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- Risk management: ISO 14971, IEC 31010, FMEA, FTA, HAZOP
Risk management: ISO 14971, IEC 31010, FMEA, FTA, HAZOP
A certifier rarely asks for "an FMEA". It asks for a risk management process, defined by a process standard (ISO 14971 for medical devices, ISO 26262 for road vehicles, ISO 12100 for machinery, ARP4761A for aircraft systems), fed by analysis techniques documented in their own IEC method standards (IEC 60812 for FMEA, IEC 61025 for FTA, IEC 61882 for HAZOP) and chosen with the help of the IEC 31010 catalogue. This guide reads ISO 14971:2019 clause by clause against Annex I of the EU MDR, counts what IEC 31010:2019 actually contains, checks the editions and dates of every standard cited, and lists the claims the texts contradict, including several that this page used to make.
Standards map
Section titled “Standards map”Editions checked against the IEC online catalogue, the Official Journal, eCFR and the publishers on October 7, 2026.
| Layer | Standard | Edition and date | Scope |
|---|---|---|---|
| Process, medical | ISO 14971:2019 | Third edition, December 2019 | Risk management process for medical devices, whole lifecycle |
| EU harmonised version | EN ISO 14971:2019 + EN ISO 14971:2019/A11:2021 | Listed for the MDR by Decision (EU) 2022/757 | European amendment adapting the standard to the MDR and IVDR requirements |
| Process guidance, medical | ISO/TR 24971:2020 | Technical report, 2020 | Guidance on applying ISO 14971 |
| Process, generic | ISO 31000:2018 | 2018 | Generic risk management principles and process |
| Techniques catalogue | IEC 31010:2019 | Edition 2.0, June 13, 2019, double logo with ISO | 42 techniques described in Annex B, replaces the 2009 edition |
| FMEA, FMECA | IEC 60812:2018 | Edition 3.0, August 10, 2018 | FMEA planning, execution, documentation, replaces the 2006 edition |
| FTA | IEC 61025:2006 | Edition 2.0, December 13, 2006, stability date 2029 | Fault tree analysis, deductive |
| ETA | IEC 62502:2010 | 2010 | Event tree analysis, inductive |
| HAZOP | IEC 61882:2016 | Edition 2.0, March 10, 2016 | Guide word driven risk identification, replaces the 2001 edition |
| Automotive functional safety | ISO 26262:2018 | Second edition | HARA, ASIL, safety lifecycle |
| Automotive SOTIF | ISO 21448:2022 | 2022 | Safety of the intended functionality |
| Automotive cybersecurity | ISO/SAE 21434:2021 | 2021 | TARA for road vehicles |
| Aviation | SAE ARP4761A (EUROCAE ED-135) | December 2023, supersedes ARP4761 of 1996 | AFHA, PASA, SFHA, PSSA, SSA, ASA and the analysis methods |
| Machinery | ISO 12100:2010, ISO 13849-1:2023, IEC 62061:2021 | Risk assessment and risk reduction, safety functions | |
| OT cybersecurity | IEC 62443-3-2 | Security risk assessment, zones and conduits | |
| Automotive FMEA | AIAG and VDA FMEA Handbook | June 2019 | 7-step approach, Action Priority, FMEA-MSR |
An electronics or embedded software project picks one process spine per target market, then picks techniques. The method standards (60812, 61025, 61882) tell you how to perform and document a technique; they do not tell you what risk is acceptable for your product. That comes from the process standard and the sector rules.
