Can Product-Specific Assurance Case Templates Be Used as Medical Device Standards?

Abstract

International standards are a key ingredient in the quality assurance of software-intensive medical devices. One problem with such standards is that they often describe a lifecycle process that should be used to develop the system, rather than describe acceptance criteria to be applied to the system itself, thus guaranteeing safety directly in terms of the artefact's attributes. In the past few years, the U.S. Food and Drug Administration (FDA) introduced a (strong) recommendation that manufacturers submit an assurance case in their submission for approval to market an infusion pump. This reflects a move toward a more product/evidence-based approach to certification, compared with the primarily process-based certification used in the past. The perceived advantage of an assurance case is that it obliges the manufacturer to make an explicit argument regarding the safety/security/reliability of their product, under expected operating conditions. Taking this idea one step further, we explore whether there are benefits to using an assurance case Template as a new kind of standard, replacing existing process standards, and we describe some benefits of doing this.