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I have just released the second post in the series “The Practical Guide to the ISO 13485:2016 Practical Guide.” This post explores insights from the Practical Guide on “risk-based approach,” the varying terminology used to reference it, and the QMS processes that require it. Of particular note, is where the risk-based approach applies (everywhere), but we’re all still wondering what it actually is. The Practical Guide mirrors 13485:2016 in that it begins to discuss the risk-based approach as if the concept has already been defined and already well understood by industry (it’s not). The requirements around the RBA are further obfuscated by the use of the term “appropriate” and what appears to be alternate wording for risk-based approach: “proportionate to the effects.” Risk-based approach as clear as mud: The Practical Guide to the ISO 13485:2016 Practical Guide Post 2This is the second post in the series “The Practical Guide to the ISO 13485:2016 Practical Guide.” If you missed the first installment, catch up by reading it here. This post explores how the Pract… source: https://www.linkedin.com/groups/78665/78665-6346067690171437056 Marked as spam
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My personal opinion, worth whatever that is, is that I think it all comes down to having a good design ethos and product development lifecycle in place from the get-go. I can only speak from ITL's point of view but we live and breathe 13485 and "Risk" be that patient, regulatory, or design-based is just part and parcel of developing a medical device.
I agree some of the wording in the guide is rather poorly chosen in places but a robust development process should (generally) help to smooth out the process and make the mud a little less thick! Marked as spam
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Edward Hawley, CQA just about a week away from hopefully more insight but at least more entertaining reading. Glad you empathize with the message.
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Eckhard Jokisch
In my experience it is not sufficient to simply replace "proportionate to the effects of" by "risk based". The key is: Any adjective in a standards asks for the organization to add quantification to it to make it measurable. In the end the NB will be the judge to accept HOW and based on what values the proportionateness will be measured and defined.
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Thank you to those who liked and commented on post 2. Post 3 is now available for your commentary: Death by risk based approach! https://wp.me/p6wmF6-eG
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