Risk Management Report of Surgical Instruments

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    Product risk management report KH/JS-CE-QXB03 A/0

    Risk Management Report of Surgical instruments

    1 Introduct ion

    In accordance with MDD (93/42/EEC) requires, in accordance with the "riskmanagement applications for medical devices", analyzed the clinical use of our productsin the hazards that may exist, and the production of each hazard was determined. Foreach hazard to the severity of damage and harm the probability of occurrence wasestimated. In a risk is unacceptable, to take control measures to reduce risk, whiletaking the risk of residual risk after control measures were evaluated. Finally, all theresidual risks to an acceptable level, to ensure safe and effective products on themarket.2 Scopes

    The Company's surgical instruments with CE mark products.3 application data

    3.1 Application StandardsISO 14971 Medical Device Risk Management applications for medical devicesISO 7153-1 Surgical instruments - Metallic Materials Part 1: Stainless steelISO / TR 14283 Implants for surgery - basic principlesISO 14630 Non-active surgical implants - General requirementsISO 15730 for the stainless steel finishing, polishing and passivation of metals and

    other inorganic coatings ASTM A 380 stainless steel parts of the standard criteria for removal and cleaningStainless steel ASTM A 967 Standard Specification for Chemical Passivation

    ASTM D4169 transport container system performance test standard operatingprocedures

    3.2 Application Information- "AO principles of fracture treatment, " translated Rong Dai Shike- "Study orthopedic surgery, " Zuber pass, Dai Jung Shike

    - "Clinical Orthopaedics Anatomy, " edited by GUO Shi Fu- "Clinical Orthopaedics" Li Shimin, editor of the party farming-cho- "Modern Orthopaedics" Zhao Dinglin Editor- "Emergency Orthopedics limb part of the " original ROBERT R. SIMON,

    STEVENJ.KOENIGSKNECHTMain translation Xiao Deming

    - "Fracture biomechanics Therapy, " Shu-Hui, Wang Xinhua, Du Maoxin editor- "Bone and bone surgical diagnosis and treatment of medical school, " Cao

    Jianzhong Hu Guangzhou, Zhang Dayong, Chang Hong Editor- "bone and joint diseases, " Zhang Shiqing, Wang, Ji Asia and Africa, edited by Liu- "Human Anatomy" Gu Xiaosong Editor

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    4 the team of ri sk analysis

    Name Position/Responsibility Duty

    Wang zhi ming Vice general manager, superviseproduction & technique

    department

    Team Leader

    Jiang de cheng Technique adviser Team Member

    Ma hao ming Manager of TechniqueDepartment

    Team Member

    Yin zhuo Standardization Team Member

    Jiang qing xing Engineer Team Member

    Cao hua Manager of Quality Department Team Member

    Wu zheng qian Manager of Logistic Department Team Member

    Wang tong Marketing Manager Team Member

    Huang fei peng Sales Manager Team Member

    Xu li Attending physician Team Member

    5 Product Descriptions

    5.1 OverviewThe object of risk management involves surgical instruments. The company providesthe surgical instruments is an essential tool for orthopedic surgery, orthopedic implantsall products are required to meet the appropriate surgical instruments to properly installand reliably fixed to the patient's body, the safety of implantable devices also removethe need to use The appropriate surgical instruments. The production of surgicalinstruments with a variety of materials, such as: stainless steel, titanium, aluminum andnon-metallic materials. Human exposure to traumatic surgical instruments, requiredhardness, toughness is moderate, leaving debris and difficult to oxidative corrosion, andhave some biocompatibility.

    5.2 FunctionSurgical instruments is a tool for orthopedic surgery. Purpose is to ensure safe and

    smooth implants implanted or removed.5.3 use of the environmentSurgical instruments available to medical institutions, the need for treatment of qualifiedand experienced doctors during the surgery.6 The implementation of risk management process

    It is recognized that the concept of risk has two components:- the probability of occurrence of the damage, ie: how the recurrent occurrence of the

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    damage;- the consequences of harm, that is: how serious it is.Now according to the requirements of ISO14971, the two parts of surgical instrumentsfor risk assessment and management products.

    6.1 The intended purpose and qualitative and quantitative characteristics of the decision Appendix C of the Company pursuant to the requirements of ISO14971, for surgicalinstruments that may affect the security features of the problem of determining thefollowing table:

    Table 1 the characteristic problem of determining the safetySerial

    NumberDetermines Whether or not affects

    C.2.1What is the intended use andhow to use?

    1.1 Expected use of productSurgical instruments are essential tools for orthopedicsurgery, adjuvant complete the operation.

