Od-2044 - Ed 2 4-Tracking
Od-2044 - Ed 2 4-Tracking
Od-2044 - Ed 2 4-Tracking
IECEE
OPERATIONAL DOCUMENT
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Contents
Contents ................................................................................................................................. 2
FOREWORD .......................................................................................................................... 3
1 Scope.............................................................................................................................. 4
2 Reference documents ..................................................................................................... 4
3 Terms and definitions ...................................................................................................... 4
4 Application of Risk Management Principle for IEC 60601 series CB Scheme investigations
....................................................................................................................................... 5
5 Assessment of Risk Management principles in the IEC 60601 series CB Scheme
investigations .................................................................................................................. 5
6 Clause mapping guide IEC 60601 / ISO 14971 .............................................................. 18
Annex A - ISO 14971:2000 Checklist (Informative) ............................................................... 51
Annex B - ISO 14971:2007 Checklist (Informative) ............................................................... 53
FOREWORD
Document Owner
History of changes
2 Reference documents
IEC 60601-1:2005, Medical electrical equipment - Part 1: General requirements for basic safety and essential
performance
IEC 60601-1:2005 Incl. Am 1:2012, Medical equipment – Part 1: General requirements for basic safety and
essential performance (Also known as IEC 60601-1:2005 + A1:2012)
IEC 60601-1-3:2008, Medical electrical equipment - Collateral Standard: Radiation protection in diagnostic X-
ray equipment
IEC 60601-1-8:2006, Medical electrical equipment - Collateral Standard: General requirements, tests and
guidance for alarm systems in medical electrical equipment and medical electrical systems
IEC 60601-1-10:2007, Medical electrical equipment - Collateral Standard: Requirements for the development of
physiologic closed-loop controllers
IEC 60601-1-11:2010, Medical electrical equipment - Collateral Standard: Requirements for medical electrical
equipment and medical electrical systems used in the home healthcare environment
IEC60601_1G, IECEE Test Report Form - IEC 60601-1: 2005 + CORR. 1(2006) + CORR 2 (2007)
IEC60601_1H, IECEE Test Report form - IEC 60601-1: 2005 + AM1 (2012)
For the purpose of this document, the Risk Management Process is a management system intended to address
all activities related to ISO 14971.
For the purpose of this document, unless otherwise specified, the following conventions are used:
• IEC 60601-1:2005 or IEC 60601-1:2005 + A1:2012 designates "the general standard" alone;
• IEC 60601-1 designates reference to IEC 60601-1:2005 and IEC 60601-1:2005 + A1:2012
• IEC 60601-1-nn designates a specific collateral standard (this applies for all the collateral standards
stated in this document where “nn” is the number of the collateral)
Disclaimer: This document is controlled and has been released electronically.
Only the version on the IECEE Website is the current document version
IECEE OD-2044:20219 © IEC 2021019 –5–
• IEC 60601 series designates the combination of the general standard IEC 60601-1:2005/IEC 60601-
1:2005 + A1:2012 and the collateral standards IEC 60601-1-nn.
• ISO 14971 designates references to ISO 14971:2000 and ISO 14971:2007
4 Application of Risk Management Principle for IEC 60601 series CB Scheme investigations
4.1 General
The third edition of IEC 60601-1:2005 is the primary standard in a series of standards that covers safety and
essential performance of medical electrical equipment. It is the first IEC standard in the scope of the CB
Scheme that incorporates risk management principles according to ISO 14971:2000. The introduction of Risk
Management is the reason for this Operational Document.
The existence of a CB Test Certificate does not solely establish legal market entry. However, it could be used
to help substantiate a request for legal market access.
This Operational Document is related solely to the IECEE CB Scheme and is intended for use by those
individuals with a working knowledge of risk management for medical electrical equipment and the provisions
of the IEC 60601 series.
NOTE: IEC 60601-1:2005 + A1:2012 incorporates risk management principles according to ISO 14971:2007.
The registration to ISO 13485 is not sufficient to demonstrate that a risk management process compliant with
ISO 14971 requirements is performed. There can be no investigation to IEC 60601 series without the
manufacturer’s Risk Management File being available, unless specifically permitted by the rules of the CB
Scheme.
The CB Test Report and Certificate confirms that there is a Risk Management Process performed which
complies with the risk management requirements of IEC 60601 series and the applicable requirements of ISO
14971. This does not mean that a complete Risk Management System in compliance with ISO 14971 is in
place. The CB Test Report is only a snapshot in time and does not necessarily assess all top management
responsibilities.
Several clauses of ISO 14971 define the requirements for the application of the Risk Management Process to
“the particular medical device being considered”. When those clauses of ISO 14971 are used to address Risk
Management requirements in IEC 60601-1, the verification shall confirm whether the Risk Management
Process is correctly applied to the particular Device Under Evaluation/Test.
