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  • 1.  One of the Model not in distribution

    This message was posted by a user wishing to remain anonymous
    Posted 14 days ago
    This message was posted by a user wishing to remain anonymous

    Hello RAPS Expert,

    One of the model we stopped selling almost 2 years ago but unfortunately we didn't submit UDI to GUDID that time.
    Not sure, it was compulsory at that time for class I (non measuring, non sterile) medical devices manufacturer. 

    Since, our expected device life is 10 years with proper maintenance and replacement of defective parts, i thought it's better to submit UDI to FDA database.

    But database is not letting me to do. Any feedback will be appreciated



  • 2.  RE: One of the Model not in distribution

    Posted 14 days ago

    Anon,

    Probably because you can not "back date" the commercial distribution end date.  You could put the Publish Date today and the Commercial End Date as tomorrow - then internally write a note to file about what was done in the GUDID database.  At least in the GUDID database it will show as not in commercial distribution.



    ------------------------------
    Richard Vincins ASQ-CQA, MTOPRA, RAC
    Principal Strategy Consultant
    NAMSA
    ------------------------------



  • 3.  RE: One of the Model not in distribution

    This message was posted by a user wishing to remain anonymous
    Posted 13 days ago
    This message was posted by a user wishing to remain anonymous

    Hello Richard, 

    Thanks for your valuable feedback!

    I'm bit confused now, I should post it to GUDID or not as Enforcement date was extended to 2022-12-08.

    What could be the circumstances/effects if we don't do? 

    Thanks




  • 4.  RE: One of the Model not in distribution

    This message was posted by a user wishing to remain anonymous
    Posted 13 days ago
    This message was posted by a user wishing to remain anonymous

    Enforcement date was extended to 2022-12-08

    https://www.fda.gov/regulatory-information/search-fda-guidance-documents/unique-device-identification-policy-regarding-compliance-dates-class-i-and-unclassified-devices




  • 5.  RE: One of the Model not in distribution

    This message was posted by a user wishing to remain anonymous
    Posted 13 days ago
    This message was posted by a user wishing to remain anonymous

    Hello Anon,

    I'm assuming, you're suggesting me, there's no need to add in GUDID now as Enforcement date was extended to 2022-12-08.
    Please clarify

    Thanks