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  • 1.  UDI Direct Marking

    Posted 24-Jan-2018 15:42

    Any FDA UDI Experts out there?

    We manufacture dental restoratives and lasers. Both have disposable 'one patient' use tips so there is no sterilization or high level disinfection required. Our Class II products require UDI numbers and labels. Now that UDI direct marking is here I want to verify my findings.

    Here is the FDA requirements:

    if a UDI is required on a device label, that device is also required to have a UDI permanently affixed to the device itself if the device is intended to be used more than once and intended to be reprocessed before each use

    We meet the first requirement of "intended to be used more than once" however we do not meet the second requirement of "intended to be reprocessed before each use".

    FDA definition of "intended to be reprocessed":

    we consider a device intended to be reprocessed if it is intended to undergo high-level disinfection and/or sterilization before each use or between uses

    Simple cleaning and low-level disinfection as we perform on our products do not reach the FDA definition of "intended to be reprocessed".

    Based on these requirements our Class II products do not require direct marking.

    Question: Am I missing something or does this sound correct?

    Thank You,
    Charles


  • 2.  RE: UDI Direct Marking

    Posted 24-Jan-2018 16:18
    Charles,

    Your interpretation is correct:  FDA in its recent finalized November 17, 2017 guidance on UDI direct marking states, "...This means that devices that are only intended to be cleaned and/or to undergo lower levels of disinfection without subsequent high-level disinfection or sterilization before each use or between uses are not required to be directly marked with a UDI under 21 CFR 801.45..."

    Hope this helps,

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    Kevin Randall, ASQ CQA, RAC (U.S., Canada, Europe)
    Principal Consultant
    ComplianceAcuity, Inc.
    Golden CO
    United States
    www.complianceacuity.com
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