Dated changes, 2019 to 2027
Section titled “Dated changes, 2019 to 2027”| Date | Event | Source |
|---|---|---|
| June 13, 2019 | IEC 31010:2019 edition 2.0 published, replacing the 2009 edition and increasing the number of techniques | IEC catalogue |
| June 2019 | AIAG and VDA FMEA Handbook released, Action Priority replaces RPN | AIAG |
| December 2019 | ISO 14971:2019 third edition published | ISO |
| December 23, 2019 | FDA recognizes ISO 14971:2019 in full (recognition number 5-125) | FDA recognized standards database |
| 2020 | ISO/TR 24971:2020 published as companion guidance | ISO |
| 2021 | EN ISO 14971:2019/A11:2021 adopted by CEN and CENELEC | Decision (EU) 2022/757, recital 4 |
| May 11, 2022 | Decision (EU) 2022/757 adds EN ISO 14971:2019 and A11:2021 as entry 16 of the MDR list (OJ L 138, May 17, 2022); Decision (EU) 2022/729 does the same for the IVDR list (OJ L 135, May 12, 2022) | Official Journal |
| January 18, 2023 | ICH Q9(R1) on quality risk management reaches Step 4 | ICH |
| December 2023 | SAE ARP4761A published, superseding ARP4761 (1996) | SAE |
| February 2, 2024 | FDA publishes the QMSR final rule (89 FR 7496) | Federal Register |
| August 30, 2024 | FAA issues AC 25.1309-1B, System Design and Analysis | FAA |
| February 2, 2026 | QMSR takes effect: 21 CFR Part 820 incorporates ISO 13485:2016 by reference | Federal Register, eCFR |
| January 20, 2027 | Machinery Regulation (EU) 2023/1230 applies and Directive 2006/42/EC is repealed | Official Journal |
ISO 14971 in practice
Section titled “ISO 14971 in practice”ISO 14971:2019 is a process standard. It does not tell you which hazards your device has or which matrix to use; it tells you what the process must contain and what must be recorded in the risk management file. In the EU, the MDR sets the legal requirement directly: Article 10(2) obliges every manufacturer to "establish, document, implement and maintain a system for risk management as described in Section 3 of Annex I". The harmonised EN version of ISO 14971 gives a presumption of conformity under Article 8 for the requirements it covers.
Clause by clause, against MDR Annex I
Section titled “Clause by clause, against MDR Annex I”| ISO 14971:2019 clause | What it requires | Matching MDR Annex I text |
|---|---|---|
| 4.1 Risk management process | A documented process covering the whole lifecycle | Section 3: "a continuous iterative process throughout the entire lifecycle" |
| 4.2 Management responsibilities | Top management defines and documents a policy for establishing criteria for risk acceptability | Section 1: risks acceptable "when weighed against the benefits", "taking into account the generally acknowledged state of the art" |
| 4.4 Risk management plan | One plan per device, with acceptability criteria and verification activities | Section 3(a): "establish and document a risk management plan for each device" |
| 4.5 Risk management file | Traceability for each identified hazard | Annex II technical documentation |
| 5 Risk analysis | Intended use, reasonably foreseeable misuse, characteristics related to safety, hazards and hazardous situations, risk estimation | Section 3(b) and 3(c) |
| 6 Risk evaluation | Compare each estimated risk with the criteria of the plan | Section 3(c) |
| 7.1 Risk control option analysis | Priority order: inherently safe design and manufacture, then protective measures, then information for safety | Section 4: safe design and manufacture, then protection measures "including alarms if necessary", then information for safety and, where appropriate, training |
| 7.3 Residual risk evaluation | Each residual risk evaluated against the criteria | Section 4: "the residual risk associated with each hazard ... is judged acceptable" |
| 7.4 Benefit-risk analysis | Only when a residual risk is not acceptable and further control is not practicable | Sections 1 and 8 |
| 7.5, 7.6 | Risks arising from risk control measures, completeness of risk control | Section 4 |
| 8 Evaluation of overall residual risk | All residual risks taken together, against the benefits of the intended use | Section 4: "as well as the overall residual risk is judged acceptable" |
| 9 Risk management review | Before commercial distribution, review that the plan was implemented; record the results as the risk management report | Annex II technical documentation |
| 10 Production and post-production activities | Collect and review production and post-production information and act on it | Section 3(e) and 3(f), post-market surveillance (Annex III) |
Acceptability criteria and "as far as possible"
Section titled “Acceptability criteria and "as far as possible"”ISO 14971:2019 leaves the acceptability criteria to the manufacturer, under a policy set by top management. Many manufacturers express them as a consequence and likelihood matrix (IEC 31010:2019 describes this technique in B.10.3, and ALARP and SFAIRP in B.8.2). For the EU, check the policy against MDR Annex I Section 2: "reduce risks as far as possible means the reduction of risks as far as possible without adversely affecting the benefit-risk ratio". A matrix that stops risk reduction because a risk is "low enough" or because further reduction is costly does not read the same way as that sentence. CEN and CENELEC adopted the European amendment A11:2021 to adapt EN ISO 14971:2019 to the requirements of the MDR (Decision (EU) 2022/757, recital 4). Section 4 also requires manufacturers to "inform users of any residual risks".
