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FDA releases Final Guidance on Content of Premarket Submissions for Device Software Functions.  This final guidance provides requirements for the recommended documentation manufacturers should include in premarket submissions for the FDA’s evaluation of the safety and effectiveness of device software functions. The guidance replaces the FDA’s Guidance for the Guidance for the Content of Premarket...
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Tampa, FL, May 10, 2023.  Crisis Prevention and Recovery, LLC, dba SoftwareCPR® announced today that Windi has joined SoftwareCPR® as a Partner. In her role, Windi will lead the expert regulatory and quality team, bringing a unique client-side perspective for both US, Canada, UK/EU, and Japan markets. Windi’s career path is one marked by a...
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The FDA completed its review of an Automated Ejection Fraction SaMD De Novo leading to a new Class II code, ‘QVD.’  The FDA notice follows including the special controls. FDA Notice Re: DEN220063 Trade/Device Name: Caption Interpretation Automated Ejection Fraction Software Regulation Number: 21 CFR 892.2055 Regulation Name: Radiological machine learning-based quantitative imaging software with...
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Company: BioReference Health, LLC Date of Enforcement Report: 06/02/2023 Class II PRODUCT The 4Kscore Test is an in vitro serum or plasma test that combines the results of four immunoassays (Roche Elecsys total PSA (prostate specific antigen), Roche Elecsys free PSA, intact PSA, and human kallikrein 2) into a single numerical score that also incorporates...
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Company: Medtronic Navigation, Inc. Date of Enforcement Report: 06/02/2023 Class I PRODUCT StealthStation Cranial Software, Model: 9735585, used with StealthStation S7/i7 systems Recall Number: Z-1666-2023 REASON: In nonaxial/some axial exams if surgical plan utilized, Target Guidance selected, tip projection utilized, Navigate Projection enabled, software anomaly may occur during tumor resection/shunt placement/deep brain stimulation, where distance...
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Company: Medtronic Navigation, Inc. Date of Enforcement Report: 06/02/2023 Class I PRODUCT StealthStation Cranial Software, Model: 9735585, used with StealthStation S7/i7 systems Recall Number: Z-1666-2023 REASON: In nonaxial/some axial exams if surgical plan utilized, Target Guidance selected, tip projection utilized, Navigate Projection enabled, software anomaly may occur during tumor resection/shunt placement/deep brain stimulation, where distance...
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Company: BioReference Health, LLC Date of Enforcement Report: 06/02/2023 Class II PRODUCT The 4Kscore Test is an in vitro serum or plasma test that combines the results of four immunoassays (Roche Elecsys total PSA (prostate specific antigen), Roche Elecsys free PSA, intact PSA, and human kallikrein 2) into a single numerical score that also incorporates...
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Company: Medtronic Navigation, Inc. Date of Enforcement Report: 06/02/2023 Class I PRODUCT StealthStation Cranial Software, Models: 9735585, 9735586 (kit), 9735587 (kit), used with StealthStation S7/i7 systems Recall Number: Z-1630-2023 REASON: During non-axial/some axial exams, software anomalies occur during procedures affecting depth gauge graphic displays for cranial biopsy; causing displays to no longer synchronize with other...
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New to medical device software?  Our partners Mike Russell and Ginny Kwan Gattinger will be presenting a Regulatory Affairs Professional Society (RAPS) webinar on Wednesday, May 17, 2023 at 1:00 pm EDT to discus the unique and amplified challenges with software development for SiMD and SaMD.  They will discuss approaches for addressing the challenges and...
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Company: Draeger Medical Systems, Inc. Date of Enforcement Report: 4/27/2023 Class II PRODUCT Draeger Infinity CentralStation (ICS), centralized monitoring of adult, pediatric and neonatal patient data within the hospital or clinical environment, Software versions VG2.1.3 and lower Recall Number: Z-1471-2023 REASON: The software on the Infinity CentralStation drops peaks on narrow waveforms causing the Infinity...
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Company: Hamilton Medical AG Date of Enforcement Report: 4/25/2023 Class II PRODUCT HAMILTON-C6, REF: 160021 Recall Number: Z-1429-2023 REASON: Software error causes, safety ventilation malfunction, in which ventilation continues in the “safety ventilation” mode with audible/visible alarm – patient inputs are not monitored, if the following coincide 1) A mode change to an adaptive mode...
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The US FDA has a continuous challenge trying to ensure that regulations keep up with advancements in technology.  As with any new technology, manufacturers try and make the existing regulations applicable, while FDA assesses whether or not existing regulations are appropriate for the new technology.  This involves FDA collecting data to inform whether new and/or creative...
