FDA UDI Compliance Presentation Title Experience in Japan ... · FDA UDI Requested Attributes (64...
Transcript of FDA UDI Compliance Presentation Title Experience in Japan ... · FDA UDI Requested Attributes (64...
1WorldSyncPresentation Title
1WorldSyncFDA UDI Compliance
Experience in Japan and Korea
April 11, 2017
Agenda
▪ About 1WorldSync
▪ FDA UDI Compliance
▪ Experience in Japan and Korea
▪ What’s Coming Next
– FDA GUDID
– UK NHS (Scan4Safety)
– EU EUDAMED
About 1WorldSync
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Distribute &
Deliverthe product information
and digital content that
powers global commerce
Empower
Peoplewith trusted product information
for informed purchase decisions
& everyday well-being.
Bring Simplicity
& Efficiencyto global trading networks, through
technology, transparency, trust and
standardization.
Our Mission & Purpose
1WorldSync is the premier global network
for trusted product information, used by 20,000+ brands,
digital content providers and their trading communities
© 2016 1WorldSync Inc.
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1WorldSync Focus
3Focus Audiences
5Core Verticals 11
Solutions for
• Retail
• Hardlines
• Consumer Goods
• Food Service
• Healthcare
Sources OR Recipients
• Supply Chain MDM
• Transparency &
Compliance
• Omni-Channel & Digital
Commerce© 2016 1WorldSync Inc.
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1WorldSync Focus
1WorldSync is focusing on 5 core industries and 3 core audiences. Today’s focus is Healthcare and Compliance.
1WorldSync and GS1
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™
1WorldSync
1WorldSync is owned by
Leading Med Device/IVD Manufacturers are using
1WorldSync for Product Information Distribution Strategies
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FDA UDI Compliance
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Objective of the UDI Program
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FDA UDI Rules
▪ The label of every medical device (including all IVDs)
must have a UDI (Unique Device Identification).
▪ UDI = Device ID (DI) + Product ID (PI)
– Device Identifier (DI) (static) specific to device version or
model (GTIN is most commonly used)
– • Production Identifier(s) (PI) (dynamic) one or more
currently used control/production identifiers such as
lot/batch number, serial number, manufacturing date, or
expiration date
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UDI on Label vs UDI Database (GUDID)
Submission
© 2016 1WorldSync Inc.
Labeling System
GUDID Submission Data
Medical Device Manufacturer
Prepare/Source Data
UDI Label
GUDID
Medical Device Manufacturers are required to label their products according to FDA rules and submit GUDID Data (device attributes) to FDA Global UDI Database (GUDID).
FDA UDI Compliance Dates
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• Year 1: Class III and devices licensed under Public Health Services Act
• Year 2: Class II/I implants and life-supporting/sustaining
• Year 3: Class II items
• Year 5: Class I and items that have not been assigned a class
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FDA UDI Requested Attributes (64 attributes)
▪ Primary Device Identifier (DI) (no control Information
▪ Secondary Device Identifier
▪ Unit of Use DI (If different from DI)
▪ Manufacturer’s Name, Address, Contact Information.
▪ GMDN
▪ Device Description
▪ Additional Product Description
▪ Trade Name/Brand Name (of DI and if part of a device
family)
▪ Model Number/Catalog Number (of DI and if part of a
model family)
▪ Clinical Size (volume, length, gauge, etc.)
▪ Storage Conditions
▪ Sterile?
▪ Sterilize prior to use, and method of sterilization
▪ Type of Control (PI) (serial number, Lot/Batch,
Expiration Date, and/or manufacturing date) (not actual
number or date)
▪ Can DI be reused?
▪ Contains Latex?
▪ Contains Human Tissue?
▪ FDA Numbers-
— Product Code
— Listing Number
— Premarket Authorization, 510K
— Supplement Number
▪ Direct Marking DI (if different from DI)
▪ Direct Marking Exemption Reason
▪ Marketing Status
▪ Is DI part of a Kit? Or a Combination Item?