Benefit-risk, individual and overall
Section titled “Benefit-risk, individual and overall”Clause 7.4 is not a step that every residual risk goes through. It is the route for a residual risk that fails the plan criteria when further risk control is not practicable: the manufacturer may then gather data and literature to decide whether the benefits of the intended use outweigh it. Clause 8 is mandatory: the overall residual risk is evaluated with all residual risks together, against the benefits. ISO/TR 24971:2020 is the companion guidance for these steps.
IEC 31010, the techniques catalogue
Section titled “IEC 31010, the techniques catalogue”IEC 31010:2019 is guidance, not a requirements standard. It covers planning, applying and reviewing a risk assessment (clause 6), selecting techniques (clause 7, with a characterisation table in Annex A) and, in Annex B, a summary of each technique with references to the documents that describe it in detail. It was prepared by IEC technical committee 56 (Dependability) with ISO/TC 262 (Risk management).
What Annex B contains
Section titled “What Annex B contains”| Annex B group | Techniques described | Count |
|---|---|---|
| B.1 Eliciting views from stakeholders and experts | Brainstorming, Delphi, nominal group technique, structured or semi-structured interviews, surveys | 5 |
| B.2 Identifying risk | Checklists and taxonomies, FMEA and FMECA, HAZOP, scenario analysis, SWIFT | 5 |
| B.3 Sources, causes and drivers of risk | Cindynic approach, Ishikawa (cause and effect diagram) | 2 |
| B.4 Analysing controls | Bow tie, HACCP, LOPA | 3 |
| B.5 Consequences and likelihood | Bayesian analysis, Bayesian networks and influence diagrams, business impact analysis, cause-consequence analysis, ETA, FTA, human reliability analysis, Markov analysis, Monte Carlo simulation, privacy impact analysis (DPIA) | 10 |
| B.6 Dependencies and interactions | Causal mapping, cross impact analysis | 2 |
| B.7 Measures of risk | Toxicological risk assessment, value at risk, conditional value at risk | 3 |
| B.8 Evaluating significance of risk | ALARP and SFAIRP, F-N diagrams, Pareto charts, reliability centred maintenance, risk indices | 5 |
| B.9 Selecting between options | Cost/benefit analysis, decision tree analysis, game theory, multi-criteria analysis | 4 |
| B.10 Recording and reporting | Risk registers, consequence/likelihood matrix, S-curves | 3 |
| Total | 42 |
Two consequences for a dossier. First, the risk matrix and ALARP are techniques in this catalogue, not requirements of ISO 14971. Second, STPA is not among the 42, so a dossier using it should cite its own reference.
Selection logic
Section titled “Selection logic”The right technique is the one that fits the question, the data available and the maturity of the design. In practice: brainstorming, checklists and SWIFT in concept phase; FMEA when the architecture or the process steps exist; FTA on the most severe top events once the design is detailed; HAZOP when design intent and sequences are defined; Bayesian or Markov models when dependencies and repair matter.
FMEA and FMECA
Section titled “FMEA and FMECA”IEC 60812:2018 (edition 3.0) applies to hardware, software, processes including human action, and their interfaces. Its foreword lists what changed from the 2006 edition: generic normative text; informative examples for safety, automotive, software and service processes; tailoring; reporting formats including a database information system; alternative ways of calculating risk priority numbers; a criticality matrix method; and the relationship with other dependability methods. When failure modes are prioritised, the analysis is called FMECA, and the prioritisation "can be based on a ranking of the severity alone".
