The IAMERS FDA Committee has also been reviewing the proposed regulations concerning the Unique Device Identification System. The proposed rule was published for comment in the July 10, 2012 Federal Register. Comments on the proposed rule are due by September 10 as they pertain to information collection issues under the Paperwork Reduction Act of 1995 and by November 7, 2012 for the substance of the proposed rule. In many ways the proposed rule follows the general tenets of the Global Harmonization Task force by requiring that each medical device be labeled and that information on the label (e.g., type of device, lot, batch number) be captured in plain text and in a form that automatically identifies and captures information (bar code). Little is said as to when the UDI is to be changed and how the UDI is to be captured on large equipment purchases. While the expected implementation date for Class II devices is expected to be three years after the final rule, the IAMERS FDA committee is working with the FDA on addressing issues of particular concern to our industry. The full proposed rule and comment are readily accessible on the FDA website. (Caution: its lengthy). IAMERS welcomes comments concerning the proposed rule and the proposed requirement of post market surveillance (whereby information concerning the equipment is kept for purposes of product recall).
