Two ISO standards. One regulation. Distinct purposes.
ISO 31000 sets the universal grammar for enterprise risk management. ISO 14971 prescribes a lifecycle process specific to medical devices. FDA 21 CFR Part 117 is binding U.S. law for human food. Each answers a different question — and each demands a different evidentiary footprint.
STANDARD 01 — ISO 31000
Risk Management — Guidelines · 2018
A non-certifiable, guidance-based standard issued by the International Organization for Standardization. ISO 31000 establishes a universal vocabulary, set of principles, framework, and process for managing risk across any organization — regardless of size, sector, or activity.
The 2018 revision deliberately shortened the document to emphasize integration with strategy and decision-making. It treats risk as “the effect of uncertainty on objectives” and applies equally to financial, operational, strategic, reputational, and compliance risk.
| Type | Scope | Core Output | Authority |
|---|---|---|---|
|
Guideline • Non-certifiable |
Enterprise-wide | ERM Framework | ISO (Voluntary) |
STANDARD 02 — ISO 14971
Medical Devices — Risk Management · 2019
The international standard specifying terminology, principles, and a full lifecycle process for risk management of medical devices, including software as a medical device (SaMD) and in vitro diagnostics (IVDs). The 2019 third edition strengthened requirements around benefit-risk analysis, production and post-production activity, and overall residual risk.
Recognized by the U.S. FDA and harmonized with EU MDR/IVDR via EN ISO 14971:2019/A11:2021. Companion guidance is provided in ISO/TR 24971:2020.
| Type | Scope | Core Output | Authority |
|---|---|---|---|
| Requirement Standard | Medical Devices • IVD • SaMD | Risk Management File | FDA-recognized • EU MDR |
What each standard actually asks of you.
ISO 31000 prescribes a way of thinking. ISO 14971 prescribes a sequence of actions and an artefact trail. The distinction is consequential — and reflected in how each is implemented.
ISO 31000 REQUIREMENTS — GUIDANCE
01
Eight guiding principles
Integrated, structured, customized, inclusive, dynamic, best-available-information, human/cultural factors, continual improvement.
02
Leadership & commitment
Top management defines a risk policy, allocates resources, and embeds risk management into governance.
03
Framework design
Understand the organization's external and internal context; tailor the framework accordingly.
04
The risk management process
Communication & consultation → scope/context/criteria → risk identification → analysis → evaluation → treatment → monitoring & review → recording & reporting.
05
Integration into decision-making
Risk considerations must inform strategy, planning, performance, and culture — not run parallel to them.
06
Continual improvement
Monitor, learn, and revise the framework as the internal and external context evolves.
ISO 14971 REQUIREMENTS — PRESCRIPTIVE
01
Risk management process
A documented, top-management-approved process applied across the entire device lifecycle.
02
Risk management plan
Per-device plan covering scope, responsibilities, acceptability criteria, verification activities, and post-production information collection.
03
Risk analysis
Intended use, reasonably foreseeable misuse, hazard identification, hazardous situation identification, and risk estimation.
04
Risk evaluation & control
Compare estimated risk against acceptability criteria; apply control measures in order — inherent safety by design, protective measures, information for safety.
05
Residual & overall residual risk
Evaluate every residual risk and the overall residual risk against benefit; document the benefit-risk determination.
06
Production & post-production
Systematically collect and review information from production, the supply chain, users, complaints, and the state of the art; feed it back into the file.
07
Risk Management File & Report
Maintain a traceable file containing every artefact; produce a Risk Management Report prior to release of the device.
ISO 31000 · ISO 14971 · 21 CFR 117.
