Who Uses STPA in Medical Devices

Manufacturers, pharmaceutical companies, regulators, standards bodies, certification houses, and hospitals have applied STPA to devices (insulin pumps, defibrillators, radiotherapy systems, surgical robots, diagnostics) and to the safety processes around them.

Page Overview

The Evidence

  1. 1
    The State of STPA in Medical Devices

    Where STPA stands with manufacturers, regulators, standards bodies, and hospitals, in six points.

  2. 2
    Manufacturers, Regulators & Standards Bodies

    Medtronic, the FDA, Roche, UL, and others, with their published STPA work.

  3. 3
    Commercial Devices Analyzed with STPA

    Radixact, Varian, and other named products, and a decade of STPA in radiation oncology.

  4. 4
    Specific Medical Devices, Analyzed with STPA

    From a cochlear implant and an analgesia pump to AI/ML-enabled devices.

The Wider Field

  1. 5
    Tooling & Standards Maturing Alongside the Practice

    Commercial tools for STPA, SAE’s STPA recommended practice, and the medical-device supplement in development.

  2. 6
    Organizations That Report Using STPA

    Device makers, regulators, and hospitals that report using STPA.

  3. 7
    The STAMP Community

    Device companies that have taken part in the MIT STAMP Workshop.

Part 1 of 7

The State of STPA in Medical Devices

  • A device manufacturer has taken STPA into ISO 14971 risk management on a product headed for certification (DeltaLife), and published the result.
  • A major manufacturer applied it in the development of an artificial pancreas, and separately set out how to roll STPA out across an engineering organization (Medtronic).
  • A published, industry-endorsed STPA standard (SAE J3187) explicitly names medical devices among its applicable domains, with a fully worked defibrillator example.
  • Regulators apply and extend it (FDA), certification bodies use it (UL), and a global pharmaceutical company applies it in pharmacovigilance (Roche).
  • Complex, software-driven commercial devices (radiotherapy systems, surgical robots, proton therapy) have been through detailed STPA, producing hundreds of analyzed control actions per system.
  • Recent work has moved into interoperability and security: an STPA analysis of cross-vendor interoperability fed Annex J of the ANSI/AAMI/UL 2800-1 standard, and STPA-Sec has been applied to adversarial data-injection threats in AI/ML-enabled devices.

Part 2 of 7

Manufacturers, Regulators & Standards Bodies

Organizations with public STPA work on record.

Medtronic

Artificial pancreas · org-wide adoption

Medtronic applied STPA in the development of its artificial pancreas, the closed-loop system that automates insulin delivery, and presented the work at the first MIT STAMP Workshop in 2012. Separately, the company set out how to drive STPA adoption across an engineering organization, treating it as a change-management problem: leadership buy-in and early adopters.

DeltaLife

Insulin pump → ISO 14971 · São Paulo

A well-documented published example of STPA driving a device toward certification. Working with the Federal University of São Paulo on a low-cost insulin infusion pump, the company’s director is a named co-author on peer-reviewed STPA work that feeds into ISO 14971 risk management. It produced both architectural safeguards and user-procedure requirements for a device headed to market, and the work spans a decade and multiple publications.

F. Hoffmann-La Roche

Pharmacovigilance safety-signal process

Applied STPA to a pharmacovigilance safety-signal management process. The analysis built a hierarchical control structure and defined losses to include patient harm and regulatory non-compliance. Roche has also taken an active part in the STAMP community, including the European STAMP Workshop.

U.S. FDA (CDRH)

Applies & extends the method

FDA staff extended STPA to catch use-related hazards buried in medical-device user-interface software. The peer-reviewed method added a fuller set of causal-factor categories, found more UI hazards than standard STPA on a radiotherapy system, and yielded safety requirements precise enough to verify formally. The FDA has also commissioned STPA work on in-vitro diagnostics and laboratory data exchange, and reports using the method.

Underwriters Laboratories

Interoperable medical systems

Applied STPA to risk management for interoperable medical systems (2015) with Kansas State University and the FDA. UL and kVA by UL both report using the method.

Paul Scherrer Institute

Proton therapy · regulatory acceptability

Builds and operates its own proton therapy system, and evaluated STPA on its Gantry 2 system in 2012. A separate MIT doctoral study of its PROSCAN facility concluded that STPA would be acceptable under both US and European marketing regulations for external-beam radiotherapy devices.

Codethink & Linux Foundation

Open-source OpenAPS

With the Linux Foundation, applied STPA to the open-source OpenAPS artificial pancreas system (2021), a counterpart to Medtronic’s earlier work. The control structure, unsafe control actions, and loss scenarios were produced and published in the open, available for anyone to review and reuse. The team also mapped which Linux kernel subsystems OpenAPS relies on, extending the analysis down to the open-source software stack the device runs on.

