1.0 QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 1 of 28 Purpose / Scope The purpose of this Work Instruction (WI) is to describe how to apply Failure Mode and Effects Analysis (FMEA) to medical devices. This WI is governed by QSP – Risk Management, 812264. This WI applies to all devices designed and/or manufactured and sold by Terumo CVS – Ann Arbor throughout all phases of the product life-cycle. "Distributed Product" is not within the scope of this procedure. FMEA supports, and is not a substitute for, Hazard Analysis (see WI – Hazard Analysis for Device Risk Management, 78-8067-5094-5) and does not apply to Software. 2.0 Roles / Responsibilities The following roles are responsible for performing the tasks in this WI: 3.0 Role Job Title or Training Curriculum Clinical Services Representative Refer to training curriculum (R) FMEA Performers for a list of qualified Associates Cross-Functional FMEA Team Member Refer to training curriculum (R) FMEA Participants for a list of qualified Associates Following this process and conducting FMEA for the relevant product or system. Design Quality Assurance (DQA) Representative Refer to training curriculum (R) FMEA Performers for a list of qualified Associates Ensuring this process is properly followed. Team Leader Refer to training curriculum (R) FMEA Performers for a list of qualified Associates Following this process, scheduling and leading the Cross-Functional Team, and authoring the DFMEA and UFMEA Worksheet and Report. An Operations Engineer is responsible for following this process, scheduling and leading the Cross-Functional Team, and authoring the PFMEA. Responsible for Providing the expertise to evaluate all potential Failure Modes for Harms. Updating LST – Master Harms, 824606 as necessary. Definitions Definitions for terms used within this WI are found in LST – Master Definitions, 824768. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed 4.0 QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 2 of 28 Referenced Documents The following documents are referenced within this WI. For each document referenced in this WI, the relationship to other Quality System Management Documents (QSMDs) is specified in the QSMD Relationship column. Document Number 5.0 Document Class – Document Title QSMD Relationship 78-8067-5094-5 WI – Hazard Analysis for Device Risk Management Output 78-8067-7475-4 LST – Record Retention and Storage None 812264 QSP – Risk Management Parent 812680 TMP – FMEA Worksheet and Report Child 817777 WI – Technical Review Output 819725 WI – Software Hazard Analysis for Device Risk Management None 824606 LST – Master Harms None 824768 LST – Master Definitions None 825406 QSP – Usability Engineering Process None Safety There are no safety issues for Associates performing this procedure. 6.0 Records The records created as a result of performing this WI are listed in the table below. See LST – Record Retention and Storage, 78-8067-7475-4, for specific information regarding storage location and retention requirements for the records. Record Name FMEA Worksheet and Report Quality Record Category Engineering: Risk Management Files Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed 7.0 QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 3 of 28 Procedure This section defines the Terumo CVS Failure Mode Effects Analysis (FMEA) process. Reference FMEA Flowchart for Device Risk Management below. Refer to QSP – Usability Engineering Process, 825406, for more information about how to consider use of the device while performing an FMEA. The main concept of FMEA as applied to medical device risk management is to analyze Failure Modes (typically "Causes" from an associated Hazard Analysis Worksheet), determining Failure Mode Causes, and developing Control measures to reduce the likelihood of the Failure Mode Cause occurring. Failure Mode Effect is used as a parameter to develop the Risk Priority Number (RPN). All device FMEA activities shall be documented in TMP – FMEA Worksheet and Report, 812680, and shall reside in the product Risk Management File. The initial release of an FMEA, and significant revisions, shall undergo a review using WI – Technical Review, 817777. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 4 of 28 FMEA Flowchart for Device Risk Management START 1 Define Purpose and Scope of the FMEA 2 Describe intended use or process 3 Develop supporting documentation 4 Identify the Function DFMEA) or Use step (UFMEA) or Process Step and Process Requirement (PFMEA) B 5 Identify potential Failure Modes 6 Fill in occurrence rating of the Failure Mode 7 Fill in Potential Effects of the Failure Mode 8 Fill in severity rating Use WIF – Master Harms List (if appropriate) 9 Fill in cause of Failure Mode 10 Fill in existing Failure Mode detection means 11 Fill in detection rating 12 Calculate Risk Priority Number (RPN) A Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 5 of 28 FMEA Flowchart for Device Risk Management (cont.) A 13 Document Risk Level No 14 Identify practicable controls 15 IBD PMx Implement risk controls Verify risk controls Risk Management Plan Acceptability Criteria 16 Evaluate RPN after implementation of risk controls 17 Is post-control Severity 3, 4 or 5? No 18 Document Information for Safety 19 More Failure Modes? Refer Failure Mode to Associated Hazard Analysis Yes Return IFS Yes B No 20 Create