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Company: Spacelabs Healthcare, Inc Date of Enforcement Report: 4/12/2023 Class II PRODUCT Ultraview SL (UVSL) Command Module, Model 91496 Recall Number: Z-1503-2023 REASON: Command modules will display the following when parameter processing is suspended, depending on software version: 1) Older versions will have waveforms present with no alarms, 2) Newer versions have waveforms absent with...
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Company: Outset Medical, Inc. Date of Enforcement Report: 4/07/2023 Class II PRODUCT Outset Tablo Model Numbers (REF): PN-0006000 PN-0007001 Tablo is a next generation, self-contained hemodialysis system (Hemodialysis System or System), intended for acute, home and chronic dialysis therapy with or without ultrafiltration, in an acute or chronic care facility. Recall Number: Z-1351-2023 REASON: An...
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Company: Shanghai United Imaging Healthcare Co., Ltd Date of Enforcement Report: 4/7/2023 Class II PRODUCT Shanghai United Imaging Healthcare Co., Ltd. Positron Emission Tomography (PET) and Computed Tomography (CT), Model uMI 550 Part Number: 88000657 88000057 Recall Number: Z-1353-2023 REASON: Due to a software issue where the process of patient scanning, the scatter correction may...
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FDA Draft Submission Guidance AI/ML For Use of AI/Machine Learning-Enabled Device Software Functions Almost every day there is another news story about something involving “artificial intelligence.” So it seems timely that the FDA has just released a draft guidance for Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence/Machine Learning (AI/ML)-Enabled Device...
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(Denis Pasero. Med-Tech News. 3-10-23) Microbatteries in implantable devices are allowing earlier detection along with closer and more regular observation of the patient. A major benefit would be the real-time monitoring of the patient in areas not previously possible due to size, comfort levels, and the complexity of surgery. Much work is still to be...
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Company: CareFusion 303, Inc. Date of Enforcement Report: 3/01/2023 Class II PRODUCT Alaris PC Unit 8015 utilizing 802.11 b/g or 802.11 a/b/g wireless network cards, with IP addresses from x.x.x.224 to x.x.x.255 Recall Number: Z-1192-2023 REASON: Infusion pump PCs with specific software/network cards/IP addresses can have network/wireless connection failure. Could cause inability to receive new...
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Company: Stryker Corporation Date of Enforcement Report: 2/27/2023 Class II PRODUCT Finished Goods Box of 50 Inserts and Scanning Labels for Medivac Guardian 2L Catalog Number: FG 12010. Intended adjunct in the estimation of blood loss. RECALL NUMBER: Z-1184-2023 REASON: Triton Canister Software, Insert & Scanning Label may cause the Triton Canister System to output...
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Company: Getinge Usa Sales Inc Date of Enforcement Report: 1/26/2023 Class I PRODUCT Getinge Flow-i Anesthesia Systems Flow-i C20, Part no. 6677200 Flow-i C30, Part no. 6677300 Flow-i C40, Part no. 6677400 Programmable Diagnostic Computer Recall Number: Z-0959-2023 REASON Due to a software bug, under certain conditions, pressure cannot be built up resulting in no...
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Company: Align Technology Inc. Date of Enforcement Report: 1/26/2023 Class II PRODUCT Invisalign Express 10 REF 8512 Invisalign System Comprehensive REF 9000 Invisalign System Moderate REF 9001 Recall Number: Z-1017-2023 REASON 3D orthodontic planning software has a defect that leads to an issue where incorrect number of aligners may be produced (less or greater than...
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(Jim Lynch. Science Daily. University of Michigan. 01-02-2023) New 3D imaging capturing sound waves by X-rays provides the ability to map radiation doses. Doctors are now equipped with real-time data to guide treatments. Prior to this break through, medical professionals were left in the dark as to how much radiation was hitting their target area....
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Company: Agfa Healthcare NV Date of Enforcement Report: 1/20/2023 Class II PRODUCT Agfa HealthCare Enterprise Imaging XERO Viewer Recall Number: Z-0775-2023 REASON There is a software defect that can cause issues with images. RECALLING FIRM/MANUFACTURER Agfa Healthcare NV VOLUME OF PRODUCT IN COMMERCE 110 units DISTRIBUTION Distribution throughout US OUS distribution to Australia, Belgium, Brazil,...
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Company: Medtronic Neuromodulation Date of Enforcement Report: 01/06/2023 Class II PRODUCT Devices Recall Number: Z-0911-2023 REASON Software anomalies, CP App messages: “Too Many Device Found”, “Unexpected Device Error Code 1502”, and “System Update Needed, Service Code 303” RECALLING FIRM/MANUFACTURER Medtronic Neuromodulation VOLUME OF PRODUCT IN COMMERCE 440 units DISTRIBUTION Worldwide distribution
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(Ann R. Thryft. 11-16-22. Mddionline.com) A team made up of Sensoria Health, Foot Defender, and former Nike shoe designers came together to create a cloud-based patient monitoring boot for Diabetes patients. On the extreme, but very realistic side, this technology could help save patients from requiring an amputation if used correctly after ulcer surgery. The...