Synensys

Diagnostic data safety · with MIT

With MIT, produced an FDA-commissioned STPA of the U.S. diagnostic laboratory data ecosystem (2023), a socio-technical system spanning technology, operations, and regulation. On the technology side, the analysis showed how gaps in laboratory data standards and in the interfaces between laboratory systems, EHRs, and the devices feeding them let unsafe or misread results reach clinicians. A 2024 report analyzed over-the-counter and point-of-care IVD devices and the data they generate. That analysis found device-to-EHR connectivity effectively unregulated, with proprietary interfaces that do not interoperate and device software updates that change a result’s format so it silently stops reaching the patient record. The report also showed how thin feedback from the field leaves manufacturers and the FDA slow to detect an underperforming device, and its eight recommendations reach device certification, connectivity requirements, and post-market data.

SSE Group & UC San Diego

Next-gen AED · worked example

A detailed public worked example of STPA on a device: a next-generation automated external defibrillator, presented in 2024. It walks through hazard selection, control-structure design, unsafe control actions, and causal scenarios, addressing factors like rescuer stress, language barriers, and coordination among multiple bystanders. References SAE’s J3187-5, the in-development medical-device-specific supplement to its STPA Recommended Practice.

Part 3 of 7

Commercial Devices Analyzed with STPA

Manufacturers’ own commercial products have been through published STPA analysis by the clinical and academic teams that operate them.

Featured analysis · Accuray Radixact + Synchrony

From a Warning in the Manual to Fixes in the Clinic

A hospital radiation-oncology team ran a complete published STPA of the Radixact treatment-delivery system across the full patient journey. Its Synchrony feature tracks a moving tumor and adapts the beam to follow it.

12sub-systems
21control actions
108unsafe control actions
595causal scenarios
61carried to mitigation

Accuray’s treatment delivery manual already lists Synchrony’s tracking settings as a residual risk. STPA showed the clinic how that risk could arise in its own workflow. One control action is the radiation therapist providing the patient’s tracking settings when the plan is loaded. STPA’s scenario step asks how that could go wrong, and it found ways that need no component failure.

How the Wrong Settings Could Reach the Machine

  • The therapist believes the default settings are right for this patient, or doesn’t know they need tailoring.
  • The patient’s tailored settings were never written down, or were written down in the wrong place.
  • The settings revert to default before treatment.
  • The settings are changed but never saved.

The analysis ties incorrect settings to a hazard for the dose the tumor receives. Short of that, they mean poor tracking, or a treatment held up by repeated beam holds and rebuilt motion models.

Changes the Team Proposed

  • One standard place to record each patient’s settings and why they were chosen, ideally digital and linked to the patient record.
  • A quick-reference guide and training for therapists on tracking settings.
  • Testing how the settings affect tracking quality, turned into recommendations.

Carried through to actionable mitigations, where earlier radiotherapy analyses stopped at the risk list. The authors estimate an experienced team could do a comparable analysis in 200–250 hours.

Radiotherapy · Siemens Healthineers

Varian

The Halcyon, Ethos, and TrueBeam systems have all been analyzed with STPA across at least three published papers, including one built around a single-vendor environment.

Surgical robotics

Intuitive-class systems

STPA has been applied to the RAVEN II open telerobotic surgery platform, with hazard scenarios driven by real robotic-surgery incidents from the FDA MAUDE database.

Prosthetics

Össur

Microprocessor-controlled prosthetic knees, Össur’s core product line, compared head-to-head under ISO 31000, ISO 14971, and STAMP/STPA (European STAMP Workshop, 2017).

Int. J. Safety Sci. 2(1), 2018

STPA in Radiation Oncology

Radiation oncology has its own sustained body of STPA work on named commercial systems. A representative sequence:

1
Cranial radiosurgeryA widely cited application of STPA in radiation oncology. The analysis modeled an online adaptive cranial radiosurgery procedure across ten control loops spanning the whole clinic, traced unsafe control actions back to specific hazards, and demonstrated STPA as a pragmatic hazard-analysis tool for the field.Pawlicki et al. (UC San Diego), Med Phys 2016view
2
Intensity-modulated radiotherapy (IMRT)Applied STPA to a mature IMRT process and surfaced 142 unsafe control actions, catching hazards a prior HFMEA study had missed and turning a subset into concrete mitigations. This began a sustained four-part European thread that ran through 2024.Silvis-Cividjian et al. (VU Amsterdam), Saf Sci 2020view
3
Varian EthosSTPA of the Varian Ethos in a multi-vendor environment produced 496 unsafe control actions across 119 control actions, with 239 prioritized for mitigation. Most traced to how staff and software interact rather than to equipment failure, and the findings shaped the clinic’s quality-management program.Foote et al. (Mass General Hospital), JACMP 2025view
4
CyberKnife, TomoTherapy, Ethos, and moreA PRISMA systematic review screened 689 studies and analyzed 62 prospective hazard analyses across roughly a dozen named radiotherapy systems, mapping where STPA now sits alongside FMEA in the evidence base.Hindmarsh et al., Med Phys 2025view
5
Control structures from process mapsBuilding the control structure is the step teams most often get stuck on. This method derives one from a clinic’s existing process maps, and was demonstrated beyond radiotherapy on ambulance patient offloading and stroke care.Wong & Pawlicki (UC San Diego), Risk Anal 2023view