COMPARISON
Three frameworks, three different legal weights, three different hazard models. Side by side, the contrasts make implementation choices easier — and reveal where the requirements overlap.
| Attribute | ISO 31000:2018 | ISO 14971:2019 | 21 CFR Part 117 (FSMA) |
|---|---|---|---|
| Legal status | Voluntary guideline. Not certifiable. No third-party audit. | Voluntary standard, but FDA-recognized consensus standard and required by EU MDR/IVDR. | Federal regulation. Mandatory for covered facilities. Enforced by FDA inspection. |
| Risk concept | “Effect of uncertainty on objectives” — strategic, operational, financial, reputational. | Combination of probability of harm × severity of harm to patient, user, or environment. | Known or reasonably foreseeable biological, chemical, physical, radiological hazards in food. |
| Hazard analysis methodology | Generic; tools chosen by organization (SWOT, bowtie, FMEA, scenario analysis). | Structured: intended use, hazards, hazardous situations, sequence of events, harm. | HACCP-derived: hazard ID, evaluation, preventive controls, monitoring, corrective action, verification. |
| Required output | Framework, policy, process records—format at the organization’s discretion. | Risk Management Plan, Risk Management File, Risk Management Report. | Written Food Safety Plan signed by owner/operator; monitoring & verification records. |
| Qualified personnel | Competent staff; no formal credential specified. | Persons with appropriate knowledge & experience; risk management responsibility defined. | Preventive Controls Qualified Individual (PCQI) — FSPCA-recognized training or equivalent. |
| Record retention | Not specified; per organization’s own procedures. | Throughout device lifecycle plus post-market surveillance period. | Minimum 2 years on-site; reasonably accessible for FDA inspection. |
| Audit consequence | Reputational; no penalty for non-conformance. | Loss of CE mark, FDA 483 observations, market access blocked. | FDA 483, warning letters, civil penalties, injunction, criminal referral. |
| Lifecycle scope | Organizational lifecycle; ongoing review. | Concept → design → production → post-market → end-of-life. | Receiving → processing → packaging → storage → distribution; reanalysis every 3 years. |
Which standard for which industry?
A direct mapping of the five FDA-regulated sectors most often asked about — drugs, medical devices, dietary supplements, food, and tobacco — and the standards each is expected, or required, to comply with.
Drugs & Pharmaceuticals
Regulated under 21 CFR 210/211 (cGMP) & ICH Q9. ISO 31000 informs enterprise risk; 14971 generally does not apply unless combination product.
- ISO 31000 (ERM)
- ICH Q9 (Quality Risk)
- 21 CFR 117 (excluded)
Medical Devices
ISO 14971 is the de facto global expectation. Required for CE mark; FDA recognizes it as consensus standard for premarket submissions.
- ISO 14971 (required)
- ISO 13485 (QMS)
- ISO 31000 (ERM)
Dietary Supplements
Primarily 21 CFR 111 (cGMP for Dietary Supplements); facilities also doing food-related activities fall under 21 CFR 117 hazard analysis.
- 21 CFR 111 (cGMP)
- 21 CFR 117 (where applicable)
- ISO 31000 (ERM)
Food (Human)
21 CFR Part 117 is mandatory: written Food Safety Plan, hazard analysis, preventive controls, supplier verification, recall plan, PCQI.
- 21 CFR 117 (required)
- FSSC 22000 / SQF / BRCGS
- ISO 31000 (ERM)
Tobacco
Regulated under Family Smoking Prevention & Tobacco Control Act and 21 CFR 1100–1143. Not under 117. ISO 31000 used for enterprise risk and PMTA submissions.
- 21 CFR 117 (n/a)
- 21 CFR 1100–1143
- ISO 31000 (ERM)
A four-phase path to defensible compliance.
Whichever framework applies, the implementation rhythm is consistent: establish context, identify and analyze, treat and document, monitor and improve.
01
Establish Context
Define scope, intended use, regulatory landscape, and acceptability criteria. Assign accountable leaders. For 21 CFR 117, name a PCQI; for 14971, name a risk management responsible person.
02
Identify & Analyze
Perform systematic hazard identification — biological, chemical, physical, radiological, mechanical, environmental, software. Estimate likelihood and severity using consistent criteria.