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Company: Siemens Medical Solutions USA, Inc. Date of Enforcement Report: 12/31/2022 Class II PRODUCT Programmable Diagnostic Computer Recall Number: Z-0775-2023 REASON The firm will be performing a software update to address a software error which affects the listed products. This correction addresses four potential software issues: 1) “PASSWORD STORE CORRUPTED” error message during system boot;...
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(Med-TechNews, December 12, 2022). Sir Nicholas Wright and Digistain in the UK has created a new tool to aid the early detection of breast cancer. Based on clinical trials, this new development is helping those eligible successfully avoid chemotherapy through earlier and more personalized test results. This allows patients more time to make decisions, less...
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Company: Fresenius Medical Care Holdings, Inc. Date of Enforcement Report:12/20/202 Class II PRODUCT 2008T and 2008TBluestar Hemodialysis Machines with CDX-Indicated for acute and chronic dialysis therapy in a healthcare facility Models: (1) 190713 2008T HEMODIALYSIS SYS., with CDX; (2) 190766 2008T HEMODIALYSIS SYSTEM W/BIBAG W/CDX ; (3) 191124 2008T HD SYS. CDX BLUESTAR; (4) 191126...
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RightEye, LLC was issued a Warning Letter from the FDA due to “the RightEye Vision System was cleared under K181771 with the following indications: “recording, viewing, and analyzing eye movements in support of identifying visual tracking impairment in human subjects.” However, your firm’s promotion of the device provides evidence that the device is intended to...
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(November 8, 2022. Nick Paul Taylor. MedTech Dive) H2o Therapeutics is the company behind the app, Parky, which promises to track Parkinson’s symptoms using an Apple watch. Patients are able to take advantage of Apple’s pre-existing movement disorder API features in their wearables. This can provide valuable and reliable insight to clinicians between visits through...
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This Playbook was prepared by The MITRE Corporation and the Medical Device Innovation Consortium using funds from the U.S. Food and Drug Administration in November 2021.  Download playbook here:  Playbook-for-Threat-Modeling-Medical-Devices-2021 The playbook is not prescriptive in that it does not describe one approach to be used when threat modeling medical devices. It is intended to...
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Crisis Prevention and Recovery, LLC / SoftwareCPR, Tampa, FL USA – (November 22, 2022) “We are pleased to announce that our Partner and General Manager, Brian Pate, has been selected  for membership on the UL 1998 Standards Technical Panel for Software (STP), with oversight of UL 1998 standard, Software in Programmable Components.  Brian will provide stakeholder input to...
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Company: Abbott Molecular, Inc. Date of Enforcement Report: 11/18/2022 Class II PRODUCT Alinity m System, REF 08N53-002, For In Vitro Diagnostic Use Recall Number: Z-0268-2023 REASON Abbott has identified potential performance issues for the Alinity m System software version 1.6.5: 1) In a unique scenario, the waste chute flapper was found to not open when...
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Crisis Prevention and Recovery, LLC / SoftwareCPR, Tampa, FL USA – (November 15, 2022) “We are pleased to announce that our partner, Dr Peter Rech, has been reappointed to serve the next 3 years as convener for IEC technical committee 62/SC 62D/MT23 Infusion Pumps.  In this role, Dr Rech will be responsible for organizing and administering...
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(November 8, 2022. Nick Paul Taylor. MedTech Dive)  Could a “biomechanical energy harvester turn the movement of the chest wall during inhalation and exhalation into power for a DBS device”? Nick Paul Taylor discusses this as a very real possibility. This would reduce the need to complete a surgery every few years for battery changes....
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ISO 14971:2019 Medical Device Risk Management, A Software Organization’s Perspective Public Training Course DATES:  Jan 9-11, 2023 Includes “how to” for application of IEC 62304 for software risk management! COST: 3 Full Days for $2,995 DISCOUNTS: 3 or more students from same company: 10% discount (off full registration) November 2022 Early Registration:  $2,395 Register at...
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Company:Boston Scientific Corporation Date of Enforcement Report: 10/31/2022 Class II PRODUCT ARTIS pheno, Interventional fluoroscopic x-ray system, Model No. 10849000 Recall Number: Z-0151-2023 REASON There is an incorrect manufacturing date/timestamp within the software which causes an inaccurate display of battery capacity. RECALLING FIRM/MANUFACTURER Siemens Medical Solutions USA, Inc VOLUME OF PRODUCT IN COMMERCE 7 devices...
