Traceability in risk analysis

Vetty007

Involved In Discussions
Hi,
the requirements regarding the traceability of risks or hazards in risk analysis are not entirely clear to me and hopefully your comments can help me to better understand it.

DIN EN ISO 14971 states that traceability is intended to ensure that all hazards have been considered and I would then number the hazards, whereby I could already use the characteristic (e.g. unsuitable raw material) to avoid discussions in small parts (as the hazard is e.g. toxic raw material, material-incompatible raw material etc.) and rather dealt with them under a general term (in this case the characteristic). For tracing purposes, I thus number the characteristics and then assign a sub-item for the hazard that fall under them, which could be also a combination of a letter abbreviation with a number.

But somewhere (unfortunately I can't remember where) its said, that the risks should be traceable, which means the potential damage. This is where things get complicated for me in terms of numbering and tracking, as each hazard is broken down into different harms for users, third parties, environment, medical device, etc and also leads to different risk minimization measures (RMM). I also had codes for each harm and RMM in the past, but didn't see an advantage of having them and thus stopped to use them.

How do you implement the traceability requirement and which aspects do you include in your traceability code?

What I would also be interested in is, at what point does this code actually benefit me? In the clinical evaluation I copy the data 1:1 from the risk analysis (feature, danger, damage, risk minimization measure) and taking over an additional column with a traceability code only needs unnecessary space. At least I don't see any advantage here. For reasons of readability, I would always speak specifically about the danger instead of just stating the code. Am I missing any advantage here or where can the traceability codes be used practically?

I am curious about your enlighting thoughts :)
 

Tidge

Trusted Information Resource
DIN EN ISO 14971 states that traceability is intended to ensure that all hazards have been considered and I would then number the hazards, whereby I could already use the characteristic (e.g. unsuitable raw material) to avoid discussions in small parts (as the hazard is e.g. toxic raw material, material-incompatible raw material etc.) and rather dealt with them under a general term (in this case the characteristic). For tracing purposes, I thus number the characteristics and then assign a sub-item for the hazard that fall under them, which could be also a combination of a letter abbreviation with a number.

Hazards are potential sources of harm.

I prefer to think of Hazards as been fundamental, universally-present, qua-elemental forces that exist independent of any particular device. E.g. Electricity, Fire, Infectious Agents, Radiation, et al.

"Incompatible material" is some sort of failure mode. Maybe a failure of the design, maybe a failure of some sort of process. I keep failure mode analysis separate from hazard analysis; Hazard Analysis is where the risks are assessed.

As for traceability: Risks (analyzed in a hazard analysis) can either
  1. Exist such that need to be controlled, the controls for these risks will be allocated (downwards) from the HA to design/use/process subordinate documents
  2. Be introduced, via design/use/process choices... these risks will come upwards from subordinate elements.
It is important to be able to recognize the difference between the two. Each will have to trace to the parent risk analysis.
 
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