Just received an e-mail update on the status of the DRAFT NB-MED document on 3rd edition of EN60601 Implementation for the EU. The pertinent points are:

1) Substantial progress has been made over the last couple months on the document

2) The NB-MED has presented their observations and comments on the proposed document to the team proposal early in Dec 2011

3) The team has worked on integrating the observations and responding to the comments

4) on 13 Jan 2012 the group forwarded their results to the NB MED working group for their approval (validation).

5) It is expected that this document will formally be published hopefully within a couple of weeks not months.

For more details on this DRAFT document please go to http://wwww.EisnerSafety.com/draft-results-implementation-of-3ed-en60601-series-for-ce-marking/ for a copy of the DRAFT document and
http://www.eisnersafety.com/eu-en-iec60601-1-3rd-ed-request-for-issues-on-the-use-of-the-std-for-ce-conformity/ for the first announcement about this process.

On October 1, 2011 the DRAFT “FAQ related to Implementation of EN 60601-1:2006 Clarification of open issues” was issued and this DRAFT document is being sent to NB-MED for commenting on the document.  NB-MED is also known as TEAM NB.  This organization is the European Association of Notified Bodies for Medical Devices which covers the MDD (93/42/EEC), AIMDD (90/385/EEC), and IVDD (98/79/EC).  This group publishes guidances that are agreed on by the Medical Device Directives (93/42/EEC, 90/385/EEC, and 98/79/EC) Notified Bodies. Once all the responses are agreed to it is anticipated that the document will be released as an NB-MED guidance document.

The History of this DRAFT document is restated below.  Note that any “click here” links are not live in the below text but are live in the actual DRAFT document.

History

During spring 2011, it was realized that the use of EN 60601-1 and its many family members in demonstrating compliance with the relevant and applicable requirements of the European medical device regulatory framework was not too trivial. While relevant guidance on the matter had been published at the CENELEC website as a Q&A document (click here), some Notified Bodies were giving advice that was felt to be not in line with that guidance. On other occasions, questions were raised that were not covered in the guidance.

So, it was concluded that the situation for electrical equipment in medical practice was not totally clear and that additional guidance would be useful. Further contact with the chair of the NB-MED confirmed this desirability, and a small group of experts was established. This group developed an enquiry asking for “practical issues in the implementation”, that was sent to many stakeholders in June 2011(see Annex 1). Also at the international level of IEC the request was distributed (62A/769/INF).

The response to the request was beyond expectation and the small team of experts, initially consisting of three, was expanded with Dr. Klaus Neuder of DKE (Frankfurt, Germany).

End of July 2011, the work on digesting the issues submitted until then started and it took until end of September 2011 until all material had been thoroughly discussed and answers formulated to the questions that were raised. In some cases, the questions were slightly amended to make them a little more general, and a few additional “connecting” questions were developed by the team.

It is believed that the answers, developed in close team cooperation, present a fair response to the issues brought forward and that they can be used as a reference for all stakeholders.

Now it is time for the NB-MED to scrutinize the proposed responses and see if they are also acceptable to all members of NB-MED. The NB-MED comments are kindly awaited by the end of October 2011, at the same e-mail address that was used for the initial submission of the issues: 60601Ed3.NBMED.issues@gmail.com, using the form supplied together with this document.

Happy reading!

The 60601-1 Issues Team:

Dr. Wolfgang Leetz, Dr. Peter Linders Dr. Klaus Neuder Mr. Martin Schneeberg

On March 3rd join FX Conferences and Leo Eisner to learn about the home healthcare environment and the proposed emergency medical services standards, respectively IEC 60601-1-11 & IEC 60601-1-12 (hopefully).  More information can be found on our blog post on this topic.

On March 4th  join Leo Eisner in Foster City, CA as he & several other presenters focus on the topic of “Evolving Risk-Based Regulatory Requirements” for a whole day workshop put on by RAPS (SF Bay Area Chapter) & ASQ (Biomedical Division Northern CA Discussion Group).  Leo will be presenting on the 3rd ed. of IEC 60601-1, the series of standards, and also the impact of change on the medical device industry.  Other topics will include Usability & Human Factors verification, validation, and regulatory requirements; and Clinical evaluation & investigation regulatory requirements. More information can be found on our blog post on this topic.

Topic: “Implications of the Electro-medical Standards IEC 60601-1-11:2010 & Proposed IEC 60601-1-12” The Medical Electrical Device Collateral Standards in the Home Healthcare Environment and the Proposed Emergency Medical Services Environment, respectively

Presenter: Leo Eisner of Eisner Safety Consultants

When: March 3, 2011 (Thursday), 8:30 – 9:30AM (Pacific), 11:30AM – 12:30PM (Eastern)

Where: At your office or conference room (No travel required)

What’s it about: Get up to speed on the latest and developing requirements for the electro-medical collateral standards for the home healthcare environment (HHE) IEC 60601-1-11:2010 and the proposed IEC 60601-1-12 standard for the emergency medical environment (EMS).  Is your company ready for the implications of these standards as you will have regulatory requirements for the HHE standard come up soon (depending on the country of concern) and it will be similar once the EMS standard is published.