Variants
Section titled “Variants”| Variant | Scope | Typical use |
|---|---|---|
| System FMEA | Functions, architecture, interfaces | Concept and architecture phase |
| Design FMEA | Components, sub-assemblies, design choices | Detailed design, board level |
| Process FMEA | Manufacturing and assembly steps | Industrialisation, production |
| FMEA-MSR | Monitoring and system response | Automotive, AIAG and VDA handbook |
| Software FMEA | Software functions and their failure modes | Embedded software, alongside other analyses |
RPN versus Action Priority
Section titled “RPN versus Action Priority”The classic risk priority number is RPN = Severity x Occurrence x Detection. Its known weakness is that different triplets give the same number and that a good detection score can lower the rank of a severe failure mode. The AIAG and VDA FMEA Handbook (June 2019) answered this by replacing RPN with Action Priority tables. IEC 60812:2018 took another route: it keeps RPN, adds alternative calculations and a criticality matrix, and lets the analyst rank on severity alone. Choose one method per project, write it in the plan, and keep the severity scale identical across all worksheets.
Frequent errors
Section titled “Frequent errors”- Severity scale changing between worksheets, so priorities cannot be compared across the dossier,
- Detection credited for tests that have not been performed,
- Occurrence estimated without looking at field returns of similar products,
- FMEA started after design freeze, too late to influence choices,
- Actions not traced to a design change and to verification evidence.
FTA, ETA and cut sets
Section titled “FTA, ETA and cut sets”Fault tree analysis (IEC 61025:2006, edition 2.0, which replaced the 1990 edition and added the quantitative and reliability aspects) is deductive: from a top event, the analyst decomposes causes through logic gates down to basic events. Event tree analysis (IEC 62502:2010) is inductive: from an initiating event, it follows the branches of success or failure of each barrier.
FTA in practice
Section titled “FTA in practice”FTA identifies the minimal cut sets, the smallest combinations of basic events that produce the top event. A cut set of size one is a single point of failure. With basic-event probabilities, FTA quantifies the top event, which is how aircraft system safety assessments show compliance with numerical objectives. FAA AC 25.1309-1B (August 30, 2024) gives the commonly accepted ranges, per flight hour:
| Failure condition | Required probability | Range in AC 25.1309-1B |
|---|---|---|
| No safety effect | No probability requirement | |
| Minor | May be probable | Probable: on the order of 1 x 10⁻³ or less, but greater than on the order of 1 x 10⁻⁵ |
| Major | No more frequent than remote | On the order of 1 x 10⁻⁵ or less |
| Hazardous | No more frequent than extremely remote | On the order of 1 x 10⁻⁷ or less |
| Catastrophic | Extremely improbable | On the order of 1 x 10⁻⁹ or less |
The AC states that meeting these numbers "provides some, but not necessarily sufficient, evidence" of compliance. The safety assessment process itself is described in SAE ARP4761A (December 2023), which splits the old single FHA into aircraft and system level assessments and lists FTA, dependence diagrams, Markov analysis, FMEA and FMES, zonal safety analysis, particular risk analysis and common mode analysis among its methods.
Frequent errors
Section titled “Frequent errors”- Basic events missing, which makes the top-event probability optimistic,
- Independence assumed between events that share a cause (power supply, software module, sensor),
- Failure rates unsourced, taken from a reliability handbook without saying which one and why,
- Tree not updated when the design or the component selection changes.
HAZOP and structured what-if
Section titled “HAZOP and structured what-if”IEC 61882:2016 calls HAZOP "guide word-driven risk identification". Its introduction notes that the technique originated in the process industries and that the standard gives guidance across many industries; its worked examples include an automatic train protection system, a piezo valve control system and a procedural HAZOP for a train stabling yard horn procedure. The 2016 edition aligned its terminology with ISO 31000:2009 and ISO Guide 73:2009 and added an improved procedural HAZOP case study.
