T-012-020 Predetermined Change Control Plan
Device identification
Clearly identify the device covered by the PCCP, including name of the device, risk class, software version and unique identifier.
Purpose
Define the purpose of the PCCP specifying why a predetermined change control plan is being established and what types of changes it will cover.
Roles and responsibilities
Identify the personnel responsible for each stage of the modification process.
Example: JD-005
leads the technical assessments, testing, and validation for each modification.
Description of modifications
Scope of modifications
Define the types of modifications included in this PCCP. For each type of modification, provide a clear definition and description.
Examples of changes definition and description:
- Software updates: includes security patches, performance improvements, bug fixes, and feature enhancements that do not alter core functionality.
- Labeling changes: adjustments in device labeling or instructions for use to improve clarity without affecting regulatory claims.
List and description of modifications
For each type of modification, provide a detailed description, including the rationale, potential anticipated impact on safety, effectiveness, or device performance, and risk management considerations. Provide details on whether the modifications will be implemented automatically, manually or a combination; provide the expected update frequency.
It is important to code the modifications as it is recommended to create a traceability matrix between modifications and information available in Modification protocol
of this template.
Examples:
- Modification type: Software update (security patch)
- Modification ID MOD-001
- Description: Updates to the software to address identified cybersecurity vulnerabilities
- Rationale: To enhanca cybersecurity resilience and protect patient data
- Risk management considerations: Updated risk assessment under ISO 14971 indicates a low risk to patient safety. Testing ensures compatibility with previous software versions
- Implementation of change: manually
- Frequency of update: one-time implementation
Modification protocol
Data management practices
Provide details on data collection, annotation, curation, storage, and use; assurance of deployment of isolated training, tuning, and test datasets to prevent overfitting and bias; use of diverse datasets representative of the device's intended use population and clinical scenarios; processes for maintaining up-to-date, unbiased, and high-quality data.
Re-training practices
Identify the objective of the retraining process, provide a description of the AI model, identify the device components that may be modified, outline the practices that will be followed, and identify any triggers for re-training.
Performance evaluation
Describe how performance evaluation will be triggered; how test data representative of the clinical population and intended use will be applied for testing; what performance metrics will be computed; what statistical analysis plans will be employed to test hypotheses relevant to performance objectives for each modification; acceptance criteria; study design.
Provide information if there is an unresolvable failure in performance evaluation for a specific modification.
Update procedures
Provide a description of how software updates will be implemented, a description of how legacy users will be affected by the software update (if applicable), a description of how modifications will be communicated to the users, including transparency on any differences in performance or device inputs, and/or known issues that were addressed in the update.
Traceability matrix
Fill in the table provided in this section to ensure traceability between each modification described in the Description of modifications
section of this PCCP and the information provided in the Modification protocol
section.
Modification | Data management practices | Re-training practices | Performance evaluation | Update procedures |
---|---|---|---|---|
MOD-001 | ||||
MOD-002 | ||||
MOD-003 |
Impact assessment
Include the following key points:
- Comparison of versions: evaluate the device with each modification individually against the unmodified device
- Benefit-risk analysis: discuss benefits, risks (including harm and unintended bias), and risk mitigations for each modification
- Verification and validation assurance: confirm that proposed verification and validation activities maintain safety and effectiveness
- Interdependence of modifications: assess how implementing one modification affects others
- Cumulative impact: analyse the combined effects of all modifications on the device.
- Overall functionality: assess the impact of the planned modifications on the overall functionality of the device.
Signature meaning
The signatures for the approval process of this document can be found in the verified commits at the repository for the QMS. As a reference, the team members who are expected to participate in this document and their roles in the approval process, as defined in Annex I Responsibility Matrix
of the GP-001
, are:
- Author: Team members involved
- Reviewer: JD-003, JD-004
- Approver: JD-001