Benefit-Risk Analysis is 医療機器の臨床的便益とリスクを比較して、意図した用途における受容性を判断する体系的評価。
Complete Guide to Benefit-Risk Analysis
Benefit-Risk Analysis is a critical regulatory requirement that systematically evaluates whether the clinical benefits of a medical device outweigh its risks for the intended patient population and use. This ongoing process is central to EU MDR compliance, ISO 14971 risk management, and global regulatory submissions.
Regulatory Requirements:
Benefit-Risk Analysis is explicitly required under EU MDR Article 61 and Annex XIV for clinical evaluation. The analysis must demonstrate that residual risks are acceptable when weighed against the benefits, and that benefits cannot be achieved with less risky alternatives. FDA also requires benefit-risk considerations in premarket submissions (510k, PMA), while other jurisdictions like Health Canada, TGA, and PMDA incorporate similar requirements.
ISO 14971 Integration:
The benefit-risk determination is the culmination of the ISO 14971 risk management process. After implementing risk control measures and evaluating residual risks, manufacturers must conduct an overall residual risk evaluation. This evaluation considers whether the medical benefits of the intended use outweigh the residual risks, and whether the overall residual risk is acceptable.
Clinical Benefits Evaluation:
Benefits must be scientifically substantiated through clinical data, including clinical investigations, literature review, and post-market clinical follow-up. Benefits can include improved health outcomes, reduced symptoms, enhanced quality of life, diagnostic accuracy, or therapeutic effectiveness. The evaluation must be specific to the target population and intended use, considering any special patient groups such as pediatrics or vulnerable populations.
Risk Assessment Component:
Risks encompass all potential harms, including known risks from clinical use, theoretical risks identified through risk analysis, and risks from similar devices. The analysis must address risk probability, severity, and acceptability criteria. Residual risks remaining after risk control measures must be justified against clinical benefits.
Acceptability Criteria:
Manufacturers must establish clear criteria for determining when benefits outweigh risks. This includes defining acceptable risk levels based on state of the art, considering risks of alternative treatments or no treatment, and establishing thresholds for different harm severities. The analysis must demonstrate that risks are minimized as far as possible while maintaining benefits.
Ongoing Evaluation:
Benefit-Risk Analysis is not a one-time assessment but an ongoing process throughout the device lifecycle. Post-market surveillance data, incident reports, and real-world clinical evidence must be continuously evaluated. If new risks emerge or benefits prove less than expected, the analysis must be updated and may trigger design changes or field safety corrective actions.
Documentation Requirements:
The benefit-risk analysis must be thoroughly documented in the clinical evaluation report and risk management file. Documentation includes benefit claims and supporting evidence, complete risk analysis and residual risks, justification for acceptability, consideration of alternative treatments, and conclusions supporting device safety and performance. This documentation is scrutinized during regulatory reviews and notified body assessments.
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