New QMS Risk Entry
Risk Priority Number (RPN) = Severity ร Probability ร Detectability. Threshold for mandatory action: RPN โฅ 50. Per ISO 14971, any catastrophic severity (S=5) requires action regardless of RPN.
ISO 14971 โ Medical Device Risk Management Link
ISO 13485 requires implementation of risk management throughout the product lifecycle (Clause 7.1). ISO 14971:2019 is the dedicated risk management standard for medical devices and provides the detailed risk management process referenced by ISO 13485. Together these standards ensure safe, effective devices reach patients.
Hazard Identification
ISO 14971 Clause 5: Identify all hazards associated with the device, its intended use, and foreseeable misuse. Consider physical, chemical, biological, electrical, and functional hazards.
Risk Estimation
Clause 6: Estimate probability of hazardous situation occurring and severity of resulting harm. Risk = Probability ร Severity. Document all assumptions and data sources.
Risk Evaluation
Clause 7: Compare estimated risk against risk acceptability criteria defined in Risk Management Plan. Is the risk acceptable? Must benefit outweigh risk for medical devices.
Risk Control
Clause 8: Apply controls in priority order โ (1) Inherently safe design, (2) Protective measures in device or manufacture, (3) Information for safety/training. Verify effectiveness.
Residual Risk / Benefit-Risk
Clause 9: Evaluate overall residual risk. For medical devices, residual risk must be judged acceptable based on benefit to patient. Required for MDR Technical Documentation.
Post-Market Monitoring
Clause 10: Production & post-production information (PMS/PMCF). Review risk file in light of post-market data, complaints, vigilance reports, literature surveillance.
Medical Device Lifecycle โ ISO 13485 Scope
ISO 13485 requires risk management throughout the entire medical device lifecycle. Risks must be identified and controlled at each phase, from initial concept through to decommissioning.
1Design & Development
Design inputs/outputs, V&V, DFMEA, biocompatibility, software development, usability engineering, clinical evaluation. Clause 7.3 requirements.
2Regulatory Approval
Technical documentation, clinical evidence, conformity assessment (MDR), 510(k)/PMA (FDA), Notified Body review. Risk file completeness.
3Manufacturing
Process validation (IQ/OQ/PQ), PFMEA, supplier qualification, incoming inspection, in-process controls, environmental monitoring, sterile barrier. Clauses 7.4โ7.5.
4Distribution & Installation
Cold chain / preservation requirements, installation procedures, traceability records, UDI labelling, distribution controls. Clauses 7.5.11, 7.5.3.
5Clinical Use
Use by healthcare professionals / patients, operator training, maintenance requirements, servicing procedures, customer feedback capture. Clauses 7.5.4, 8.2.1.
6Post-Market Surveillance
PMS plan/report, PMCF (MDR), complaint analysis, adverse event/vigilance reporting, FSCA, risk file updates, literature surveillance, PSUR. Clauses 8.2.1โ8.2.3.
ISO 13485:2016 โ Key Risk-Related Clauses
7.1 โ Risk Management in Planning
Risk management must be part of product realisation planning. Risk management activities must be documented and planned across the entire lifecycle per ISO 14971.
7.3 โ Design Controls
Design FMEA, design verification, design validation, design reviews, risk inputs/outputs. Risk management must be integrated into all D&D activities (7.3.1โ7.3.10).
7.5 โ Production Controls
Process FMEA (PFMEA), process validation, sterilisation validation, contamination control, traceability. Risk drives validation requirements for special processes.
8.2.2 โ Complaint Handling
All complaints must be evaluated for regulatory reportability. Risk assessment drives complaint decisions โ investigate, report, or close without CAPA.
8.5 โ CAPA
Risk assessment determines CA/PA priority and scope. Effectiveness of actions must be verified and documented. 8.5.2 CA, 8.5.3 PA โ both risk-driven.
8.3 โ Nonconforming Product
Risk assessment must be performed for all nonconforming product decisions โ rework, scrap, use-as-is, or concession. Documented risk justification required.
RPN 1โ24: Negligible RPN 25โ49: Low RPN 50โ74: Medium RPN 75โ99: High RPN 100โ125: Critical
Note: Catastrophic severity (S=5) is always Critical regardless of RPN โ patient fatality or life-threatening injury cannot be accepted on probability grounds alone.