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Medical Devices IVDs FDA Guidance IVD Point-of-Care · Laboratory Systems

Usability Engineering According to IEC 62366-1 – Safe to Use, Regulatorily Compliant

Metecon supports you in setting up usability engineering in accordance with IEC 62366-1 so that the context of use, use-related risks, user requirements, and development work together consistently—usability engineering with logical traceability throughout the entire product life cycle. From the use specification to the summative evaluation, we guide you every step of the way—for medical devices and in-vitro diagnostic medical devices.

10+ years of IEC 62366-1 expertise · Medical Devices MDR · In-Vitro Diagnostics IVDR
25+
years of experience in usability engineering
150+
usability files (UEF)
IEC 62366 &
FDA HFE
IVD usability
30+
formative and summative studies organized

Usability According to IEC 62366-1: Usability Engineering as Part of Product Safety

Usability engineering helps to systematically identify and assess user-related risks and reduce them through safe interface design. IEC 62366-1 describes the internationally recognized process for this purpose.

Three Problems We Solve with Usability Engineering

Our USP: Usability with transparent traceability—product design, product safety, and usability consistently integrated.
What this means for you in concrete terms and how Metecon supports you in this regard:

Usability Engineering Comes Too Late

If you don’t begin your usability activities until shortly before approval, they will lead to delays in the approval of the medical device, since usability aspects—as late-stage requirements—may need to be incorporated into the product design.

Metecon works with you starting in the development phase and plans your activities across the entire product life cycle.

Use-Related Risks Remain Isolated

If use-related risks are not consistently incorporated into your risk management and development decisions, your product will not meet regulatory requirements.

Metecon seamlessly integrates usability activities, risk management, and development for you—with end-to-end traceability.

Insights Are Lost

If results from formative and summative activities are not consistently incorporated into development and documentation, knowledge is lost.

Metecon provides tailored support to help all stakeholders implement regulatory requirements.

Usability

A characteristic of the user interface that enables its intended users to achieve their goals effectively, efficiently, and with the required level of satisfaction within the specified usage environment.
IEC 62366-1 requires that use-related risks be systematically identified, assessed, and controlled. This includes, in particular, addressing use errors and use scenarios in which the design of the user interface or the use context may contribute to misuse.

Use Error & Use-Related Risk

A use error is an action or omission during use that leads to a result different from that intended by the manufacturer or expected by the user, and that may thus contribute to a hazardous situation.
IEC 62366-1 and ISO 14971 focus on the systematic management of use-related risks through the design of the user interface and the provision of appropriate safety information, taking into account the context of use and foreseeable misuse.

Usability Engineering According to IEC 62366-1: 7 Steps to Usability Documentation

1

Specification for Use
medical indication, patientpPopulation, user profile, use environment, operatingpPrinciples
2

Usage Requirements
as part of the interface requirements (interface collection of requirements) use cases
3

Risk Assessment
(interface with risk management)
identification of potential use errors, foreseeable hazards and hazardous situations, and hazard-related use scenarios—ISO 14971
4

UI Design
implementing risk mitigation measures in the product
5

Formative Evaluation
tests conducted throughout development to identify at an early stage any risk-related issues in the implementation of the product’s user interface
6

Summative Evaluation
validation of the risk-free nature of hazard-related use scenarios
7

UEF
finalization of the UEF with all required content

Comprehensive Analysis of the Product from a Usability Perspective

The use specification according to IEC 62366-1 §5.1 begins with a precise description of use, the use environment, and user groups. Reviews often reveal that when only the “operator” is considered, safety-related interactions involving preparation, installation, cleaning, maintenance, or administration are overlooked. This is precisely where gaps arise in critical tasks, use scenarios, and use-related risks—and thus lead to follow-up questions in the usability file. Metecon helps counteract the sometimes unavoidable “operational blindness” in this area, thereby ensuring a more practical and comprehensive assessment of usability.

  • Personas as a Method for Further Characterizing Product Users: To make user profiles more accessible in regulatory work, Metecon develops a persona for each user profile. Naturally, care is taken to ensure that, in addition to the primary users, supporting roles are also taken into account in both the personas and the user profiles.

Usability Documentation in Accordance with IEC 62366-1 and FDA HFE

The usability documentation can be structured in such a way that requirements from IEC 62366-1 and FDA Human Factors Engineering are clearly reflected. However, country-specific considerations regarding applicability may need to be incorporated as necessary.

How Metecon Supports You – Usability Services at a Glance

Available as individual add-ons or as ongoing support throughout the entire usability process—tailored to your project’s current stage.

Usability Engineering File (UEF)

Structured documentation of usability in accordance with IEC 62366-1, including the use specification, risk identification, and formative and summative results.

