A medical device engineer reviews test data on a computer while evaluating a wearable infusion system in a medical equipment testing laboratory
28 Sep 2026

A More Product-specific Approach Will Reshape Medical Device Safety Evaluations

Work on the fourth edition of IEC 60601-1 is still underway, and publication is not expected for several years. Even so, the direction of the standard is becoming clearer.

Manufacturers beginning new product development programs should pay attention now, particularly when designing equipment that may remain on the market well into the next decade. The fourth edition is expected to reflect a medical technology landscape that has changed significantly since the current structure was developed. Devices are more connected, more mobile, and more likely to operate outside traditional clinical settings. They may exchange data with other equipment, depend on remote communications or incorporate varying levels of autonomy.

Addressing these developments requires more than adding a few new tests. The standard is being reorganized around a more detailed understanding of the product, its users, its operating environments and the conditions it may encounter throughout its expected lifetime.

Bringing Requirements into a More Cohesive Structure

One of the most substantial proposed changes is the integration of requirements currently found in collateral standards into the general IEC 60601-1 framework. Requirements addressing electromagnetic disturbances, alarms, X-ray equipment, and other subjects would become part of a more unified structure.

At first glance, this could make an already extensive standard appear even more complex.

The longer-term objective, however, is to make the requirements more relevant to the individual product. A future digital implementation could allow a manufacturer to define its device and generate a tailored collection of applicable requirements. Instead of reviewing multiple documents and determining which clauses apply, the manufacturer could work from a product-specific set of requirements that connects more directly with its design and compliance documentation.

This approach could also reduce some of the uncertainty created when the general standard and its collateral standards are revised or adopted on different schedules. The transition will require careful coordination, but the intended result is a more cohesive compliance framework.

Intended Use Will Require Greater Precision

The fourth edition is expected to place increased emphasis on the device’s use specification. Manufacturers will need to describe more precisely who will use the equipment, who will receive treatment, where the product will operate and what conditions may influence its safety or essential performance.

Patient population is an important part of this discussion. A device may be intended for neonatal, pediatric, adult, or geriatric patients, and differences in physical size, weight, and physiological characteristics can affect its requirements. The standard is also considering veterinary applications, where assumptions developed for human patients may not always be appropriate.

These details should not be treated as information added after the design is complete. They can influence materials, protective measures, usability controls, accessories, and the test program itself.

A well-defined use specification helps the manufacturer and testing laboratory establish a more relevant evaluation. It may identify tests that are essential for one product while supporting a documented rationale for why other tests do not apply. By making these decisions earlier, manufacturers can build a clearer connection between intended use, risk management, and the eventual compliance program.

Medical Environments are Becoming More Varied

The distinction between a hospital and a home is no longer enough to describe where medical equipment may be used. The fourth edition is expected to recognize a broader range of environments within professional healthcare facilities as well as less controlled settings outside them.

Within a hospital, equipment may be used in general treatment areas, critical care spaces, protective environments, isolation areas, or rooms with specialized hazards. An MRI installation, for example, can include technical, operator, and examination areas with very different access restrictions and safety considerations. Equipment entering the examination room may also need to be assessed for hazards associated with the magnetic field.

Protective clothing can change the use environment as well.

If healthcare personnel are wearing masks, face shields, goggles, or other personal protective equipment, can they still see warnings, read displays, and operate controls correctly? A safety feature that works under ordinary conditions may become less effective in a restricted or protective area.

Home use is similarly broad. A portable oxygen concentrator may be used in a living room, in a vehicle or outdoors for several hours. Outdoor exposure introduces sunlight, temperature changes, moisture, and ultraviolet radiation that may affect enclosure materials, displays, or other safety-related features.

Manufacturers should consider how people will realistically use the device, not simply where its labeling says the device belongs.

Connectivity Introduces New Dependencies

Medical devices increasingly interact with other equipment, networks, applications, and infrastructure. Their functional connections can include electrical interfaces, data communications, gas lines, water lines, and numerous other physical or digital inputs.

Each connection may create a new dependency or failure condition. Manufacturers will need to determine what happens when another device provides incorrect information, a connection is interrupted, or supporting infrastructure becomes unavailable.

Remote operation deserves particular attention. A connected device may perform well in a controlled environment with reliable broadband and cellular service, but that assumption does not hold everywhere. Rural communities and other underserved areas may have limited bandwidth, intermittent coverage, or no dependable connection at all.

A medical device should therefore be assessed for the consequences of delayed, degraded, or lost communications. If a remote consultation is interrupted, important information could be missed. If a device depends on cloud connectivity, manufacturers need to understand which functions remain available when that connection fails and whether the device continues to provide an acceptable level of safety.

Connectivity can expand access to care, but it also makes communications infrastructure part of the product’s real-world operating environment.

Autonomy and AI Remain Moving Targets

The fourth edition is also being developed during rapid advances in artificial intelligence and autonomous medical systems. Autonomy can range from conventional equipment controlled by a healthcare professional to systems capable of performing increasingly complex actions with limited human involvement.

Standards developers must account for these technologies without trying to predict every future application. AI is especially challenging because its capabilities, uses and regulatory treatment continue to evolve.

Manufacturers should not wait for a standard to define every answer.

They need to establish the boundaries of an AI-enabled function, identify the decisions it can make, and document where human oversight remains necessary. Basic safety and essential performance still depend on understanding what the product does, how it can fail, and what risks result from those failures. As autonomy increases, the assumptions behind those safety determinations will need to become more explicit.

Expected Lifetime Needs Supporting Evidence

The fourth edition is expected to clarify the concept currently known as expected service life, with greater focus on the period during which the device can remain compliant with its applicable safety requirements.

Declaring a five-year expected lifetime does not necessarily mean the product must be removed from use after five years. It means the manufacturer should have evidence supporting the device’s ability to maintain safety and essential performance over that period.

Evidence may come from accelerated aging, real-life simulations, engineering calculations, historical performance data, or post-market experience. The appropriate approach will depend on the product, its materials, its critical components, and the conditions under which it is expected to operate.

Components must also be considered. If a critical power supply has supporting documentation for three years but the finished device claims five years, the manufacturer must address that difference through additional evidence, maintenance, replacement, or risk management controls. A component’s certification does not automatically demonstrate that it will remain suitable throughout the finished device’s declared lifetime.

Preparation Can Begin Today

Manufacturers do not need to wait for the final fourth edition to improve their readiness. A valuable starting point is to create a product safety test plan similar to the planning already performed for EMC evaluations.

That plan should define the intended patient populations, users, use environments, functional connections, expected lifetime, and reasonably foreseeable conditions of use. It should also connect these factors to risk management, essential performance, and the proposed evaluation strategy.

Starting this work early can reveal gaps that might otherwise remain hidden until formal testing begins. It can also help engineering, regulatory, and compliance teams make decisions from the same set of product assumptions.

The fourth edition is still developing, and individual requirements may change. Its overall direction is clear, however. Future compliance will depend on more complete product definitions, stronger supporting evidence, and a safety evaluation tailored to how the device will actually be used.

Manufacturers that begin building that foundation now will be better positioned when the new edition arrives.

Headshot of Todd R. Konieczny
Todd Konieczny

Regional Quality Manager and Corporate Laser Safety Officer

Todd has been with Intertek for more than 25 years, helping many manufacturers around the world navigate the complexities of product safety and compliance. His areas of expertise include the 60601/60825/61010/80601 series of standards, and he is a Satellite Lead Assessor and IECEE Technical Assessor. Todd is a participant in numerous AAMI and IEC Technical Committees, including IEC TC62 which is currently developing the 4th Edition of 60601.

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