Hello Chris

To fulfill requirements of risk management according to ISO 14971, you have to
identify all the hazard situations whhich could turn a hazard into harm. This
means identifying all the foreseeable sequence or combinations of events that
could led to the hazard situation. 

Three points here:

First: sometimes people think that they only have to identify the hazard (for
example, electrical shock). But there are a lot of situations (probabilities)
in which this hazard could arise, and there are a lot of outcomes (severities)
if the hazard turn into harm. So you have to determine the risks of each
hazard situation, not only of the more "general" hazard.

Second point: Foreseeable. It means that, although theoretically there are an
infinite number of hazard situations, you still have to limit it to some
number to keep it manageable. In fact, "where to stop" really depends on
manufacturer. It should be noted that there are some technoques for doing
this, for example, taking into consideration the intented use and reasonably
foreseeable misuse as initial parameters.

Third: although IEC safety product standard (in which the IEC 60601 series are
an example of) follow the single fault philosophy, ISO 14971 is not restricted
to single faults. So yes, there could have doube or triple faults on your risk
management (but try to use just the foreseeable ones, please:-)). Also, it´s
always toog to keep in mind that the single fault philosophy in IEC 60601 can
only be applied if the situation falls under some specific boundaries (these
boundaries are explanied in the examplanation to 4.7 in Annex A). If the
situation are outside these boundaries, then the single fault philosophy
cannot be aplied. For more on this interaction i suggest the following paper:
R.G. Mellish, "The single fault philosophy: How it fits with risk.
management,"presented at ACOS Workshop VI, Safety of Electromedical
Equipment—An Integrated Approach through IEC Standards, Toronto, May 6–7,
1998.

Cheers!

Best regards

Marcelo Antunes
Regulatory strategy consultant
SQR Consulting - Safety and quality through risk management
http://www.sqrconsulting.com.br <http://www.sqrconsulting.com.br/>  

Electromedicalinfo
http://www.electromedicalinfo.com <http://www.electromedicalinfo.com/> 

Gtalk: mmantu...@gmail.com
MSN: marcelo_antu...@hotmail.com
- Show quoted text -






            Chris.Dupres@elek
            ta.com
                                                                       To
            03/17/2008 09:06          ted.eck...@apcc.com
            AM                                                         cc
                                      emc-p...@ieee.org
                                                                  Subject
                                      Re: Protective Earthing Terminal
                                      Construction Requirements










Ted Ekert said:

<If a ground connection fails, there will be no indication of a problem to
the user.  The product will likely continue to operate perfectly normally.
A second failure, such as a loose line wire, could lead to the sudden and
unexpected energizing of exposed metal.  The product has now become
hazardous without warning.>

This makes sense of course, but (going off track a little bit) this implies
that the equipment has TWO faults, and the premise at the moment seems to
be  'Safety under SINGLE FAULT conditions'.

I guess I'm asking for opinions, in view of the latest standards leaning or
Risk Analysis etc., (e.g. IEC 60601-1 Rev 3) is..  "How many stacked risks
should we take into account?" when defining 'Risk'.

I mean, it's perfectly feasible to lose a ground connection on a case (1
fault), and for a live wire to come loose and touch the case (2 fault).  Do
we have to take ALL scenario's like that into account?  In other words,
ensure the design is safe under double, or even triple fault conditions?

I'm reminded of a mains plug on a piece of UK equipment, where the lead was
tugged, the Earth wire pulled out and ended up on the Live wire.   Of
course the whole case became live.This was found because a secretary felt a
'tingle' when she touched the case.  I guess her plastic high heels saved
her that time.  One event, but two faults.

So how many levels of fault should we take into account in order to fulfil
the Risk Analysis requirements?

Regards,

Chris.

Chris Duprés
Compliance Engineer
Elekta Limited
Linac House
Fleming Way
Crawley
West Sussex
RH10 9RR

www.elekta.com
tel:  +44 (0) 1293 654311
fax:  +44 (0) 1293 654260


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