Submission of the Human Engineering File to the FDA and Other Regulatory Bodies, Section 8: Part VI

This is the easiest for me to cover largely because the requirements for the validation section are clearly spelled out in detail.

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Details of human factors validation testing Rationale for test type selected (i.e., simulated use, actual use or clinical study) Test environment and conditions of use Number and type of test participants Training provided to test participants and how it corresponded to real-world training levels Critical tasks and use scenarios included in testing Definition of successful performance of each test task  Description of data to be collected and methods for documenting observations and interview responses Test results: Observations of task performance and occurrences of use errors, close calls, and use problems  Test results: Feedback from interviews with test participants regarding device use, critical tasks, use errors, and problems (as applicable)   Description and analysis of all use errors and difficulties that could cause harm, root causes of the problems, and implications for additional risk elimination or reduction

These requirements are largely self explanatory. However, I would like to make a few comments and additions.

• Validation testing -- including verification testing -- are often performed by outside consulting firms. Thus it is extremely important that you spell out how your testing should be performed and the measurements to be collected and reported. I've noted that often times consulting company is asked to write both the protocol and the testing script. This is a mistake. The organization that performed the work up to the validation testing stage should be responsible for creating the protocol and the script, because it is this organization that will be responsible for the submission of the HE file to the FDA and/or other regulatory bodies. It's important that the research and development as well as the submission be responsible and in full control of what takes place during the validation step.
• Verification and Validation testing. Verification testing takes place under laboratory conditions using as testing participants members of the targeted user population. This is an additional check on the usability of the system or device. Validation testing takes place in actual or simulated actual conditions -- with all the distractions and problems that users will likely encounter.
• Rationale for type of testing performed and the conditions chosen for validation testing can be extremely important especially if you have chosen a testing procedure less rigorous than performance testing under real or simulated real conditions. Consult IEC 62366 and AAMI HE75 for guidance.
• Testing procedure should insure that full testing of critical tasks are performed and likely to be repeatedly performed by testing participants.
• Suggested additional measurement: If your system or device has error trapping and redirecting capabilities, be sure to report how often these capabilities were triggered and if they enabled the testing participant to successfully complete the task. This could be labeled as: task successfully completed, close call. However, a system or device with the capability to protect against use errors is a capability worth pointing out. 

What to include in your narrative?

Include the abstract or abstracts of your validation testing in your narrative. 

If you haven't included any significant issues or root cause analysis in your abstract, be sure to include this in your narrative. Be sure you surface all issues or concerns in your narrative, if you don't it could appear to a reviewer that you're trying to hide any problems that you encountered. Even the appearance of hiding problems could cause problems with receiving approval for your system or device.