03
Treat & Document
Apply controls in priority order. Verify their effectiveness. Capture every decision, every justification, and every residual risk in the appropriate file — Risk Management File or Food Safety Plan.
04
Monitor & Improve
Collect post-production information, complaints, deviations, and supplier data. Reanalyze at the prescribed cadence (≤3 years for 21 CFR 117) and whenever a material change occurs.
The documents that prove compliance.
Auditors and inspectors do not assess intent — they assess records. Below: the documents every organization should be prepared to produce, organized by framework.
For ISO 31000
Framework • Voluntary- Risk Management Policy approved by top management
- Risk Management Framework document
- Organizational context analysis (PESTEL / stakeholder map)
- Risk appetite & tolerance statement
- Risk criteria and evaluation matrix
- Risk register with owners and treatments
- Risk treatment plans
- Roles, responsibilities & authority matrix
- Communication & consultation records
- Monitoring, review & KRI reports
- Management review minutes
- Training & competence records
For ISO 14971
Risk Management File- Risk Management Plan (per device)
- Intended use & reasonably foreseeable misuse statement
- Hazard, hazardous situation & harm list
- Risk analysis records (FMEA / FTA / etc.)
- Risk evaluation against acceptability criteria
- Risk control measures & verification of effectiveness
- Residual risk evaluation & benefit-risk analysis
- Overall residual risk evaluation
- Risk Management Report (pre-release)
- Production & post-production information procedures
- Cybersecurity risk records (per Annex F, ISO/TR 24971)
- Change-control linked risk reassessments
For 21 CFR 117
Food Safety Plan- Written Food Safety Plan signed & dated by owner/operator
- Hazard analysis (biological, chemical, physical, radiological)
- Process, food allergen, sanitation & supply-chain controls
- Monitoring procedures & monitoring records
- Corrective action procedures & records
- Verification & validation activities
- Supplier approval & verification records
- Recall plan
- Environmental monitoring records (where applicable)
- PCQI training certificates & employee training records
- Reanalysis of the Food Safety Plan (≤3 years)
- All records retained ≥2 years, on-site or reasonably accessible
From the first gap assessment to the moment your inspector signs off.
JJCC Group provides end-to-end risk management and regulatory compliance services across all three frameworks. We work with FDA-regulated manufacturers, importers, processors, and emerging brands — building the documents, training the people, and standing beside you during audits and inspections.
001 — Gap Assessment
Regulatory Diagnostic
A structured gap analysis against ISO 31000, ISO 14971, 21 CFR 117, 21 CFR 111, and parallel international standards. We deliver a quantified findings register, prioritized remediation plan, and executive-ready briefing within four to six weeks.
002 — Framework Build
Risk Management System Design
Custom-built ERM frameworks (ISO 31000), device-specific Risk Management Files (ISO 14971), and Food Safety Plans (21 CFR 117) — written, version-controlled, signed-off, and ready to defend under inspection.
003 — Hazard Analysis
HACCP & Preventive Controls
End-to-end hazard analysis delivered by qualified specialists, including PCQI-led food safety hazard analysis, FMEA and FTA for devices, and integrated enterprise-level risk assessments for boards and executives.
004 — Documentation
Document & Record Architecture
We author every document the standard expects — policies, plans, registers, SOPs, monitoring forms, validation protocols, training matrices — and structure them inside a controlled document system that survives turnover and audit.
005 — Training
PCQI & Risk Management Training
Role-based training programs for PCQI, HACCP teams, risk owners, internal auditors, and executive leadership. FSPCA-aligned curricula, ISO 14971/24971 deep-dives, and tailored workshops for cross-functional teams.
006 — Audit & Inspection
Mock Audits & FDA Readiness
Mock FDA inspections, supplier audits, notified-body readiness reviews, and on-site representation. We rehearse your team for the questions that will be asked — and the records that will be demanded.