a Failure Modes RPN Summary Document in FMEA Report Send Failure Modes RPN Summaries To Risk Management Report END Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 6 of 28 There are 3 types of FMEAs: A Design FMEA (DFMEA) evaluates Failure Modes with respect to the design of the system, sub-system, sub-assembly, module or component. A Use FMEA (UFMEA) evaluates the Failure Modes with respect to use and/or misuse of the device. A Process FMEA (PFMEA) evaluates Failure Modes with respect to the assembly and manufacturing process. For each FMEA, use TMP – FMEA Worksheet and Report, 812680. In the instructions below, the column to be used in the FMEA Worksheet is indicated in bold as Column [n]. The Project Technical Leader associated with the device under development for the FMEA shall act as Team Leader and form a Cross-Functional FMEA Team (referred to as "Team"). Team Members shall minimally consist of Product Development (software, hardware and/or post market engineering as applicable), Design Quality Assurance, Site Quality, Clinical Services, Operations Engineering, Supplier Quality Engineering, and Service. The DQA Representative is responsible for ensuring the FMEA process is properly followed. The Team Leader, with support from Team Members, shall complete TMP – FMEA Worksheet and Report, 812680, following the steps described below. 7.1 Step 1 Document the Purpose, Scope, FMEA Type, and Participant Roles and Responsibilities. Team Members shall have the appropriate knowledge and experience for their role on the team. Reference Appendix A for guidance on key team members and things to consider for each type of FMEA. 7.2 Step 2 In Section 3, System Description, of TMP – FMEA Worksheet and Report, 812680, the Team shall document and describe the system, subsystem or process being analyzed. For DFMEA or UFMA, describe the intended use. For PFMEA, use the manufacturing process information. Also document the following information: 7.3 Identification and description of the medical device(s) Use Case (to be used for UFMEA) Process Flowcharts (to be used for PFMEA) Description and listing of all accessories, regardless of their origin (to be used for DFMEA or UFMEA) Functional block diagram of the system and all sub-systems (to be used for DFMEA or UFMEA) Step 3 In Section 4, Supporting Documentation, of TMP – FMEA Worksheet and Report, 812680, the Team shall identify and document all the supporting documentation used to perform the FMEA. The supporting documentation includes (as appropriate): Risk Control Option Analysis Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 7 of 28 7.4 Rating Scales for FMEA’s RPN Level and Evaluation Criteria Schematics Drawings Process Flowcharts Unique symbols, terminology, and conventions Use Case Scenarios Architecture Design Documents Detailed Design Documents Requirements Design Documents Technical Review Minutes Functional specifications Design input documents Manufacturing Work Instructions, Procedures, Routers, Flow Diagrams Existing risk management documents for the project Fault analyses (e.g., Ishakawa diagrams (fish-bone), Fault Tree Analysis (FTA)) Occurrence data (from similar products or processes) Prototypes, pictures, diagrams Any other information that will help to identify Failure Modes, causes and effects Guidance for filling out TMP – FMEA Worksheet and Report, 812680 For additional assistance understanding or performing an FMEA, reference Appendix B. For each Failure Mode (see below) in the FMEA Worksheet, create a unique identifier (UID) in Column [1]. Step 4 Fill in the Column [2] items in the worksheet per the list below. For a UFMEA, enter a step from an identified Use Case For a DFMEA, enter the function of the system, sub-system, or components For a PFMEA, enter the step of the Process flowchart or other manufacturing process documentation and fill in the Process Requirement in Column [2a] Step 5 Fill in Potential Failure Modes (Column [3]) for the corresponding Column [2] item. Write the related Hazard Analysis UID for a Hazardous Situation Cause (Hazard Analysis Worksheet Column [1]) in the Potential Failure Mode cell, if applicable. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 8 of 28 Each function or process step may have more than one Potential Failure Mode. When listing Failure Modes, ask the question, “How can the item fail?” and consider the following verbiage to describe the failure: Too much Not enough Circuit Open / Closed Inconsistent/intermittent Won’t fit/assemble Incorrect test results (passes bad, fails good) Step 6 Fill in the estimated probability of the occurrence of each Failure Mode in the Occurrence (“O”) Column [4]. To predict the Occurrence for a new product, historical data from similar products is a good source, including Complaint and NCR data. Reliability analyses may also be used (reference Appendix C). If the Team develops and/or uses a quantitative occurrence rating scale (reference Appendix E for guidance), the assumptions and rationale for the scale shall be documented in or attached to TMP – FMEA Worksheet and Report, 812680. Step 7 When an associated hazard analysis drives the FMEA Failure Mode, the Potential Effect of the Failure is equivalent to the Hazard Analysis Harm associated with the Hazard Analysis Cause which defined the FMEA Failure Mode. If multiple Hazard Analysis lines apply, the line with the highest Severity applies. Summarize the Hazard Analysis line’s Sequence of Events and Hazardous Situation sufficiently to describe the situation leading to the Harm. Fill in the Potential Effect of the Failure in Column [5] for each Failure Mode. When documenting the Potential Effect of the Failure, two options exist when determining the Harm and are listed in priority order: 1. If the Potential Failure Mode is (traceable) from the HA, fill in the same Harm as in the HA and state the Harm/Cause and reference the HA Harm/Cause line UID (select most severe Harm if more than one Harm is associated with the HA Cause item). 