4 ms·
> I don't think you should think about the risk in isolation like that. I don't disagree with the sentiment but FDA asks you precisely to do this analysis piec
by seren 8y ago
> I don't think you should think about the risk in isolation like that.
I don't disagree with the sentiment but FDA asks you precisely to do this analysis piecewise by what they call "SW units". And for each SW unit, you have to define a severity of hazard that can result from a malfunction of that SW unit. (from minor injury to death or irreparable damage)
Now you can always say you have a single "SW unit" to not have to check the boundaries or interactions, but then all the SW should have been developed with the same methodology/process, and this is not possible when you are using SW coming from an external source. (because you have no idea how it has been developed, and it was likely not targeting medical devices)
As as aside, the recommendation by the FDA is that, prior any mitigation, you have to assume that a SW bug as a 100% chance of happening. (That tells you how confident are the regulators..) But all SW bugs do not necessarily create an hazardous situation.
> But what's the risk of not having the app because you were afraid of the other risk? Doctors getting fluids wrong - and we found in practice they did get them wrong regularly and significantly.
You are allowed to use the benefits risk analysis by the FDA, but you have to demonstrate first there are no other mitigations possible, that you are ALARP (As low as reasonably possible) [0]. You need to explicitly write it in a risk management document to demonstrate you have analyzed that source of hazard.
To be fair, I am not anti regulation, but I think most of these standards are more applicable to SW written in the 80s or 90s when the SW stack where a bit smaller and simpler. And I have hard time to understand how they can be applied in practice in complex SW stacks like iOS. That's why I was interested by your experience, but it seems NHS did not challenge you on the finer implementation details. I understand this is complex because we are talking about 2 different regulation frameworks, so it is not necessarily transferable.
Thanks for chiming in, that is still great to know that is is possible to get something approved on a modern tech stack.
[0] https://en.wikipedia.org/wiki/ALARP https://en.wikipedia.org/wiki/ALARP