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Open-source medical devices: When code can kill or cure
- WiseWeasel 14y agoThese guys at the Generic Infusion Pump project should partner with vTitan and put up a Kickstarter page for a cheap infusion pump with open source software (or maybe vTitan could do it themselves), if it's the type of device people might buy directly. Many in need would love to sponsor this type of advance while securing early access for themselves, since they are so acutely aware of the device's value.
- excuse-me 14y agoAnd, their funders, their pets and everyone their funders know will be sued into poverty as soon as it's announced. I met a company that was going to make a powered wheelchair. At the moment your choice is a manual chair or a big heavy expensive and complex mobility scooter - like you see fat/lazy people using in Walmart. Their product was a smart power assist that gave you an automatic extra push on kerbs, ramps etc but could be cheaply bolted onto an existing manual chair. It had sensors that measured the force you were pushing with, the chair angle, speed etc, along with modern brushless DC motors and laptop batteries. Then they hit FDA. There is no FDA approval class for accelerometers - nobody has ever made a medical device using accelerometers so not only would they need their device tested and approved they would need to prove "equivalency" for a mems accelerometer. Apparently General Relativity and Mach's principle isn't enough for the FDA. They did propose simply opensourcing the design for anyone to build but were told that if anyone did build one they would be essentially in the same legal position as publishing instructions for making illegal drugs! In the FDA's eyes telling someone how to make an affordable electric wheelchair = running an meth lab.
- WiseWeasel 14y agoI could certainly see the FDA obstructing novel products without prohibitively expensive studies, but wouldn't it be significantly cheaper to demonstrate equivalence to existing devices?
- HeyLaughingBoy 14y agoYes, it would. Problem is that "significantly cheaper" means it costs $1 million instead of $5 million.
- WiseWeasel 14y ago$1M+ might be in the realm of the attainable for a Kickstarter project, assuming the device has a sufficiently wide usage. The estimated cost of approval would need to be included in the funding goal. [If the same studies might be used to seek approval in several countries at once, then it might make such an approach to funding medical devices more attainable for the size of their market. The missing piece of the puzzle seems to be an affordable method for conducting studies to get medical devices approved. It seems like the industry is highly vertical, with difficult access to financing and compliance infrastructure. This might be an opportunity for a service provider to come in, establish a selection process for clients, partner with universities around the world to conduct studies to the specifications of US FDA, and its EU, Canada, Japan, etc. equivalents' approval, and help store and file the needed paperwork in exchange for a cut of sales. Maybe it's also time for the UN to create a world body for standards of approval of medical technology which all these nations should recognize; or maybe ISO should take that role.]
- jmj42 14y agoThis sounds like IntelliWheels, a UIUC startup. If it is, I don't think the FDA process has been that big of a obstacle. I was at another startup at UIUC's incubator when IntelliWheels spun up, and it looks like they are on track to meet their original projected release date (at least it's the only projection I've ever heard). That said, as pointed out elsewhere, there are some very good reasons for many of the regulations concerning DME. In many cases, it is about life and death. Understand, I'm not arguing for the status quo, here, but the FDA does provide, necessary, oversight. The DME industry and even the FDA are in dire need of an infusion of common sense, but this idea that no oversight or even disbanning the FDA (common talk among a certain political element in the states these days), is absolutely not what we need.
- excuse-me 14y agoThe situation in the US is insane. Yes there are systems, like radiotherapy machines or pacemakers, that need to be developed and tested to Nasa like specs But the FDA take the approach that anything medical is life threatening. It's as if the FAA demanded avionics approval for the point of sale machine in the McDonalds at the airport You cannot use a camera on a microscope in the US for medical purposes, there is no approval and there won't be because the first company to do so has to prove beyond all doubt every concept of the camera, computer and display operation. Not just of their specific device - you have to prove that a camera is equivalent to an eye in basic principles. Then once you have done that every other maker can come on your coat tales. That's why in europe your cervical smear test will go through an automated scanner which uses state of the art image processing to examine every single cell - and quickly enough that the entire population (or at least the half with a cervix) can be screened. In the US it will be looked at for 5mins with 50year old eyes with a 30year old microscope by a doctor who will then guess (sorry use his years of experience) to decide. Strange really - I don't imagine the FAA would accept an aircraft maker saying that they don't use CFD tools or computers but old Billy has a certificate saying he went to engineering school and so can estimate the load in a carbon fibre turbine blade by eye.
- dbcooper 14y agoI'm a medical/biotech device engineer, yet I did not know this. Do you have a link to a good source for this issue? ETA: It seems that the FDA has approved BD's automated screening system for cervical smears. http://www.bd.com/tripath/labs/fp_screening.asp http://www.bd.com/tripath/labs/fp_screening.asp http://www.bd.com/contentmanager/b_article.asp?Item_ID=23597&ContentType_ID=1&BusinessCode=20001&d=BD+Worldwide&s=&dTitle=&dc=&dcTitle= http://www.bd.com/contentmanager/b_article.asp?Item_ID=23597...
