AI Regulatory Affairs Specialist
An AI Regulatory Affairs Specialist ensures that AI- and ML-driven medical devices, digital therapeutics, and clinical decision-su…
Skill Guide
The systematic framework that applies ISO 13485's medical device quality management requirements to the unique lifecycle, verification, and risk management challenges of software and AI-based medical device software (SaMD).
Scenario
You are a QA engineer on a team developing an AI tool to detect skin lesions in smartphone images. Your manager asks you to start the DHF for this feature.
Scenario
Six months after launch, monitoring shows your AI algorithm's sensitivity for detecting diabetic retinopathy has degraded by 10% in real-world use, likely due to population data drift. A complaint has been filed.
Scenario
Your company is preparing a 510(k) submission for an AI-powered clinical decision support tool. You are the quality lead responsible for ensuring the QMS is inspection-ready for a potential FDA audit of your software development and risk management processes.
The core regulatory and normative stack for medical device software. ISO 13485 provides the QMS framework, IEC 62304 details software lifecycle processes, ISO 14971 governs risk management, and IEC 81001-5-1 addresses cybersecurity. Use them as binding requirements, not guidelines.
Purpose-built QMS platforms that manage controlled documents, design controls, traceability, and CAPA workflows. They are critical for maintaining a 'single source of truth' and demonstrating compliance during audits. Integrate them with development tools like Jira and GitHub where possible.
Systematic tools for hazard identification, risk estimation, and risk control. FMEA is used proactively during design, while FTA is used reactively to analyze known failure events. A well-structured RMF is the central, auditable output of ISO 14971 compliance.
Answer Strategy
Demonstrate a process-oriented mindset. The answer should connect SDLC phases directly to regulatory clauses. Sample: 'I'd start by mapping our SDLC phases to the Design and Development controls in ISO 13485 clause 7.3. I would define a Software Development Plan per IEC 62304 that specifies our process for requirements analysis, architectural design, unit implementation, and integration testing. For AI specifically, I would add a dedicated process for data management, model training, and performance validation, with clear entry/exit criteria. All activities would be traced in our design history file using a requirements management tool.'
Answer Strategy
Tests crisis management and knowledge of CAPA. The response must be procedural, not ad-hoc. Sample: 'Immediately, I would initiate a field safety corrective action (FSCA) if patient risk is imminent, in parallel with starting a formal CAPA per ISO 13485 clause 8.5.2. I would assemble a cross-functional team (engineering, clinical, regulatory) to perform a root cause analysis. The long-term fix would involve not just patching the model, but updating our training data validation protocols and implementing more robust post-market performance monitoring. The CAPA would be verified for effectiveness by showing the new controls prevent recurrence.'
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