: question 3a and 3b both need to be answered. The FDA has clarified the significant role of risk management in the regulatory filing decision process.
The burden is on the industry to adopt and implement an effective risk-based change assessment process for its filing decisions. Several recommendations for updating existing regulatory filing decisions and processes related to design and intended use changes are provided below. It also is recommended that a comparison of the proposed changes against the cleared device be available and to include current and aggregate changes since device clearance. Furthermore, software change assessment documentation must address the questions in Table 2.
Key functional stakeholders should be able to provide expert input to address clinical, design, and risk management considerations to ensure a fully comprehensive and error-proof decision process.
Some comments objected to the discussion of standardization and reuse of software components and asked for more recognition of the trend toward increased use of OTS and component-based development methods. At each stage of the software life cycle, there is information available that can contribute to a conclusion that the software meets user needs and intended uses.
Therefore, the validation process does not end when the device is shipped. That is not what we meant. Based on the comments received, we have rewritten the discussion to emphasize the need for regression analysis after a change, followed by an appropriate level of regression testing to reestablish the validation status of the software.
We have deleted specific MP3) of retrospective validation and reverse engineering of nonvalidated software, but these issues should be covered during the regression analysis.
Some of the most significant comments we received had to do with our basic definition of software validation. In the previous draft guidance, we relied upon technical definitions used by the National Institute of Standards and Technology and by the Institute of Electrical and Electronic Engineers. These technical definitions created some confusion with other definitions in our quality system regulation. They stated that both design review and verification are distinctly separable quality concepts and are not a part of validation.
In response to these concerns, we have changed the definition of software validation to be more consistent with the quality system regulation and other international quality standards.
Other comments objected to possible interpretation of these as mandatory tasks. In response to these comments, we have also added text to explain that there are typical verification and testing tasks that support an overall conclusion that software is validated.
Several comments noted inconsistencies in terminology from that contained in the quality system regulation, in two software guidances issued by the Office of Device Evaluation, and in the FDA glossary of computerized system and software development terminology.
However, we continue to emphasize that while there are many MP3) risks e. At their next revision, we expect to update other software guidance documents and the FDA glossary with consistent definitions of validation, verification, and risk analysis. Some comments questioned whether OTS software could be validated because the device manufacturer frequently does not have access to the source code.
Where the source code is not available, it is incumbent upon the device manufacturer to use other means such as audits, or more extensive black box testing to infer the structural integrity of the OTS software. This issue is clearly addressed in comment of the preamble to the quality system regulation 61 FR at Other comments from the pharmaceutical industry suggested incorporation of widely understood process validation terminology i.
As noted above, design reviews are not a part of validation. In fact, several comments noted that results of verification and validation are inputs to design reviews—not the other way around.
One suggested that design review was an adequate substitute for traceability analysis. We disagree. Traceability is an essential aspect of verification, and it is an important input into design reviews. We therefore do not believe that design review could be an adequate substitute for traceability analysis. One comment stated that requirements are not always neatly structured, and it is very difficult to trace exactly how they are implemented in the design.
There are numerous many-to-one and one-to-many relationships to be mapped from requirements to design to code. We agree with this observation; however, it actually further supports the need for traceability.
The larger and more complex the project, the more important the traceability analysis becomes. Therefore, we have retained the discussions regarding traceability, and in response to several other comments, we have added traceability of software requirements to the safety risk analysis. Another comment noted that inherent traceability can be built into documentation and code without having to have a separate traceability document. There may be many other approaches to traceability. Software developers have flexibility in how they want to implement traceability.
Many comments questioned the concept of a software failure modes and effects analysis FMEA. They stated that given the difficulty of predicting specific software failure modes, FMEA is better used as a system level risk analysis tool. We have revised the guidance to discuss software risk analysis within the context of system safety.
However, while we acknowledge some limitations in its use, we also believe that software FMEA can be a useful tool, especially for safety critical aspects of software applications. It may also be useful early in the development process for analyzing safety critical software requirements. One comment objected to the suggestion that risk analysis begin at the stage where requirements are defined.
However, to be useful and have an impact on the software development process, we believe that risk analysis needs to begin early and needs to be updated as the project progresses. In addition, we have revised various portions of the guidance to emphasize that the level of safety risk is a major factor in determining the level of effort to be applied in testing and other verification and validation tasks.
Several comments questioned the idea of early test planning, which was recommended in the draft guidance. For example, they argued that there is insufficient information available during requirements development to be able to develop a system test plan or an acceptance test plan. The fact that there is insufficient information for a particular test plan is valuable feedback to the development process that perhaps the requirements or design processes are not yet sufficiently complete.
Planning is a dynamic activity that should be reexamined and updated as the project progresses. However, that is widely recognized as one the major flaws in software development, and its correction is one of the most important messages intended by this guidance. In order to be complete, a software requirements specification should cover all the pertinent issues—not just a selected few. One comment noted that requirements may not always be measurable. We agree regarding internal interfaces and have changed the text accordingly.
