Single lot release for sterile packaging

shimonv

Trusted Information Resource
Hi everyone,
I have a question for you. One company I work for intends to do a clinical trial with a sterile disposable instrument.
By way of sterilisation, they will do EtO single lot release. The question is what about packaging. They did do some feasibility tests of dye and peal but not PQ. How do companies go about this? Is there a "single lot release" allowance in packaging standards? and how would you handle the shelf life statement in the labelling.

Thanks a lot,
Shimon
 
Last edited:

planB

Super Moderator
Shimonv,

to my knowledge, the governing standard ISO 11607-1 is silent about "single lot release". ISO 11135:2014/Amd 1:2018, Annex E section gives two tiny hints what could be done:

E.2.4 A representative number of samples taken from the manufacturing batch shall be selected for [...] packaging tests, [...]
and
E2.14 Other test samples should also be removed at an appropriate time after the process (e.g. samples for [...] packaging integrity tests, [...].

So you would add an appropriate dedicated packaging-testing samples to your single sterilisation lot and test them afterwards according to the same or similar acceptance criteria that you apply during a packaging validation.

Another option would be to aim at packaging the product into an existing validated sterile barrier system, e.g. provided by packaging contractors. This would also allow you to establish a shelf life based on already existing validation activities.

Hope this helps,
 

shimonv

Trusted Information Resource
Hi PlanB,
It is also my understanding that there is no process for a "single lot" packaging release. That is the problem. A colleague of mine suggested that I can get away with it by using ANZI AQL release with peel and dye tests. He also suggested using chevron pouch for an added mitigation. Not sure what else can be done and how to handle shelf life.
 

chris1price

Trusted Information Resource
I would agree, either base sample size on a AQL or as a binomial. For the packaging test, you may not have to use real product, just empty pouches or trays may be ok.

I would expect most clinical trials to use the samples quickly, so a short shelf-life test would be ok. You could do it as a basic accelerated test, 6 months in 3 weeks.
 