2. If the Potential Failure Mode is not (traceable) from the HA, consult LST – Master Harms, 824606, to select the appropriate most severe Harm as the Potential Failure Mode. NOTE: If there is not an appropriate Harm in LST – Master Harms, 824606, then consult with Clinical Services. A Clinical Services Representative shall provide the expertise to evaluate all potential Failure Modes for Harms. If necessary, the Clinical Services Representative shall update LST – Master Harms, 824606, per WI – Hazard Analysis for Device Risk Management, 78-8067-5094-5. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 9 of 28 Refer to Appendix C of WI – Hazard Analysis for Device Risk Management, 788067-5094-5. Step 8 Fill in the Severity rating for each Failure Mode Effect in Column [6]. Reference LST – Master Harms, 824606. Severity ratings shall be taken from the associated Hazard Analysis or LST – Master Harms, 824606 (if Team determines a new Harm not from the Hazard Analysis). Step 9 Fill in the Potential Cause of failure for each Failure Mode (Column [7]), as determined by the Team analysis. Multiple Causes may be determined for a Failure Mode. Step 10 Fill in the existing detection methods into Column [8]. Reference Appendix C. Important: Detection is the ability to detect the Failure Mode, before the Failure Mode effect occurs. Once the Failure Mode effect has happened, it is too late for detection. See QSP – Risk Management, 812264, Appendix C for FMEA typespecific guidance on Detection. Step 11 Fill in the Detection rating in the “D” column (Column [9]). Reference Appendix C. Step 12 Fill in the Risk Priority Number (RPN) value (Column [10]), calculated as: S x O x D = RPN. Reference Appendix D. Step 13 Fill in the initial RPN Level column (Column [11]) on the FMEA Worksheet, based on the RPN levels defined in the Risk Management Plan. At this point in the FMEA effort, if it is appropriate to approve the document as an Initial FMEA (refer to QSP – Risk Management, 812264), the following columns of the worksheet may be left blank and approvals pursued per section 7.6. Step 14 Identify all practicable Risk Controls, classify them (e.g., IBD, PMD, PMM), and document and reference them in (Column [12]) as IBD, PMD, or PMM. Practicable controls are those controls which can be done by the company without causing disruption to the product design so as to make it unfeasible to provide to the marketplace (taking into account the technical, clinical, regulatory, sociological and political context). Document all risk control option analysis discussions in a Risk Control Option Analysis (RCOA) document with a unique document number, and reference the RCOA document in the FMEA Report (reference Appendix C). Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 10 of 28 The Risk Control Option Analysis document shall be maintained as a separate document in the Risk Management File, referenced by or attached to the FMEA. This document requires update whenever a risk control is added, deleted or changed in a substantial way. RCOA shall consider risk controls that will reduce the RPN to the lowest possible level. Refer to Appendix D of WI – Hazard Analysis for Device Risk Management, 78-8067-5094-5, for further instruction. See section 7.6 for completing the approvals coversheet. FMEA RCOA shall support the reduction of risks in the Hazard Analysis. Acceptable objective evidence of a risk control includes referencing the following elements by title and with a controlled document number: Design requirement, Product specification, Labeling specification, Procedures (i.e., Manufacturing Work Instruction). Step 15 Implement all practicable risk controls. Document the objective evidence of verification of implementation and the verification of effectiveness in Column [13] of the worksheet. Reference Appendix C. Step 16 Determine if the practicable controls reduce the RPN. Use similar methodology for re-estimation of severity and occurrence and detection (see step 6, 8 and 10) after RPN controls. Document the new severity (Column [14]), new occurrence in (Column [15]) and new detection (Column [16]). Compute the new RPN and place the value in Column [17] of the FMEA Worksheet (reference Appendix D and Appendix F). Step 17 Evaluate new RPN. Refer any Failure Modes back to the associated Hazard Analysis if they have a Severity rating of 3, 4 or 5 for further evaluation in the Hazard Analysis as potentially new risks. Refer Failure Mode controls UIDs to Hazard Analysis Worksheet (risk controls). Step 18 Document the Information For Safety (IFS) to be disclosed, as determined by the Risk Control Option Analysis, on (Column [19]) of the FMEA worksheet. Include verification of implementation. