Aligned Elements is a Medical Device application lifecycle management (ALM) solution enabling fast development and regulatory compliance through improved Design History File management.

August 27 2018

Requirements Management is strange. It is a well-researched area which each year yields an impressive number of articles, conferences and known best-practices. Still, this body of knowledge remains remarkably underused by the people who would gain from it most. In many of the organisations I encounter, well-established requirements elicitation techniques are simply not undertaken.

Perhaps this has to do with the deceivingly simple task at hand. "I just need to write down what the device should be able to do. How hard can it be?". Hard enough it seems, if one considers the many reports stating how mismanaged requirements leads to enormous costs down the line.

This is exactly what Prof. Dr. Samuel Fricker and his team has established in their paper "Requirements Engineering: Best Practices" (2015).

He concludes that although each and every one of the 419 participating organisations "...elicited, planned, analysed, specified, checked, and managed requirements...", very few of them apply formal requirement elicitation techniques.

For those who did "...only three techniques correlated with requirements engineering success: scenarios of system use, business cases, and stakeholder workshops."

The common idea with these techniques is to:

  1. bring structure into elicitation process
  2. involve many people into the discussion

Both parts are essential to success. Doing 1) without 2) misses out on critical knowledge in the organisation. Doing 2) without 1) is just wasteful. Personally, I have particularly good results from applying a variant of Use Scenarios called "Task Analysis / Task Risk Management" described by Andy Brisk. In short, this is a basic Task Analysis method, where processes are analysed step by step for requirements and risks.

Opposing the natural inclination of engineers to decompose a system into parts for analysis, this method focus on how you use the device, i.e. the system is decomposed into the scenarios where the user interact with the system.

In other words, we let use drive design.

Mr. Brisk lists a number of process examples which coincides well those applied to a generic medical device, such as:

  • Unpacking
  • Setup / Installation
  • Calibration
  • Start up
  • Daily Operation
  • Shutdown
  • Maintenance
  • Service
  • Alarms and Alerts
  • Decommission

If the found processes are too large to analyse, Mr. Brisk advices to decompose them further into manageable sizes.

Once the processes are identified, Mr. Brisk prioritizes the processes according to risk, in terms of:

  • Are there significant damaging consequences if the task is performed incorrectly? (High Severity of potential Harms)
  • Is there a reasonable likelihood that tasks will be performed incorrectly? (High Probability of Use Errors)

The idea of this risk-based prioritization is to focus on high-risk processes and analyse them early and thoroughly.

The processes are now analysed step-by-step, preferably by a group of people. They imagine and discuss the steps an imaginary user goes through to perform a task. How is the system accessed? How does the user communicate his intentions to the system and vice versa? What potential errors might the users make?

Task Analysis

Coloured post-it notes can be used to describe the steps on a wall. A tip is to use different colours for process steps and identified potential use errors. This approach manages to create both a common vocabulary of describing the system and its use, as well as creating a common understanding of how the device is meant to be used. It also tends to highlight areas where people had a different understanding of how the system should be used (by simply measuring the loudness of the discussion).

The Task Analysis described above is an easy and straight-forward way of eliciting requirements AND uncover high-level risks in a usage context. What makes it particularly suitable for Medical Device manufacturers is that it combines risk- and requirement elicitation in a single, common activity. Much too often, these two tasks are performed by separate groups in separate contexts.

A further bonus is that it intrinsically produces both Use Scenarios and Use Errors, which are substantial an essential parts of the Usability Management File.

Some important lessons learnt using this method includes:

  • Try to use a similar step granularity in all processes
  • Before starting, try to agree on what shall be considered "known" about the system
  • Define a clear Goal as well as Start and End point for each process in order to declare the scope
  • Be generous with risks, rather too many than too few
  • Do not forget to write down the elicitated Scenarios and Risks before you leave the room

Aligned Elements supports the documentation of Use Scenarios and their associated Use Errors as described above in our IEC 62366 Configuration. The Use Errors are applied in the overall High-Level Risk Assessment to drive further design decisions.

July 15 2018

That medical device development entails a lot of documentation should not be a surprise to anyone. Hundreds of documents are created, reviewed, released, then modified, reviewed and released again. The majority of these documents needs to be signed, often by two persons or more. Collecting signatures, although it seems like a trivial task, becomes a significant nuisance when the number of documents and releases increase.