Thread starter Similar threads Forum Replies Date
D Device History Record - Single file for each lot with all the lots history? 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 9
FRA 2 FDA Reusable Vs Single Use Medical Devices in EU Other Medical Device and Orthopedic Related Topics 1
R MDR vs. Machinery Directive - Single EU Declaration of Conformity EU Medical Device Regulations 2
H The capacitors in single-fault condition IEC 60601 - Medical Electrical Equipment Safety Standards Series 9
dgrainger Informational Consultation: Medical devices – single identifier for similar highly individualised devices EU Medical Device Regulations 0
E Process capability in a single batch Capability, Accuracy and Stability - Processes, Machines, etc. 3
S Cleaning validation of single-use tips providing treatment of women’s intimate areas Manufacturing and Related Processes 3
B Single fault analysis and negligible probability of IC internal fault IEC 60601 - Medical Electrical Equipment Safety Standards Series 2
I MOPP required for SIP when considering Single Fault Condition (SFC) in 60601-1 IEC 60601 - Medical Electrical Equipment Safety Standards Series 16
J Critical Supplier Initial evaluation for single purchases Oil and Gas Industry Standards and Regulations 16
B Labeling question about different manufacturers on a single label Manufacturing and Related Processes 4
J Single Fault Testing for Secondary Circuits (60601-1 section 13.1) IEC 60601 - Medical Electrical Equipment Safety Standards Series 4
K ISO 2859-5 (single run production) control plan issues FMEA and Control Plans 2
J Can you assign two EMDN codes to a single device for EUDAMED? EU Medical Device Regulations 3
A Single-Use accessory disinfected prior to use Other Medical Device Related Standards 6
L Single-cell lithium ion battery regulations IEC 60601 - Medical Electrical Equipment Safety Standards Series 0
R Labeling requirements for single use devices Manufacturing and Related Processes 4
renenatasha Single Registration Number (SRN) EU Medical Device Regulations 2
E Sources of every single paragraph of the ISO 9001 standards? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 12
K Lithium Ion - Single Fault Safe - Deep Discharge IEC 60601 - Medical Electrical Equipment Safety Standards Series 2
S DHF/DMR/MDF for a software-only, cloud-based, single-instance device Medical Information Technology, Medical Software and Health Informatics 2
N Is this a single integral drug device combination product EU MDR CE Marking (Conformité Européene) / CB Scheme 1
R CND nomenclature for single use instruments CE Marking (Conformité Européene) / CB Scheme 1
P Violation of CE mark - Re-use of single-use Products CE Marking (Conformité Européene) / CB Scheme 2
M What are the basics of Medical Device Single Audit Program (MDSAP)? ISO 13485:2016 - Medical Device Quality Management Systems 7
D SINGLE FAULT CONDITION, short circuit and open circuit of any component (IEC 60601-1 3.1) IEC 60601 - Medical Electrical Equipment Safety Standards Series 9
N Where to find Regulations for Reprocessing and Reuse of Single-Use Devices Other Medical Device Related Standards 2
T Single Fault Condition IEC 60601 Clause 8.7.1 shorting Cr/Cl in Patient Applied Part IEC 60601 - Medical Electrical Equipment Safety Standards Series 8
D Partial FAI - AS9102 - One single drawing has 10 part numbers AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 5
Sidney Vianna Informational IAF and ILAC Seek Contractor for Establishment of a Single International Organization for Accreditation ASQ, ANAB, UKAS, IAF, IRCA, Exemplar Global and Related Organizations 2
F UDI - Unit of Use and Class I, single-use devices EU Medical Device Regulations 5
A Single use non-sterile syringe used in the oral cavity - Laboratory test advice US Food and Drug Administration (FDA) 7
D How to get EUDAMED Single Registration Number (SRN) EU Medical Device Regulations 19
CycleMike GD&T - Hole pattern - Print (attached) has a single Datum Reference Frame Inspection, Prints (Drawings), Testing, Sampling and Related Topics 4
K Does company who manufacture but does not design or carry out clinical trials is responsible for CE marking for single use medical devices? ISO 13485:2016 - Medical Device Quality Management Systems 4
F 2017/745 Article 31 Single Registration Number Medical Device and FDA Regulations and Standards News 5
M Informational EU draft act – Single-use medical devices – safety and performance requirements for reprocessing Medical Device and FDA Regulations and Standards News 0
Q IATF rule for single site - Ingots from scrap metal recycling company IATF 16949 - Automotive Quality Systems Standard 0
R Supplier Controls we can place on Single-Source Suppliers ISO 13485:2016 - Medical Device Quality Management Systems 2
R Critical suppliers (Definition of) and MDSAP (Medical Device Single Audit Program) ISO 13485:2016 - Medical Device Quality Management Systems 22
A Touch current in single fault conditions test and earth leakage current in normal conditions test, are they really different tests? IEC 60601 - Medical Electrical Equipment Safety Standards Series 9
Ed Panek Can a single supplier fit two or more categories for risk? ISO 13485:2016 - Medical Device Quality Management Systems 2
T No Defined Shelf Life/Expiration Date - Disposable single-use, non-invasive, non-sterile Other Medical Device Regulations World-Wide 2
F Reprocessing or refurbishing? Single Use Medical Device CE Marking (Conformité Européene) / CB Scheme 0
S How to make Single Sign On (SSO) Comply e-sig requirements? ISO 13485:2016 - Medical Device Quality Management Systems 4
E Sample size for design verification of variable in single use device Design and Development of Products and Processes 20
Ed Panek Sensitive Supplier Issue - Single source supplier ISO 13485:2016 - Medical Device Quality Management Systems 6
G Single DFU for multiple medical devices in one box Other Medical Device Regulations World-Wide 0
M Medical Device News Health Canada - Medical Device Single Audit Program (MDSAP) Transition Plan Canada Medical Device Regulations 2
A ISO 2859 Single Sampling - Clarification regarding the sampling table Inspection, Prints (Drawings), Testing, Sampling and Related Topics 4

Similar threads

Top Bottom