Regulatory Open Forum

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  • 1.  UDI Machine Readable Verification

    Posted 14-Nov-2016 12:02

    The UDI regulation modifies the QSR device labeling inspection to " ... Labeling shall not be released for storage or use until a designated individual(s) has examined the labeling for accuracy including, where applicable, the correct unique device identifier (UDI) or universal product code (UPC), ..."

     

    What methods have you applied to document a designated individual has examined the machine readable UDI format for accuracy?

     

    Do you use a machine readable verifier as an in-process control to confirm that the printed machine readable symbol meets GS1 or HIBCC standards?

     

    Regards,

     

     

    Gary Syring

    Quality & Regulatory Associates, LLC

    800 Levanger Lane

    Stoughton, WI 53589

    Phone: 608 877-2635

    Cell: 608 712-7451

    Email: GSyring@QRAsupport.com

     



  • 2.  RE: UDI Machine Readable Verification

    Posted 16-Nov-2016 08:28

    Hi, Gary,

    Several companies I know are using printers that include verification capabilities.  These verify the readability and grade the labels according to GS1 standards.  The printer/verifiers and software should be validated on installation.

    The final lot should be verified as part of your final QC.  All QC personnel should be trained on how to use a reader to compare the printed bar code with the DI and PI in the Device History Record.  Their signature on the final inspection sheet will confirm the accuracy of the UDI information on the label.

    Regards,

    ------------------------------
    John Minier RAC
    Sr. Regulatory Compliance Consultant
    JMC Medical, LLC
    Highland Mills NY
    United States