Part 4 of 7

Specific Medical Devices, Analyzed with STPA

1
Diagnostic analyzerA systems-theoretic analysis of a real accident on a complex clinical diagnostic analyzer. The study surfaced hazards the regulator-approved FMECA had missed and generated design requirements that would have prevented the accident.Balgos (MIT), 2012view
2
Cochlear implantAn STPA of the clinical software audiologists use to program a cochlear implant, where mis-set stimulation parameters can harm or under-serve the patient. The analysis mapped the unsafe control actions in how those settings get configured and applied.MIT STAMP Workshop, 2017view
3
Tomographic radiotherapyA head-to-head comparison of FMEA and STPA on a tomographic treatment system. STPA identified a larger set of causal scenarios by accounting for how humans, hardware, and software interact, not just how components fail.Yamaguchi & Thomas, Saf Sci 2019view
4
Patient-controlled analgesia pumpAn STPA of an intravenous patient-controlled analgesia pump, the device that lets patients self-administer opioid pain relief. The analysis traced how unsafe control actions could lead to over- or under-medication.J. Thomas (MIT), 2016view
5
Assistive mammography robotCombined SHARD and STPA on MammoBot, a robot that assists breast screening, and carried the results through to 27 verifiable safety requirements for the device.Univ. of York & NHS Trust, 2026view
6
Interoperable devicesUsability and safety recommendations for next-generation integrated, interoperable medical devices. This cross-vendor interoperability analysis fed Annex J of the ANSI/AAMI/UL 2800-1 standard and was co-authored with the FDA.AAMI BI&T, 2021view
7
AI/ML-enabled devicesApplied STPA-Sec to find false-data-injection scenarios across five FDA-cleared AI/ML-enabled devices, showing how adversarial inputs could drive unsafe outputs and where to defend against them.arXiv, 2026view

Part 5 of 7

Tooling & Standards Maturing Alongside the Practice

RM Studio

STPA embedded as a module inside an established commercial risk-management application.

ZHAW 2017

ANSYS medini analyze

Commercial safety-analysis tooling applied together with STPA.

Ansys

SAE J3187

Published STPA Recommended Practice that names medical devices among its applicable domains.

SAE

SAE J3187-5

A medical-device-specific STPA supplement, currently in development.

SAE

Part 6 of 7

Organizations That Report Using STPA

Beyond published analyses, a range of medical-sector organizations have reported that they actively use STAMP/STPA. Source ↗

Device & Pharmaceutical

Medtronic Spacelabs Healthcare Smith & Nephew Bristol Myers Squibb Roche Amazon Health Lumenis

Regulators, Agencies & Standards

U.S. FDA CMS TGA (Australia) Government of Canada UK HSSIB NHS Underwriters Laboratories ANSYS medini

Hospitals & Academic Centers

Memorial Sloan Kettering Massachusetts General Hospital Harvard Medical School Children’s Hospital Colorado Children’s Mercy (UMKC) Rigshospitalet UCL Monash University Federal University of São Paulo

Part 7 of 7

The STAMP Community

A broad cross-section of the medical device industry has engaged with the STPA community through the MIT STAMP Workshop. These organizations have taken part without necessarily publishing their work; the breadth indicates where interest sits across the sector. Source ↗

Large Device Manufacturers

AbbottBoston ScientificStryker Johnson & JohnsonVerb SurgicalEthicon R&D Smiths MedicalFresenius Medical CareSt. Jude Medical ThoratecLeMaitre Vascular

Radiotherapy & Imaging

ElektaVarian Medical Systems

Diagnostics & Lab

Instrumentation Laboratory (Werfen)Foundation Medicine

Diabetes & Digital Health

Bigfoot BiomedicalTidepoolMedisasBionic Labs

Development & Contract Engineering

Cambridge ConsultantsCharles Stark Draper LaboratoryPhilotech

Pharma with Device Exposure

NovartisAstraZenecaBiogen BayerModernaIQVIA

Interoperability & Standards

MD PnP (MGH/Harvard)Healthcare Systems Engineering Institute ACRESUnited States Pharmacopeia
The bottom line

Is STPA Used for Medical Devices?

STPA is established practice in medical devices. Manufacturers have applied it to insulin pumps, defibrillators, radiotherapy systems, and surgical robots. Regulators and certification bodies use it in their own work, hospitals run it on the systems they operate, and SAE has written it into published recommended practice. For a team adopting it, STPA feeds directly into ISO 14971 risk management and IEC 62304 software work, satisfying many of their requirements.

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