Yet another great variation in how the industry does business....
The DI for the base device (Unit of Use) will not change, but the DI for each pack level and sterility status will.
Assuming your statement about using the same DI for the base device and the package of 1 is applied consistently, you need 3 DIs for the product.
Sterile device Base DI 1
Sterile device pack of 1 DI 1 same DI because unit of use is same as pack size
Non-Sterile device Base DI 2 different base DI because it is non Sterile
Non Sterile device pack of 1 DI 2 same DI because unit of use is same as pack size
Non Sterile device pack of 4 Base DI 2, Pack level DI 3
The different issuing agencies have different rules about formatting of DIs, so how the ADIC is encoded depends on your chosen issuing agency.
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Michael Chellson
RAC
Original Message:
Sent: 27-Oct-2016 18:10
From: Michael Thomas
Subject: UDI Quantity per Package
Hi Brandon,
My company just released prepackaged sterile devices that are also 1 device per pouch, 1 pouch per box. Our interpretation led us to match the UDI for the device with the pouch (unit of measure 0, quantity 1, since this is representative of what's inside), then the box was labeled with unit of measure 1, quantity 1, since this is the secondary packaging. We've been told this is sufficient, but there are so many interpretations flying around right now we're still trying to get a handle on best practices.
Additionally, we have a non-sterile part with a unit of measure 0, packaged in both quantities of 1 and 4. With the UDI ruling, it's been very difficult trying to pinpoint how best to label these. The parts inside the pouch are still unit of measure 0, but if we label the pouches differently (q1 for singles, q4 for 4packs), then the UDI on the pouch is not representative of the individual device inside. If anyone has any insight on how best to move forward with this, I would be grateful.
Thanks
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Michael Thomas
Regulatory Affairs Associate
Salt Lake City UT
United States
Original Message:
Sent: 08-Sep-2016 15:05
From: Brandon Bell
Subject: UDI Quantity per Package
My question is about quantity per package in GUDID. The GUDID Data Elements Reference Table states that quantity per package must be greater than 1. However, we have a product that contains 1 base device, packaged in 1 pouch, which is then packaged in 1 box. We currently place the UDI on the box label and pouch label. Is it okay to put a Quantity per Package of 1?
Thanks!
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Brandon Bell
Columbia SC
United States
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