On Friday morning, September 20, 2013, at the UDI User Conference in Baltimore, MD, Jay Crowley, FDA’s Senior Advisor for patient safety, CDRH, raised a glass to toast the completion of a decade long journey. He, his staff and members from the Medical Device industry and solution providers celebrated the announcement of the publishing of the Final Rule for the establishment of the Unique Device Identification system. The final rule will be officially published Sept 24, 2013 on the U.S. Federal Register.
That date is an important one as it establishes the start date for the timeline for all medical devices to be coded with a Unique Device Identifier (“UDI”), which is to be printed in plain text and barcode (or other AIDC technology) on the device’s label. Manufacturers of Class III medical devices will have one year to comply with the rule. Class II and Class I devices which are used as implants and/or are life supporting/sustaining in nature have 2 years to comply. All other Class II devices must comply within 3 years of the publish date and all Class I and unclassified medical devices must comply within 5 years of the published date, per the Final Rule.
A number of changes were made from the original proposed rule, but one proposed requirement which was hotly debated by industry was the proposed required date format. The original date format on labeling was proposed to be the US-centric “MMM DD, YYYY” format. However, with the final rule, the requirement has been changed to the more global-friendly (and ISO compliant): YYYY-MM-DD
Furthermore, this rule institutes a new FDA Global Unique Identification database (or “GUDID”, pronounced “Good ID”), into which all manufacturers (or “labelers” as defined in the rule) must populate their unique Device Identification numbers. This database will also require providing FDA required attribute information. Once populated, the GUDID database will be used by healthcare providers and the public to search for and gain information about the device.
The initial goal of this rule is to be able to better identify devices in the healthcare area, to help healthcare providers identify items in cases of adverse effects/recalls, as well as to better understand and manage their inventory.
AssurX will be working with current and future customers to use our solution to help them comply with their UDI management and eventual submission to FDA’s GUDID database.