These requirements are separate from a unique reference number and lot number. You must contract with an Accredited Issuing Agency that will issue you a Device Identification (DI).
You must include the DI as well as Production Identifiers, such as a lot number, on the label. The Accredited Agency will provide the format for the PIs.
Technically, the label must include the information in "AIDC format". This is Automatic Identification and Capture, which could be any method you choose. Currently the methods seem to be linear bar code, 2D bar code, and RFID.
Your accredited agency should provide the specifications for the method you choose. It appears, as an example, that GS1 has a prescribed format for a linear bar code. This means that if you were to choose GS1 and use a linear barcode, then your label would have the GS1 format for the linear barcode.
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Dan O'Leary
Swanzey NH
United States
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Original Message:
Sent: 05-30-2014 15:26
From: Joy Pelfrey
Subject: FDA, UDI, and IVDs
Thank you for the information! The new requirements are separate from simply having a unique reference number and lot number, correct? The bar code is part of the new requirement?
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Joy Pelfrey
IMMY
Norman OK
United States
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Original Message:
Sent: 05-30-2014 14:18
From: Dan O'Leary
Subject: FDA, UDI, and IVDs
IVDs are medical devices in the US, so all of the medical device regulations apply.
Quickly, you will put a UDI on every device. The UDI is composed of a Device Identifier (DI) and any Production Identifiers (PI) that you use. Often people say, UDI = DI + PI. In addition, you must load information into FDA's database, the GUDID.
Standard packaging configurations require a different DI. For example, if you ship kits individually the kit will have a UDI on the label. If you ship 5 kits as a configuration, 10 kits, etc. each standard configuration requires a DI.
The compliance date for Class II devices is Sep. 24, 2016. The compliance date for Class I devices is Sep. 24, 2018.
The bar code is not simply a bar code you develop. It is a bar code that follows the requirements of an Accredited Issuing Agency. At this writing, there are only 3 such organizations.
There are other issues for kits, Class I devices, devices sold at retail, etc. I have not tried to cover them.
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Dan O'Leary
Swanzey NH
United States
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Original Message:
Sent: 05-30-2014 13:02
From: Joy Pelfrey
Subject: FDA, UDI, and IVDs
Can anyone clarify how the FDA's rule on UDI effect Class I and II IVDs? Will Class I and II IVD manufacturers be required to apply barcodes on outer packaging?
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Joy Pelfrey
Norman OK
United States
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