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 11 of 28 Step 19 Determine whether new Failure Modes have been introduced in the course of developing and implementing the risk controls. If new Failure Modes have been identified, go to Step 5, Identification of Failure Modes. Check to determine if more Failure Modes remain to be analyzed. If yes, go to step 5. If no new Failure Modes have been identified, proceed to Step 19. 7.5 Step 20 Create a summary of all evaluated Failure Modes with their associated RPNs for this FMEA. Document this summary in TMP – FMEA Worksheet and Report, 812680, Section 5: FMEA Summary. This report shall be reviewed and approved to complete this activity. The summary shall include, but not be limited to, the following: Quantity of Items Analyzed, Quantity of “line items” that had initial RPN of High, Medium or Low. Quantity of “line items” that had initial RPN of Medium that were reduced to Low. Quantity of “line items” that had initial RPN of High that were reduced to Medium. Quantity of “line items” that had initial RPN of High that were reduced to Low. Quantity of “line items” that had initial RPN of High that remained High. All risk controls have been verified as being implemented. Ensure this summary is also included in the Risk Management Report document. 7.6 Approvals Fill in the cover sheet with the approvers’ names and functions per the Roles and Responsibilities. If the document is to be approved electronically, fill in the names and functions and enter “see electronic signature” in the Signature column. NOTE: When the document is being approved electronically, ensure that the Effective Date is entered as “DD-MMM-YYYY”; the effective date will be added by the Configuration Manager during CC/ECO processing. If it is not being approved electronically, ensure that the Effective Date is “See last approval date”. 8.0 Revision History The Revision History contains a brief summary of the changes made to this document. Refer to the ECO for a complete summary of changes. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 12 of 28 Author Bill Hansen Revision K Summary Description of Change Converted to new format per 812381, Rev. P. ECO Number Effective Date 85472 See Effective Date in header 83666 21-JAN-2013 83363 12-OCT-2012 Clarified how Risk Control Option Analysis is documented, including new template. Removed risk acceptability terms and replace with High/Medium/Low. Disallowed the use of IFS controls to reduce risk level; create a separate column for listing of IFS. Fixed formatting and create a recurring header in the worksheet section. Required risk control consideration for ALL risks, even those considered Broadly Accepted. Clarified the need for Technical Reviews. Bill Hansen J Added statement regarding concept and use of FMEA; replaced flowchart to better represent process flow; re-ordered types of FMEAs Added " for Hazardous Situation Cause" after Hazard Analysis UID to clarify the FMEA Failure Mode is the HA Hazardous Situation Cause Added "practicable" to risk controls and defined practicable. Also added language to require risk control option analyses. Added reference to Appendix C: Examples of Failure Mode Cause Risk Controls and Failure Mode Inherent Detection Appendix C – added new appendix for examples of risk controls and inherent failure mode detection means Bill Hansen H Added statement indicating use of WI – Technical Review, 817777, pre-commercialization. Clarified that Failure Mode Effect is associated to the Hazard Analysis Cause and the Failure Mode Effect is the associated Hazard Analysis Harm. If the FMEA line item is not driven from a Hazard Analysis Cause/Harm, then the Harm must be established by the cross-functional team and selected from the Master Harms List. Delineated Hazard analysis Cause and Failure Mode Cause more clearly. Clarified definitions in initial risk evaluation to Broadly Acceptable, Intolerable or ALARP Identify RPN acceptability criteria and clarify failure modes UIDs to Hazard Analysis Worksheet. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 13 of 28 Appendix A – Types of FMEAs The table below gives some guidelines on these types of FMEA. These are recommendations; each FMEA effort should be planned to best fulfill its scope and need. While the full cross-functional team is required for each type of FMEA, the “key team members” listed below may have the greatest involvement in the creation of the FMEA. TYPE Design (DFMEA) Use (UFMEA) Process (PFMEA) KEY TEAM MEMBERS Quality PD Operations Engineering Supplier Quality Engineering Service Quality PD Clinical DIAGRAM TYPE Functional block diagram, functional decomposition, BOM, component drawing, or use case - Use Case documents - Quality PD Operations Engineering Supplier Quality Engineering Service Process flow diagram THINGS TO CONSIDER Component “infant mortality” Tolerance stack-ups Wear-out and end-of-life Design control process issues Reasonably foreseeable misuse Differences in clinical techniques Setup and cleanup Critical situation responses Service activity - Incoming inspection processes - Storage and handling processes - Manufacturing processes - Packaging and labeling processes - Shipping processes Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 14 of 28 Appendix B – Guidance for an FMEA Effort Guidance for Use FMEA (UFMEA) A Use