3
ISAO participation reduces reporting requirements
to the FDA considerably. From a legal standpoint,
I would go so far as to say it reduces liability also,
in the fact that it shows the manufacturers
commitment to safety and negates any ill intent on
the manufacturers part.
BLOOMBERG BNA: How will the implementation of the
recommended risk management programs by medical
device companies impact their economic outlook?
PRIVACY WATCH
ISSN 0000-0000
YANNELLA: If done properly, using ISAO data sharing
and the NIST Framework for improving critical infrastructure, the costs to a manufacturer should be reasonable. The increased security should increase the physician and patient conï¬dence in the safety of medical devices and encourage greater use.
As with all additional Quality Systems requirements,
if integrated appropriately into the design and post
market monitoring of the device, the economic impact
should be no more than compliance with various sections of 21 CFR 820 for QSR, complaint handling, quality audit, corrective and preventive action, software
validation and risk analysis and servicing and monitoring. Companies who have good Quality Assurance systems will have little additional cost or trouble implementing the new guidance recommendations.
Yannella would like to thank Neil DiSpirito, of counsel Ballard Spahr, for his assistance.
BNA
2-25-16
.