In this audio conference, Leo Eisner guides you through IEC 60601-1-11:2010 with new definitions, additions and changes to the general standard. The presentation reviews the significant issues including earthing requirements and additional mechanical and environmental tests. It also compares the requirements of each standard to provide a perspective on what the EMS may look like vs. the HHE standard.

Cost & Registration: Fx Conferences registration page for this event. Cost is normally $249.00 but with the Eisner Safety Consultants special discount you pay only $199.00. When checking out use the $50.00 discount code AF2009EIS.

Our Events Listing Page has events we are presenting at and also there is a listing of industry events that may interest you.

A proposal has been circulated, on 21-JAN-2011, for a vote to form a Joint Working Group between ISO/TC 184/SC 2, Robots and robotic devices (non-medical robots) and IEC/TC 62 and its subcommittees to establish a new Joint Working Group on Safety for medical devices using robotic technology.  The following info is only part of the complete proposal.  If you have further interest please contact Leo Eisner at Leo@EisnerSafety.com.

Some Background:

Currently published international standards only cover robots in industrial environments. However, the situation is changing and new types of service robots are emerging. In light of these developments, ISO/TC 184/SC2 established a new work group (WG 7) on personal care robots. That group has been focused on formulating safety requirement for non-medical personal care robots. That group is working on a new standard, ISO 13482, Robots and robotic devices – Safety requirements – Non-medical personal care robot. This document will be advancing to the Enquiry Stage (ISO DIS) in early 2011 and publication is expected in 2012.

While initially focused on non-medical applications, WG 7 recognized early that work was likely to be needed on medical devices utilizing robotic technology. In June 2008, a liaison with IEC/SC 62A was established. Prof. John Hedley-Whyte volunteered to serve as the liaison officer. In September 2009, ISO/TC 184/SC 2 established a WG 7 study group on medical care robots. The study group is comprised of experts from Canada, France, Germany, Japan, Korea, Romania, Switzerland, UK and USA. The Secretary of SC 62A has attended two of the study group’s meetings. Members of the study group also participated in a workshop on Medical Care Robots sponsored by the US Food and Drug Administration (FDA) and the Association for the Advancement of Medical Instrumentation (AAMI) and held at FDA’s offices outside Washington D.C. in February 2010.

The WG 7 study group has concluded that the time is appropriate to initiate formal work on safety standard(s) for medical devices using robotic technology. The study group made a series of proposals to ISO/TC 184/SC 2 that resulted in the resolution in Annex A (please contact Leo Eisner if you would like a copy of this Annex). The potential for a joint project between IEC/TC 62 and its subcommittees and ISO/TC 184/SC 2 was also discussed at the IEC/TC 62 Chairman Advisory Group meeting in October 2010 in Seattle.

The Proposal:

ISO/TC 184/SC 2 is proposing the formation of a JWG with IEC/SC 62A under IEC administrative lead to develop a new work item proposal for a Collateral Standard in the IEC 60601 family. The scope of this work would be:

Establish basic safety and essential performance requirements for medical electrical equipment and systems employing robotic technology (i.e., medical robots). The work would encompass medical applications (including aids for the disabled) covering invasive and non- invasive procedures such as surgery, rehabilitation therapy, imaging and other robots for medical diagnosis and treatment.

The current working definition of a robot is an “actuated mechanism programmable in more than one axis with a degree of autonomy, moving within its environment, to perform intended tasks”. Autonomy is currently defined as the “ability to control movement and communication to perform intended tasks without human intervention”. Before a meaningful new work item proposal can be circulated, the proposed JWG will need to refine these definitions so as to establish the appropriate boundaries for this work.

While the initial work would be with SC 62A dealing with the general aspects of medical robots, close liaison will be maintained with other TC 62 subcommittees, particularly SC 62D, looking forward to the potential for work on standards for particular medical robot applications.

If approved, it is expected that the experts currently serving on the study group would be transferred to the JWG and a New Call for Experts issued in IEC/SC 62A and ISO/TC 184/SC2.

National Committees are requested to provide their responses using the IEC electronic voting system by: 2011-04-22

So, if you would like to have some input to your National Committee you will need to contact them soon as national votes tend to be called for at least 1 month prior to the official deadline for the National Committees.

Please feel free to contact us on this matter if you would like some assistance in learning more about this proposed standard as it applies to your products.

Leo@EisnerSafety.com 
503-244-6151 (USA)