Case document is the starting point for a UFMEA. As there may be multiple Use Cases for one system, review and analyze each use case to determine the correct one that applies to the situation under analysis in the UFMEA. A UFMEA shall cover each step of the Use Cases associated with the application and intended use of the product under analysis. For each heading on the worksheet (Use Case Element 1.0, Use Case Element 2.0, etc.), use a Use Case heading from a Use Case document and identify the steps from the Use Case in the worksheet. Guidance for Design FMEA (DFMEA) For large, complex designs, the practice of partitioning the DFMEA into a system, subsystem and component hierarchical structure is encouraged. For efficiency and manageability it is usually best to partition the FMEA work such that it corresponds to system partitioning decided upon for requirements definition, design and development and assembly. Use diagrams/drawings that reflect the organization of the FMEA. Diagrams or drawings may also be included that show the device in its use environment, a functional block diagram, a component drawing, or other drawings that clarify the device and the scope of the FMEA. The system partitioning/drawings/diagrams used shall be documented in the device Risk Management Plan. Consider items which can be used on other systems (e.g., the flow sensor). Consider items which are clearly separated from other parts of the system (e.g., the Delphin battery) under analysis. These items should be separated into sub-system DFMEAs for clarity or to enable re-use in another system which may use this same sub-system. This architectural breakdown into subsystems should be documented in the Risk Management Plan. Critical components require consideration in an FMEA as appropriate. Additional consideration of mechanical interfaces and functions, electrical/electronic interfaces and functions, material considerations and chemical and biological considerations are also appropriate. Include Supplier Quality Engineering quality considerations for control of components or subsystems provided by external suppliers, including the prevention of the receipt of nonconforming components or subsystems. Component-level FMEA, as well as Fault Tree Analysis (FTA), may be used to support Design FMEA and identify critical components or characteristics. Design FMEA is intended to analyze failures of the design process resulting in poor design. Failures of the device in the field represent a design Failure Mode as related to reliability, maintenance or other design-related issues, and should be considered as opportunities to improve these aspects. Software items are considered in the SW HA (refer to WI – Software Hazard Analysis for Device Risk Management, 819725). Pre-mitigation information comes from previous designs and their previous FMEA information. When compliance to standards is defined as a starting condition and a risk control, the risk control option analysis indicates compliance to the IEC standard is required and therefore shall be verified. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 15 of 28 Guidance for Process FMEA (PFMEA) For a particular product that involves several production processes, provide a diagram showing the relationship of these to support all PFMEA activity in the product development or product under analysis (put the diagram in the associated Risk Management Plan). Additionally, for each PFMEA, reference the Process Flow Diagram for the process. The flowchart shows all process steps covered by the PFMEA, and will follow the organization and sequence of the PFMEA; this will make the document easier to follow, especially for a complex process. The Sample Process Flowchart below illustrates the sequential steps and the various processes that may be necessary to build a product. As illustrated, the flowchart uses several sources of manufacturing process information. This information includes: Operation Step # (OP Step) Routers Procedures Manufacturing Instructions The flow chart shall show the relationships among all the process steps required to manufacture the assembly or sub-assembly. The flowchart shall show all relationships between PFMEA Process element # and the process item in the manufacturing process. The PFMEA Process element number divides the PFMEA Worksheet into sections to analyze each associated process step in that associated Process element. The process procedure step number is placed in Column [2] of the Worksheet. A PFMEA can be conducted on any process that is used to build a device. The scope of process FMEAs may include, but is not limited to: Incoming inspection processes Storage and handling procedures Manufacturing processes (such as fabrication, sub-assembly, final assembly, painting, welding/soldering, etc.), Packaging and labeling processes Shipping processes Service and repair processes Include Supplier Quality Engineering quality considerations for control of components or subsystems provided by external suppliers. PFMEAs are not to be performed on manufacturing tests. Manufacturing tests shall be verified and validated using Test Method Validation processes. