Regulatory Open Forum

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  • 1.  FDA, UDI, and IVDs

    Posted 30-May-2014 13:03
    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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  • 2.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 14:18

    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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  • 3.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 15:26
    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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  • 4.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 15:41


    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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  • 5.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 15:32
    Dan's response is spot on.

    My recommendation in general (not just for IVDs) is to study the new/amended regulations line by line to determine the applicability to your devices, and create an action plan.

    I have created a FDA UDI Gap Analysis and Impact Assessment template document for that purpose.
    Sam Lazzara FDA UDI Regulations Gap Analysis and Impact Assessment template.docx

    The template is password protected. The password is my name with no spaces.
    Please let me know how it can be improved.

    Link to my FDA UDI (DI+PI) FAQ article published in May ASQ Biomedical Division newsletter
    Comments are appreciated.


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    Sam Lazzara
    Medical Device QA/RA Consultant
    sam@lazzara.net
    San Francisco CA USA
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  • 6.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 15:48

    I feel good when Sam agrees with me.

     

    I have given you, at best, the top level issues. There is complexity here and it often requires a more detailed analysis of the situation. This is a case in which an appropriate consultant can provide value. For the West Coast, Sam is your first choice. For the East Coast, use Dan O'Leary.

     

    The issue here is long term familiarity with the regulations, their implementation, and the ability to apply them to specific situations

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    Dan O'Leary
    Swanzey NH
    United States
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  • 7.  RE: FDA, UDI, and IVDs

    Posted 30-May-2014 16:11
    You may want to visit the LinkedIn group "Medical Device Labeling and UDI."

    If you post a question, you can interact with others including the same Dan, Jay Crowley, and other service providers, etc. 

    https://www.linkedin.com/groups/Medical-Device-Labeling-UDI-4995811


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    http://www.regulatorydoctor.com
    Riner VA
    United States
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  • 8.  RE: FDA, UDI, and IVDs

    Posted 11-Jun-2014 16:51
    Thank you all for the help!  One more question.  How do EAN codes play into the UDI requirements?  We recently had an international distributor ask for our EAN codes, which we do not have.

    Joy

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    Joy Pelfrey
    Norman OK
    United States
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