As discussed in our last post, medical device manufacturers must recognize that the FDA leaves it up to the manufacturers to mandate their own software processes and regulatory expectations. Here are some important references that provide good information on this point.
- First, in the AAMI TIR section on “The U.S. FDA Regulatory Perspective”, it explains that FDA Design Controls “do not define a development process or prescribe a specific development methodology or a specific software development lifecycle; rather, they specify controls that must be integrated into the manufacturer’s development processes, methodology, and lifecycle”.
- Second, in the FDA’s “General Principles of Software Validation; Final Guidance for Industry and FDA Staff,” which provides guidance on the FDA’s expectations for software development processes, in the early section on “Scope” the guidance says: “Based on the intended use and the safety risk associated with the software to be developed, the software developer should determine the specific approach, the combination of techniques to be used, and the level of effort to be applied. While this guidance does not recommend any specific life cycle model or any specific technique or method, it does recommend that software validation and verification activities be conducted throughout the entire software life cycle.”
- Finally, in the FDA’s “Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices,” there is a description of the activities to be performed for software development and the deliverables that must come from those activities, but it does not prescribe how those activities must be performed or the exact format of the deliverables. This is left up to the manufacturer to define and describe – in fact, a description of the software development environment and processes is one of the required elements of a medical device software submission.
So, it is clear that it is not a question of whether Agile is suitable for medical device software, it is a question of how Agile can be applied in a way that satisfies regulatory expectations. “TIR45:2012 Guidance on the use of agile practices in the development of medical device software” provides recommendations to help you answer the how questions.
To order a copy of the Agile TIR from AAMI, visit their marketplace website and enter “TIR45” in the search box.
Don’t forget to join us for the PMI-MN Agile Local Interest Group on Monday, June17 at 5:30 pm to hear Kelly Weyrauch talk about these concepts and more. Admission is FREE of charge for the 5:30 – 6:30 session held at the Crown Plaza Minneapolis West, 3131 Campus Drive, Plymouth, MN 55441