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You must have a:
Quality
Management
System
IEC 62304 Action List
for medical devices that rely on one or more software
components, parts, or accessories for Basic Safety
or Essential Peformance
General Requirements1
Classification is assigned based on risk severity.
The device manufacturer assigns a safety class to
each Software System that contributes to the imple-
mentation of a Risk Control measure. If a class is not
assigned, then Class C requirements apply.
Software Safety Classification2
For all classes, this plan must:
q Reference system design
and development
q Be updated as development
progresses
q Include Verification Planning
q Include Risk Management Planning
q Include Configuration Management Planning
Class B and Class C must also provide:
q Integration and Integration Testing Planning
q Supporting items to be controlled
q Software Configuration Item Control before
verification
Software Development Plan3
Class A
No injury or damage to health
is possible
Class B Non-serious injury is possible
Class C
All classes must define and document the software
requirements for their system. This includes:
q Preparing software requirement content
q Re-evaluating medical device risk analysis
q Updating system requirements
q Verifying software requirements
Software Requirements Analysis4
Classes B and C must transform their software
requirements and the interfaces of software items
into an architecture.
q Specify functional and performance require-
ments of SOUP (Software of Unknown Pedi-
gree) items
q Specify system hardware and software required
by SOUP items
q Identify software segregation necessary for
risk control
q Verify software architecture
Software Architectural Design
Requirements
5
Class C must also provide:
q Software Development Standards,
Methods and Tools Plan
Class B and Class C must also analyze change
requests.
Class B and Class C must also include risk control
measures.
Class C must go into more depth by:
q Developing Detailed Design for each Software
Unit
q Developing Detailed Design for Interfaces
q Verifying the Detailed Design
Software Detailed Design6
Implement Each Software Unit7
Software Unit Verification Process8
Classes B and C must refine their Software
Architecture into Software Units.
Classes B and C must establish a Software
Unit Verification Process. Where Verification
is done by testing, the test procedures will
be evaluated for correctness.
q Develop Software Unit Acceptance Criteria
q Complete Software Unit Verification
Software Integration &
Integration Testing
9
Classes B and C must:
q Integrate Software Units
q Verify Software Integration
q Test Integrated Software
q Prepare Integration Testing content
q Verify Integration Test Procedures
q Conduct Regression Tests
q Prepare Integration Test Records
q Use Software Problem Resolution Process
Death or serious injury is possible
Risk Management
Process in Compliance
with ISO 14971
SDLC Process in
Compliance with
IEC 62304
code
Additionally, Class B and Class C must:
q Ensure Software Verification is complete
q Document known residual anomalies
q Evaluate known residual anomalies
q Document how released software was created
q Ensure activities and tasks are complete
q Archive software
q Assure repeatability of Software Release
All classes must document the version of the released
software.
Software Release11
All classes must establish a Software Maintenance
Plan. Problem and Modification Analysis is also
required. All classes must:
q Document and evaluate feedback
q Monitor feedback
q Evaluate Problem Report’s effects on safety
q Use Software Problem Resolution Process
q Include change request approval
q Communicate to users and regulators
Software Maintenance Process12
You must use an established process to implement
modification. Upon making changes, you are also
required to re-release the modified software system.
Modification Implementation13
All classes must analyze changes
to their medical device software
with respect to safety.
When complete, documents should be sent to the
test lab in an editable format. The lab will assign your
device a pass or fail upon review. If you fail, make
necessary changes. If you pass – congratulations!
Risk Management of
Software Changes
16
All classes must implement configuration
identification. This includes:
q Establishing a means to identify
configuration items
q Identifying SOUP
q Identifying system configuration documentation
q Configure change controls
q Approve change requests
q Implement changes
q Verify changes
q Provide means for traceability of change
q Configure status accounting
Software Configuration Management
Process
17
All classes must implement a process for resolving
software problems. This includes how you will:
q Prepare problem reports
q Investigate the problem
q Advise relevant parties of the problem
q Use change control processes
q Maintain records of the problems
q Analyze problems for trends
q Verify Software Problem Resolution
q Test documentation contents.
