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Developers need to consider the ‘human factor’ when it comes to testing medical device software.
April 1, 2020
By: Bruce Johnston
Safety is one of the most important issues to consider for medical device software development. The user experience with such devices plays a significant role in determining whether they can be used correctly and safely both today and in the future. Adding the consideration of the usability of a product and the risks its use may pose during medical software development ultimately enables OEMs to offer safe, innovative new devices that will consistently perform as intended. Software has the power to improve a patient’s quality of life and drive better outcomes. But design problems with medical software products and devices contribute to thousands of injuries and deaths each year. Software design failures stemming from inadequate development practices, poor designs, coding errors, and cybersecurity vulnerabilities are the leading cause of medical device recalls. Many of these problems are set in place before the first line of code is even written and could be prevented by the application of well-known software development best practices. Human Factors and Usability for Medical Software The regulation of medical software can be used as a means to get software developers to think about their project and how that project is going to be put together to achieve its goals through the application of software development best practices. One example of this is the guidance from the FDA concerning the usability of medical software. Software development tends to focus on what the software should do. How an operator will get the software to do what it should do is often a secondary consideration. With this guidance, the FDA is asking software developers to think about how their software will be used by people for which it is intended. Under this guidance, mistakes made by operators using a software (use errors) are considered to be a problem with the software, not with the user. Focus on Usability Despite the use of development best practices, under intense regulatory scrutiny, a significant number of medical device incidents and recalls involve a use error or other user interface issues. It’s the number of such incidents and recalls that has drawn attention to the usability of medical devices and software. Part of the problem may be that it is easy to forget how hard something is to do when you do it all day, every day. Software development teams become so familiar with their products, they don’t see the difficulties someone else may have interacting with it. Assumptions are often made, either explicitly or implicitly, about the expertise and training of the users of the software or device. Software developers may imagine well-trained operators who have memorized the user’s manual standing in front of their devices carefully entering information and reading every prompt and bit of text displayed. Reality is often very different. The device may be one of several dozen different devices from different manufacturers on a floor, half of which are beeping or have screeching alarms. An understaffed, overworked team that may be months behind on its training is dashing from device to device and has perhaps 10 to 15 seconds to interact with the device before something else demands their attention. These scenarios represent two extremes; the real world lies somewhere in between, but it is likely closer to the latter. The FDA is seeking to focus attention on these concerns with its recent guidance on usability and human factors analysis in the development of medical software. All too often “we’ll address that in the user’s manual” has become the work-around for potential usability problems. Issues seen in the field are often explained away as a mistake made by an incompetent or poorly trained user. With this latest guidance, however, use errors made by operators of a software device are considered to be a problem with the software, not with the user. The new paradigm is to design in usability, and design out use error. The main tool to assess the usability of a software device and drive the process of “designing out use error” is the human factors analysis. Manufacturers seeking FDA approval for new devices must submit evidence of systematic human factors analysis of use errors. Human Factors Analysis: What Does It Mean? Human factors analysis, in the context of medical software development, has three main goals:
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