Human Factors and Usability under EU MDR/IVDR2025-08-29T10:25:54+05:30

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Human Factors and Usability under EU MDR/IVDR

The European Union Medical Device Regulation (EU MDR 2017/745) and the In Vitro Diagnostic Medical Device Regulation (EU IVDR 2017/746) place strong emphasis on human factors and usability engineering as integral parts of device safety and performance. Both regulations recognise that many adverse events and device related incidents are caused not by technical malfunctions but by use errors linked to poor design, unclear instructions, or failure to consider the abilities and limitations of the intended users.

To address this, MDR and IVDR require manufacturers to demonstrate that devices are designed and manufactured in a way that ensures safe, effective, and intuitive use across the full range of intended users whether healthcare professionals, patients, or lay-man and within the environments where the devices will be used, such as hospitals, laboratories, or home settings. These requirements are reflected in the General Safety and Performance Requirements (Annex I) of both regulations, which specifically call for usability considerations in areas like labeling, instructions for use, device interface, and risk control.

Compliance is closely tied to standards such as ISO 62366-1 (Usability Engineering for Medical Devices) and ISO 14971 (Risk Management), ensuring that usability is systematically evaluated throughout design, risk management, and clinical evaluation. For IVDs, usability plays a crucial role in preventing misinterpretation of test results, ensuring that lay users and professionals alike can operate devices correctly and consistently.

In short, under EU MDR and IVDR, human factors and usability are not optional, they are mandatory requirements that must be addressed in the technical documentation, risk management files, and clinical/performance evaluation reports to achieve CE certification.

MDR 2017/745 Requirements on Human Factors & Usability

  • General Safety and Performance Requirements (Annex I)

    • Annex I, Chapter I, Section 5: Devices must be designed and manufactured in such a way that, when used under the intended conditions, they are suitable for their intended purpose and safe, taking into account the knowledge, experience, education and training, and the environment of the intended users. This directly requires considering human factors.
    • Annex I, Chapter II, Section 14.2 (c, d, e): Usability of controls, displays, and user interfaces must minimize use error. Instructions for use, training needs, and design elements must support safe use.
    • Annex I, Section 23.4 (IFU requirements): Information must be understandable by the intended user (patient, lay user, healthcare professional).
  • Integration with Risk Management

    • Human factors are tied to risk management per ISO 14971.
    • MDR requires identification and reduction of use related risks (errors due to design, labelling, IFU, etc.).
    • Risk benefit analysis must account for misuse risks foreseeable with normal use.
  • Clinical Evaluation / Performance Evaluation connection

    • Clinical data must show that users can operate the device safely and effectively.
    • Any user related issues identified in clinical investigations, PMCF (Post-Market Clinical Follow-up), or vigilance must feed back into usability updates.
    • Any user related issues identified in Performance evaluation Post Market Performance Follow Up (PMPF), or vigilance must feed back into usability updates.
  • Documentation in the Technical File

    Manufacturers must include a Usability Engineering File (per ISO 62366-1) inside the Technical Documentation:

    • User profiles (who will use it – clinician, patient, lay caregiver).

    • Intended use environments (hospital, home, ambulance, etc.).

    • Critical tasks and associated use errors.

    • Formative and summative usability evaluations.

    • Residual use related risks and mitigations.

    • Traceability between risk analysis (ISO 14971), usability findings, and final design

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service related FAQ’s

Can RegHelps handle PMCF for devices already on the market?2025-08-08T11:02:42+05:30

Absolutely. We can take over PMCF activities for devices already CE-marked and on the EU market, ensuring that your data collection, evaluation, and reporting fully meet MDR requirements — even if your existing documentation needs corrective action before the next Notified Body audit.

Is PMCF mandatory for all CE marked medical devices under MDR?2025-08-08T11:00:55+05:30

Yes. Under EU MDR 2017/745, PMCF is a mandatory and ongoing activity for all CE-marked medical devices, regardless of risk class. The extent of PMCF activities may vary depending on the device’s risk profile, clinical history, and available data.

Will your EC REP name appear on my product label?2025-08-05T10:22:35+05:30

Yes. According to MDR and IVDR requirements, the EC REP’s name and address must be clearly visible on the product labeling, outer packaging, or accompanying documents, allowing EU authorities to easily identify the representative.

Do you assist with Notified Body selection?2025-08-03T09:02:48+05:30

Yes. We help you identify the most suitable Notified Body based on your device type, risk class, and review timelines and support you throughout the submission and technical documentation review process.

Why UKCA Certification Matters for Medical Device Companies2025-08-06T09:44:10+05:30

After Brexit, UKCA replaced CE marking in Great Britain. Manufacturers must comply with MHRA rules to legally place devices on the UK market.

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