Risk Assessment of Usability

Evaluation of usability aspects in risk analysis, including the presentation of results in risk management and usability documentation in compliance with regulatory requirements.

Formative Evaluation (Protocol & Report)

Assessment of user interfaces throughout the development process through formative evaluation (e.g., by supporting and documenting expert reviews or formative usability tests).

Summative Evaluation

Planning and support for summative usability testing in accordance with IEC 62366-1, including test protocols, evaluation, and documentation of results.

FDA Human Factors Engineering

Consideration of FDA HFE requirements when structuring performance documentation and summative evaluations, including country-specific considerations.

Usability Engineering for Medical Devices in Accordance with the MDR

Use Specification, Usability Risk Assessment, and formative and summative evaluation in accordance with IEC 62366-1— for use-related safety and traceable usability documentation in accordance with the MDR.

MDR Annex I: Usability as a Fundamental Safety and Performance Requirement

MDR Annex I requires that risks associated with use be eliminated or minimized through appropriate product design. EN 62366-1 describes the recognized usability engineering process for this purpose.

Formative Evaluation: Support for Usability Testing Throughout the Development Process

Formative evaluation accompanies the development process and helps identify use-related issues early on.

The results are incorporated into the design of the user interface, use scenarios, and safety-related activities.

Formative
Heuristic Evaluation
Experts evaluate the user interface based on established usability principles. This method is particularly well-suited for identifying early weaknesses in the user interface design without the need for time-consuming user testing.
Formative / Summative
Think-Aloud Test
Users speak aloud during use, describing what they perceive, expect, and decide. This allows for the early identification of comprehension issues, misinterpretations, and potential use errors.
Formative
Cognitive Walkthrough
Testers analyze use scenarios step by step from the user’s perspective—especially in situations where use errors could have safety implications.
Formative
User Surveys and Interviews
Structured user survey regarding their expectations, experiences, and perceived difficulties. Complements observational methods and helps to better understand use contexts.
Formative / Summative
Simulation
Simulation of realistic application scenarios, e.g., involving emergency equipment or safety-critical operating procedures. This allows for the testing of use scenarios that would be difficult to test in a real-world healthcare setting.

Summative Evaluation: Testing the Usability of the Final Product

The summative evaluation uses a representative sample of users to determine whether safety-related tasks can be performed effectively on the final product under realistic conditions.

Summative Evaluation with Representative Users

Number of Participants and User Group Planning

IEC 62366-1 does not specify a fixed number of subjects. What is crucial is that the relevant user groups, use contexts, and safety-related tasks are adequately represented. The data set generated in this way must make it possible to derive statistically significant conclusions regarding the product’s safety in its intended context of use.

Test Plan, Scenario Plans, and Definition of Activities

Identified hazard-related use scenarios are justified (risk-based) and taken into account in the summative evaluation: use scenarios under realistic conditions, defining success criteria, and systematically recording use errors. Metecon prepares comprehensive test plans—compliant with IEC 62366-1 and FDA regulations.

Coordinating External Labs—No Need for an In-House Usability Lab

Metecon assists with planning suitable test environments and coordinates external usability labs as needed. What matters most is a representative use context—not necessarily a certified lab space.

Summative Evaluation Report and Final Statement

The results of the summative evaluation are documented in a transparent manner and prepared for inclusion in the usability documentation.

Identification and Assessment of Risk-Related Use Scenarios: The Interface Between Usability and Risk Management

In risk management, the product’s risk context with regard to its use is examined from various perspectives. This approach is also reflected as such in the standard.

Identification of potential use errors, taking into account the product’s primary operating function. Here, user interface characteristics are typically first examined formally using a checklist to assess their potential impact on the product’s safety. Furthermore, these safety-related characteristics of the user interface are examined, together with the use specification, for potential use errors.

Identification of foreseeable hazards and hazardous situations related to the use of the product as part of the product’s risk analysis.

The identified hazard-related use scenarios are documented along with the associated tasks (including sequence), severity level, and associated harm. These hazard-related use scenarios are selected, with justification, for further investigation in a summative evaluation.

Usability Documentation in Accordance with IEC 62366-1

Required Content of the Usability Documentation According to IEC 62366-1

The usability documentation includes, among other things, the use specification, use errors, hazard-related use scenarios, results of formative evaluations, and the planning and results of the summative evaluation.

The goal is to provide a transparent overview of the usability engineering process in accordance with IEC 62366-1. Additional human factors requirements may be relevant for international target markets. Metecon assesses whether existing IEC 62366-1 documentation needs to be expanded to address these requirements.

FDA Human Factors Engineering

For manufacturers with access to the U.S. market, FDA HFE requirements must also be taken into account.

