Thursday, 16 June 2022
device and if that is not possible it shall be placed on the packaging
so i am pontus yada i have worked as the technical planning manager for an mdr
notified body for several years and this video is part of my course introduction
to mdr the medicaid device regulation and are you interested in the full course
on the mdr check out the course by visiting the course page that is linked below
and if you need a record of your training in this area the full course will
result in you receiving a course certificate before we start ensure that you are
subscribed to our channel to make sure you're always on top of content then
click the notification button too let's dig right into it now let's look at the
requirements related to the unique device identifier or just short udi udi is
applicable to all manufacturer of medica devices in europe and before we dig
into the udi requirements in europe i would just like to clarify once and for
all that the udi requirements in europe are not identical to the udi
requirements of other markets like the u.s market a colleague of mine once said
during a training session we had on medicare devices that should be a slogan for
udi i think okay i said and what would that be he answered udi more than just
the barcode and i actually have to admit that he was quite right at the time it
is a lot more than just the barcode even though i never heard this slogan again
after that meeting sorry i know it's a bit nerdy but what more can we do to
bring more attention to this important subject but jokes aside this udi thingy
is actually a whole world of its own so let's start to introduce you to this
world let's start with an overview of the udi concept we can picture it as three
pillars starting from the left and i will then further elaborate the pillars
first we have the basic udidi or sometimes called beauty the purpose of the
basic udidi is to act as the main key in udemy and relevant documentation like
certificates declaration of conformity technical documentation periodic safety
update reports and sscps but also certificates of free sales worth noting for
those of you taking this course outside europe is that the basic udidi is unique
to the european union and therefore there is no corresponding codes available in
for example us which has already and will probably continue to cause some
confusion the basic udidi is kind of a collective code used to cover devices
with the same intended purpose risk class and essential design and manufacturing
characteristics the basic udidi shall not be on any device or packaging it is
only to be used as a collective term for grouping devices and for reporting into
udemed moving down in this blue pillar now one basic udidi can then cover
several udis as i just explained but a udi cannot be included in several basic
udidis the actual udi is then split into two parts the udidi and the udi pi di
stands for device identifier and pi stands for production identifier the udi
part is mandatory for all medicaid devices whereas the udi pi part is only
applicable where production related information is required to be included in
the labeling like lot number serial number software release or when expiry date
is essential to communicate so please understand that if expiry date or
manufacturing date is essential for your device independent on class a udi pi is
required so basically we can say that any essential information on the label
that is defined during the production will require a udi pi the udi shall be
placed on the product by the manufacturer and no one else and thereby it is also
a requirement that the manufacturer has integrated the assignment and
application of the udi in their qms below this video you'll find an mdcg endos
document explaining the udi requirements in relation to the manufacturer's qms
it is really quite a good guidance so i recommend you to read it and i expect or
actually i know that notified bodies will follow this guideline both the
beauties and the duties shall be unique to the manufacturer and must be obtained
from a designated issuing entity in accordance to that issuing entities
nomenclature there is a list of currently available issuing entities below this
video the basic udidi is an alphanumeric code that shall be readable for humans
a human readable interface or short hri so no need for barcodes on the basic
udidi but the udi including then the udidi and pi shall both be readable to
humans and to machines and machine readable interface is abbreviated aidc which
stands for automatic identification and data capture examples of aidcs are 2d
barcodes dot matric codes biometric codes or rfid as i just mentioned the basic
udidi is for example used for certificate but also needed when registering the
actual device in udemad together with the udidi and those two are the so-called
static parts of the udi system meaning as long as you don't change your device
or add or remove devices they remain the same there is an mdcg endorsed document
mdcg 2018-1 published that explains when you need to change gud idi and also the
relationship to the basic udidi for those you find the link under the video
focusing on the udi di a bit then the udidi must be unique to a manufacturer and
a device and it shall be both human and machine readable so to put it in normal
words the ud idi is kind of corresponding to the order number that you will use
for selling your devices this is also known as the ref number but please note
that this doesn't mean that you need to replace your order number ref number
with the actual udidi code but they must be linked internally and also in udemed
this also means if you offer your product in different quantities for example a
five pack of a product or a twenty pack and they have different order numbers
you need to have different udi idis for those levels of packaging meaning one ud
idi for the actual device and another udidi for the sales package if so if in
anything else than a single pack but please note that shipping containers are
excluded from the udi requirements that was a summary of the udi setup now let's
continue with the udi carrier which is basically the label then first of all
let's just make it clear again the udi carrier shall not include the basic udidi
only the udidi and if applicable to udi pi and once again the udai carrier shall
be readable both to humans and machines the udi shall be placed on the actual
let'sdevice and if that is not possible it shall be placed on the packaging
then focus a bit on the udi pi part the pi production identifier part of the udi
code is the code that is dynamic and used to identify the specific data related
to the production of that specific device such as serial number lot number
software identification manufacturing or expiry date or both of those dates and
for devices exclusively intended for retail sales for example band aids the udi
pi is not required to appear on the sales packaging as aidc meaning machine
readable so that is excluded for those retail devices and at the other end of
the risk scale there are active implantable medical devices and for them the
serial number on unit level is mandatory to be included in the udi pi so what
could one of those machine readable codes look like well here is an example of a
2d barcode udi including the udidi and the udi pi and as you hopefully
understand if the pi part needs more data then we need a longer code and if your
product doesn't have a really big label it could become a challenge to fit this
barcode onto the existing one but there are dot matrix codes available to use
also if a 2d barcode will be too long but still the data must be able to be read
by humans also so when do you need to comply with this marking of the udi on
your device here you see the dates when the udi carrier must be on your device
the upper row is for normal devices and the bottom row is for devices that are
intended to be reduced like surgical instruments and the dates for those
reusable devices shown here is the date when the actual device needs to be the
udi carrier themselves so basically meaning marking the device itself with the
full udi not just on the label as you can see now udi is more than just a
barcode so the majority of the mdr requirements are collected in article 27 and
annex 6 but i have to admit that this annex is quite messy and not the best part
of the mdr actually and since there are quite many things in the mdr that needs
to be clarified in relation to udi the mdcg has been busy in issuing guidance
documents on this subject so i strongly recommend you to frequently check the
mdcg web to see if when new or updated guidelines are published related to udi
and be aware that there are some specific requirements for software and
procedure packs plus some other devices that have specific guidelines published
by the mdcg for the udi feel free to drop a comment or question below i'd love
to talk to you are you on linkedin make sure you follow medicaldevicehq there
and do tell our friends from the medical device industry to connect with us too
that's all for now thanks for watching once again and see you next time
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