Agile in FDA Regulated Medical Software – Sweat the Details

Michael Walkden

This post was previously on the Pathfinder Software site. Pathfinder Software changed its name to Orthogonal in 2016. Read more.

Very few people in the software development community have issues with maintaining good attention to the details. However, I bet those who live in the regulated software community view the “normal” software world as quite sloppy. Attention to detail is a matter of life and death for a medical device. Because of this, the entire software community does a good job maintaining checks and balances. I have three suggestions that will make a tremendous difference when you start a regulated project or when you finally get near to releasing your medical device.

#1 Plan to get audited

It is a good bet you are going to get audited sooner or later. Its even possible to get a product out into the market only to have it get audited a second time. An FDA auditor will keep asking “why do you think that works?” type questions and continue to drill down until they find something or are satisfied there is nothing to find. If they find something you are going to get a warning letter and start the expensive process of FDA remediation. Getting past this will cost you a significant amount of resources and likely delay new product development. Usually just in time for your competitors to catch up. Keep good records.

#2 Do Test Driven Development (TDD) Well

By well I mean do all of the normal activities that are part of TDD … and do one more thing. Create self-documenting code that also lends itself to traceability directly back to product requirements. Imagine telling an auditor that you can prove that you tested every path of the code EVERY time you checked your code in…thousands of times.  All of these tests can be directly linked back to product requirements. That would make an audit pretty easy.

#3 Create a Traceability Matrix

This may seem obvious. However, I know of many, successful, software shops that have stopped doing this. Ask a developer with 1-2 years of experience why they would need a traceability matrix and you will know what I mean. If you are planning to get audited and want to show that all of your requirements have been tested thousands of times, you need a traceability matrix.

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