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Content of Human Factors Information in Medical Device Marketing Submissions: Draft Guidance for Industry and Food and Drug Administration Staff

DraftCenter for Devices and Radiological Health12/09/2022

Description

This draft guidance document provides the FDA’s recommendations on the human factors information that should be documented and included in medical device marketing submissions, when such are required. The recommendations are intended to promote consistency and facilitate efficient review of medical device submissions.

Scope & Applicability

Product Classes

7
Medical Device

FDA intends to assess device cybersecurity based on a number of factors; demonstrate or maintain its safety and effectiveness; ensuring cybersecurity has become essential to FDA’s ability to protect the public health; Cyber-resiliency capabilities for medical devices

portable fingertip oximeter

New portable fingertip oximeter intended for spot checking oxygen saturation.

stent

Approved PMA for a stent with a balloon catheter delivery system.

implantable infusion pump

An implantable infusion pump has a physician programmer.

Gas Machine for Anesthesia

device intended for use in hospital environments; Scenario involving changing the GUI of the gas machine for anesthesia.

Gastrointestinal Lesion Software Detection System

computer-assisted detection device used in endoscopy

Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Stakeholders

5
Manufacturer

Entity responsible for submitting NDINs

patient

individual receiving expanded access treatment; The individual receiving the investigational treatment and providing consent.

physician

medical professional requesting HCT/P for urgent need; requesting HCT/P based on urgent medical need

Submitter

The entity providing information for the AFIC process.

Healthcare professional

User population that might train lay users or perform specific tasks.

Regulatory Context

Attributes

6
Critical tasks

Tasks identified during human factors assessment; Tasks which, if performed incorrectly, could lead to serious harm.

HF Submission Category 3

Recommended HF information in this marketing submission.

HF Submission Category 2

Recommended HF information in this marketing submission.; The recommended HF Submission Category in this marketing submission

HF Submission Category 1

Recommended HF information in this marketing submission.

Critical Task

User tasks which, if performed incorrectly, could cause harm.

Residual Risk

Overall risk remaining after risk control measures have been implemented

Identified Hazards

Hazards

4
Use-related hazards

hazards related to human-automation interactions and cognitive limitations

serious harm

cause serious harm to the user/patient

Use Error

Potential errors that may occur during product use tasks.

Abnormal Use

intentional act or intentional omission of an act that reflects violative or reckless use

Related CFR Sections (4)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Hong Qiangxing Shenzhen Electronics Limited

    2025-11-25
  • CGMP/QSR/Medical Devices/Adulterated

    Contec Medical Systems Co., Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Royal Philips

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Qianjiang Kingphar Medical Material Co Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated

    LEVO AG

    2025-10-21
  • CGMP/QSR/Medical Devices/Adulterated

    Technological Medical Advancements LLC

    2025-10-07
  • Medical Device/Adulterated/Misbranded/Lacks PMA and/or 510(k)

    The Richline Group, Inc.

    2025-09-23
  • Investigational Device Exemptions (IDE)/Premarket Approval Application (PMA) Adulterated Device

    SeniorLife Technologies, Inc.

    2025-09-16
  • CGMP/QSR/Medical Devices/Adulterated

    Miach Orthopaedics

    2025-08-26

See Also (8)