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  • 1.  UDI direct part marking

    This message was posted by a user wishing to remain anonymous
    Posted 26-Sep-2018 09:19
    This message was posted by a user wishing to remain anonymous

    Hi,

    Can you confirm if we need to have all the Production identifiers in the barcode , or can we have only have the serial number ( our devices are non-sterile and do not have an expiry date) .Is it mandatory to have a manufacturing date?

     

    Also can you confirm if it is permissible to have only the AIDC ( barcode only) without the Human readable text for small reusable devices (direct marking) ?



  • 2.  RE: UDI direct part marking

    Posted 27-Sep-2018 13:59
    Hello Anon -

    Per 21 CFR 801.30(d) a Product Identifier (PI) is not required for DPM (direct part marking) of Class I devices. So there is no need to mark variable information (mfg. / exp. dates, lot/ serial numbers etc.) on the device in your case. 

    Regarding your second question, UDI rule states that a manufacturer may choose to use AIDC or Human Readable Text or both for DPM. See 21 CFR 801. 45 (c).

    Regards, 


    ------------------------------
    Phani Puppala
    Quality Regulatory Specialist
    Franklin MA
    United States
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  • 3.  RE: UDI direct part marking

    This message was posted by a user wishing to remain anonymous
    Posted 01-Oct-2018 09:11
    This message was posted by a user wishing to remain anonymous

    ​Hi,

    I needed the information for class II (reusables).



  • 4.  RE: UDI direct part marking

    Posted 02-Oct-2018 11:19

    For Class II devices, the complete UDI (DI+PI) is required to be marked on the device (per UDI rule, the device must be marked with all the production identifiers that appear on the device label). The components of the PI depend on your UDI issuing agency (GS1/ HIBCC and  ICCBBA).

    Hope this helps!



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    Phani Puppala
    Quality Regulatory Specialist
    Franklin MA
    United States
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  • 5.  RE: UDI direct part marking

    Posted 09-Oct-2018 08:14
    ​To add to this discussion, make sure that DM is required.  It focuses on the definition of reprocessing.

      UDI Direct Marking Requirement

     

    "Sec. 801.45 Devices that must be directly marked with a unique device identifier. 

    (a) In general. A device that must bear a unique device identifier (UDI) on its label must also bear a permanent marking providing the UDI on the device itself if the device is intended to be used more than once and intended to be reprocessed before each use."

     

     

    FDA UDI Guidance Document

     

    "For purposes of UDI direct marking requirements, we consider a device that is intended to be cleaned and either sterilized or disinfected before each use to be intended to be reprocessed. If a device is intended only to be cleaned between uses by different patients, this would not be considered reprocessing for the purposes of the UDI direct marking requirements. If the device is intended to be used more than once on or by the same patient, and not on or by different patients, the device does not need to be directly marked with a UDI."



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    Michael Winter RAC
    Curbell Medical
    Sr. Director, Quality and Regulatory Affairs
    Alden NY
    United States
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  • 6.  RE: UDI direct part marking

    Posted 10-Oct-2018 07:54
    Hello,

    I need to reply to the comment on UDI direct marking for reprocessed devices.  FDA put out a clarification on this guidance last year that direct marking of reusable devices was only applicable for those devices sterilized or cleaned with a high-level or intermediate disinfectant...(I.e., a critical or semi-critical device).  This would NOT apply to something considered  a non-critical device (per CDC guidance) not sterilized and disinfected by a means such as wiping down with isopropyl alcohol. 

    So I would suggest you review the CDC guidance and classify your device (critical, semi-critical, or non-critical) then build this  into your  risk assessment and do a note or letter to file or something in your design requirements that direct part marking is or is not required, with the rationale.

    As always,   you still have to prove and document the suitability of the reprocessing process, whatever it is, and provide instruction on it to the user.


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    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
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