A
Human Factors Engineering or
Usability Engineering (HFE/UE) report included in a premarket submission should provide information pertaining to device use safety and effectiveness in summary form. The report should discuss the safety-related HFE/UE considerations, issues, processes, resolutions, and conclusions. The level of detail of documentation submitted should be sufficient to describe your identification, evaluation, and final assessment of all serious use-related hazards for the device. To facilitate FDA review, materials used directly in the HF/UE process, including portions of risk analyses focusing on user interactions with the device and specific risk analysis processes, results and conclusions should be included in the HFE/UE report. A recommended structure for the HFE/UE report, which will support efficient FDA review of these materials, is listed and described in the table below.
Sec. | Contents |
1 | Conclusion
The device has been found to be safe and effective for the intended users, uses and use environments.
- Brief summary of HFE/UE processes and results that support this conclusion
- Discussion of residual use-related risk
|
2 | Descriptions of intended device users, uses, use environments, and training
- Intended user population(s) and meaningful differences in capabilities between multiple user populations that could affect user interactions with the device
- Intended use and operational contexts of use
- Use environments and conditions that could affect user interactions with the device
- Training intended for users
|
3 | Description of device user interface
- Graphical representation of device and its user interface
- Description of device user interface
- Device labeling
- Overview of operational sequence of device and expected user interactions with user interface
|
4 | Summary of known use problems
- Known use problems with previous models of the subject device
- Known use problems with similar devices, predicate devices or devices with similar user interface elements
- Design modifications implemented in response to post-market use error problems
|
5 | Analysis of hazards and risks associated with use of the device
- Potential use errors
- Potential harm and severity of harm that could result from each use error
- Risk management measures implemented to eliminate or reduce the risk
- Evidence of effectiveness of each risk management measure
|
6 | Summary of preliminary analyses and evaluations
- Evaluation methods used
- Key results and design modifications implemented in response
- Key findings that informed the human factors validation test protocol
|
7 | Description and categorization of critical tasks
- Process used to identify critical tasks
- List and descriptions of critical tasks
- Categorization of critical tasks by severity of potential harm
- Descriptions of use scenarios that include critical tasks
|
8 | Details of human factors validation testing
- Rationale for test type selected (i.e., simulated use, actual use or clinical study)
- Test environment and conditions of use
- Number and type of test participants
- Training provided to test participants and how it corresponded to real-world training levels
- Critical tasks and use scenarios included in testing
- Definition of successful performance of each test task
- Description of data to be collected and methods for documenting observations and interview responses
- Test results: Observations of task performance and occurrences of use errors, close calls, and use problems
- Test results: Feedback from interviews with test participants regarding device use, critical tasks, use errors, and problems (as applicable)
- Description and analysis of all use errors and difficulties that could cause harm, root causes of the problems, and implications for additional risk elimination or reduction
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