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 16 of 28 Sample Process Flowchart Initiate Process Flow P/N Material A P/N Material B Incoming QA Incoming QA Routing OP #1 Procedure # Component/Asby F P/N P/N Component E (fab) Routing OP #2 Procedure # Component/Asby F P/N Routing OP# Procedure # Component/Asby E P/N Routing OP #3 Procedure # Component/Asby F P/N QA Step Inventory Routing Op # Procedure# P/N Sub-Assembly G Routing OP # Procedure # P/N Sub-Assembly H Routing OP # Procedure # P/N Sub-Assembly G Routing OP # Procedure # P/N Sub-Assembly H Routing Op # Procedure # P/N Sub-Assembly K Finish Process Flow Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed P/N Material C QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 17 of 28 Appendix C – Failure Mode Inherent Detection and Control of Failure Mode Causes Common Inherent Risk Detections Inherent Risk Detection – A method for detecting a Failure Mode which does not rely on product-specific inspections or tests, but are rather inherent to the process or Quality System. Inherent Risk Detections are “built-in”, not “tested-in”. DFMEA: Given that a Failure Mode is present in the product’s design, the likelihood that the Failure Mode will be detected during product development prior to product commercialization. PFMEA: Given that a Failure Mode is present in the product as produced, the likelihood that the Failure Mode will be detected during production, prior to the device completing the processes under analysis. UFMEA: Given that a Failure Mode is present during the use of the device, the likelihood that the Failure Mode will be detected by the user prior to the effects occurring. Common Inherent Risk Detections Detection Design Detections Usage / Detail Usage: Design Detections followed by Detail. Detail Verification of Implementation Verification of Effectiveness Inspection records Test records Design outputs Review records Risk Review Data per WI 824650 Verification test records Validation test records 1. Software Control 2. Design to standards (IEC 60601-x) 3. Design controls (Poka-yoke) 4. Technical design reviews 5. Reliability Program 6. Independent reviewer Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 18 of 28 Common Inherent Risk Detections Detection Supplier Detection Usage / Detail Usage: Supplier Detection followed by Detail. Detail 1. Supplier Evaluation and Selection process 2. AQPQ program Personnel Detection Usage: Personnel Detection followed by Detail. Verification of Implementation Supplier audit procedures and checklists APQP evidence of detection are: Supplier FMEA Supplier Control Plan Supplier Validation HR personnel testing requirements Verification of Effectiveness Risk Review Data per WI 824650 Supplier performance data Supplier Evaluation records Risk Review Data per WI 824650 HR records Detail 1. Eye site testing System Level Detection Usage: System Level Detection followed by Detail Detail Use Validation protocols SDD and/or SAC (software alarms and graphical interface) HDD (hardware alarms) Risk Review Data per WI 824650 Verification test records Validation test records 1. Alarms 2. BIT (Built in Test) 3. Graphical Interface (T-Link, APS1, CDI) Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 19 of 28 Common Inherent Risk Detections Detection Visual Detection Usage / Detail Usage: Visual Detection followed by Detail. Detail: Verification of Implementation Drawings Specifications Use Validation protocols Verification of Effectiveness Risk Review Data per WI 824650 Verification test records Validation test records 1. Clear pump covers to see when pump stops 2. Clear tubing 3. Clear bags 4. Clear centrifugal pump housing 5. Clear housings Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 20 of 28 Examples of Failure Mode Risk Controls HARDWARE RISK CONTROLS Control Inherent Safety By Design (IBD) Usage / Detail Usage: IBD or PMD followed by Detail or Protective Measures in the Design (PMD) (IBD or PMD dependent on how the control is used and its effect on the risk) Detail for Design measures Use of specific designs to eliminate or prevent failure mode or risk causes. Can involve partitioning the hardware design implementation, separation Detail for preventive measures 1. 2. Design to standards Design controls (including Poka-yoke techniques) 3. Materials Selections 4. Industry standards for materials (ASTM) 5. Reliability Program (ref. WI 814482) 6. Standardized Symbols 7. Independent reviewer 8. Best practices (ref. WI 814476) Verification of Implementation Verification of Effectiveness Specific design standard met (IEE, ASTM, IEC, AAMI, IPC, ANSI, ISO, DIN, SAE, JSA, JCAHO, etc.) Verification / Validation protocols Specific Drawing numbers Reliability Program may include: o Reliability as Designed o Reliability as Manufactured o Reliability as Maintained Best Practices may include: o Locking connectors o Thread locker o Tie downs o Shock absorbers o EM shielding / ferrites o Strain relief’s o Insulators o Hardware selection o Torque specifications Risk Review Data per WI 824650 Verification / Validation Reports Reliability testing results Test reports to support Certifications Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 21 of 28 HARDWARE RISK CONTROLS Control Usage / Detail Protective Measures in the Design (PMD) Usage: HPQ followed by Detail Hardware Design Process Quality (HPQ) 1. 2. 