A separate certification of registration to ISO 14971 indicates that a risk management system conforming to
ISO 14971 is in place, but does not necessarily provide the risk management device specific documentation to
meet the requirements of IEC 60601 series. IEC 60601 series requires specific Risk Management activities to
be done and the CB Test Report requires objective evidence that these activities have been performed for the
Device Under Test.
A CB Scheme Test Certificate does not imply that an audit of the manufacturer’s Risk Management System
was conducted.
In view of the above and similar to the second edition, the CB Test Report according to IEC 60601-1 is not
necessarily a guarantee of certification by an accepting NCB.
A certificate of registration may be requested for local or regional certification to IEC 60601 series as it relates
to follow-up services. There may be differences in requirements that are the subject of local legal market entry
requirements.
Disclaimer: This document is controlled and has been released electronically.
Only the version on the IECEE Website is the current document version
–6– IECEE OD-2044:20219 © IEC 2021019
5.2 Implementation of ISO 14971 into the IEC 60601 series
In the clauses of IEC 60601-1 series there are three types of references to ISO 14971 Risk Management
requirements:
a) Direct reference to Risk Management Process as specified by ISO 14971 (for example clause 4.2 or
4.2.2).
b) Test related references to give appropriate alternative to the application of laboratory testing with
specific pass/fail criteria or to select appropriate tests to be performed on the specific product (for
example clause 5.7).
c) Indirect reference to offer additional elements to be considered in the implementation of the Risk
Management Process specified by ISO 14971 for the specific product. (for example clause 14.1)
The manufacturer can also identify alternative means to provide an equivalent safety level to IEC 60601 series.
The manufacturer may implement new and original approaches to developing effective means of protection
against unacceptable risks. The manufacturer must verify that the residual risks that result from applying the
alternative means are equal to or less than the residual risks that result from applying the requirements of IEC
60601 series. All these activities must be performed in accordance with the requirements of ISO 14971.
Clause 4.2 of IEC 60601-1:2005 and Clause 4.2.2 of IEC 60601-1:2005 + A1:2012 do not require post market
monitoring (e.g. clause 9 of ISO 14971) of the effectiveness of the risk control measures
Tables appended in Clause 6 of this Operational Document provide mapping with all the clauses of
IEC 60601-1 and the IEC collaterals standards which require risk management, and the applicable clauses in
ISO 14971. These tables provide guidance and considerations for application and assessment of RM criteria.
This situation is not valid when referring to IEC 60601-1-6:2010 which includes a direct link to IEC 62366:2007.
The IEC 62366:2007 also refers directly to ISO 14971:2007. This situation is also not valid when referring to
IEC 60601-1:2005 + A1:2012 which also makes a direct reference to ISO 14971:2007.
For this reason, in the tables appended that provide mapping with all the clauses of IEC 60601 series, the
following references have been made:
• ISO 14971:2000 clauses are used to address the risk management process required by IEC 60601-1 series
aligned with IEC 60601-1:2005;
• ISO 14971:2007 clauses used to address the risk management process required by IEC 60601-1 series
aligned with IEC 60601-1:2005 + A1:2012;
• ISO 14971:2007 clauses are used to address the risk management process required by IEC 62366:2007
(IEC 60601-1-6:2010).
5.4 Description of ISO 14971 clauses application in regards to IEC 60601-1 standard
The following Table is a guidance document. Refer to standard ISO 14971 for more detailed requirements and
supporting rationales. This table explains what action or evidence is required for each clause of ISO 14971.
6.2 Risk control option The manufacturer identifies risk control measure(s) P
analysis that are appropriate for reducing the risk(s) to an
acceptable level. The manufacturer uses one or more
of the following risk control options in the priority
order listed:
a) inherent safety by design;
b) protective measures in the medical device itself or
in the manufacturing process;
c) information for safety
The manufacturer records the risk control measure(s)
in the risk management file.
If, during risk control option analysis, the
manufacturer determines that required risk reduction
is not practicable, the manufacturer shall conduct a
risk/benefit analysis of the residual risk (proceed to
6.5).
The CBTL reviews the manufacturer’s chosen risk
control measure(s) for each hazard based
requirement from IEC 60601 series of standards and
documents their findings in the Risk Management
Results Tables in the TRF.
6.3 Implementation of risk The manufacturer implements the identified risk P
control measure(s) control measure(s). The manufacturer verifies the
implementation of each hazard based risk control
measure. The effectiveness of the risk control
measure(s) shall be verified and the results shall be
recorded in the risk management file.