Method
Section titled “Method”The system is divided into parts. For each part the team states the design intent, then applies guide words: NO or NOT, MORE, LESS, AS WELL AS, PART OF, REVERSE, OTHER THAN, and for time and sequence guide words such as EARLY, LATE, BEFORE and AFTER. Each meaningful deviation is examined for causes, consequences, existing protection and actions. The standard stresses the examination session, in which "a multi-disciplinary team under the guidance of a study leader systematically examines all relevant parts of a design or system". It also rejects using the name HAZOP for checklist-based variants.
Frequent errors
Section titled “Frequent errors”- Parts too coarse, which hides intermediate deviations,
- Design intent not written for each part, so the guide words have nothing to apply to,
- One engineer instead of a team, which removes what the method relies on,
- No traceability from HAZOP actions to design changes or verification.
STAMP and STPA
Section titled “STAMP and STPA”STAMP (System-Theoretic Accident Model and Processes), developed by Nancy Leveson at MIT, treats accidents as the result of inadequate control rather than chains of component failures. Its hazard analysis method, STPA, is described in the STPA Handbook (Leveson and Thomas, March 2018): define the purpose of the analysis, model the control structure, identify unsafe control actions, then identify loss scenarios. The handbook lists four ways a control action can be unsafe: not providing it leads to a hazard; providing it leads to a hazard; providing it too early, too late or in the wrong order; and, for continuous actions, applying it too long or stopping it too soon.
STPA is useful where software and interactions drive the risk, for example in industrial robotics, ISO 10218 and 15066. It complements FMEA and FTA rather than replacing them.
Sector overlays
Section titled “Sector overlays”| Sector | Risk approach | Key references |
|---|---|---|
| Medical | ISO 14971 process within an ISO 13485 QMS | MDR Annex I, IVDR Annex I, 21 CFR Part 820 (QMSR), ISO 14971 |
| Automotive functional safety | HARA, ASIL determination | ISO 26262, ISO 21448 |
| Automotive cybersecurity | TARA | ISO/SAE 21434, UN R155, R156 |
| Aviation | AFHA, SFHA, PSSA, SSA, common cause analyses | ARP4761A, ARP4754, AC 25.1309-1B, DO-178C and DO-254 |
| Machinery | Risk assessment and risk reduction, PL or SIL for safety functions | ISO 12100, ISO 13849-1 and IEC 62061, Directive 2006/42/EC and Regulation 2023/1230 |
| Process and E/E/PE systems | LOPA, SIL determination | IEC 61511, IEC 61508 |
| Industrial cybersecurity | Zones and conduits, security risk assessment | IEC 62443-3-2 |
| Pharmaceutical quality | Quality risk management | ICH Q9(R1) |
Each sector defines its own integrity or acceptability scale (ASIL, DAL, PL, SIL, or the manufacturer criteria under ISO 14971). A product sold into several sectors can share the same FMEA and FTA backbone, but the acceptability argument has to be written separately for each process standard.
Documentation chain
Section titled “Documentation chain”A complete risk file establishes traceability from hazard to verification:
- Hazards and hazardous situations (intended use, reasonably foreseeable misuse, electrical, mechanical, thermal, software, cybersecurity, biological where relevant),
- Risk estimation for each hazardous situation,
- Risk control measures, allocated to design requirements, in the priority order of the process standard,
- Verification of implementation and effectiveness of each control measure (test, analysis, inspection),
- Residual risk evaluation for each hazard,
- Overall residual risk evaluation, with benefit-risk where the process standard requires it,
- Risk management report recording the review of the plan,
- Production and post-production information fed back into the file at each review.
Each link should reference the next by document number and version, so an auditor can follow a hazard from identification to the verification evidence and to the field data that confirm or contradict the estimate.
Integration into the certification dossier
Section titled “Integration into the certification dossier”The risk file sits next to design controls, verification and validation, manufacturing and post-market surveillance. See QMS overview (ISO 9001, AS 9100, ISO 13485, TL 9000), laboratory and measurement safety, IEC 61010 and, for connected products, the Cyber Resilience Act (CRA), whose reporting obligations apply from September 11, 2026 and full application from December 11, 2027.