▪ DI Discontinued Date (if applicable)
▪ Higher level information
▪ Parent DI, Child DI, Child Quantity
Some UDI UDI Statistics
▪ More than 1.3 Million DIs are registered submitted to
GUDID as of March 2017.
– Was less than 700K items as of April 2016 so the number
of items doubled in 1 year.
▪ More than 3500 companies have published records to
GUDID.
▪ More than 90% of DIs are identified with GS1 GTIN.
© 2016 1WorldSync Inc.
GS1 and FDA UDI
▪ FDA recognizes 3 issuing agencies for UDI (DI):
– GS1(GTIN)
– HIBCC
– ICBBA
▪ GS1 GDSN standard attributes are extended and
validation rules adjusted to meet the need of FDA
GUDID attribute requirements.
© 2016 1WorldSync Inc.
“GDSN” = standard process to exchange
trusted product information.
▪ Based on GS1 standards – network of GS1 certified data pools.
▪ Used in Healthcare as in many other Industries
▪ Enabling immediate access from Trusts, Hubs, Distributors,
Regulatory bodies (FDA, EUDAMED, NHS) to high quality data
provided by the Brand Owners
Our Experience in Japan and Korea
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UDI Seminars and Conferences
▪ Japan
– First UDI Seminar with GS1 Japan on Aug. 6, 2014
– 1WS UDI Conferences
▪ Oct. 7, 2015
▪ Apr. 13, 2016
▪ Jul. 21, 2016 (joint event with Globizz Inc.)
▪ 1WS will have a booth at MEDTEC Japan from April 19 to 21
http://www.medtecjapan.com/
▪ Other events planned in 2017 including workshops at US
Embassy in Tokyo, JETRO etc.
▪ Korea
– Invited to GS1 Korea’s UDI Seminar (Dec. 22, 2015) 18
Typical issues heard from device
manufacturers
▪ Many have no idea how to get items into GUDID except manually entering
data onto the GUDID GUI – they wanted a way to mass upload data onto
GUDID.
▪ Language barrier– understanding basic rules, applying for a GUDID
account, everything needs to be communicated in English via FDA helpdesk
▪ Many unfamiliar vocabularies – GMDN, DUNS, Sterilization Method, Single
Use, Direct Marking, Secondary DI, Convenience Kit…
▪ Several manufacturers are also requested by US GPOs to publish data via
GDSN.
▪ Lack of resources to do the job and internal employee trainings were
required and help needed preparing data to be submitted
▪ Some considered developing their own M2M connection with GUDID but it
was too costly to develop a one-off solution.
© 2016 1WorldSync Inc.
How to submit data to GUDID
© 2016 1WorldSync Inc.
Quick Comparison: Direct GUDID vs 1WS
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DIRECT GUDID Submission Submission via 1WorldSync
Date entry methods Web UI
HL7 SPL (via ESG)
Web UI
Spreadsheet upload
XML
API
Data Loading and Maintenance (DLM)
service
Data published to FDA GUDID only Hospitals, GPOs, FDA GUDID, NHS and
other regulatory bodies
Language supported English Mandarin, Japanese, English, etc.
Test account Test account available for M2M
users only
Test account available (can prepare data in
advance)
Support location US US, Germany, UK, Japan, Taiwan
Support method FDA Helpdesk (Webform) Telephone, email
Training Online training (recorded video
only)
F2F training or webinar in English,
Mandarin, Japanese, and Korean.
How 1WS helped medical device
manufacturers
▪ FDA UDI rules
– Addressed general questions on UDI rules
– GUDID attribute requirements and mapping with GDSN including
product hierarchy rules
– Basic UDI trainings for internal employees (a.k.a “Special
Training”)
– Setting up UDI accounts
▪ Data submission and DLM (Data Loading and Maintenance) Service
– Most manufacturers used spreadsheet upload – 1WorldSync
staff helped validating data
– Many also applied for DLM for data quality assurance and
guaranteed data delivery to FDA
– Support for FDA certification test for M2M / SPL submission© 2016 1WorldSync Inc.
