Wednesday, January 11, 2017

What are the UDI Compliance Activities that Typically Cause Companies Problems?

The first way we start every engagement is by getting a list of stock keeping units (SKUs): finished devices, accessories, and components put into commercial distribution in the US. That is often a difficult task as within data systems SKUs are not retired. It is not easy to tell whether your company makes that product or if your company still has that product. You will need to triangulate against a number of different systems in order to understand the different products your company distributes in the U.S. and what they all look like. Pertaining to the contract manufacturing third party, having all of the necessary conversations, determining who is going to do what, and updating contracts and supplier agreements you have, takes an enormous amount of time especially if you have 30 to 40 contract manufacturers or private labeler relationships.

Collecting all of the Global UDI Database (GUDID) attributes can also take a lot of time and energy depending on the organization. The data does not reside in one location, whatever your product labeling system is, it will not contain all the data.  It is common for some data to be in word document or excel spreadsheet. Some of the data will be site specific or corporate specific. Other data only exists on labels and therefore you must find the correct labels. So if you have not started that, what USDM recommends is that you pick a small, representative sample of your product and start collecting that data. Understand who owns the product, what the processes around it are, and what that is going to look like as you scale up to all of your products. It can take quite a bit of time depending on your organization, where the data is, and how easy it will be for you to collect, verify and normalize all of the data.

USDM Life Sciences will help you assess, plan and execute the changes and enhancements necessary to meet UDI regulations. Our team of UDI experts will assess your products, the markets where they are sold and determine an implementation strategy for the changes that need to be made. USDM's assessment methodology is extensive and includes the labels and packaging, the management of identification changes to each product, the changes to PLM, ERP, EPCIS and packaging systems, changes to printing, vision inspection and warehouse/inventory management systems and interfaces to the GUDID.

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