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Testing in a Medical Device Context 
Limitations are few 
Ruud Cox, Improve Quality Services 
www.eurostarconferences.com 
@esconfs 
#esconfs
From Research to Manufacturing 
Hospital 
Market Segment 
Healthcare, Deep Brain Stimulation 
Big Organisation 
Divisions 
Manufacturer 
Research 
Law 
Regulations 
Products 
Probe 
Tools to support Surgical Procedures 
Product Prototypes 
Hospital 
Hospital 
Hospital 
New organisation 
Manufacturer
Deep Brain Stimulation 
A pacemaker for the brain
Almost no testing 
Incomplete, overdue documentation
Organise Testing 
Approach: 
(Verification & Validation) 
Exploratory Testing 
Learning, investigation, discovery 
followed by 
Scripted Testing to demonstrate that the product 
conforms to specified requirements and to provide 
objective evidence for submission. 
Conformance, Compliance
Exploratory Testing 
In the given situation, this was the best way to 
• Learn more about the product 
• Add value by providing feedback 
Charters, Debriefs, Screen Recordings, Managed 
A big success
Regulations and Testing 
Verification only 
§820.3(aa) Verification means confirmation by 
examination and provision of objective 
evidence that specified requirements have been 
fulfilled. 
Testing is one of many possible 
verification activities 
DESIGN CONTROL GUIDANCE FOR MEDICAL DEVICE MANUFACTURERS 
This Guidance relates to FDA 21 CFR 820.30 and Sub-clause 4.4 of ISO 9001
Objective Evidence 
Check pressure. 
Check that the pressure is OK. 
Record the pressure here ___. Check that the 
pressure is between 50 and 75 psi. 
A check requires a decision rule 
i.e. specific, measurable requirements 
Example from 
Medical Device Software Verification, Validation and Compliance by David A. Vogel 
ISBN 1596934220
Specified Requirements 
• User Stories 
– Sometimes with acceptance criteria 
• Traditional requirements 
– “The product shall...” 
• User Stories and traditional requirements 
were not linked 
A real challenge!
System 
Global Design 
Component 
Graphical User Interface 
Business Logic 
Component Component Component
Component Testing 
Software Interface 
Testability 
Exploratory Testing 
Coverage/risk outline 
Scripted Testing 
[Test] 
[RequirementTags("Req1", "Req7")] 
void FooBar() 
{ 
Assert.That(…); 
} 
Unit tests annotated with requirement tags for 
traceability 
Specify test cases for high risk specified requirements only
Structure 
Functions 
Data 
Time 
Operations 
Platform 
Coverage 
Bugs 
Issues 
Risks
Structure 
Functions 
Data 
Bugs 
Issues 
Risks 
Time 
Operations 
Platform 
Coverage/Risk outline
Why PASS and FAIL is not enough 
PASS only means that no problem was found, 
which doesn’t mean that there’s no problem 
Comparable Products 
• Lots of remarks during evaluation at hospital 
• Our product side-by-side to competitors 
product
Independent Testing 
• Testers were reponsible for 
– ALL test documentation 
– Providing Objective Evidence 
• Developers did some unit testing but 
– Their tests were undocumented 
– Could not be used as Objective Evidence 
Why does testing take so long?
Time-out 
JIGGLE! 
Testing 
Incomplete, overdue specified requirements. Independent testing. “I 
don’t know nothing about testing.” What does the team know about 
or does have experience with working in a Medical Device 
Context? 
Agile/Scrum 
Almost no Agile practices. The team didn’t live Scrum. What does 
the team know about or does have experience with 
Agile/Scrum?
Regulations and Agile/Scrum 
CONCURRENT ENGINEERING. Although the 
waterfall model is a useful tool for introducing 
design controls, its usefulness in practice is 
limited. 
DESIGN CONTROL GUIDANCE FOR MEDICAL DEVICE MANUFACTURERS 
This Guidance relates to FDA 21 CFR 820.30 and Sub-clause 4.4 of ISO 9001 
Agile TIR SW Committee Draft 1.0 
Guidance on the use of AGILE practices in the 
development of medical device software
Improvements after Time-out 
Testing 
• IEC 62304 training, Less independent testing. 
Agile/Scrum 
• Product Backlog, Sprint Planning, Definition of 
Done, Scrum Board, Sprint Review, 
Retrospectives, Smaller Teams each with their 
own Scrum Master 
• Scrum Master, Product Owner training 
• Agile/Scrum Coach 
Overdue specified requirements
Other Identified Risks 
Component not traceable to 
global design and risk 
analysis 
3D mathematical model was not 
specified 
Claim these results
Clarify mission 
System Architect 
Status reporting 
Director 
Quality & Regulations 
Program Director Test Architect 
Product Owner
Observe the work of testing 
A diary might help
Lessons Learned, Conclusions 
• A feedback loop is mandatory 
– Mission 
– Status Reporting 
• Medical Device Context is not limiting 
– Exploratory testing is possible 
– Agile/Scrum is possible 
No matter what the problem is, it’s always a people problem. 
