Regulatory Open Forum

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  • 1.  UDI Quantity per Package

    Posted 08-Sep-2016 15:05

    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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  • 2.  RE: UDI Quantity per Package

    Posted 08-Sep-2016 15:16

    In your case, you don’t have a packaging configuration. This is intended for the situation where you might have five devices in a carton. Then the Package DI Number would be the next lower packaging level and the Quantity per Package would be 5.

    You have a “1 in a 1”, which is not a packaging configuration. Leave that section blank for the situation you describe.

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    Dan O'Leary
    Swanzey NH
    United States



  • 3.  RE: UDI Quantity per Package

    Posted 08-Sep-2016 15:30

    Thanks Dan! So in this scenario, we would really only need the UDI on that box level, correct?

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    Brandon Bell
    Columbia SC
    United States



  • 4.  RE: UDI Quantity per Package

    Posted 09-Sep-2016 17:05

    Your DI for the pouch and the box level will be same so you'll be in compliance with UDI if your label is on the box.

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    Aditi Iyengar
    United States



  • 5.  RE: UDI Quantity per Package

    Posted 27-Oct-2016 18:10

    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



  • 6.  RE: UDI Quantity per Package

    Posted 28-Oct-2016 11:02

    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