One of our customers insisted on having 3 people sign each test case before release. Their 18 000 test cases yielded a combined signature collection effort of 5 man-years (estimated 30 mins to collect a single signature, their estimation).

It is rare to find medical device manufacturers that enjoy writing medical device development documents, but it is even rarer to find those who gladly spend their days collecting signatures for the said documents.

The obvious question is hence: how can we spend less time on document signatures?

For many medical device manufacturers, the equally obvious answer seems to be electronic (or digital) signatures.

So why is it so hard to get a signature?

There are several potential reasons for this. Maybe the Signer is a very busy person and simply has no time for this task. Maybe the Signer is located somewhere else through work, travelling, vacation or other reasons. Or perhaps the previous Signer did not pass on the document to the next Signer in line. Or maybe a formal signature sequence (order) is forced by the document process in question, where a Signer that actually is available, is prevented to carry out the task since some Signer further up the signing sequence has not fulfilled hers. Or it might be that the document in question cannot be signed before some other related document has been released (i.e. signed).

Thus, there can be formal reasons but also trivial reasons why a signature does not get timely collected.

The most trivial is of course that it is just hard to physically get the document in front of the Signer (or the other way around) for some reason or another. Once you get that far, the literary "stroke of the pen" is usually a quick affair. This is the perceived major efficiency benefit of Electronic Signatures. You do not have to physically get the document in front of the Signer. The document does not need to get passed around. The Signer can pull it up (from an E-Signing System) whenever he wants, from wherever he is. This allows a quasi-parallel execution of signatures. Two people on different sides of the planet can sign the same document at the same time (almost)! Costs associated with printing, sending, scanning and storing the paper copy are eliminated. E-Signatures also entail increased measures of security, enhanced authenticity, resisting tampering and also provide accurate signature audit trails.

Before explaining how to introduce an E-Signing System, let me say a few words about Digital and Electronic Signatures.

Digital and Electronic Signatures

Even though the terms are often used interchangeably, there are some notable differences between the two concepts.

According to FDA, Electronic Signatures are "Compilation of data (user name / password, dongles, biometric)", which is unique for a person. This can be used to sign documents and is as legally binding as a “wet signature”. The signature and the association with the signed entity (document) is stored in a database of the Signature System. Furthermore, not all E-Signing Systems leave a visual mark on the signed document that indicates that it has actually been signed.

Digital Signatures on the other hand, require a Digital Certificate that ensures the identity of the signer. A part of that Digital Certificate gets embedded in the signed document during the signing process. As a result, the validity of the signature can be checked independently of the E-Signing System.

So, someone needs to guarantee the identity of the signer.

For Electronic Signatures, the organisation (the manufacturer) does this by using the validates E-Signing System.

For Digital Signatures, it is the issuer of the Digital Certificate that ensures the identity of the signer. Digitally signed documents often also contain a visible signature.

Obviously, there seem to be several advantages using Digital Signatures. The validity of the signed document can be inspected independently of the E-Signing System, which is an advantage if the E-Signing System goes down, is corrupted or the system vendor goes bankrupt.

Any drawbacks?

Yes, a few. Obtaining a Digital Certificate from a third-party vendor is expensive and requires an administrative effort. There is the obvious question of where and how to store these certificates as well as associate them with the user. They also have the nuisance to expire after a while and therefore need to get regularly renewed. People also have a tendency to marry and change their names etc. which also leads to renewals. Furthermore, it is not guaranteed that the validity shows up correctly in third party viewers (like Acrobat PDF Reader), for technical reasons having to do with root certificates.

An organisation can circumvent all this by issuing their own Digital Certificates. This is somewhat of an IT "adventure" but it can be done. Costs can then be lowered somewhat but there is still a significant administrative effort. Moreover, internally generated Digital Certificates can of course not be validated by third party viewers (like Acrobat PDF Reader).

So, there are pros and cons with both options.

However, they have several similarities and most important of all, both methods are recognized by the FDA.

Let's do E-SIgning!

Let's say we want to engage in eSigning (Electronic or Digital). What kind of effort can we expect to get this up and running?