Software Problem Resolution Process18
Submit to Test Lab19
The Software Risk Management Process is critical for
Class B and Class C. These classes must:
q Conduct an analysis of software that contrib-
utes to hazardous situations
q Identify potential causes of the contribution
q Evaluate published SOUP anomaly lists
q Document potential causes
q Document sequences of events
Software Risk Management Process14
Classes B and C must complete
Risk Control Measures, including:
q Defining said Risk Control
Measures
q Identifying Risk Control Measures
implemented in the software
q Verify Risk Control Measures
q Document any new sequences of events
q Document traceability
Risk Control Measures15
In addition, classes B and C must:
q Analyze the impact of software changes on
existing risk control measures
q Perform risk management activities based on
these analyses
Software System Testing10
Classes B and C must:
q Establish tests for Software
Requirements
q Use Software Problem
Resolution Process
q Retest after changes
q Perform relevant risk management activities
q Verify Software System Testing
q Use Software Problem Resolution Process
q Prepare System Test Record contents
code
code
IEC 62304 is the international standard that defines software development lifecycle requirements for medical device software.
The standard was developed from the perspective that product testing alone is insufficient to ensure patient safety when
software is involved. The standard requires all aspects of the software development life cycle to be scrutinized.
Preparing
Your Device
for Market
MethodSense is a life science consulting firm, specializing in helping companies bring medical and technological products
to market. They guide medical device, biotech and pharmaceutical companies with quality, regulatory and technology
solutions, which enable clients to operate more effectively during the commercialization process and beyond. In addition to
their expertise as regulatory consultants, MethodSense has developed a 21 CFR Part 11 compliant software as a service tool,
InfoStrength Smart Enterprise Suite, that allows them to guide their clients to success. For more information about
MethodSense, please visit www.methodsense.com.
Please note: This IEC 62304 Action List represents a high level summary of the standard’s requirements and does not
constitute advice for compliance with this or any other regulatory requirement. Manufacturers should consult with their
regulatory affairs professional to determine the appropriate compliance strategy for any particular medical device.

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IEC 62304 Action List

  • 1. You must have a: Quality Management System IEC 62304 Action List for medical devices that rely on one or more software components, parts, or accessories for Basic Safety or Essential Peformance General Requirements1 Classification is assigned based on risk severity. The device manufacturer assigns a safety class to each Software System that contributes to the imple- mentation of a Risk Control measure. If a class is not assigned, then Class C requirements apply. Software Safety Classification2 For all classes, this plan must: q Reference system design and development q Be updated as development progresses q Include Verification Planning q Include Risk Management Planning q Include Configuration Management Planning Class B and Class C must also provide: q Integration and Integration Testing Planning q Supporting items to be controlled q Software Configuration Item Control before verification Software Development Plan3 Class A No injury or damage to health is possible Class B Non-serious injury is possible Class C All classes must define and document the software requirements for their system. This includes: q Preparing software requirement content q Re-evaluating medical device risk analysis q Updating system requirements q Verifying software requirements Software Requirements Analysis4 Classes B and C must transform their software requirements and the interfaces of software items into an architecture. q Specify functional and performance require- ments of SOUP (Software of Unknown Pedi- gree) items q Specify system hardware and software required by SOUP items q Identify software segregation necessary for risk control q Verify software architecture Software Architectural Design Requirements 5 Class C must also provide: q Software Development Standards, Methods and Tools Plan Class B and Class C must also analyze change requests. Class B and Class C must also include risk control measures. Class C must go into more depth by: q Developing Detailed Design for each Software Unit q Developing Detailed Design for Interfaces q Verifying the Detailed Design Software Detailed Design6 Implement Each Software Unit7 Software Unit Verification Process8 Classes B and C must refine their Software Architecture into Software Units. Classes B and C must establish a Software Unit Verification Process. Where Verification is done by testing, the test procedures will be evaluated for correctness. q Develop Software Unit Acceptance