To be in compliance
with this section of identification, sponsor should always establish procedures
and protocols to provide a system and instruction for product identification.
It is not only apply to finished products, the system should also apply to
materials, parts, sub-assemblies and other critical components.
Sponsor
should establish part number and device configuration record and traceability
record. Purchased materials, parts and components are identified with unique
numbers, codes, or names. The identifications should be maintained while the
‘products’ are in the production, finished product, storage and even at
consumers locations.
Identification
should be performed during production. During all stages of production,
manufactured parts and sub-assemblies are identified by the work order. Work
orders accompany products as they move from one workstation or production
process to the next.
Identification
should be performed during finished product. Finished products are identified
by a label that is permanently affixed to the product. The identification label
includes the name and model of the product; the name, address and phone number
of the manufacturer; and the serial or lot number.
Identification
of Returned Product: Products returned for servicing are brought to the
receiving desk in the servicing department and are tagged with the service job
number. New products returned for exchange, refund or for any other reason are
labeled HOLD and are placed in a designate a holding (quarantine) area before
moving redistribution area or being repaired.
The following
is the exact wording from FDA website.
Sec. 820.60
Identification.
|
Each manufacturer shall
establish and maintain procedures for identifying product during all stages
of receipt, production, distribution, and installation to prevent mixups. |
1.
–CFR-Code of Federal Regulation Title 21 part 820 Quality
System Regulation, www.fda.gov,
page last updated 06/01/2013.
The next I shall blog about
traceability of product.
Disclaimer:
Although
the author had exhaustively researched all sources to ensure the accuracy and
completeness of the information contained in this blog, but no warranty and
fitness is implied. I assumed no responsibility and implied warranty of any
kind for errors, inaccuracies, omission, or any inconsistency herein. No
liability is assumed for incidental or consequential damages in connection with
the use of the information contained herein. Readers should always use their
own judgment and review all related regulatory guidelines. Guidelines can
change over time.
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