However, since software requirements are derived from system requirements, there may be some internal system interfaces prescribed from the high level system design that would impact software requirements.
Software developers have flexibility as to where in their life cycle they wish to cover particular issues. We rejected most comments requesting even greater levels of detail and specificity regarding static verification techniques. FDA investigators will expect to see a verification procedure that includes a means for identifying and resolving incomplete, ambiguous, and conflicting requirements, as required by the regulation.
They will also expect to see objective documented evidence that the verification procedure was implemented. We have retained wording about the need for design specifications to be complete enough for programmers not to have to make ad hoc decisions. The intent is to ensure that the code created is consistent with the design specification. When programmers or engineers decide to add new functionality not identified previously in the requirements or design, those specifications need to be updated to reflect the actual code created.
The project manager, design team, and any future maintainers of the software need Start Printed Page to have accurate documentation in order to do their work. We have dropped the listing of specific approaches to software design, and we have included a more general description of what should be included in a software design specification. Some comments considered the previous list to be too prescriptive as well as incomplete. We recognize that portions of the software are completed and released incrementally, and life cycle processes are repeated iteratively.
The intent is that those portions of the software have design documentation that is consistent with the software application that is implemented. One comment noted that in a rapid application development RAD environment, there is typically no formal design document in place during coding. We recognize that RAD is valuable as a prototyping tool, but its use does not preclude the need to document the specific design, once it is agreed upon.
We have changed the title of this subsection to reflect that the creation of a software application can be either through coding, or through combining existing software components, such as OTS software products or functional components from existing code libraries. Comments objected to the idea of having to keep results of all compilations of the code. We renamed and revised this subsection to provide a better explanation of the purpose of testing, and to avoid prescriptive language concerning use of specific testing techniques.
We have added language regarding use of incremental development and testing methodologies. We expanded the discussion of testing coverage to explain how different degrees of coverage should be considered for varying levels of risk, and that the manufacturer has flexibility to choose the right level of coverage. One comment noted that the intent of testing is to find errors, and suggested a better explanation of this and other tenets of a software testing strategy.
We have added such an explanation. Other comments argued that statistical testing based on usage profiles is more effective than extensive structural testing in finding software defects.
We agree that statistical testing is one of many valuable testing methodologies, and we have added information about its use. However, it is important to note that statistical testing is an adjunctive approach, rather than an outright replacement for other types of testing.
User site testing can be any one of several types of testing performed by the user or by others at the user site. System level testing performed by the software developer under conditions that simulate the user's environment is an important part of validation for some products, and it may substitute for some aspects of user site testing. However, for certain products such as blood establishment software, there are specific FDA requirements for additional testing to be performed at the user site.
For manufacturing and quality system software, user site testing is frequently performed by the device manufacturer. We have made appropriate changes to the text. However, we continue to emphasize that the validation of all software changes needs to include a regression analysis and, as appropriate, regression testing to show that the change has not negatively impacted the software.
In response to other comments, we have added information regarding anomaly evaluation, problem identification and resolution tracking, and the need to update documentation. We have added a new section to the document dealing with validation of automated process equipment and quality system software. This change was in response to the many comments that raised issues and asked for more detailed information about validating such software, especially OTS automated equipment and OTS software. Many comments discussed the difficulties encountered in trying to validate OTS software, and suggested a different approach for validation of manufacturing and quality system software.
Source code True Guidance - Vital (V2E) Elements* & Micky Finn - So Good / True Guidance (File life cycle documentation are frequently unavailable for review, so structural testing is usually not possible. Auditing the vendor's software development activities is one possibility, True Guidance - Vital (V2E) Elements* & Micky Finn - So Good / True Guidance (File, but some software vendors will not agree to being audited.
One comment suggested that risk analysis, design, coding, and unit testing should not apply to quality system software, especially if it is purchased, and further suggested that functional testing is the most that can be expected. Several comments suggested that for widely used applications, there can be a reasonable assumption that the vendor validated the software at the time it was developed, and that installation qualification by the user should be sufficient.
FDA will not tolerate fraud…meaning what, exactly? Jun 25, Jun 10, Jun 9, Jun 8, Sub-supplier change from manual to automated process - same specs - Report to FDA? Jun 1, FDA Establishment registration - Buying some medical devices from another manufacturer.
May 21, How to classify a medical device based on FDA? May 14, May 4, Apr 27, What is considered a "core algorithm"? From an FDA guidance document. Apr 26, Apr 16, Apr 10, Apr 3, FDA's E submitter - For clinical electronic thermometer. Mar 11, FDA wants electrical safety testing on battery powered medical device.
Feb 12, Jan 24, Jan 6, Jan 3, Mislabeling - Consider this an FDA notified recall? Dec 12, Dec 1, Nov 19, When does the FDA consider a component a medical device?
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