Gerald M. Weinberg
Questions 
Ruud Cox 
email 
rco@improveqs.nl 
Twitter 
@ruudcox 
Blog 
http://ruudcox.wordpress.com/

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Ruud Cox - Testing in a Medical Device Context - EuroSTAR 2012

  • 1. Testing in a Medical Device Context Limitations are few Ruud Cox, Improve Quality Services www.eurostarconferences.com @esconfs #esconfs
  • 2. From Research to Manufacturing Hospital Market Segment Healthcare, Deep Brain Stimulation Big Organisation Divisions Manufacturer Research Law Regulations Products Probe Tools to support Surgical Procedures Product Prototypes Hospital Hospital Hospital New organisation Manufacturer
  • 3. Deep Brain Stimulation A pacemaker for the brain
  • 4. Almost no testing Incomplete, overdue documentation
  • 5. Organise Testing Approach: (Verification & Validation) Exploratory Testing Learning, investigation, discovery followed by Scripted Testing to demonstrate that the product conforms to specified requirements and to provide objective evidence for submission. Conformance, Compliance
  • 6. Exploratory Testing In the given situation, this was the best way to • Learn more about the product • Add value by providing feedback Charters, Debriefs, Screen Recordings, Managed A big success
  • 7. Regulations and Testing Verification only §820.3(aa) Verification means confirmation by examination and provision of objective evidence that specified requirements have been fulfilled. Testing is one of many possible verification activities DESIGN CONTROL GUIDANCE FOR MEDICAL DEVICE MANUFACTURERS This Guidance relates to FDA 21 CFR 820.30 and Sub-clause 4.4 of ISO 9001
  • 8. Objective Evidence Check pressure. Check that the pressure is OK. Record the pressure here ___. Check that the pressure is between 50 and 75 psi. A check requires a decision rule i.e. specific, measurable requirements Example from Medical Device Software Verification, Validation and Compliance by David A. Vogel ISBN 1596934220
  • 9. Specified Requirements • User Stories – Sometimes with acceptance criteria • Traditional requirements – “The product shall...” • User Stories and traditional requirements were not linked A real challenge!
  • 10. System Global Design Component Graphical User Interface Business Logic Component Component Component
  • 11. Component Testing Software Interface Testability Exploratory Testing Coverage/risk outline Scripted Testing [Test] [RequirementTags("Req1", "Req7")] void FooBar() { Assert.That(…); } Unit tests annotated with requirement tags for traceability Specify test cases for high risk specified requirements only
  • 12.
  • 13. Structure Functions Data Time Operations Platform Coverage Bugs Issues Risks
  • 14. Structure Functions Data Bugs Issues Risks Time Operations Platform Coverage/Risk outline
  • 15. Why PASS and FAIL is not enough PASS only means that no problem was found, which doesn’t mean that there’s no problem Comparable Products • Lots of remarks during evaluation at hospital • Our product side-by-side to competitors product
  • 16. Independent Testing • Testers were reponsible for – ALL test documentation – Providing Objective Evidence • Developers did some unit testing but – Their tests were undocumented – Could not be used as Objective Evidence Why does testing take so long?
  • 17. Time-out JIGGLE! Testing Incomplete, overdue specified requirements. Independent testing. “I don’t know nothing about testing.” What does the team know about or does have experience with working in a Medical Device Context? Agile/Scrum Almost no Agile practices. The team didn’t live Scrum. What does the team know about or does have experience with Agile/Scrum?
  • 18. Regulations and Agile/Scrum CONCURRENT ENGINEERING. Although the waterfall model is a useful tool for introducing design controls, its usefulness in practice is limited. DESIGN CONTROL GUIDANCE FOR MEDICAL DEVICE MANUFACTURERS This Guidance relates to FDA 21 CFR 820.30 and Sub-clause 4.4 of ISO 9001 Agile TIR SW Committee Draft 1.0 Guidance on the use of AGILE practices in the development of medical device software
  • 19. Improvements after Time-out Testing • IEC 62304 training, Less independent testing. Agile/Scrum • Product Backlog, Sprint Planning, Definition of Done, Scrum Board, Sprint Review, Retrospectives, Smaller Teams each with their own Scrum Master • Scrum Master, Product Owner training • Agile/Scrum Coach Overdue specified requirements
  • 20. Other Identified Risks Component not traceable to global design and risk analysis 3D mathematical model was not specified Claim these results
  • 21. Clarify mission System Architect Status reporting Director Quality & Regulations Program Director Test Architect Product Owner
  • 22. Observe the work of testing A diary might help
  • 23. Lessons Learned, Conclusions • A feedback loop is mandatory – Mission – Status Reporting • Medical Device Context is not limiting – Exploratory testing is possible – Agile/Scrum is possible No matter what the problem is, it’s always a people problem. Gerald M. Weinberg
  • 24. Questions Ruud Cox email rco@improveqs.nl Twitter @ruudcox Blog http://ruudcox.wordpress.com/