007 — Post-Market
Surveillance & Continuous Improvement
Post-production information collection, complaint trending, CAPA management, environmental monitoring programs, and structured periodic reanalysis — keeping your risk file alive instead of frozen at release.
008 — Integration
Multi-Standard Harmonization
For organizations subject to more than one framework (a combination product manufacturer; a food and supplement co-packer), we design a single, harmonized risk management system that satisfies every applicable standard without redundant work.
009 — Advisory
Fractional Risk & Quality Leadership
Embedded fractional Quality, Risk, and Regulatory leadership for emerging companies — a senior practitioner at the table during the months when full-time hire isn't yet justified but expert decisions still must be made.
Let's build the file
before the inspector asks for it.
Tell us the standards you face and the gaps you suspect. We will return a scoped engagement plan within five business days.
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Risk Management Standards. The questions, answered.
ISO 31000 is the international standard for enterprise risk management, published by the International Organization for Standardization in 2018. It provides principles, a framework, and a process for managing any kind of risk — strategic, operational, financial, compliance, reputational, or safety-related — in any organization, regardless of size or sector. ISO 31000 defines risk as “the effect of uncertainty on objectives” and is intended to integrate risk management into governance, leadership, and decision-making rather than running as a parallel exercise. It is a voluntary, non-certifiable guidance document, meaning organizations apply it but are not audited or certified against it.
ISO 14971 is the international standard for risk management of medical devices, currently in its 2019 third edition. It applies to manufacturers of medical devices, in vitro diagnostic devices (IVDs), and software as a medical device (SaMD) across the entire product lifecycle — from concept and design through production, post-market surveillance, and end-of-life. ISO 14971 is recognized by the U.S. FDA as a consensus standard for premarket submissions and is required for CE marking in the European Union under MDR (EU 2017/745) and IVDR (EU 2017/746) via the harmonized version EN ISO 14971:2019/A11:2021. Unlike ISO 31000, ISO 14971 is prescriptive: it requires a documented Risk Management Plan, a Risk Management File, and a Risk Management Report for each device.
The core difference is scope and prescriptiveness: ISO 31000 is a voluntary, generic guideline for enterprise-wide risk management, while ISO 14971 is a prescriptive standard specific to medical device risk management across the product lifecycle. ISO 31000 treats risk broadly as any effect of uncertainty on objectives and lets organizations choose their own tools and methods. ISO 14971 narrows risk to the probability of harm multiplied by the severity of harm to a patient, user, or the environment, and requires specific deliverables: hazard identification, hazardous-situation analysis, risk evaluation against acceptability criteria, risk controls in a defined hierarchy, residual-risk and benefit-risk analysis, and a complete Risk Management File maintained throughout the device lifecycle. ISO 31000 is not certifiable; ISO 14971 is FDA-recognized and required under EU MDR/IVDR.
21 CFR Part 117 is binding U.S. federal law for human food facilities, while ISO 31000 and ISO 14971 are voluntary international standards. 21 CFR Part 117 — the FDA's Preventive Controls for Human Food rule under the Food Safety Modernization Act (FSMA) — requires covered food facilities to develop a written Food Safety Plan based on HACCP principles, with hazard analysis, preventive controls, monitoring, corrective actions, verification, and supplier programs. The Food Safety Plan must be prepared or overseen by a Preventive Controls Qualified Individual (PCQI). Records must be retained for at least two years on-site. Non-compliance can result in FDA Form 483 observations, warning letters, civil penalties, injunction, or criminal referral. ISO 31000 and ISO 14971, by contrast, carry no direct legal penalty in the United States, though ISO 14971 effectively functions as a market-access requirement for medical device manufacturers.