A common pattern in a medical device file: ISO 14971 plan and report at the top, a design FMEA on the electronics feeding the device-level analysis, FTA on the most severe top events, HAZOP or STPA on the embedded control sequences and user interaction, and a traceability matrix from each control measure to a requirement and to its verification evidence.
Claims the texts contradict
Section titled “Claims the texts contradict”| Claim | What the text says |
|---|---|
| "ISO 14971 is harmonised under the MDR since Decision 2021/1182." | The July 2021 list did not contain it. EN ISO 14971:2019 with A11:2021 was added as entry 16 by Decision (EU) 2022/757 of May 11, 2022. |
| "ISO 14971 underpins GSPR 1 to 4." | Risk management runs through Sections 1 to 5 and 8 of MDR Annex I: Section 2 defines "as far as possible", Section 3 the risk management system, Section 4 the control priority, Section 5 use error, Section 8 side effects. |
| "Each residual risk undergoes a benefit-risk analysis, in the ALARP zone." | ISO 14971:2019 clause 7.4 applies when a residual risk is not acceptable and further control is not practicable. ALARP is a technique described in IEC 31010:2019 B.8.2, not a zone defined by ISO 14971, and MDR Annex I Section 2 uses "as far as possible". |
| "The risk management report must be signed by top management, otherwise it is a formal nonconformity." | Clause 4.2 gives top management the acceptability policy. Clause 9 requires a review before commercial distribution, documented as the risk management report. No signature by top management is required by that clause. |
| "The QMSR replaced Part 820 and references ISO 14971." | The QMSR amends 21 CFR Part 820 and incorporates ISO 13485:2016 and clause 3 of ISO 9000:2015. ISO 14971 is not incorporated; it is an FDA recognized consensus standard (5-125). |
| "IEC 31010 catalogues some thirty techniques, including STAMP/STPA." | Annex B of IEC 31010:2019 describes 42 techniques in ten groups. STPA is not one of them. |
| "IEC 61882:2016 documents a software extension of HAZOP used in EN 50128." | The standard is a generic application guide whose 2016 changes were terminology alignment and a procedural HAZOP case study. Its examples include control systems, but it does not define a software HAZOP. |
| "ARP4761 (1996); minor failure conditions 1E-3 per flight hour." | ARP4761A superseded it in December 2023. AC 25.1309-1B says minor failure conditions may be probable and sets no numerical objective for them. |
| "The AIAG and VDA handbook replaces SAE J1739 and VDA 4." | AIAG describes it as harmonising the AIAG 4th edition FMEA manual and VDA Volume 4. |
| "Pharma and radioactive: ICH Q9." | ICH Q9 is a pharmaceutical quality guideline, revised as ICH Q9(R1), Step 4 on January 18, 2023. |
Frequent pitfalls
Section titled “Frequent pitfalls”| Pitfall | Consequence |
|---|---|
| Risk file produced once and not updated with production and post-production information | Estimates no longer match field data, against ISO 14971 clause 10 and MDR Annex I Section 3(e) |
| Acceptability criteria copied from another company or sector | Criteria not tied to the manufacturer policy required by clause 4.2 |
| Matrix policy that stops reducing a risk once it is "acceptable" | Gap against "as far as possible" in MDR Annex I Section 2 |
| FMEA with no link to design controls | The reviewer cannot follow a control measure to its verification |
| FTA with missing basic events or false independence | Top-event probability optimistic, common cause not mitigated |
| RPN letting a good detection score hide a severe failure mode | Severe risk insufficiently controlled |
