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DCONN1
Hello all,
I am looking for guidance as to what exactly is required/mandated in terms of establishing barcode quality by the FDA UDI final rule. My knowledge on this topic is not comprehensive, and I certainly understand that using standards such as ISO/IEC 15415 and ISO/IEC 15416 could be of great use. However, I haven't been able to find any requirement mandating a specific barcode quality standard. The most relevant information I've encountered is:
§ 820.120 Device labeling
"(b)Labeling inspection.Labeling shall not be released for storage or use until a designated individual(s) has examined the labeling for accuracy[emphasis mine] including, where applicable, the correct unique device identifier (UDI) or universal product code (UPC), expiration date, control number, storage instructions, handling instructions, and any additional processing instructions. The release, including the date and signature of the individual(s) performing the examination, shall be documented in the DHR."
However, this section does not address quality; if you have a scanner which is able to read the barcode and show that the information is accurate, would this not satisfy this requirement?
Section (a) of § 820.120 remains unchanged by the UDI final rule and is relevant to the printed quality of the UDI:
"(a)Label integrity.Labels shall be printed and applied so as to remain legible and affixed during the customary conditions of processing, storage, handling, distribution, and where appropriate use."
"Remaining legible" in terms of the barcode (as well as human readable components) would certainly involve ensuring sustained readable barcode/human readable quality in some manner. However, since ISO/IEC 15415 and ISO/IEC 15416 are not referenced within the UDI final rule to my knowledge, is there a requirement to conform to these standards? Or is the method and scope of demonstrating compliance left up to the labeler?
My company uses GS1 as our accredited issuing agency. I am aware that GS1 has implementation guides for establishing verification programs for 1D and 2D barcodes which conform to /IEC 15415 and ISO/IEC 15416. However, is it necessary to follow these guidelines, or can a labeler establish a program as they see fit?
Again, I apologize for any ignorance on this topic and any help would be very much appreciated.
I am looking for guidance as to what exactly is required/mandated in terms of establishing barcode quality by the FDA UDI final rule. My knowledge on this topic is not comprehensive, and I certainly understand that using standards such as ISO/IEC 15415 and ISO/IEC 15416 could be of great use. However, I haven't been able to find any requirement mandating a specific barcode quality standard. The most relevant information I've encountered is:
§ 820.120 Device labeling
"(b)Labeling inspection.Labeling shall not be released for storage or use until a designated individual(s) has examined the labeling for accuracy[emphasis mine] including, where applicable, the correct unique device identifier (UDI) or universal product code (UPC), expiration date, control number, storage instructions, handling instructions, and any additional processing instructions. The release, including the date and signature of the individual(s) performing the examination, shall be documented in the DHR."
However, this section does not address quality; if you have a scanner which is able to read the barcode and show that the information is accurate, would this not satisfy this requirement?
Section (a) of § 820.120 remains unchanged by the UDI final rule and is relevant to the printed quality of the UDI:
"(a)Label integrity.Labels shall be printed and applied so as to remain legible and affixed during the customary conditions of processing, storage, handling, distribution, and where appropriate use."
"Remaining legible" in terms of the barcode (as well as human readable components) would certainly involve ensuring sustained readable barcode/human readable quality in some manner. However, since ISO/IEC 15415 and ISO/IEC 15416 are not referenced within the UDI final rule to my knowledge, is there a requirement to conform to these standards? Or is the method and scope of demonstrating compliance left up to the labeler?
My company uses GS1 as our accredited issuing agency. I am aware that GS1 has implementation guides for establishing verification programs for 1D and 2D barcodes which conform to /IEC 15415 and ISO/IEC 15416. However, is it necessary to follow these guidelines, or can a labeler establish a program as they see fit?
Again, I apologize for any ignorance on this topic and any help would be very much appreciated.