3. Detail EMI / EMC protections Vibration / Shock resistance Design Rules (electrical rules, SPICE, tolerance stacking) 4. Independent reviewer 5. Technical reviews 6. Literature Reviews Verification of Implementation Specific design standard met (IEE, ASTM, IEC, AAMI, IPC, ANSI, ISO, DIN, SAE, JSA, JCAHO, etc.) Verification / Validation protocols Specific Drawing numbers Standard used for symbols Design Review meeting agenda’s Literature citations Verification of Effectiveness Risk Review Data per WI 824650 Design Review meeting minutes Verification / Validation Reports Reliability testing results Test reports to support Certifications QUALITY SYSTEM RISK CONTROLS Control Protective Measures in the Manufacturing Process Usage / Detail Usage: Supplier Controls followed by Detail. Detail Supplier Controls 1. Supplier Evaluation and Selection process 2. On-going supplier evaluation and rating process 3. AQPQ program (ref. WI819750) 4. Mold Validation 5. Purchase to standards (IPC 600, 610, 620) 6. C of C for purchased product Verification of Implementation Supplier Evaluation documents Supplier Corrective Action Requests Mold Validation protocols Supplier agreement (SSAF) Copy of C of C APQP evidence of controls are: Verification of Effectiveness Risk Review Data per WI 824650 Supplier FMEA, Test, and Validation results Supplier performance results Mold Validation results Supplier Corrective Action results Supplier FMEA Supplier Control Plan Supplier Validation Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 22 of 28 QUALITY SYSTEM RISK CONTROLS Control Protective Measures in the Manufacturing Process Usage / Detail Usage: Receiving Inspection followed by Detail. Detail 1. Receiving inspection 2. First Article Inspection Verification of Implementation Receiving inspection record PIP / QIP document number FA inspection information NCR Process Verification of Effectiveness Risk Review Data per WI 824650 Inspection results NCR Results Receiving Inspection Process Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 23 of 28 QUALITY SYSTEM RISK CONTROLS Control Protective Measures in the Manufacturing Process Production Controls Usage / Detail Usage: Production Controls followed by Detail. Detail 1. Laminar flow hoods 2. ESD Tables / wrist straps 3. Deionizers 4. Inspection magnification 5. 5S program 6. Tool control 7. Lighting specifications 8. Controlled Area Requirements 9. Controlled Area Personnel Controls (gowning, beard / hair nets, booties, etc.) 10. Sterility Controls 11. Pest Control 12. Test Method Validation 13. ESD Controls 14. Inventory controls 15. Production area access controls 16. Process Validation 17. White paint mark used after torque verification 18. NCR system 19. Acceptance tags 20. Segregation on floor (tested passed vs. not tested vs. failed) 21. Graphical work instructions 22. Standardized DHR 23. Controlled BOM’s 24. Equipment IQ, OQ, PQ 25. Poka-Yoke assembly methods Verification of Implementation Receiving inspection record PIP / QIP document number FA inspection information Calibration / PM procedures ESD control procedures Controlled area test procedures Sterility test procedures Pest Control contract TMV Protocols NCM Procedure DHR Procedure IQ, OQ, PQ Procedures NCR System Verification of Effectiveness Risk Review Data per WI 824650 Production metrics Calibration records ESD Test records Controlled area test records Inspection records Sterility test reports Pest Control records TMV Reports Validation reports NCR’s DHR’s IQ, OQ, PQ Reports Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 24 of 28 QUALITY SYSTEM RISK CONTROLS Control Protective Measures in the Manufacturing Process Production Inspection and Testing (PIT) Processes Protective Measures in the Manufacturing Process Usage / Detail Usage: PIT followed by Detail. Detail 1. Production Testing (receiving, in-process, final) 2. In-process inspection 3. Hipot 4. Milk test for X coating 5. CDI fiber bundle testing 6. Pouch pull 7. Leak testing 8. Color chip testing 9. Vibration testing 10. Shock testing 11. Drop testing 12. Internal test to IPC 610, 620 13. Burn-in testing 14. HASS testing 15. Bio-burden testing 16. Shelf life testing 17. Cable testing Usage: Personnel Controls followed by Detail. Verification of Implementation Inspection work instructions Testing work instructions TMV protocols Risk Review Data per WI 824650 Inspection Records Test Records TMV records HR procedures Risk Review Data per WI 824650 HR Records Internal Audit results Detail Personnel Controls Protective Measures in the Manufacturing Process 1. 2. 3. 4. Verification of Effectiveness Eye sight testing Employee selection process Job descriptions Training Usage: Calibration Detail 1. Calibration Calibration protocols Risk Review Data per WI 824650 Calibration records Internal Audit results Calibration Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 25 of 28 QUALITY SYSTEM RISK CONTROLS Control Protective Measures (General) Field service replaceable components Usage / Detail Usage: Field service replaceable components Usage: Use by medically trained personnel, expertise in OR personnel Use by medically trained personnel, expertise in OR personnel Detail Protective Measures (General) Usage: User facility standards 1. Use by medically trained personnel, expertise in OR personnel Detail 1. User facility standards Protective Measures (General) Usage: Expiration dating Detail Expiration dating Verification of Effectiveness Field service item list Risk Review Data per WI 824650 IFU references to minimum personnel