The documentation can be structured in such a way that it consistently reflects both IEC 62366-1 and FDA Human Factors Engineering requirements.

IEC 60601-1-6 for Active Electrical Medical Devices

For active electrical medical devices, IEC 60601-1-6 may also be relevant.

It refers to IEC 62366-1 and supports the usability assessment of electrical devices and user interfaces.

SaMD & Software Usability: The Interplay Between IEC 62366-1 and IEC 62304

For software that is a medical device and for software embedded in a product, on-screen sequences, error messages, navigation, and user guidance contribute to the product’s risk.

IEC 62366-1 supports the assessment of software-based use scenarios and potential use errors.

IEC TR 62366-2: User Guide for IEC 62366-1

IEC TR 62366-2 provides practical guidance and examples for implementing IEC 62366-1. Metecon uses this technical report, among other resources, as a guide for practical usability engineering documentation.

Standards & Guidelines: Usability Engineering for Medical Devices (MDR)

  • EN 62366-1 – Application of usability engineering to medical devices (State of the Art)
  • IEC TR 62366-2:2016 – Technical Report: application guide to IEC 62366-1
  • EN 60601-1-6 – Usability of active electrical medical devices (horizontal standard)
  • MDR (EU) 2017/745 – Annex I, No. 5: usability as a GSPR requirement
  • ISO 14971:2019 – risk management interface ↔ (IEC 62366-1, 5.4)
  • ISO 9241:2019 – ergonomics of human-system interaction (reference: IEC 62366-1)
  • EN 62304 – software life cycle for medical devices (SaMD usability interface)

Usability for IVDs in Accordance with the IVDR and IEC 62366-1

IVD place special demands on usability engineering: User profiles range from professional laboratory personnel to medical laypeople in near-patient testing (point-of-care, POC) and self-testing.

PoC and self-tests are critical to usability:

For IVDs used in point-of-care or self-testing settings, safety depends not only on the performance of the test, but also on whether users handle specimens correctly, follow the procedure, and interpret results accurately. For these user groups and usage contexts, use-related risks must be systematically identified and controlled. It is crucial that the user interface, information on safe use, and risk controls work together consistently and are documented in a traceable manner. Metecon translates your intended user groups and application scenarios into a robust use specification, derives critical tasks and use-related risks from it, and documents the evidence trail in a traceable manner in the usability file—coordinated with risk management and the instructions for use.

IVD Usability: Three User Groups with Different Needs

1

Professional Laboratory Users

High-throughput analyzers and clinical laboratory systems: The focus is on multi-user scenarios, LIMS integration, and stable routine processes.

2

Point-of-Care (POC) – Healthcare Professionals

Point-of-care applications (near-patient testing) in emergency rooms, doctors’ offices, or nursing settings require clear operating procedures, robust user guidance, and easy-to-understand result presentation—often under time pressure.

3


IVD for Self-Testing (Laypersons)

IVD for self-testing are performed by laypersons without specialized medical training. Sample collection, test administration, and result interpretation must therefore be designed to be particularly clear and error-tolerant.

Usability for Point-of-Care Tests and Self-Testing: Clear Workflows for Different User Groups

Point-of-care tests and devices for self-testing require a precise use specification: user groups, context of use, sample handling, and interpretation of results must be described realistically and taken into account in the evaluation. Metecon addresses this specific user profile as a separate use specification.

Point-of-Care Tests and Self-Testing: Requirements for Usability Evaluation

Use Specification for Lay Users According to IEC 62366-1 and IVDR

For self-testing devices, the target users, use situations, and typical limitations must be described realistically—such as use at home, limited experience, stress, or impaired motor skills. This results in relevant use scenarios for the evaluation.

Safety-Critical Tasks in Self-Testing: Focus on Risk Analysis

Typical use errors regarding devices for self-testing involve sample collection, test administration, waiting times, or result interpretation. These use scenarios should be described in a structured manner in the UEF and addressed through appropriate interface and information design.

Summative Evaluation with Lay Participants

Summative evaluations for self-administered tests should reflect a representative sample of lay users and realistic use scenarios. Metecon provides support with test planning, defining user groups, and evaluating the results.

Laboratory System Usability: High-Throughput Analyzers and Multi-User Scenarios

The specific ways in which users interact with the products must be taken into account in the use scenarios, such as continuous use of the product across shifts, during parallel work processes, and when user roles change.

Laboratory System Usability: Requirements for Clinical Laboratory Analyzers

Use Scenarios for High-Throughput Laboratory Systems

Clinical laboratory systems have complex user profiles and use scenarios: routine operations, malfunctions, maintenance, shift changes, and multi-use scenarios.

Metecon develops use specifications that clearly map these use contexts and systematically document safety-related tasks.

