Sunday, December 24, 2017

HFE/UE Validation Report Contained in a Premarket Application or Submission--Medical Devices

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
1Conclusion
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
2Descriptions 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
3Description 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
4Summary 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
5Analysis 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
6Summary 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
7Description 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
8Details 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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