requirements Industry standards for personnel to operate equipment National certifications of personnel Organizational certifications of personnel IFU references to minimum user facility requirements / standards. Industry standards for user facilities to operate equipment National certifications for user facilities Organizational certifications of user facilities Approved documents requiring expiration dating on products Risk Review Data per WI 824650 Organizational certifications Personnel certifications Detail 1. Field service replaceable components Protective Measures (General) User Facility standards Verification of Implementation Risk Review Data per WI 824650 Organizational certifications Personnel certifications Risk Review Data per WI 824650 DHR indicating expiration dating 1. Expiration dating Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 26 of 28 QUALITY SYSTEM RISK CONTROLS Control Protective Measures (General) Usage / Detail Usage: Shelf life testing Verification of Implementation Verification of Effectiveness Shelf life testing protocols Risk Review Data per WI 824650 Test results Approved documents requiring product installation by Terumo Field Service Risk Review Data per WI 824650 Detail Shelf life testing 1. Shelf life testing Protective Measures (General) Usage: Product Installation by Terumo Field Service (e.g. T-Link, APS1) Product Installation by Terumo Field Service (e.g. TLink, APS1) Detail 1. Product Installation by Terumo Field Service (e.g. TLink, APS1) Protective Measures (General) Usage: Field Service Required Field Service Protective Measures (General) In-House Service / PM Required Detail 1. Field Service Usage: In-House Service / PM Required Field Service procedures Field Service personnel training requirements Risk Review Data per WI 824650 Field Service personnel training records IFS or other Risk Review Data documents directing service by only inhouse personnel. Detail 1. In-House Service / PM Required Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed per WI 824650 QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 27 of 28 Appendix D – FMEA Rating Scales Use the Severity, Occurrence and Detection scales as contained in Appendix C of QSP – Risk Management, 812264. Risk Priority Number (RPN) is the product of Severity (S), Occurrence (O) and Detection (D). The scales for Occurrence and Detection are different for FMEA vs. Hazard Analysis (the detection tables are specific for DFMEA, UFMEA or PFMEA). Be careful to select the proper table from Appendix C of QSP – Risk Management, 812264. Appendix E – Field Failure Occurrence Data When developing quantitative occurrence ratings, it is especially important to document all assumptions regarding analysis time frames, production rates, length of production, number of units in the field, and customer usage rates of fielded product. EM products: Probability failure mode = Ocomplaints / ((cases/unit/year) * (x yrs.) * (units in field)) SP products: Probability failure mode = Ocomplaints / units in field For both EM and SP products, the following definitions apply: Ocomplaints – Number of occurrences of a Failure Mode as derived from completed complaints taken from the EtQ Database for the period of analysis. Cases/unit/year - 121 x yrs. – interval from which the complaints would be taken. Determine if other numbers would be valid. Units in field – For EM, total number of units in the field back 10 years. For SP, total number of units in the field back 2 years Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed QS Category Doc. Class Document No. Revision Risk Management WI 78-8067-8973-7 K Title Effective Date Page FMEA for Device Risk Management 29-OCT-2014 28 of 28 Appendix F – RPN Evaluation and Acceptability Each Failure Mode of the FMEA represents a possible risk to the patient or user. These Failure Modes shall be evaluated, to determine the RPN level. RPN (Risk Priority Number, S x O x D) is composed of 3 components: Severity (S), Occurrence (O) and Detection (D). After all of the Failure Modes in the FMEA have been evaluated, sort them by RPN value. If two (2) or more items have the same RPN, then sort those RPNs in the following priority: 1) Severity 2) Detection 3) Occurrence. RPN levels as established in the associated Risk Management Plan shall be used in the evaluation. Each RPN falls into one of these ranges: High Medium Low All risks shall be further evaluated by using Risk Control Option Analysis as defined in QSP – Risk Management, 812264. Redesigns, controls, or other mitigations shall be considered and if an RPN cannot be reduced to a lower level, then the item shall be investigated and an explanation written to explain why it is not further reducible. All rationale shall be documented in the Risk Control Option Analysis and/or the Technical Review minutes. Failure Modes shall be evaluated in the associated Hazard Analysis if the Severity rating of the Failure Effect is rated as 3, 4 or 5. When an item is modified, due to redesign or addition of controls or mitigations, the changes shall be examined to make sure that no new Failure Modes have been created. If new Failure Modes have been created, they shall be entered in the FMEA and evaluated. Terumo Cardiovascular Systems Corporation Confidential Uncontrolled Document When Printed
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