Here is a short list of some of the steps:

  • Assess the E-Signing System for Part 11 / Annex 11 compliance
  • Qualify the E-Signing System Vendor as Supplier according to your QMS
  • Assign responsible roles and people for the E-Signing System
  • Install and configure the E-Signing System
  • Make or buy the Digital Certificates (if used)
  • Adapt your QMS to recognize E-Signatures and describe how they are intended to work
  • Prepare all the Document Templates to be used for eSigning (the system needs to know where in the document the signature shall be placed. Page nr, location on page, margins and spaces etc).
  • Validate the E-Signing System
  • Create E-Signature User Guidelines and train all users in how to use it
  • Notify the FDA (which is compulsory)

There is thus a non-neglectable initial effort to set up the E-Signing System, and also an effort to keep it maintained, both from a process as well as from an IT perspective.

There are also several other things to consider before you decide to go down the Electronic Signature path:

Document Life Cycle

All documents have a life cycle and the signing is only a very small part of this process. You need to consider how the document gets into the E-Signing System, how it interfaces with other systems such as Document Management Systems, workflow engines or e-Forms of which the document may be a part.

You also need to pay attention on how you plan to archive the electronic documents. This might seem like a trivial question but it is more depth here than you think.

External Users

If external users (as in external to your organisation) are going to use the system, you need to prepare a process where they get access to the E-Signing System, including setting up a corresponding user in the system with the appropriate Digital Certificate if applicable. These external users also need to get trained in how to use the system.

Hybrid Signature Situations

Are you going to end up with documents that are partly signed electronically and partly with traditional "wet signatures"? If so, you need a described process for this as well.

Ownership

Last but not least you need to establish who has the ownership of the E-Signing System. Is it the IT Department that usually acquire and maintain IT systems? Or is it the R&D department that probably is the most frequent user of the system? Or is it the HR department that is concerned with the identity of the people working in the organisation? This needs to be clarified before you start.

Predicted Outcome

As mentioned, an E-Signing System will decrease the effort of placing the document in front of the Signer. It will reduce costs associated with transporting the paper copy of the document. It will also potentially increase security and authenticity of the documents.

But there are things an E-Signing System cannot do. Regardless of how deep you entrench E-Signatures as a paradigm in your organisation, you will almost inevitable have a residual number of documents that are signed with ink. Thus, no matter how much you push E-Signatures you will end up with a hybrid system, composed by documents signed electronically and documents signed with ink. Be prepared for this.

Then, a Signature System is per se an IT system with all the work it entails. It needs to be validated and maintained, people will repeatedly forget their credentials if they do not use the system frequently and there will be the ubiquitous bugs and errors. This all means increased costs that need to be compared and contrasted with the costs by using a manual system.

Finally, an E-Signature System does not make bad processes good just by digitizing them. Overloaded employees will still remain overloaded regardless.

For which situations does E-Signatures make sense?

E-Signatures make sense when signing is a routine operation i.e. when a user makes several signings per week. E-signing for the occasional (or maybe even singular) CEO signature on a Product Requirements Document does not warrant the effort.  

Document types that are well suited for E-Signatures are those that exist in many instances and that are comparably small amount of actual content (as in quick to read). Examples of such document types are time reports, expense reports, purchasing approvals and test case documents.

Last but not least, maintenance is of course made easier if all Signers are part of the organisation (as opposed to involving multiple external users).

Efficient with and without E-signatures

If you find it cumbersome to collect signatures today, there are several ways you can scrutinize your organisation for efficiency improvements.

Analyse current signing process

Are all these signatures really necessary? Ask yourself why they were added ("It is required by our process" is not a valid answer) and most importantly, what does the particular signature mean? In what way does a particular signature make the document "better"?

Don’t get dependent on busy Signers

The overloaded Project Manager or CTO that never has time for signing is a common bottleneck in many organisations. Appoint deputies to all signing functions (the deputies shall also have deputies). Try to avoid sequentially forced signature sequences. They cost more than they bring. Finally, simply planning the signing occasion like a regular meeting (set up a meeting in the calendar) might yield you some good results.

I hope this post has highlighted some of the pros and cons of employing Electronic Signatures. If there is anything I want you to take home it is probably this:

  • Signature efficiency stands and falls with the process, not the system
  • Analyse and improve the process first!!
  • E-signatures can be very beneficial in specific situations
  • E-signatures gains (i.e. speed gains) must be weighed against costs

Aligned Elements supports electronic as well as digital signatures of documents with automatic relaying to external Document Management Systems.

If you would like to get a demonstration of e-Signatures in Aligned Elements, just let us know.