    1.2 How to use medical device

    The Company's surgical instruments products fromorthopedic doctor according to the type of surgery,choose the appropriate surgery for patients withsurgical instruments.

    1.3

    What is the role of Medicaldevices in the diagnosis,prevention, care, treatment ormitigation, trauma anddisability compensation,replacement or correction ofanatomy, etc.

    Not applicable

    1.4What is the indication (e.g.patient population)?

    patients who need Orthopedic surgery

    1.5Whether to maintain orsupport medical equipmentlife?

    Not applicable

    Continued Table 1 The characteristic problem of determining the safety Serial

    NumberDetermines Whether or not affects

    1.6In the case of failure of medicaldevices need specialintervention?

    Not applicable

    C.2.2Implantable medical devicesare expected to be used?

    Not applicable

    C.2.3 Medical equipments are Applicable. Part of the surgical instruments during

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    expected to and contact withpatients or other staff?

    surgery when necessary, contact with patients.

    C.2.4

    In the medical device whichcontains materials and (or)

    components, or for sharing, oraccess to medical devices?

    Applicable. The company's products, its biologicalproperties and mechanical properties were already

    recognized by the medical profession.

    C.2.5Have the energy to givepatients access to or from thebody?

    Not applicable

    C.2.6 Are there materials available tothe patients or from patients?

    Not applicable

    C.2.7

    Whether the medical deviceswith biological material andthen re-use, injection or

    transplant?

    Not applicable

    C.2.8

    Medical care is provided in theform or preparing a sterilesterilized by the user, or othermethod of sterilization ofmicrobial control?

    Not applicable

    C.2.9Medical devices are expectedby the routine cleaning anddisinfection of the user?

    Applicable. The company's products in the form ofnon-sterile products for use by the user (installer) forcleaning and disinfection.

    C.2.10Medical equipment areexpected to improve thepatient's environment?

    Not applicable

    C.2.11Whether the medical device tomeasure?

    Applicable. Part of the caliper, sounding devicewith measuring function

    C.2.12Whether the analysis andprocessing of medical devices?

    Not applicable

    C.2.13

    Medical equipment areexpected, and other medicaldevices, drugs or other medicaltechniques used incombination?

    Not applicable

    C.2.14Is there no hope for energy ormaterial output?

    Not applicable

    C.2.15Medical devices are sensitiveto the environmental impact?

    Not applicable

    C.2.16Medical devices affect theenvironment?

    Not applicable

    C.2.17 Are there basic suppliesmedical equipment oraccessories

    Not applicable

    C.2.18

    The need for maintenance and

    calibration?Use. Repeated use of the products after use to bemaintained.

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    C.2.19Medical devices havesoftware?

    Not applicable

    C.2.20Medical devices have limitedstorage life?

    Not applicable

    C.2.21 For delayed and (or) long-termuse effects? Not applicable

    C.2.22What kind of medicalequipment to withstandmechanical forces?

    Not applicable

    C.2.23What determines the life ofmedical devices?

    Applicable. Surgical instruments used in the wear andtear or improper operation.

    C.2.24Single-use medical devices areexpected?

    Not applicable. Can be reused, clean and sterilizedbefore use.

    C.2.25

    The need for safety of medical

    devices out of operation ordisposal?

    Not applicable

    Continued Table 1 The characteristic problem of determining the safety Serial

    NumberDetermines Whether or not affects

    C.2.26Installation or use of medicaldevices requires specialtraining or special skills?

    Applicable. The installation of surgical instrumentswith the necessary skills to use the need for surgical(orthopedic) medical use.

    C.2.27How safe use of theinformation provided?

    Applicable. The installation of surgical instruments

    with the necessary skills to use the need for surgical(orthopedic) medical use.

    C.2.28Need to establish or introducenew production processes?

    Not applicable

    C.2.29

    Successful use of medicaldevices, is decisive dependson human factors, such as userinterface?

    Applicable. The success of surgical instrumentsdepends on surgeons to use clinical experience,depending on the surgeon can correct operation ofsurgical instruments.

    C.2.29.1User interface design featureswill result in the wrong?

    Not applicable

    C.2.29.2Medical equipment is used fordistraction caused by thewrong environment?

    Not applicable

    C.2.29.3 Are there parts of medical

    equipment or accessories

    connected?

    Applicable. In clinical use, some surgical instruments

    to be used together with the existence joints, use of

    the process should pay attention to the reliability of

    connection joints, or cause to fail.

    C.2.29.4 Are there medical device

    control interface?Not applicable

    C.2.29.5Whether to display information

    about medical devices? Not applicable

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    C.2.29.6Medical devices are controlled

    by the menu?Not applicable

    C.2.29.7Medical equipment whether theuse by special request?

