Regulatory Affairs • Health Canada

IP Rating & IEC 60601 Compliance Check

Published • • 13 min read

Working through a Health Canada regulatory update and applying 5-Whys showed that root-cause analysis surfaces the actual reason behind a recurring documentation gap, rather than just patching the symptom again.

A Health Canada regulatory update prompted a 5-Why exercise, and the technique did what it's supposed to: it stopped the review from patching the same symptom it had patched before.

Patching a symptom versus fixing a cause

A recurring documentation gap that gets patched the same way every time it appears is a sign the underlying cause was never actually found. 5-Whys forces the review past the immediate symptom to whatever keeps producing it.

Resolving the update required:
  • Verifying the specific regulatory requirement against the applicable market's current standard or guidance
  • Applying root-cause techniques (5-Whys) where a recurring gap needed resolving
  • Checking IEC 60601, Health Canada, and biocompatibility requirements against the actual current standard

Where the real risk was hiding

Assuming a compliance requirement is universal across markets when it is in fact market-specific leads to a missed requirement in one jurisdiction, the exact kind of assumption a root-cause review is built to catch.

What the root-cause review resolved

Completing the Health Canada regulatory update, using a 5-Why root-cause review to resolve the underlying documentation gap, meant the gap wouldn't just reappear at the next update cycle.

The Real Takeaway

Applying 5-Whys to a regulatory update surfaces the actual root cause behind a recurring documentation gap.

Rather than just patching the symptom again, which only guarantees the same gap resurfaces later.

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