Regulatory Open Forum

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  • 1.  UDI labelling

    Posted 02-Nov-2015 04:42

    Hello, 

    We are currently working on the implementation of the UDI labelling on our medical displays.

    We have medical displays (class IIb and class I), which will all receive a unique UDI label.

    Next to this we have the system package, where 2 displays are combined in a box, but here it can be that once cable A (eg Display Port) and once cable B (eg (USB) is added. Do those system levels require different UDI codes or can they still bear the UDI label referring to the medical device?

    Finally same question, but adding a non medical device (as option). This can be a luminance meter or a keypad...

    We want to ensure to be fully compliant with the rule, but our systems are a bit more complex than the example in the training with the catheters and their package levels

    Thanks in advance

    Franky

    ------------------------------
    Franky Dubois
    Regulatory Officer
    Barco
    Kortrijk
    Belgium
    ------------------------------


  • 2.  RE: UDI labelling

    Posted 02-Nov-2015 08:21

    You say your devices are class IIb and Class I. I infer that there are MDD classes, not US classes. (In the US we have only three classes.) It is important to realize the US is the only place that has implemented UDI. It is not required in the EU, but probably will be some day. The implication is that you market your devices in the US, so you need to follow US rules including device classification.

    In the US, the device class (and other device characteristics) determine the compliance date, but not the presentation of the UDI on the label. However there are some exceptions for Class I devices.

    Answering your specific question is not easy, because it requires some knowledge of the device and its configurations. You need a different label DI when you create a new version or model. This means you have gone outside the specifications, performance, size, and composition, you have set for the device. The implicit assumption is that you have set them for the device, documented them in a quality record, and use them to determine the need for a new DI.

    Although this is the technical definition, my rule of thumb says that if the customer or user would consider it different, then it needs a new DI.

    Based on your description, it appears the system package is different from each of the individual displays. One simple test is the catalog number a customer would put on a purchase order. If you have a catalog number for the system package, then it would have its own DI.

    If you sell a configuration (a separate catalog number) with an option, then it is different and would require a new DI.

    There is a lot of confusion about accessories. In the US (as in the MDD) they are considered medial devices, and, if sold separately, might also require UDI. Unfortunately FDA has never defined accessory and in the UDI rule preamble explicitly refused to offer a definition. There is a draft guidance on this topic, but the issue is murky at best.

    ------------------------------
    Dan O'Leary
    Swanzey NH
    United States



  • 3.  RE: UDI labelling

    Posted 03-Nov-2015 10:09

    A great source of information regarding Unique Device Identifiers for Medical Devices is available from the GS1 standards organization.

    http://www.gs1.org/healthcare/udi

    Currently UDIs are required in Japan and Turkey and are in the process of being implemented in the US and the UK. Coming soon for the EU & rest of world.

    GS1 can provide information about barcode traceability for items which are not medical devices as well.

     

    If the items in the package are reusable, they should each be assigned their own Device Identifier. 

    The package holding the items should also be assigned a Device Identifier if it is associated with a fixed content and catalog code for the entire system.

    Same for any larger package sizes which hold a fixed quantity of inner packages.

    That is to say – it is not just picked to order and sent in a shopping case. Shipping cases are exempt from UDI as contents varies.

     

    Best regards,

     

     

     

    Stacey Henning

    Quality Assurance Advisor

    1500 Waukegan Road, Waukegan, IL 60085

    847.887.3602 dir | 847.785.2461 fax

     


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