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(October 23, 2022. MedPage Today. Dane Brodke, MD, MPH) Some are suggesting hospital fines for the rising EMR burden might be a small step in the right direction to alleviate the undue time and stress put on healthcare workers. Though those on the front lines understand the only real answer to the burnout crisis is...
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FDA releases Guidance on AI requests.  To aid manufacturers and reviewers, this guidance emphasizes the “Least Burdensome Provisions” when responding to deficiencies in a regulatory submission.  Download the final guidance: 2022-guidance-responding-deficencies-least-burdensome As stated by FDA, this guidance is “intended to help FDA staff develop, and industry respond to, a request for additional information needed to make a...
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Company: Siemens Medical Solutions USA, Inc Date of Enforcement Report: 10/21/2022 Class II PRODUCT ARTIS pheno, Interventional fluoroscopic x-ray system, Model No. 10849000 Recall Number: Z-0119-2023 REASON Siemens has become aware of three potential software issues with ARTIS pheno systems with software version VE10B. This may lead to a hazardous situation for patients if treatment...
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(October 18, 2022. Janette Wider. Healthcare Innovation Group) One main challenge in keeping medical devices secure is the management of hardware design alongside the underlying software. Though the degree of impact on a patient will vary based on the device, these threats do have the potential for life-threatening implications.  
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(October 11, 2022. Elise Reuter. MedTechDive) The FDA issued updated recommendations for Industry and FDA staff. This guide includes CDS software functions to better understand what meets the definition of device. This welcomed clarity brings to light predictive tools that are now meet the criteria for device. Now, experts are weighing in on what predictive...
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See more discussion on Risk Management Training between our General Manager, Brian Pate, and our Partner, Dr. Peter Rech, regarding changes to ISO 14971 as they prepare for our January 2023 public training course on the application of ISO 14971 and IEC 62304 to system risk analysis and software risk analysis.  Our 3-day course will...
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Since October is Cybersecurity Awareness Month, the US FDA released a new video to provide ideas and approaches for Healthcare Professionals (HCP) discuss and explain to patients, the concepts and methods for cybersecurity with regard to  interconnected medical devices.   The video titled, “xx,” is designed to promote, and perhaps facilitate, communication  between HCPs and patients....
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(October 6, 2022. Health IT Security) The FDA has issued a user fee re-authorization bill but due to fast approaching deadlines among other constricting legislative factors, the House bill has left out medical device security leaving some experts weary of it’s consequences. https://healthitsecurity.com/features/experts-weigh-in-on-medical-device-security-exit-from-fda-user-fee-bill
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Company: Fresenius Kabi USA, LLC Date of Enforcement Report: 10/6/2022 Class I PRODUCT Ivenix Infusion System (IIS), LVP Software; LVP-SW-0004 version 5.2.0 Recall Number: Z-0002-2023 REASON The display screen may become frozen and unresponsive to user input, triggering an alarm that is evidenced by a buzzer sound and flashing red LEDs as a secondary notification....
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(September 29, 2022. Jim Hammerand) FDA and VA Ventures Innovation Institute will begin a five year partnership beginning with a focal point on interoperable systems before applying their combined strength to telehealth and artificial intelligence among others. The two agencies aim to provide the most advanced health tech faster than ever before. FDA and VA...
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MicroVention located in Costa Rica was issued a warning letter from the FDA for reason “that the methods used in, or the facilities or controls used for, their manufacture, packing, storage, or installation are not in conformity with the current good manufacturing practice requirements of the Quality System regulation found at Title 21, Code of...
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(Tampa, FL, September 28, 2022) – Crisis Prevention and Recovery, LLC is taking proactive steps to minimize impact to our clients from the landfall of Hurricane Ian in Southwest Florida.  With our corporate office in Tampa, Florida, it is likely that there could be loss of electrical power and/or internet in the next 24 to 72...
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Company: Micro-X Ltd. Date of Enforcement Report: 9/23/2022 ClassII PRODUCT MICRO-X ROVER MOBILE X-RAY SYSTEM, MXU-RV19 Recall Number: Z-1786-2022 REASON Software calibration error with product equip with a Dose Area Product (DAP) meter. This results in the product displaying the incorrect DAP meter values which may impede radiation exposure management decisions RECALLING FIRM/MANUFACTURER Micro-X Ltd....
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SoftwareCPR Training Courses:

Being Agile & Yet Compliant (Public)

Our SoftwareCPR unique approach to incorporating agile and lean engineering to your medical device software process training course is now open for registration!

  • Agile principles that align well with medical
  • Backlog management
  • Agile risk management
  • Incremental and iterative software development lifecycle management
  •  Frequent release management
  • And more!

3 days virtual (Zoom) with group exercises, quizzes, examples, Q&A.

Lead Instructor: Mike Russell

Next public offerings:

  • Americas: 11-13 February 2025
  • EU/Eastern Europe/Middle East/Africa/Atlantic/eastern South America: 18-20 February 2025
  • Southern Central Northeastern Pacific: 24-26 February 2025
See our post titled: 1st Quarter 2025 Agile Compliant Courses Scheduled

 

IEC 62304 and other emerging standards for Medical Device and HealthIT Software

Our flagship course for preparing regulatory, quality, engineering, operations, and others for the activities and documentation expected for IEC 62304 conformance and for FDA expectations. The goal is to educate on the intent and purpose so that the participants are able to make informed decisions in the future.  Focus is not simply what the standard says, but what is meant and discuss examples and approaches one might implement to comply.  Special deep discount pricing available to FDA attendees and other regulators.

3-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Brian Pate

Next public offering:  TBD

Call or email now to schedule a private, in-house class. The fall schedule is filling up!

Email training@softwarecpr.com to request a special pre-registration discount.  Limited number of pre-registration coupons.

Registration Link:

TBD

 


 

Medical Device Cybersecurity (Public or Private)

This course takes a deep dive into the US FDA expectations for cybersecurity activities in the product development process with central focus on the cybersecurity risk analysis process. Overall approach will be tied to relevant standards and FDA guidance documentation. The course will follow the ISO 14971:2019 framework for overall structure but utilize IEC 62304, IEC 81001-5-1, and AAMI TIR57 for specific details regarding cybersecurity planning, risk characterization, threat modeling, and control strategies.

2-days onsite with group exercises, quizzes, examples, Q&A.

Instructor: Dr Peter Rech, 2nd instructor (optional)

Next public offering:  TBD

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Partners located in the US (CA, FL, MA, MN, TX) and Canada.