
Introduction to Medical Device Usability Testing
1. Basic Concepts
Usability: As defined in IEC 62366-1, the characteristic of the user interface that facilitates use and thereby establishes effectiveness, efficiency and user satisfaction.
Usability Engineering (UE) / Human Factors Engineering (HFE): a systematic approach to applying usability principles to medical device design, aiming to reduce the risks caused by use errors by optimizing user–device interaction.
Core purpose: to ensure that the medical device is safe and effective when operated by intended users in the intended use environment, with acceptable use error risk.
2. Key Regulations and Standards
| Standard/guidance | Content |
|---|---|
| IEC 62366-1:2015 + A1:2020 | Application of usability engineering to medical devices (international) |
| IEC/TR 62366-2:2016 | Guidance on the application of usability engineering (technical report) |
| FDA HFE Guidance (2016) | Applying Human Factors and Usability Engineering to Medical Devices |
| FDA Draft Guidance (2022) | Draft guidance on the content and format of human factors information in 510(k) submissions |
| ANSI/AAMI HE75 | Detailed guidance on human factors engineering in medical device design |
| YY/T 1474 | Chinese equivalent standard (identical adoption of IEC 62366-1) |
| MDR (EU) 2017/745 | Usability requirements of the EU Medical Device Regulation |
3. Key Terms
| Term | Meaning |
|---|---|
| Intended user | Clinicians, nurses, patients, caregivers, etc. |
| Use environment | Operating rooms, ICUs, homes, emergency scenes, etc. |
| Use scenario | Description of the specific situation in which the user performs a task |
| Critical task | A task that, if performed incorrectly, could result in serious harm |
| Use error | A user action resulting in an outcome different from that intended |
| Use-related risk | Risk associated with user interaction |
| User interface (UI) | Includes hardware, software, labeling, IFU, training materials, etc. |
4. Usability Engineering Process (IEC 62366-1)
1. Prepare the use specification ↓ 2. Identify hazards and hazardous situations related to the user interface ↓ 3. Identify critical tasks ↓ 4. Establish the user interface specification ↓ 5. Establish the user interface evaluation plan ↓ 6. User interface design, implementation and formative evaluation ↓ 7. Summative evaluation ↓ 8. Compile the usability engineering file (UEF)
5. Two Core Types of Evaluation
1. Formative evaluation
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Timing: early and middle stages of product development; multiple rounds possible
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Purpose: find design flaws and improve iteratively
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Sample size: 5–8 participants per user group (finds 80%+ of usability problems)
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Methods: cognitive walkthrough, heuristic evaluation, usability testing, expert review
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Use of results: input to the next design iteration; not used for final validation
2. Summative evaluation
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Timing: after design freeze and before market launch
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Purpose: validate that the user interface design adequately controls use-related risks
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Sample size: at least 15 participants per user group (FDA requirement)
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Method: simulated use testing
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Requirements:
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Conducted in a representative use environment
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Using the final or production-equivalent product
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Must cover all critical tasks
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Followed by root-cause interviews (to analyze the causes of use errors)
6. User Groups
Different user groups must be tested separately. Common groupings:
| Grouping dimension | Examples |
|---|---|
| Profession | Physicians, nurses, technicians, patients, family members |
| Experience | Novices, experienced users |
| Use environment | Professional hospital use, home use |
| Physical characteristics | Users with limited vision, hearing or dexterity |
For example, a home blood glucose meter may involve two groups – patients + caregivers – each requiring ≥15 participants.
7. Identifying Critical Tasks
Critical tasks are the core of usability testing and are identified based on:
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Risk analysis (ISO 14971): tasks where use errors could cause serious harm
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Historical data: adverse events, recalls and complaints for similar products
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Task analysis: breaking down the user’s operating workflow
Typical critical task examples:
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Infusion pump: setting the correct dose and rate
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Defibrillator: selecting the correct energy and delivering the shock
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Insulin pen: loading the cartridge, setting the dose, injecting
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Blood glucose meter: sampling blood, reading results, recognizing abnormal values
8. Test Methods and Data Collection
Common methods
| Method | Applicable stage | Description |
|---|---|---|
| Simulated use testing | Formative/summative | Completing tasks in a simulated environment |
| Cognitive walkthrough | Formative | Experts analyze the user’s reasoning step by step |
| Heuristic evaluation | Formative | Reviewing the interface against usability principles |
| Interviews/questionnaires | Throughout | Collecting subjective feedback |
| Observation | Throughout | Recording actual user behavior |
Key data to record
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Task completion (success/failure/partial success)
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Completion time
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Use errors, close calls and operational difficulties
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Subjective user feedback (SUS scale, NASA-TLX, etc.)
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Video/audio recordings
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Post-test interviews (root-cause analysis of errors)
9. Usability Engineering File (UEF)
Key documents to retain:
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Use specification
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User interface specification
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Known problems analysis (similar marketed products)
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List of hazard-related use scenarios
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List of critical tasks
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Formative evaluation reports
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Summative evaluation report
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User interface evaluation plan and results
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Training materials, IFU, labeling
10. Differences Between FDA and IEC 62366
| Dimension | IEC 62366-1 | FDA HFE Guidance |
|---|---|---|
| Focus | Safety risks caused by use errors | Safety and effectiveness of critical tasks |
| Known problems analysis | Not mandatory | Mandatory (analysis of similar products) |
| Summative test sample size | Not specified | ≥15 participants per user group |
| Test report format | Relatively flexible | Detailed template requirements |
In practice, we recommend following the FDA requirements, which satisfies both.
11. Common Challenges and Recommendations
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Recruiting users is hard: recruiting professional users (e.g. surgeons) takes time and must be planned early
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Environment simulation: recreate real use conditions as closely as possible (lighting, noise, stress)
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Defining use errors: “success” and “failure” criteria must be clearly defined
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Root-cause analysis: don’t just record “user error” – dig into the causes (knowledge, perception, cognition, action)
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Design changes: significant changes after summative evaluation may require retesting
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IFU and training: usability problems cannot be solved by relying on the IFU; the design itself must be safe