    Applicable. Surgical instruments with the necessaryskills required by the surgery (orthopedics) doctors to

    operate.C.2.29.8

    User interface is used to triggerthe user's actions?

    Not applicable

    C.2.30Whether to use the alarmsystem of medical devices?

    Not applicable

    C.2.31Manner in which medicaldevices may be intentionallymisused?

    Not applicable

    C.2.32Whether to retain the medicalequipment data on critical

    patient care?

    Not applicable

    C.2.33Whether to retain themedical equipment data oncritical patient care?

    Not applicable

    C.2.34Whether the use of medicaldevices depends on the basicproperties?

    Not applicable

    35Manufacturing process shouldbe considered in the risk

    35.1

    Whether due to equipmentcaused by improper selection

    of materials of biological

    compatibility issues?

    Applicable. Surgical instruments with the necessaryskills required by the surgery (orthopedics) doctors to

    operate....

    35.2

    Whether the material dueto improper controldevices, resulting inbio-compatibility issuesand product failures?

    Applicable. Improper control of such material, theoccurrence of misuse, abuse will result inbio-compatibility issues; affect the product's life,resulting in surgery can not proceed.

    Continued Table 1 The characteristic problem of determining the safety

    SerialNumbe

    rDetermines Whether or not affects

    35.3

    Whether due to improperdesign, resulting in deviceproducts in the clinicalapplication of the process offracture?

    Not applicable. Surgical instruments are surgicalinstruments, non-implantable products

    35.4 The processing of productspossible risks?

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    Chapter total 20 pages page 7

    35.4.1Blanking process of theproduct will product ofbiological compatibility issues?

    Applicable. Products in the blanking process, due tofracture caused by taking the wrong material orbiological compatibility issues.

    35.4.2

    Products in the cutting (clamp,

    grinding) process will producea result of improper operationof the equipment failurefactors?

    Applicable. Products in the blanking process, due tofracture caused by taking the wrong material orbiological compatibility issues.

    35.4.3Products in the treatmentprocess will produce productfailure problem?

    Applicable. Improper operation of the heat treatmentprocess, not achieve the required hardness, will leadto product failure

    35.4.4Products in the polishingprocess will produce

    bio-compatibility issues?

    Applicable. Products in the polishing process, thepollution will be polishing paste, there is no netwashing polishing paste, affecting the cleanliness ofthe product, resulting in bio-compatibility issues.

    35.4.5In the first washing, it willproduce bio-compatibilityissues?

    Applicable. Products in the polishing process, thepollution will be polishing paste, there is no netwashing polishing paste, affecting the cleanliness ofthe product, resulting in bio-compatibility issues.

    35.4.6Products in the corrosion testwhether the process ofbio-compatibility issues?

    Not applicable. Corrosion test is mainly used to testwhether the product is made of stainless steelresistant to corrosion. The liquid is often used as ableach or disinfectant hydrogen peroxide, and has

    been fully diluted. Not in the product composition ofthe surface of residual risk.

    35.4.7Product marking equipment willresult in fracture of the factorsthat produce?

    Not applicable. Laser marking does not affect themechanical properties.

    35.4.8Product marking equipment willresult in fracture of the factorsthat produce?

    Applicable. Products in the passivation process, theprocessing liquid is diluted nitric acid solution, such asnitric acid solution to clean without a net, there areresidual elements left nitric acid solution to producebio-compatibility issues.

    35.5Products in the packagingprocess is causing a mixedproblem?

    Products in the packaging process, due to packagingerrors caused by the product mix, making products inuse and the model specification does not harmpatients

    35.6Products in the transportprocess caused by equipmentfaults will produce the factors?

    Products during transport, due to thebreakdown of the product packaging wasdamaged, resulting in surgery can not benormal.

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    6.2 Risk management processSurgical Instruments products are the specific characteristics of safety-related judgments, clear and product safety hto the terms of harm are the reasons for the refinement and analysis, its analysis and risk assessment, and take down mrisk of a re-evaluation of risks, the table below:

    Continued Table 2 surgical instruments list of potential hazards and measures

    Possible harm

    SerialNumber Potential

    harmReason ofoccurrence

    SeriousLevel Occurrence

    possibility

    Riskrank

    Measures toreduce risk

    ApplicablestandardsOr relateddocuments

    Whetherthe new

    risk

    26

    Broken

    surgicalinstruments,such failurecan notmeet

    (1) Do not

    have the

    necessaryskills by the

    surgery

    (bone) doctor

    from

    operating

    equipment.

