Hi

Regarding the ISO 14971 question, there´s seems to be a misunderstanding. The
risk analysis (a part of the whole risk management process described in ISO
14971) shall be made based on the normal use of the equipment (and single
fault if deemed necessary). Two explanations follow.

First, ISO 14971, generally speaking, is a standard that uses a risk managent
framework to assess the quality in the design of a equipment. Tthe
manufacturer has to use this framework to show that all risk (in normal use
AND single fault conditions AND reasonable foreseeable misuse) is kept below a
residual risk level (previously chosen). This concept comes from IEC 60513
second edition - the base for the third edition of IEC 60601-1 - where it is
stated that some risks cannot be assessed by the norma pass / fail criteria.
IEC 60513 also includes the concept of essential performance, i.e., safety of
medical electrical equipment not only comprises basic safety but also minimum
performance requirements (e.g. accuracy on the output of a electrical
stimulator). This whole risk management concept is one of the most important
points in medical electrical equipment standards development these days
(compliance to the third edition of IEC 60601-1 will only be achievable by
compliance to ISO 14971 too, and particular and colateral standards will have
this same need - this will be implemented in the near future). If you want
another standard that is already published that uses risk analysis (and
management) in normal use (and in the two other situations) look no further
than 60601-2 sister IEC 60601-1-4 on programmable electrical medical systems -
it doesn´t use ISo 14971 because it was deeveloped before, but it´s the same
thing. A recent example that can use ISO 14971 is IEC 60601-2-12 2002, which
let an equivalent degree of safety in all tests be demonstrated by means of a
risk analysis in acordance with ISO 14971.  

Second, IEC 60601-1-2 asks for a risk analysis from the manufacturer to show
which functions of the equipment are considered essential performance, ie,
which function must behave normally for the equipment to be considered
operating - so it clearly means normal use. If the risk analysis is not
performed, all functions are considered essential. This means that all
functions will have to be tested, and worse, all function shall retain their
performance and remais safe. This could lead to a lot of problems during
testing. 

Regards  

--
Marcelo de Moraes Antunes - [email protected] 
IPT - Technological Research Institute - Brazil
Electrical Evaluation Laboratory LAE-ATEE-DME 
Phone+55 (11) 3767-4948 Fax +55 (11)3767-4007 



 



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