The CDRH Software Message (October 19, 2002)

The CDRH Software Message(October 19, 2002)

John F Murray Jr..

Center for Devices & Radiological Health

US Food and Drug Administration

JFM@CDRH.FDA.GOV

Mr. John F Murray Jr.

• Mr. Murray currently serves as the:– Software and Part 11

Compliance Expert– Office of Compliance– Center for Devices and

Radiological Health (CDRH)

– US Food and Drug Administration.  

Mr. John F Murray Jr.

• In this position Mr. Murray is the primary advisor to the Director of the Office of Compliance in the areas of:– Software validation– Software policy– Software classification and – Part 11 compliance issues.

• He is also responsible for: – the software standards program and – the software engineering training program at CDRH.

Mr. John F Murray Jr.

• Mr. John F Murray Jr. joined the FDA in March 1994. • Prior to becoming an FDA staffer, he was:

– A qualified Reactor Operator with United States Navy Submarine Fleet

– A Computer Field Engineer with Telex Computer Products– An Electronics and Software Engineer with The General

Dynamics Corporation and a– Systems Engineer at Technology Management & Analysis

Mr. John F Murray Jr.

• Prior to joining the Office of Compliance in June 2001, Mr. Murray served as the Team Leader for Software and Intelligent Medical Devices with the United States Food and Drug Administration, Rockville, MD. 

• Mr. Murray is the primary Advisor to the Chief of the Medical Electronics Branch in the areas of software engineering, software safety and software standards.

Mr. John F Murray Jr.

• The software team is responsible for:– Maintaining the technical foundations that are required for

the regulation of medical device software. – Regulatory decisions regarding the safety and effectiveness

of medical device software are based on engineering and scientific foundations.

– Software Standards is one example of these engineering

foundations.

Mr. John F Murray Jr.

• Mr. Murray is chairperson for the FDA Software Standards Technical Group (STG). – The Software STG is responsible for review and recognition

of software engineering standards for use in the regulatory

process. 

• Mr. Murray also serves as Co-Chair of the AAMI

Software Committee.

Mr. John F Murray Jr.

• Mr. Murray earned a:– BS Degree in Electrical Engineering from George

Mason University– MS Degree in Computer Science from Rensselaer

Polytechnic University (RPI).

The CDRH Software Message

John F Murray Jr..

Center for Devices & Radiological Health

US Food and Drug Administration

JFM@CDRH.FDA.GOV

Public Health and Software

The Quality of Pubic Health is highly dependent on the Quality of Medical Software

i.e. Medical Device Software, Clinical Information Systems, Hospital Information Systems, Manufacturing Systems etc

What type of Quality do we Want?

To get some perspective lets try what I call the YB scale. [yugo vs. bmw]

I ask the following questions:

Where would Microsoft be on this scale?Where do we want our software quality to be?Where do you want your software to be?

Do the regulations recognize this need

Yes they do:

21 CFR 820.30

21 CFR 820.30 (a) (2) (i)

21 CFR 820.30 (g)

21 CFR 820.70 (i)

21 CFR 820.30 Design Controls

• Each manufacturer of any Class II or Class III device, and the Class I devices listed in paragraph (a)(2) of this section, shall establish and maintain procedures to control the design of the device in order to ensure that the specified design requirements are meet.

21 CFR 820.30 (a)(2)(i)

• Class I – The following Class I devices are subject to

design controls:• Devices automated with computer software

21 CFR 820.30 (g)

• Design validation shall include software validation and risk analysis where appropriate

21 CFR 820.70 (i)

• Automated processes– When computers or automated data processing

systems are used as part of production or the quality system, the manufacturer shall validate computer software for its intended use according to an established protocol. All software changes shall be validated before approval and issuance. These validation activities shall be documented.

Software is Different

Traditionally not engineered, but crafted

Not physics based

Easy to change or is it?

Does not fail the hardware way.

etc

What is the goal?

• By Law: Medical Devices must be reasonably safe and effective

• By default: Software must be safe and effective

Safe and Effective

• It depends!

• Cannot be easily defined

• What is safe and effective software– Software Engineering– Risk Management– Quality System

Conclusion

• The law and regulations are written in broad terms

• Software should be engineered using:– Software Engineering– Risk Management– Quality System

This is the CDRH Software Message

Keys to Success

• Avoid denial• Make a plan• Document your activities • Remember the three A’s of meeting the

regulatory requirement– Activities– Attributes– Artifacts