The CBTL reviews manufacturer’s implementation,
verification and effectiveness of risk control
measure(s) for each hazard based requirement from
IEC 60601 series of standards and documents their
findings in the Risk Management Results Tables in
the TRF.
a) Where this standard or its collateral or particular standards specify requirements addressing particular
HAZARDS, together with specific acceptance criteria, compliance with these requirements is presumed
to establish that the RESIDUAL RISKS have been reduced to acceptable levels unless there is
OBJECTIVE EVIDENCE to the contrary.
EXAMPLE 1: Sub-clause 8.5.1.2, MEANS OF PATIENT PROTECTION (MOPP)
c) Where this standard or its collateral or particular standards identify particular HAZARDS that have to be
investigated without providing specific technical requirements:
– The MANUFACTURER shall determine whether such HAZARDS exist for the particular ME
EQUIPMENT or ME SYSTEM, and
– where such HAZARDS exist for the particular ME EQUIPMENT or ME SYSTEM, the
MANUFACTURER shall evaluate and (if necessary) control these RISKS following the RISK
MANAGEMENT PROCESS specified in 4.2/4.2.2.
EXAMPLE 5: Sub-clause 10.2, Alpha, beta, gamma, neutron and other particle radiation Compliance is
checked by confirming that the documentation in the RISK MANAGEMENT FILE demonstrates that the
RESIDUAL RISK is acceptable using the criteria for RISK acceptability recorded in the RISK
MANAGEMENT plan, i.e. no unacceptable RISK remains.
Only the relevant parts of the RISK MANAGEMENT FILE need to be reviewed, e.g. MANUFACTURER'S
calculations or test results, or the determination of RISK acceptability.
NOTE: When ME EQUIPMENT or an ME SYSTEM has been designed in such way that for a certain type of HAZARD no
HAZARDOUS SITUATION exists, no further RISK ASSESSMENT for that HAZARD is necessary. This can be verified by tests
or inspections.
5.6 Evaluating RISK - HAZARDS not identified in the IEC 60601-series
For HAZARDS that are identified for the particular ME EQUIPMENT or ME SYSTEM but are not specifically
addressed in the Standard IEC 60601-1 or its collateral or particular standards, the MANUFACTURER shall
address those HAZARDS in the RISK MANAGEMENT PROCESS as specified in 4.2.2.
EXAMPLE 6: ME EQUIPMENT or an ME SYSTEM for which there are particular RISKS but no particular
standard
One of the IEC 60601-1:2005 risk management requirements is process based and not hazard based. This
requirement will not be found in the manufactures hazard identification. The process based clause is 4.2 and it
is expected that the manufacturer will have implemented appropriate system procedures to address this
clause.
The manufacturer addresses the hazard based clauses of the IEC 60601 series of standards according to the
ME Equipment. The Risk Management Results Tables in the TRFs are based on the requirements of the IEC
60601 series of standards. For a specific hazard, a manufacturers’ risk management file may go beyond the
specific Risk Management Results Table, or the manufacturers’ risk management file may use only a portion of
the risk management elements and, therefore, it is acceptable to enter NA into some of the identified ISO
14971 Risk Management Results Table clauses based on the specific risk for the ME Equipment.
For hazard based risk management requirements, the flow diagram below shows the steps that the
manufacturer must consider. For example, if they complete risk evaluation with an acceptable level of risk, they
may not proceed to risk control.
5.7 Risk Management Flowchart (Reference to the ISO 14971:2007, 2 nd edition – Figure B.1)
The following flowchart is used to process each identified hazard
No
Evaluation
Yes
No
Is the risk reducible? (6.2)
Yes
No
Is residual risk acceptable? (6.4)
Risk Control
No
No
Yes
Residual Risk
Evaluation
Yes
Yes
Required by the
IEC 60601 Series
of Standards
Yes Is reassessment of risk necessary? (9) No
Color
Key Not required by
the IEC 60601
Series of
Standards
For a clause from IEC 60601-1 which makes reference to the RM file refer to TABLE 1 - IEC 60601- 1 / ISO
14971 CLAUSE MAPPING GUIDE to identify which clauses from ISO 14971 need to be documented.
For example, IEC 60601-1:2005 Clause 9.2.4 which requires reference to the RM file; Table 1 of this OD 2044
specifies that documents demonstrating compliance with clauses 4.2 to 6.6 of ISO 14971:2000 shall be
provided for evaluation.
9.2.4 Emergency stopping - Does the MEE use emergency stopping devices? 4.2
devices - Are risks caused by mechanical hazards which are to
reduced by the use of the emergency stopping devices 6.6
reduced to an acceptable level?
The actual clauses that are to be used to provide evidence are referenced in the Risk Management Results
Tables of the TRF; the ISO 14971 range of clauses in table 1 is given for reference only.
After evaluation, the 9.2.4 Risk Management Results Table shall be filled in appropriately.
