Beyond FDA Compliance Webinar: 5 Hidden Benefits of Your Traceability Matrix
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Transcript of Beyond FDA Compliance Webinar: 5 Hidden Benefits of Your Traceability Matrix
Beyond FDA Compliance: 5 Hidden Benefits of Your Trace
Matrix
Slide 1Copyright © 2013 Software Quality Consulting Inc.
sponsored by
Speaker Bios
Steven R. Rakitin
President, Software Quality Consulting
Slide 2Copyright © 2013 Software Quality Consulting Inc.
Michael C. Sieve
Life Sciences Solution Engineer, Seapine Software
• 10 years experience in compliance industries, including life sciences, government, utilities, and aviation.
• Certified Master Black Belt in Lean Six Sigma, Software Validation, Risk Management, and Negotiation. Well versed in the General Principles of Software Validation and Part 11 Compliance.
• 35 years experience as a software engineer and software quality manager.
• Senior member of the IEEE Computer Society, ASQ Software Division, ASQ Biomedical Division, and the Association for the Advancement of Medical Instrumentation (AAMI).
• Helped write the first IEEE Software Engineering Standard (IEEE-STD-730 Standard for Software Quality Assurance Plans) and is currently a committee member working on revisions to both IEEE Standard 1012 (Software Verification & Validation) and 730 (Software Quality Assurance).
Topics
• Regulatory Requirements for Traceability
• Traceability Basics
• Requirements Trace Matrix (RTM) Benefits
• RTM Tool Validation
• References
Slide 3Copyright © 2013 Software Quality Consulting Inc.
Regulatory Basis for Traceability
• General Principles of Software Validation Guidance
– Software requirements traceability analysis should be conducted to trace software requirements to (and from) system requirements and to risk analysis results.
– Traceability analysis should be conducted to verify that software design implements all of the software requirements.
– As a technique for identifying where requirements are not sufficient, the traceability analysis should also verify that all aspects of the design are traceable to software requirements.
Slide 4Copyright © 2013 Software Quality Consulting Inc.
General Principles of Software Validation, FDA, Final Guidance, January 2002
Regulatory Requirements for Traceability
• General Principles of Software Validation Guidance
Source code traceability analysis is an important tool to verify that all code is linked to established specifications and established test procedures.
Source code traceability analysis should be conducted to verify that:
– Every element of software design descriptions (SDD) has been
implemented
– Source code traces back to elements in SDD and to risk analysis
– Tests trace to elements in SDD and to risk analysis
– Tests trace to source code
Slide 5Copyright © 2013 Software Quality Consulting Inc.
General Principles of Software Validation, FDA, Final Guidance, January 2002
Regulatory Requirements for Traceability
• Guidance for Pre-market Submissions Containing Software
– Traceability Analysis links together product design requirements, design specifications, and testing requirements.
– Also provides a means of tying together identified hazards with implementation and testing of mitigations.
– Traceability Analysis commonly consists of a matrix with line columns for requirements, specifications and tests, and pointers to hazard mitigations.
– Submit for review explicit traceability among these activities and associated documentation as they are essential to effective product development and to reviewer’s understanding of product design, development and testing, and hazard mitigations.
Slide 6Copyright © 2013 Software Quality Consulting Inc.
Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices, May 11, 2005
Traceability Basics
Slide 7Copyright © 2013 Software Quality Consulting Inc.
• Forward Traceability
– Trace requirements from User Needs and System Specification through software requirements, design, test, and hazard documents to ensure medical device addresses needs of clinicians and patients.
– Benefits include ensuring all requirements are implemented in design and code and that all requirements are covered by tests.
Traceability Basics
Slide 8Copyright © 2013 Software Quality Consulting Inc.
• Backwards Traceability
– Trace each unique work product (e.g., design element, object/class, source code unit, test, etc.) back to its associated requirement source(s).
– Backward traceability verifies that: • Design and implementation match
specifications and intent
• Requirements are current with changes to design, hazard analysis, source code, bug fixes, and tests.
Traceability Basics
• Typical Requirements Trace Matrix (RTM)
• Connection to issue management…
Slide 9Copyright © 2013 Software Quality Consulting Inc.
RTM Benefits
• Provides a tool for estimating tests…
• Provides evidence all requirements are implemented…
• Provides evidence all requirements have been tested…
• Provides visibility for managing changes throughout product development…
• Provides evidence hazard mitigations are implemented and validated for effectiveness…
Slide 10Copyright © 2013 Software Quality Consulting Inc.
RTM as a tool to Estimate Tests
• Use RTM early to estimate tests needed…
Slide 11Copyright © 2013 Software Quality Consulting Inc.
Provides Evidence Requirements Implemented
Slide 12Copyright © 2013 Software Quality Consulting Inc.
• Every SRS requirement maps to an SDD and to source code
Provides Evidence Requirements Tested
• Tests mapped to source code and requirements…
Slide 13Copyright © 2013 Software Quality Consulting Inc.
Provides Visibility for Managing Change
• Impact of change can be easily assessed…
• During development, use active links…
Slide 14Copyright © 2013 Software Quality Consulting Inc.
Provides Evidence Mitigations Implemented
Slide 15Copyright © 2013 Software Quality Consulting Inc.
HardwareFailure
OperatorError
InterfaceError
MemoryLeak Algorithm
errorUses
generictest strip
Doesn’t recognize
units
ExternalFactors
Thermistorfails
R14Shorts
SoftwareFailure
OROROR
Patient becomes hypoglycemic
OR
Incorrect Glucose ResultResult Delayed No Result
Provides Evidence Mitigations Implemented
Slide 16Copyright © 2013 Software Quality Consulting Inc.
Failure Modes and Effect Criticality Analysis (FMECA)
Harm: Patient Becomes Hypoglycemic Hazard: Incorrect Glucose Result
Provides Evidence Mitigations Implemented
• Mitigations reflected in the design…
• Active links: specs mitigations in Risk Tables…
Slide 17Copyright © 2013 Software Quality Consulting Inc.
Seapine TestTrack Demonstration
Slide 18Copyright © 2013 Software Quality Consulting Inc.
Documentation
Documentation Implementation
Documentation Implementation Testing
Documentation Implementation TestingIssue
Management
RTM Tool Validation
• All software tools are subject to requirement for software validation, but validation approach used for each application can vary widely.
• Risk-based approach is widely used
AAMI TIR 36:2007 provides guidance on validation of software tools…
Slide 54Copyright © 2013 Software Quality Consulting Inc.
Risk Category
Tool Description Some examples
High Tool output directly affects embedded software structure, supplies data or constants used in device, or affects configuration…
Memory (EPROM or Flash) programming tools, calculation tools (spreadsheets, etc.),
Moderate Tools that support Design Controls and the Quality System
RTM, Doc control, source code control, bug tracking, complaint handling, CAPA, etc.
Low General purpose tools used to support the product development process
Word processing, spreadsheet, presentation
Training Available from SQC
• Software Development for Medical Device Manufacturers
• Medical Device Risk Management
• Software Verification & Validation
• Computer System Validation
• For more information, please visit www.swqual.com
Slide 55Copyright © 2013 Software Quality Consulting Inc.
Thank you!
Slide 56
If you have questions, please call or e-mail...
Copyright © 2013 Software Quality Consulting Inc.