July 10 2018

What's New

Aligned Elements V2.4 SP 5 (2.4.213.14327) is a hotfix for solving an upgrade problem for projects from V2.4 SP 2 and earlier to the newest version of Aligned Elements.

Upgrade now

This is the recommended version.

Find the installer to Aligned Elements V2.4 SP 5 here.

July 03 2018

What's New

With a complete overhaul of the Aligned Elements Web Client frontend, we are pleased to give you a much better user experience. In this release we also introduce the Aligned Element dashboards, improvements to the Review Experience as well as several changes requested by our customers (to whom we always listen!)

 

Dashboards

Have you ever thought that although there is an immense amount of valuable information in Aligned Elements, getting the overview of the current state of affairs is not particularly straight forward. Enter Dashboards, you can now configure your own cockpit from a large number of Widget types. Web client information at your fingertips!

Dashboard

 

Web Client Frontend UX Enhancements

With a proper Sidebar navigation as well as side-by-side operations of Project/Trace Explorer and the Items, the need for jumping back and forth is significantly reduced. Event based updates removes the needs of manual refreshing. A useful Test Run Burndown chart is now tracks your progress.

Frontend

 

Enhance Design Review UX

The Design Reviews now display the Design Control Items just like they appear in your documents. You can create and assign issues directly to the Design Control Items without having to leave the context. We have also added an option for the Reviewer explicitly state completion of all assigned tasks with a single button click.

Review

 

What's Changed

  • New Inconsistency rules for Missing Test Executions in Test Runs and Unique attribute values
  • Improvements in management of External Issue Management systems
  • Clearing File attribute values
  • Warn on commit on selected inconsistencies
  • Improved performance for Cloud Projects

Upgrade now

With important fixes and a handful improvements, this release is a recommended upgrade.
Find the installer to Aligned Elements V2.4 SP 4 here.

April 01 2018

 

Sharpen your Skills 2018

May 17th, 2018 | HWZ University, 3 minutes from Zürich Main Station

Skills

Compliant and Efficient Medical Device Development

An impossible combination? 

Join us to gather concrete and practical advice on how to meet trending medical device development challenges in 2018.

We have called on a group of experienced industry expert to share their latest best practices on how to eliminate problems with you.

Register now to reserve your seat!

We look forward to see you at this event. If you have any questions or information requests, please don't hesitate to This email address is being protected from spambots. You need JavaScript enabled to view it.


Key Learning Objectives

Medical Device IT Security

Live hacking session, an introduction to the regulatory requirements and hands-on tips for developers of medical devices - by Prof. Dr. Christian Johner, CEO, Johner Institute

Implementing GDPR at Polar

Learn more about how Polar implemented one of the most important regulatory changes in 2018. If you haven't started yet, get the do's and don's from Niclas Granqvist, Director Apps & Electronics, Polar Electro Oy

Common Usability Engineering Pitfalls

What could possible go wrong? Expected and unexpected outcomes from the usability engineering process based on real life examples - by Andrea Schütz-Frikart, Human Factor Speciailist, Frikart Engineering GmbH

Post-market surveillance, Transition from MDD to MDR

The lean and mean approach to performing MDR post-market surveillance using a realistic framework - by Stephanie Grassmann, MedTechXperts GmbH

Modular Design Control Documentation

Can Design Control Documentation be modularized and re-used in several Medical Devices? Discover the Pros and Cons - by Karl Larsson, Design Control Documentation Expert, Aligned AG

 


Time and Place

  • Date: Thursday May 17th
  • Time: 08:15 - 13:00
  • Place: HWZ University, Zürich

Presentations are held in German. Slides written in English.

Target audience

This event is aimed at medical device development professionals, project managers, QARA professionals, R&D personnel and other industry professionals engaged in medical device development.

Registration

We are looking forward to see you at this seminar!

Registration Fee: 125 CHF

30% early bird discount for registration before May 1st.

 

 


Location

Address: HWZ Hochschule für Wirtschaft Zürich, Lagerstrasse 5, Zürich

 

HWSMap

 


About Aligned AG

Aligned AG provides Aligned Elements, a Medical Device ALM system that accelerates and ensures compliant Design Control documentation for medical devices. We assist our clients in developing regulatory compliant products within shorter time-frames, to lower costs and with higher confidence. 

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