Compliance with those sub-clauses in IEC 60601-1 that require protection against a particular condition or
event that "could result in a hazardous situation" are deemed to be satisfied if the manufacturer can show that
the particular condition or event does not result in an unacceptable risk.
5.9 Workflow
a) Based on the latest TRF version, establish the relevant clauses of IEC 60601 series that have to be
supported by RM documentation.
b) Verify the required documentation and identify the relevant reference points to be listed in the TRF. To
initiate the assessment process of a manufacturer, the CBTL may use attachment 1, from this Procedure
Disclaimer: This document is controlled and has been released electronically.
Only the version on the IECEE Website is the current document version
IECEE OD-2044:20219 © IEC 2021019 – 17 –
(ISO 14971:2000 Checklist), attachment 2 from this Procedure (ISO 14971:2007 Checklist) or equivalent.
The form is intended to facilitate an understanding of the manufacturer’s risk management procedures. The
completion of this form documents the assessment of the manufacturer’s risk management process. (Note:
It is not necessary to maintain a copy of the risk management file).
c) In case the use of RM influences the tests (see clause 5.2)
3.1 Identify the test to be conducted
3.2 Identify the test parameters and conditions to be used performing the tests
3.3 Identify the RM Pass/Fail criteria. The Pass/Fail criteria and the rationale for acceptance shall
be reported in the TRF.
The evaluation of clauses and sub-clauses in IEC 60601-1-nn, Collateral standards containing risk
management requirements are provided in Tables 1-3 through 1-11 of this document.
Note: Guidance has not yet been developed by the task force for IEC 60601 3rd edition particular standards IEC 60601-2-nn. The
collateral standard IEC 60601-1-2:2007 does not contain any risk management requirements, the RM requirements are addressed
through the IEC 60601-1 (Clause 17).
There is no planned guidance for IEC 60601-1-9:2007.
When evaluating compliance with IEC 60601-1-6:2010, it is important to understand the relationships that exist
between this standard, IEC 60601-1:2005, IEC 62366:2007 and ISO 14971:2007.
Figure 1 below provides a graphical representation of this relationship. IEC 60601-1-6:2010 is a collateral
standard in the IEC 60601-1 series covering the requirements for the Usability Engineering Process. IEC
60601-1:2005 makes a normative reference to IEC 60601-1-6 for requirements related to usability. Currently,
IEC 60601-1-6:2010 links the IEC 62366:2007 which contains requirements for the usability engineering
process.
Figure 1: Relationship between USABILITY (IEC 60601-1-6 & IEC 62366) and RISK MANAGEMENT (ISO
14971)
IEC 60601-1-6:2010 makes a normative reference to IEC 62366:2007 for the Usability Engineering Process
requirements: In turn, IEC 62366:2007 makes a normative reference to ISO 14971:2007 for the requirements
related to Risk Management.
When performing the usability engineering process and the risk management process there are deliverables
from each process that are used as inputs into the other process. Figure 1 indicates in which process these
deliverables are generated and which deliverables are necessary for completing the other process.
When complying with IEC 60601-1:2005, IEC 60601-1-6:2010, IEC 62366:2007 and ISO 14971:2007 are all
required to satisfy the requirements for the Usability Engineering Process.
When the requirements for software apply for the medical devices, 60601-1 requires compliance with
applicable clauses of IEC 62304 that makes normative reference to ISO 14971. In fact in the evaluation of a
device with respect to the requirements of 60601-1 which employs PEMS and PESS, a risk management
process is required to be followed.
According to IEC 60601-1, when the requirements in 14.2 to 14.13 apply, the requirements in subclause 4.3,
Clause 5, Clause 7, Clause 8 and Clause 9 of IEC 62304:2006 shall also apply to the development or
modification of software for PEMS and for each PESS.
The CBTL needs to ensure the manufacturer has taken into account the additional requirement for the
Software Risk Management.
Note: The Annex A above is for ISO 14971 1 st edition, if ISO 14971 2 nd edition is used Annex B is applied.
6.2 Option analysis Record of risk control option analysis (including risk-
benefit analysis, if appropriate).
6.3 Implementation Inputs from risk management activities
of risk control
measures
6.4 Residual risk Final results of the residual risk evaluation and, if
evaluation necessary, information necessary to explain the
residual risk(s) in the appropriate accompanying
documents
6.5 Risk-Benefit Evidence as necessary.
Analysis
6.6 Other generated Record of results of review of all risk controls for to
hazards identify if other hazards are introduced by any risk
control measures and the associated risk(s)
assessment(s)
6.7 Completeness of Record of assessment to assure that the risk(s) from
risk evaluation all identified hazards have been evaluated
7 Overall residual Records of related meetings, analysis, and overall
risk evaluation results.
8 Risk Documented review of risk management process prior
management to commercial distribution
report