    2 2 4

    Instructions in

    the manual

    have been sold

    only to holders

    of Surgery

    (Orthopaedics),

    MD's license.

    Manual

    operation

    instrument

    No

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    29

    (2)Improperuse ofsurgicalinstruments,resulting ininstrumentfracture.

    2 2 4

    In the product

    manual for

    products to be

    given with

    sufficient

    anatomical

    knowledge and

    understanding

    of orthopedic

    surgeons to

    operate.

    Manual

    operation

    instrument

    No

    35.3

    (3) designersdo not followproceduresfor productdesign anddevelopmentoperations

    2 2 4

    Tailor-made

    "design anddevelopmentcontrolprocedures"and "designchange controlprocedures",andperiodicallyreviewed.

    KH/QP-08KH/QP-09

    No

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    35.4.2

    (5) With thesize of thedeviationdeviceproducts,resulting inthe product isnot fit forsurgery.

    2 2 4

    In the

    production

    process, strict

    control,strengthen the

    inspection

    process.

    MechanicalprocessingcardKH/ZB-01.12

    GeneralInspectionInstructions

    No

    35.4.3

    4) Theproduct doesnot achievethe requiredhardness,

    heattreatmentprocess,leading toproductbreakage,increasedwear

    2 2 4

    Formulated the"heat treatment

    instructions,"and the specialprocess wasconfirmed,while strictlyenforced.

    KH/JS-09.10 No

    Continued Table 2 surgical instruments list of potential hazards and measuresPossible harm

    SerialNumber Potential

    harmReason ofoccurrence

    SeriousLevel

    Occurrencepossibility

    Riskrank

    Riskreduction

    approaches

    ApplicablestandardsOr relateddocuments

    Whethe n

    ri

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    35.2

    Biological

    compatibility

    of the

    product

    hazards

    Impropersurgical

    instruments

    material

    control the

    biological

    compatibility

    issues.

    2 2 4

    Set up

    special library

    materials,

    equipment,

    and the

    establishment

    of special

    management,

    monthly

    reconciliation

    of debit

    objects, to

    preventmistakes

    made.

    MWI-011 No

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    35.4.5

    (1) to oil,

    polishing

    paste after

    ning the

    urface maystill be oil,

    polishing

    paste,

    detergent

    residue

    composition,

    resulting in

    harm to

    patients.

    clea

    s

    2 5 10 No

    35.4.8

    Process

    may be left

    on the

    surface ofthe product

    caused by

    harmful

    substances

    in biological

    compatibility

    problems

    for patients

    (2)passivationtreatment,surfacecleaning isnotcompletelymade acid

    residues,resulting inharm topatients.

    2 5 10

    Cleaningprocess foreach channelone by one toconfirm andverify thecleaningprocess todevelop workinstructions,and productssent to theInstitute ofSuzhouUniversity,Biologicalevaluation ofradiationtests to verifythe processtaken by thecompany'sreasonable.Training of

    cleaningoperatives,cleaning work

    KH/JS-09.20 24SRPSU-2004-0649SRPSU-2004-0650SRPSU-2004-0651SRPSU-2004-0652SRPSU-2004-0653SRPSU-2004-0654SRPSU-2004-0655

    N

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    35.4.4

    (3) productsin thepolishing,the cleaningis notcomplete sothe surface

    acidresidues,resulting inharm topatients.

    2 5 10

    in strictaccordancewith therequirementsof operatinginstructionsfor cleaningand make aclean record,to ensure thatproductsmeet therequirementsof every

    cleaning. Ifthe cleaningagentcompositionchange orcleaning ofchanges in atimelymannerFurther

    validation andrevalidation

    N

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    35.4.1

    (4) aftercutting, dueto damagecaused bytaking thewrongmaterial

    2 3 6

    Control of themachiningprocess todevelop"machiningprocesscards."

    Machining processcard

    N

    Continued Table 2 surgical instruments list of potential hazards and measures

    Possible harm

    SerialNumber Potential

    harmReason ofoccurrence

    SeriousLevel

    Occurrencepossibility

    Riskrank

    Measures toreduce risk

    ApplicablestandardsOr relateddocuments

    Whetherthe new

    risk

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    35.5

    Product mixcaused bythepackagingprocesshazards.

    In the productpackagingprocess, dueto productmix, resultingin surgeryproducts donot apply.

    2 3 9

    In thepackagingprocess,batch print forthe sameproduct with abar codecorrespondingto the label,approved byproductpackaging.Packagingre-confirmedby theinspectors.

    KH/JS-09.04Packagingoperatinginstructions

    No

    35.6

    Duringtransportationof the producthazards.

