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by scruple 3700 days ago
I've thought about this a lot. I've had private conversations with the CEO which lead me to believe that their apathy is a, if not the, primary driver in this situation, at least within the company. Ultimately, they are the single individual who can force these changes in the departments. As things stand today, as far as I can tell, the CEO and the rest of the executive team got theirs and that's that. Anything extra is just that, extra.

We've been close to undergoing "major" scrutiny (as it was sold to me, it was A Big Deal) from the FDA before. I, personally, just a lowly and underpaid engineer, have saved executive staff from having to sign their names on that noose. I had a manager once who seemed to want to push it that far, to stand idle-by while the walls fell down around us. I, unknowingly at the time, prevented it from happening because I was trying to help our customers. I don't regret that decision, actual patients shouldn't have to suffer because of a management teams ineptitude. I do think about it often, though. I understand this is nebulous, and I'm sorry for that. This is a reality, though.

I guess that's the thing that really gets me, the FDA. We sell FDA approved devices. Where the fuck is the FDA? We send them paperwork and they are happy. I can only form the opinion that they, the FDA, are ill prepared to handle this situation; The actual situation, the "the medical devices industry is a fucking train wreck waiting to happen" situation, and especially so they are ill prepared to handle it at scale. Audits are cursory and almost as a rule non-technical. I suppose it'll take a Toyota-level incident to bring change about.

3 comments

Along the same lines as your 'where the fuck is the FDA' comment -- I've worked in Financial and Healthcare systems on and off for about the last 10 years.

I have seen SSAE16 audited companies that haven't patched anything in years. FDIC examined institutions with ATM machines still running OS/2 Warp(actually probably more secure than the ones running XP, with no updates installed. Ever.)

I once found the management interface of a SAN with a public IP address directly on the device, no firewall rules of any sort, and the device still had the default username/password. It hadn't been patched or rebooted in over 2 years.

More shocking is that a review of the logs didn't show any successful unauthorized logins. Of course, they could have cleaned up after themselves, but further investigation was outside the scope of my engagement(They didn't want to know. They were happy to present that, despite the oversight, there was no indication that PHI had been accessed by unauthorized people. Their conclusion, not mine.)

I can't help responding again. If you have tangible evidence of neglect or regulatory non-compliance, or even risks that are known about but not being dealt with by management - have you considered compiling this material and and reporting it to the FDA?

But as I've said before - I really hope you have written down your concerns to someone in management. If it gets to the point where negligence takes out the company, there's going to be an attempt to make someone a scapegoat. Depending on your role in the company you don't want to be held personally liable for the incompetence and ruthlessness of management...

>Where the fuck is the FDA? We send them paperwork and they are happy.

When regulation becomes more about permission than proficiency, you'll get corruption instead of competence.