- sien 14y agoHave a look at the FDA Guidance for pre-market solutions, they categorise device into 3 levels, major, moderate and minor. The minor level is for software that is unlikely that serious injury or death will result from the software: http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm089543.htm#6 http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidanc...
- HeyLaughingBoy 14y ago"My dream", says Dave Arney, a researcher on the project, "is that a hospital will eventually be able to print out an infusion pump using a rapid prototyping machine, download open-source software to it and have a device running within hours." What can I say; dare to dream. Because that's what this is - a dream. Print out a pump? OK. Was the 3D printer's performance to all relevant specs validated? Were the materials it uses approved and inspected along with their certificates to be sure the pump was being made from the material the designer specified? Was the material stored properly before use and was the pump it printed tested to ensure that it met all its requirements? The software is probably easier to handle, surprisingly. The FDA probably wouldn't care that it was open source, but would the OSS developers be willing to follow a validated process, document that they are following the process, submit to random audits of that process being followed? Who handles customer complaints? FDA requires that a Medical Device manufacturer have a procedure to record and respond to customer complaints and comments in a timely fashion. If a physician notices that every morning at 8:00AM the pump puts out an additional 5%, who will log that concern and investigate it. If it requires a recall, how do you even recall something you can't track since people are just printing the pumps out as they need them. The Medical Device industry is screaming for innovation and I hate to be a party pooper, but this is a dream. And unfortunately, it will remain a dream for very good, common sense reasons.
- ktizo 14y agoI cannot think of a single objection you have raised that is to do with 3d printing rather than to do with quality control and process tracking, and quality control can be made far easier with 3d printing as you can change production as soon as a fault is discovered, so you don't end up with a warehouse full of a million faulty pumps. And tracking could be achieved by embedding rfids mid-print without a problem.
- HeyLaughingBoy 14y agoThe problem isn't with the 3D printing itself, it's with an end user (the hospital) that doesn't have manufacturing skill and 21CFR knowledge printing off a medical device. It's a nice idea, but the FDA would have a change a huge amount before something like this has a ghost of a chance.
- david_shaw 14y agoI work primarily in the field of healthcare information security. Although this article does go a little bit into the realm of hyperbole--as HN commenter 'excuse-me' pointed out, not every single aspect of medical equipment is even remotely capable of interfering with patients--there is a serious security risk with networked devices that most people do not understand. The article pointed out the McAfee research on insulin pumps. Yes, these devices were hacked and could potentially kill a patient. This was a complex application attack, that while serious and certainly something that should be addressed, has a very high level of sophistication. For example, if one was trying to kill a patient, they would need physical (or very-close networked access) to the device. At that point, is it easier to write exploit code or simply kill someone? These are morbid thoughts, but it's also a requirement to think of the actual use case. Please keep in mind that I'm not trying to understate the seriousness of these findings, or others like them: we absolutely need to step up security in the healthcare field. It's a mess, and frankly makes me feel uncomfortable every time I'm in a hospital. But let's talk about things that are even simpler than the insulin pump attack. When I send engineers on-site to hospitals, we need to specifically exclude BioMed network devices, as well as anything that's connected to a patient (even through a couple of hops) for even simple network scans (nmap, etc). Why? Because even just running a contemporary port scan has a tendency to overflow device state tables/networking stacks and crash the device. Let me reiterate: just scanning the device, without any security checks or attacks, can take a device offline. You might think that devices such as these are protected from attackers by other security controls; that if someone has networked access to an internal network, that it's game over anyway. Well, yes and no. Part of the problem in healthcare information security is that hospitals and healthcare providers have thought almost exclusively about the physical security of their facilities for far too long. Sure, there are security guards in place, but how does that help when the Emergency Room "guest wifi" is bridged to the internal network? What about when there are live Ethernet ports in visiting rooms or, again, the ER? These are real problems that we're trying to find and resolve, but it's more of an industry-wide change of vision than a couple of holes we need to plug. Even the security of the internal network itself is generally a disaster (missing patches, unorganized security departments, etc). It's our job to resolve these issues, and although I'm just a little biased, it's not super hard to do on a hospital-by-hospital basis. It gets a lot tougher when we're talking about a pan-industrial change. Which is where, in the U.S., the government steps in. HIPAA compliance forces these checks to be done on a regular basis--although the tendency for hospitals to save money by getting a "checkbox compliance" scan from an automated vendor instead of having a real team of security engineers conduct analysis is still very strong. HIPAA is focused mainly around protecting electronic protected health information (PHI), but the HITECH Act and "meaningful use" allows healthcare organizations to actually receive money from the government for staying in compliance while using ePHI (instead of paper records) for a large percentage of their health records. We've got a long way to go, but the healthcare industry is steadily improving. That said, don't be too quick to discard remarks about the security of hospitals and your medical data: right now, a complete medical record is worth more on the black market than a credit card number. Keep that in mind next time you see Windows NT machines while getting your annual check-up.
- ef4 14y agoI think it's interesting that reporters are still using the Therac-25 as their go-to example of medical software harming people. I'm pleasantly surprised that we haven't had a bunch of more spectacular examples since then.