    In thetransportprocess, theproductssubject to theimpact ofexternal

    forces, theoccurrence ofproductcaused bydeformationor scratches

    2 5 10

    Productpackagingdesign canresist theimpact ofexternalforces for thespecial boxpackagingand make thenecessaryfixed.

    KH/JS-09.04Packagingoperatinginstructions

    No

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    in the surfaceof theproduct.

    8 9infection topatients aftersurgery

    Requirementsbefore usingthe operatorfails to carryoutsterilizationanddisinfection;

    2 3 6

    Instructionsin the use ofthis productis notsterile, theuse ofsteamsterilizationmethod.

    Instructionbook ofInstrumentsets

    No

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    KH/JS-CE-GZ03 A/1

    7 criteria for acceptability

    7.1 Assessment of the severity criteria

    The enterprises will be divided into five severity levels, details in Table 3.

    Table 3 severity assessment chart

    Severity Level S Severity Evaluation

    ranking

    S1 without any harm Can be negligible 0

    S2 mild damage Minor injury or no injury 1

    Serious harm to S3 Lead to injury 2

    S4 fatal hazardsResulted in one death or serious

    injury 3

    Catastrophic harm S5 Led to many deaths 4

    The definition of serious injury:

    a, life-threatening; or

    b, body function or permanent damage to permanent damage to body structure;

    c, the injury / damage to require medical or surgical repair.

    7.2 The assessment criteria probability of occurrence

    The orthopedic medical device companies will be divided into six levels of the quantitative analysis,

    see Table 4.

    Table 4 assess the scale of the probability of harm

    P Name probability P Probability (per year) Evaluation

    rankingP1 Rare P1 10 -6 1Very few occurred P2 10 -4~10 -6 2

    Rare P3 10-2

    ~10-4

    3Incidental P4 10 -1~10 -2 4Sometimes occurs P5 1~10 -1 5Frequent occur P6 1 6

    7.3 The estimated level of risk

    Orthopedic surgical instruments risk assessment based on the following formula: Risk =

    probability the level of severity

    Comprehensive description of the risks in Table 5

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    Table 5 shows the level of risk comprehensive table Severity Level

    S2 S3 S4 S5Possibility ofoccurrenceMild severe fatal catastrophic

    P6 Often ALARP NAC NAC NACP5 Sometimes ALARP ALARP NAC NACP4 Accidental ALARP ALARP ALARP NACP3 Little ACC ALARP ALARP ALARPP2 Very little ACC ACC ALARP ALARPP1 Little ACC ACC ACC ACC

    Note: ACC is acceptable, ALARP area as is reasonably practicable, NAC is not acceptable.

    7.4 Risk acceptance criteria

    The production of orthopedic surgical instruments products, integrated by the level of risk, its

    assessment of the acceptability criteria in Table 6.

    Table 6 Risk Assessment Form

    1-5 The risk may be negligible

    (6-11)

    Permissible risk (decrease has taken reasonable and practicable

    measures)

    (12-17)Do not want to, and conditional permit risk (and then reduce the

    unrealistic)

    (18-24) Does not allow the risk of

    8

    Department Facts description Corrective measures Verification

    measures

    Quality

    Department

    According to the monthly "and

    the rejection rate tables yield"

    and the annual "Product quality

    status quo and development

    trend report", the product yield,

    feed rate of waste, processing

    waste rate the quality of work

    done better than the target set

    -- --

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    KH/JS-CE-GZ03 A/1

    target

    MarketingDepartment Service

    Technical servicepersonnel are notsufficient; thenumber of thecertificate is notenough; occasionaldelivery is not ontime

    1, to enhance the

    training of technical

    services; improve

    service quality;

    2, increasing the

    single-package

    certification;

    3, reasonably and

    timely delivery

    according to customer

    requirements.

    KH/JS-18.1

    KH/JS-04.4

    9 Summaries

    The company's products, surgical instruments, in accordance with ISO14971requirements analysis, not found to harm the cause.Currently, the production of the company every step of the process of strict monitoring,the better the quality of the process to ensure product quality, meet regulatoryrequirements MDD93/42/EEC. All the hazards on the risk of surgical instruments aredescribed and evaluated the risks within the acceptable range, in normalcircumstances would not cause harm to operators and patients, but does not causelife-threatening, and therefore, we believe that surgery device products compared tothe risks and its benefits, benefits and more risky.10 related / supporting documents

    MDD 93/42/EEC (amended by 2007/47/EC)

    ISO 14971:2007 Medical Device Risk Management applications for medicaldevices

    KH/QP-CE03 medical device risk management procedures

    Department Employee Date Department Employee Date

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    Chapter total 20 pages page 20