ISO 31000 applies voluntarily to any organization; ISO 14971 applies to medical device manufacturers; 21 CFR Part 117 applies to most U.S. human food facilities. Medical device, IVD, and SaMD manufacturers follow ISO 14971 and are usually expected to maintain an ISO 13485 quality management system. Pharmaceutical manufacturers are regulated under 21 CFR Parts 210 and 211 and follow ICH Q9 for quality risk management — they are generally not subject to ISO 14971 unless producing a combination product, and not subject to 21 CFR 117. Dietary supplement manufacturers follow 21 CFR Part 111 cGMP, and may also fall under 21 CFR 117 when conducting food-related activities. Human food producers are subject to 21 CFR Part 117 and frequently certified to FSSC 22000, SQF, or BRCGS. Tobacco companies are regulated under 21 CFR Parts 1100–1143 and the Family Smoking Prevention and Tobacco Control Act, not Part 117, and often use ISO 31000 to structure PMTA-related enterprise risk. ISO 31000 is appropriate enterprise-wide for any of these sectors.
Each framework requires its own documentary architecture, and audit-readiness depends on having every required document current, signed, and retrievable. For ISO 31000, the expected documents include a risk management policy, framework document, context analysis, risk appetite statement, risk criteria, risk register, treatment plans, roles and authority matrix, monitoring and KRI reports, management review minutes, and training records. For ISO 14971, the Risk Management File must include a per-device Risk Management Plan, intended-use statement, hazard and harm list, risk analysis records, risk evaluation, risk control measures with verification of effectiveness, residual risk and benefit-risk analyses, the Risk Management Report prior to release, post-production information procedures, and change-control linked reassessments. For 21 CFR Part 117, required records include the written Food Safety Plan signed by the owner or operator, the hazard analysis, preventive controls (process, allergen, sanitation, supply chain), monitoring records, corrective action records, verification and validation activities, supplier programs, recall plan, environmental monitoring records, PCQI training certificates, and reanalysis of the Food Safety Plan at least every three years. 21 CFR 117 records must be retained for a minimum of two years.
Whether the framework is ISO 31000, ISO 14971, or 21 CFR Part 117, implementation follows the same four-phase rhythm: establish context, identify and analyze, treat and document, monitor and improve. Establishing context means defining scope, intended use, regulatory landscape, acceptability criteria, and assigning accountable leaders — naming a PCQI under 21 CFR 117, a risk management responsible person under ISO 14971, or a risk owner network under ISO 31000. Identifying and analyzing means systematic hazard identification (biological, chemical, physical, radiological, mechanical, environmental, software-related, as applicable) and consistent estimation of likelihood and severity. Treating and documenting means applying controls in priority order — design controls before protective measures before information for safety — and capturing every decision and residual risk in the appropriate file. Monitoring and improving means collecting post-production information, complaints, deviations, and supplier data, and reanalyzing at the cadence the standard requires (no later than every three years for 21 CFR 117; whenever change occurs for ISO 14971; continually for ISO 31000).
The consequences range from reputational damage (ISO 31000) to loss of market access (ISO 14971) to federal enforcement action (21 CFR Part 117). Non-conformance with ISO 31000 carries no direct penalty because it is a voluntary guideline, but the absence of a functioning ERM framework is increasingly cited in investor due diligence, insurance underwriting, and board oversight. Non-conformance with ISO 14971 can result in FDA Form 483 observations, warning letters, refusal of premarket clearance, loss of CE marking under EU MDR or IVDR, recall, or product liability exposure. Non-compliance with 21 CFR Part 117 can trigger FDA Form 483 observations, FDA warning letters, civil monetary penalties, seizure or injunction, suspension of facility registration, and in serious cases criminal prosecution under the Federal Food, Drug, and Cosmetic Act. In every case, the most common citation is not the absence of controls but the absence of records demonstrating that controls were considered, justified, implemented, and verified.
Have a different question?
We probably have an answer.
JJCC Group works with FDA-regulated manufacturers, importers, and emerging brands on ISO 31000, ISO 14971, and 21 CFR Part 117 compliance — from first gap assessment to inspector sign-off.