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The 4 Most Common Mistakes in the Risk Acceptance Matrix

Updated: Mar 14

In the past, medical device manufacturers have used risk acceptance matrices with large green areas where the occurrence of damage was acceptable. Today, this indicates that something is wrong with the risk acceptance matrix.

4 Mistakes in the Risk Acceptance Matrix | Medical Device Manufacturing

Mistakes in the risk acceptance matrix

Risk Acceptance Matrix with mistakes that are often found at medical device manufacturers

What errors does this risk acceptance matrix contain?

Mistake 1: According to MDR Appendix I, chap. I, paragraph 1, are risks (related to harm to patients/users/third parties) are only acceptable if they are "minimized as much as possible" and "reasonable compared to the benefits". This means that there must be no per se acceptable risks in the risk acceptance matrix about harm to patients/users/third parties. In this form, the green fields are therefore wrong as acceptable per se.

Mistake 2: ALARP is not allowed. The MDR Annex I, chap. Paragraph 1 clearly states that risks must be minimized "as far as possible". Annex C of CEN ISO TR 24971:2020 specifies several approaches. However, here the MDR's legal requirements beat the standard's requirements.

Mistake 3: There are no fields for the acceptable occurrence of catastrophic damage. Since no acceptable occurrence of catastrophic damage can be achieved, it is impossible to bring these risks to an acceptable level. Catastrophic damage is, therefore, never acceptable. The acceptance limit for these damages is not shown.

Mistake 4: For negligible damage, there are no fields for unacceptable occurrence. Negligible damage is always acceptable. Thus, there is no acceptance limit for negligible damage.

How to correctly use the risk acceptance matrix


To effectively use the risk acceptance matrix as a tool over the entire area, these 4 common mistakes should be avoided.

Bernhard Lindner | SIFo Medical | Risk Management Expert

Author: Bernhard Lindner, MSc

Are you still having questions about how to use the risk acceptance matrix in a way that complies with the Medical Device Regulation?

Our expert Bernhard Lindner will be happy to support you – contact us at

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