Multi-user and Shift Operations

Multi-user scenarios and shift changes affect operational procedures, responsibilities, and the handoff of information.

These use situations should be taken into account in use cases and evaluations.

LIMS Integration and Software Usability

For laboratory analyzers, data entry, result transmission, and error messages are particularly important.

Usability considerations should ensure that user guidance and feedback are clear and unambiguous.

Standards & Guidelines: Usability of IVDs / IVDR

  • IVDR (EU) 2017/746 – Annex I: General safety and performance requirements for IVDs
  • EN 62366-1:2015 + COR1:2016 + AMD1:2020 – Medical Devices – Part 1: Application of usability engineering to medical devices
  • IEC TR 62366-2:2016-04 – Medical devices – Part 2: Guidance on the application of usability engineering to medical devices (including IVD examples)
  • ISO 9241-306:2018 – Ergonomics of human-system interaction
metecon-stefan-kemmann

Stefan Kemmann

Team Lead, Regulatory Affairs & Technical Documentation · Metecon GmbH

Stefan Kemmann leads the Regulatory Affairs & Technical Documentation team at Metecon and has extensive expertise in usability engineering in accordance with IEC 62366-1. The usability experts at Metecon support manufacturers from the analysis of the usage environment through to summative evaluation, closely linking the usability process with risk management to ensure that the effort contributes effectively to the safety of the user-product interface.

"If you don’t factor in usability engineering during development, you’ll end up facing costly surprises. Through consistent risk management and by leveraging all available usability tools, we help you get a firm handle on the processes and documentation required for submission."

– Stefan Kemmann, Team Lead, Regulatory Affairs & Technical Documentation, Metecon

Frequently Asked Questions About Usability for Medical Devices and IVDs

How does early usability engineering shorten development time and ensure product success?

Those who correctly identify the context of use and application-specific risks early in the design and development phase and later can avoid costly redesigns shortly before approval. Formative activities uncover usability weaknesses during development, while changes can still be made cost-effectively. Metecon takes all regulatory requirements into account from the very beginning, ensuring that summative validation does not become a surprise at the end.

How can usability engineering be structured so that future product changes do not result in a disproportionate amount of work to document them?

The key is to consistently link the use specification, risks, and supporting evidence. If these are clearly linked, it is possible to specifically assess which supporting evidence is affected when a change occurs—rather than having to collect everything from scratch. Metecon creates the usability file in a way that allows for updates, with traceability between risk management, requirements, and usability content.

How can you tell if a usability report that is complete in form is also substantively sound?

Completeness alone is not enough: What matters is whether safety-critical tasks, application-specific risks, and findings from formative and summative evaluations are clearly linked. Where usability is not integrated with risk management, the Notified Body will raise questions. Metecon thoroughly examines precisely this soundness—not merely the presence of the documents.

When should you outsource usability engineering—and when can it be handled in-house?

Formative evaluation activities can often be conducted internally. External support is worthwhile when integrating usability aspects with risk management and during summative evaluation with representative users. Metecon provides support on an ad hoc or ongoing basis, including coordination of external usability labs, without requiring you to maintain your own infrastructure.

What are the consequences if the results of the summative evaluation are not linked to risks, requirements, and development decisions?

In that case, the final declaration regarding usability is open to challenge: The Notified Body cannot verify whether application-related risks are effectively controlled. This leads to additional inquiries and, in the worst case, to retesting. Metecon ensures end-to-end traceability between the summative evaluation and application-related risks.

How do you incorporate findings from PMS, vigilance, or product changes into existing usability documentation?

Reports of errors when oprating the product during the market phase serve as the basis for the risk assessment and, if necessary, revisions regarding the product’s usability. Without clear traceability, the documentation and the actual product will drift apart. Metecon structures the usability file so that PMS and vigilance findings are incorporated in a structured manner.

What distinguishes usability engineering from a simple usability test—and why is this crucial for medical devices?

A test is a one-time assessment; usability engineering is a continuous process that spans from the use specification through formative to summative evaluation—integrated with risk management. This is the only way to demonstrably manage risks associated with the product’s use. Metecon structures this very process in accordance with IEC 62366-1.

Which factors determine the cost and scope of usability engineering projects?

Key factors include the product’s risk class and safety in use, the number of user groups (e.g., trained professionals vs. laypeople), the scope of summative studies, and the target markets (e.g., MDR/IVDR and/or FDA, or other international markets). Metecon begins with a concise assessment and then provides a detailed proposal—the free initial consultation is the first step.

Ready for your NB-compliant usability file?

Start with a free initial consultation, and we’ll provide you with a clear assessment—whether it’s a use specification, formative, or summative evaluation.

Your contact:

Milan Weiß
Sales Manager
T: +49 621 123469-040
milan.weiss@metecon.de

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