Regulatory Open Forum

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  • 1.  GUDID (variable information) How often we need submit it to FDA

    Posted 29-Apr-2016 11:08

    Good morning,

    I would like clarification on the submission of variable information to FDA.

    In the last GUDID webinar offered by the FDA, I specifically asked the speaker how often the manufacturer will need to submit the variable information to FDA through the GUDID account, and I was told that we only submit the device information once, when we list the device in the GUDID account with its GTIN and every time there is a change on the device/device ID thereafter. However, I just finished a conference call with the regulatory group of one of our contract manufacturer and they are certain that it is necessary to submit the information to FDA for every lot manufactured.

    Can anyone share with me their understanding and current experience in this topic?

    Thanks,

    Valeria

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    Valeria Sena-Weltin, M.S., RAC(US)
    Regulatory Affairs Specialist
    Gaithersburg, MD
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  • 2.  RE: GUDID (variable information) How often we need submit it to FDA

    Posted 29-Apr-2016 18:09

    First, I want to make sure that I answer the question you ask. For me, the variable information is the value of the production identifiers (PIs) on the label, such as lot or batch number.

    In GUDID, you do not enter the values of the PIs. You only enter an identification of whether or the label uses a given PI.  For example, if your label includes the lot number, you add it to AIDC portion of the label and tell GUDID that you use a lot number, i.e., YES. You do enter any lot numbers into GUDID.

    FDA has an Excel file that has the structure of the data to submit. You will see there is only a “check box” for lot number – there is no place for the actual lot numbers.

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    Dan O'Leary
    Swanzey NH
    United States



  • 3.  RE: GUDID (variable information) How often we need submit it to FDA

    Posted 29-Apr-2016 19:53

    Only DI (Device Identifier = statiic) information is submitted to the GUDID. The labeler is responsible for keeping track of PI (Production Identifier = variable) information, which they should be doing already if they use lot numbers or serialization.

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    Lena Cordie
    Qualitas Professional Services
    Watertown MN
    United States