Criteria q Complete Software Unit Verification Software Integration & Integration Testing 9 Classes B and C must: q Integrate Software Units q Verify Software Integration q Test Integrated Software q Prepare Integration Testing content q Verify Integration Test Procedures q Conduct Regression Tests q Prepare Integration Test Records q Use Software Problem Resolution Process Death or serious injury is possible Risk Management Process in Compliance with ISO 14971 SDLC Process in Compliance with IEC 62304 code Additionally, Class B and Class C must: q Ensure Software Verification is complete q Document known residual anomalies q Evaluate known residual anomalies q Document how released software was created q Ensure activities and tasks are complete q Archive software q Assure repeatability of Software Release All classes must document the version of the released software. Software Release11 All classes must establish a Software Maintenance Plan. Problem and Modification Analysis is also required. All classes must: q Document and evaluate feedback q Monitor feedback q Evaluate Problem Report’s effects on safety q Use Software Problem Resolution Process q Include change request approval q Communicate to users and regulators Software Maintenance Process12 You must use an established process to implement modification. Upon making changes, you are also required to re-release the modified software system. Modification Implementation13 All classes must analyze changes to their medical device software with respect to safety. When complete, documents should be sent to the test lab in an editable format. The lab will assign your device a pass or fail upon review. If you fail, make necessary changes. If you pass – congratulations! Risk Management of Software Changes 16 All classes must implement configuration identification. This includes: q Establishing a means to identify configuration items q Identifying SOUP q Identifying system configuration documentation q Configure change controls q Approve change requests q Implement changes q Verify changes q Provide means for traceability of change q Configure status accounting Software Configuration Management Process 17 All classes must implement a process for resolving software problems. This includes how you will: q Prepare problem reports q Investigate the problem q Advise relevant parties of the problem q Use change control processes q Maintain records of the problems q Analyze problems for trends q Verify Software Problem Resolution q Test documentation contents. Software Problem Resolution Process18 Submit to Test Lab19 The Software Risk Management Process is critical for Class B and Class C. These classes must: q Conduct an analysis of software that contrib- utes to hazardous situations q Identify potential causes of the contribution q Evaluate published SOUP anomaly lists q Document potential causes q Document sequences of events Software Risk Management Process14 Classes B and C must complete Risk Control Measures, including: q Defining said Risk Control Measures q Identifying Risk Control Measures implemented in the software q Verify Risk Control Measures q Document any new sequences of events q Document traceability Risk Control Measures15 In addition, classes B and C must: q Analyze the impact of software changes on existing risk control measures q Perform risk management activities based on these analyses Software System Testing10 Classes B and C must: q Establish tests for Software Requirements q Use Software Problem Resolution Process q Retest after changes q Perform relevant risk management activities q Verify Software System Testing q Use Software Problem Resolution Process q Prepare System Test Record contents code code IEC 62304 is the international standard that defines software development lifecycle requirements for medical device software. The standard was developed from the perspective that product testing alone is insufficient to ensure patient safety when software is involved. The standard requires all aspects of the software development life cycle to be scrutinized. Preparing Your Device for Market MethodSense is a life science consulting firm, specializing in helping companies bring medical and technological products to market. They guide medical device, biotech and pharmaceutical companies with quality, regulatory and technology solutions, which enable clients to operate more effectively during the commercialization process and beyond. In addition to their expertise as regulatory consultants, MethodSense has developed a 21 CFR Part 11 compliant software as a service tool, InfoStrength Smart Enterprise Suite, that allows them to guide their clients to success. For more information about MethodSense, please visit www.methodsense.com. Please note: This IEC 62304 Action List represents a high level summary of the standard’s requirements and does not constitute advice for compliance with this or any other regulatory requirement. Manufacturers should consult with their regulatory affairs professional to determine the appropriate compliance strategy for any particular medical device.