| HAZOP by one person, or with parts too coarse | Deviations missed |
| Failure rates without a stated source | Quantitative result hard to defend |
| Individual residual risks never evaluated together | Clause 8 overall residual risk evaluation missing |
Going further
Section titled “Going further”- Industrial robotics, ISO 10218 and 15066: risk assessment for robot cells and collaborative operation
- Laboratory and measurement safety, IEC 61010: risk analysis for measurement and laboratory equipment
- QMS overview (ISO 9001, AS 9100, ISO 13485, TL 9000): quality system within which the risk file is maintained
- Cyber Resilience Act (CRA): cybersecurity risk assessment under the EU CRA
- Glossary: definitions of FMEA, FMECA, FTA, ETA, HAZOP, STPA, ASIL, DAL, SIL, PL, ALARP, GSPR
See also
Section titled “See also”- MDR: the EU Medical Device Regulation (2017/745)
- MDR class IIb and III: UDI, EUDAMED, NB, surveillance
- IVDR (EU) 2017/746: in vitro diagnostic medical devices
- FDA 510(k), De Novo and PMA: US medical devices
- ISO 26262: automotive functional safety
- IEC 61508: functional safety and SIL
Sources & references
- ISO 14971:2019, Medical devices, Application of risk management to medical devices, ISO www.iso.org/standard/72704.html
- ISO/TR 24971:2020, Guidance on the application of ISO 14971, ISO www.iso.org/standard/74437.html
- Commission Implementing Decision (EU) 2022/757 amending Decision (EU) 2021/1182 (EN ISO 14971:2019/A11:2021 added for the MDR), European Commission eur-lex.europa.eu/eli/dec_impl/2022/757/oj
- Commission Implementing Decision (EU) 2022/729 amending Decision (EU) 2021/1195 (IVDR), European Commission eur-lex.europa.eu/eli/dec_impl/2022/729/oj
- Regulation (EU) 2017/745 on medical devices, Article 10 and Annex I, EUR-Lex eur-lex.europa.eu/eli/reg/2017/745/oj
- 21 CFR Part 820, Quality Management System Regulation, eCFR www.ecfr.gov/current/title-21/chapter-I/subchapter-H/part-820
- Medical Devices; Quality System Regulation Amendments, final rule (89 FR 7496), Federal Register www.federalregister.gov/documents/2024/02/02/2024-01709/medical-devices-quality-system-regulation-amendments
- FDA recognized consensus standard 5-125, ISO 14971:2019, US FDA www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfStandards/detail.cfm?standard__identification_no=41349
- IEC 31010:2019, Risk management, Risk assessment techniques, IEC webstore.iec.ch/en/publication/59809
- IEC 60812:2018, Failure modes and effects analysis (FMEA and FMECA), IEC webstore.iec.ch/publication/26359
- IEC 61025:2006, Fault tree analysis (FTA), IEC webstore.iec.ch/publication/4311
- IEC 61882:2016, Hazard and operability studies (HAZOP studies), Application guide, IEC webstore.iec.ch/publication/24321
- New AIAG and VDA FMEA Handbook (June 2019), Action Priority replaces RPN, AIAG blog.aiag.org/new-aiag-vda-fmea-handbook-and-trainings-available
- STPA Handbook, Leveson and Thomas, March 2018, MIT Partnership for Systems Approaches to Safety and Security psas.scripts.mit.edu/home/get_file.php?name=STPA_handbook.pdf
- AC 25.1309-1B, System Design and Analysis (August 30, 2024), US FAA www.faa.gov/documentLibrary/media/Advisory_Circular/AC_25.1309-1B.pdf
- ARP4761A, Guidelines for Conducting the Safety Assessment Process on Civil Aircraft, Systems, and Equipment, SAE International saemobilus.sae.org/standards/arp4761a-guidelines-conducting-safety-assessment-process-civil-aircraft-systems-equipment
- The ICH Q9(R1) Guideline reaches Step 4 of the ICH Process, ICH ich.org/news/ich-q9r1-guideline-reaches-step-4-ich-process
Frequently asked questions
- What is the difference between ISO 14971 and IEC 31010?