2016 Results – Class II compliance deadline
▪ 12 manufacturers from Japan and 2 manufacturers from Korea
successfully submitted Class II UDI data, all of them met the
deadline.
– More than 8,000 items loaded into GUDID via 1WS from Japan
and Korea
– 100% of those items use GS1 GTIN as DI
– They all used the GDSN-based solution but non-GDSN solution
is also available (i.e. items with non-GS1 DI)
▪ Several device manufacturers are publishing data not only to FDA
but also to GPOs.
© 2016 1WorldSync Inc.
What’s Coming Next
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US FDA GUDID Compliance
▪ If you have Class III or Class II devices, you must be compliant NOW!
– There are manufacturers who are not compliant on time and
manufacturers introducing new items to the US market - Class II
devices are continued to be submitted.
▪ Compliance date for Class I products is Sept. 24, 2018.
– It is not announced yet when the GUDID account will be open for Class
I manufacturers.
– 1WorldSync can provide access to 1WS system and manufacturers can
start preparing data and validate against FDA rules from today!
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NHS Scan4Safety
▪ NHS is National Health Service covering the UK
▪ There are 154 NHS Trusts in England providing
secondary case service. They group hospitals on a
geographical basis.
▪ Purpose of Scan4Safety is adoption of GS1 standards
and PEPPOL standards.
– Improving patient safety
– Efficiency and cost savings
▪ Scan4Safety demands suppliers to publish product data
to NHS via GS1 GDSN.
DH – Leading the nation’s health and
care
Supplier compliance timetable for NHS
© 2016 1WorldSync Inc. 27
Class Item Sync Compliance DatePrice Sync Compliance
Date
Class III
IVD List ASept. 30, 2017 Sept. 30, 2018
ClassⅡb
IVD List BSept. 30, 2018 Sept. 30, 2019
ClassⅡa
IVD self-testSept. 30, 2018 Sept. 30, 2019
ClassⅠIVD General
Sept. 30, 2019 Sept. 30, 2020
61 attributes required by NHS.
EU UDI Requirements Update
▪ EU Parliament adopted on April 5 the EU UDI regulation (also
known as the MDR, Medical Device Regulation).
▪ All medical device suppliers must submit their item data to
EUDAMED (European Database on Medical Devices) within 3 years
- by 2020 for MDs and 2022 for IVDs.
▪ 1WorldSync has launched the MDM Implementation Task Force with
selected healthcare customers.
– MD / IVD registration
– Validation
– Digital Assets
– Feedback of information provided by EUDAMED
© 2016 1WorldSync Inc. 28
EU UDI Regulation approved on 5th April 2017
Implementation plan over 3 years for MD’s
EU Commission Regulation
Q2 2017
EU Implementation Plan, Functional
Specifications
Audit
Testing Begins
Help Desk Creation
Production Go Live
Q2 2020
3 Years
EUDAMED Items to note
▪ EUDAMED attributes identified as of today are about 30.
▪ All class of medical devices go live at the same time
– IVD’s go live in 2022
▪ GS1, HIBCC, & ICCBA will be acceptable Identifiers
▪ GMDN will not be mandatory
– EU will research for a nomenclature
▪ Must be Free and available to all
▪ Member states are not allowed to adjust
▪ All levels of hierarchy, except shipping containers
The impact on your organization
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Prepare your strategy - Ask yourself…
▪ How many products do you have?
▪ How do you manage your product content
_ Governance - people & definitions?
_ Where is the information today?
_ Attributes ?
_ How do you communicate today with your trading
partners?
▪ How do you want to leverage the FDA / NHS / EUDAMED
mandates to share product content in the global market?
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We can help you to :
▪ START NOW!
▪ Take control…before you lose control.
▪ Organize your processes
▪ Create a single source of product information truth
▪ Implement a single data distribution strategy for global
commercial and regulatory compliance
▪ Developing or establishing a formal data governance
strategy
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© 2017 1W or ldSync
Thank you
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