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168   Safety Risk Management for Medical Devices


                usually English, and then translated to other languages. The problem is that not all
                concepts can be directly translated from one language to another. Here are some
                examples of potential sources of confusion in translations:

                   English: Bend the wire into a J, or hockey stick shape
                   Problem: Many languages don’t have the letter J. Many cultures are unfamiliar with
                   hockey.
                   English: When the alarm goes off do .. .
                   Problem: Does this mean when the alarm begins, or when the alarm ends?

                   Sometimes a translated word has one connotation in one geography, and another
                in a different geography. French in France is not the same as French in Canada;
                Portuguese in Portugal is not the same as Portuguese in Brazil, and English in the
                United States is not the same as English in the United Kingdom. For example:
                   First Floor
                   United States: Ground floor
                   United Kingdom: the floor above the ground floor
                   Chips
                   United States: Thinly sliced, deep-fried, baked, or kettle-cooked crunchy potatoes
                   (crisps in the United Kingdom)
                   United Kingdom: Cut and deep-fried potatoes

                   Another element of the guidance from Guide 51 [1] is conciseness and unambigu-
                ity. This is a challenge for technical writers, particularly with respect to product label-
                ing and screen user interfaces where space is limited.
                   As stated earlier, an important requirement for information for safety is that it
                must be demonstrated to be effective. This demonstration is typically done as part of
                summative usability testing. Through objective evidence, it must be shown that users
                will refer to, comprehend, and use the information for safety, such that it produces
                the expected reduction in risk.



                18.5 SAMPLE RISK CONTROLS

                Risk Controls should be a narrative to a specific action. Each Risk Control can be
                implemented via various means, such as System Requirements, operating procedures,
                and conformance to recognized standards. Some example Risk Controls that can be
                used as models are as follows:

                   • The device is designed to withstand up to 10 N of tensile pull-force
                   • The GUI is designed to minimize erroneous button pushes
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