- They nest. ISO 14971:2019 (third edition, December 2019) is a requirements standard for the risk management process of medical devices: plan, risk analysis, risk evaluation, risk control, evaluation of overall residual risk, risk management review, and production and post-production activities. IEC 31010:2019 (edition 2.0, June 2019, published as a double logo standard with ISO) is guidance on selecting and applying risk assessment techniques: its Annex B describes 42 techniques in ten groups, from brainstorming to Monte Carlo simulation. A medical project uses ISO 14971 as the process and picks FMEA, FTA or HAZOP to feed its risk analysis.
- Is ISO 14971 harmonised under the EU MDR?
- Yes, as EN ISO 14971:2019 together with its European amendment EN ISO 14971:2019/A11:2021. Commission Implementing Decision (EU) 2022/757 of May 11, 2022 added both references as entry 16 of the list in Implementing Decision (EU) 2021/1182, giving a presumption of conformity under Article 8 of Regulation (EU) 2017/745. The original 2021/1182 list of July 2021 did not contain it. Decision (EU) 2022/729 did the same for the IVDR list.
- Is FMEA enough for a certification dossier?
- Rarely on its own. IEC 60812:2018 describes FMEA as a method for identifying how items or processes fail and the effects of those failures, and states that, as a generic standard, it does not specifically address safety. FMEA looks at failure modes one by one, so combinations of failures are normally covered by a deductive analysis such as FTA, and deviations from design intent or procedures by HAZOP or STPA. Sector texts such as FAA AC 25.1309-1B and SAE ARP4761A list FMEA next to FTA, dependence diagrams, Markov analysis and common cause analyses.
- Should we still use RPN or move to Action Priority?
- It depends on the reference you are held to. The AIAG and VDA FMEA Handbook, released in June 2019 to harmonise the AIAG 4th edition FMEA manual and VDA Volume 4, replaced RPN with Action Priority (AP) tables. IEC 60812:2018 keeps the risk priority number, adds alternative ways of calculating it, and adds a criticality matrix method; it also allows prioritisation on severity alone. Automotive suppliers working to the AIAG and VDA handbook use AP; other sectors choose and justify their criticality method.
- How are residual risks evaluated under ISO 14971?
- In three places. Clause 7.3 evaluates each residual risk after risk control against the acceptability criteria of the plan. If a residual risk is not acceptable and further risk control is not practicable, clause 7.4 allows the manufacturer to gather data and literature to decide whether the benefits of the intended use outweigh it. Clause 8 then evaluates the overall residual risk, taking into account all residual risks, against the benefits. Under the MDR, Annex I Section 4 requires the residual risk of each hazard and the overall residual risk to be judged acceptable, and Section 2 requires risks to be reduced as far as possible without adversely affecting the benefit-risk ratio.
- When should HAZOP be used rather than FMEA?
- IEC 61882:2016 describes HAZOP as guide word driven risk identification: a multidisciplinary team under a study leader examines each part of a design against its design intent using guide words such as NO, MORE, LESS, AS WELL AS, PART OF, REVERSE and OTHER THAN, plus guide words for time and sequence. It needs a fairly detailed design and suits processes, procedures and control sequences. FMEA starts from component or process step failure modes. On a programmable device the two are complementary.
- Does the FDA QMSR require ISO 14971?
- Not by name. The Quality Management System Regulation (final rule published February 2, 2024, effective February 2, 2026) amends 21 CFR Part 820 and incorporates by reference ISO 13485:2016 and clause 3 of ISO 9000:2015. ISO 14971 is not incorporated in Part 820. FDA lists ISO 14971:2019 as a recognized consensus standard (recognition number 5-125, complete recognition, entered December 23, 2019), so it can be used in premarket submissions, and ISO 13485 itself requires risk management in product realisation.
- What is STPA and is it in IEC 31010?
- STPA (System-Theoretic Process Analysis) is the hazard analysis method built on the STAMP accident model by Nancy Leveson at MIT. The STPA Handbook of March 2018 (Leveson and Thomas) defines four ways a control action can be unsafe: not provided, provided when unsafe, provided too early, too late or in the wrong order, and stopped too soon or applied too long. STPA is not one of the 42 techniques described in Annex B of IEC 31010:2019, so cite the handbook, not IEC 31010, when you use it.