Medical Device Tracking

FDA had released draft guidance for identification tags that will track medical devices from manufacturers to users.

The guidelines come as the number of medical devices required to meet the tracking regulations has expected to grow this fall.

Manufacturers are required to track certain devices from their manufacture through the distribution chain when they receive an order from the Food and Drug Administration (FDA) to implement a tracking system for a certain type of device. The purpose of device tracking is to ensure that manufacturers of certain devices establish tracking systems that will enable them to promptly locate devices in commercial distribution. Tracking information may be used to facilitate notifications and recalls ordered by FDA in the case of serious risks to health presented by the devices.

Manufacturers must adopt a method of tracking devices whose failure would be reasonably likely to have serious, adverse health consequences; or which is intended to be implanted in the human body for more than one year; or are life-sustaining or life-supporting devices used outside of a device user facility. The regulations implementing the tracking requirements became effective on August 29, 1993, and can be found in 21 CFR Part 821.

On the effective day i.e on February 19, 1998, the tracking requirement was changed to eliminate automatic mandatory tracking for certain devices; instead has discretion to order manufacturers of certain types of Class II or Class III devices to initiate a program to track their medical devices down to the patient level.

Information on implementation of the Medical Device Tracking Regulation along with a list of devices that FDA has ordered to be tracked can be found in the following guidance “Medical Device Tracking – Guidance for Industry and Food and Drug Administration Staff“. Please note that 21 CFR 821 does not contain the current list of devices to be tracked. The list may be found in the guidance document referenced above and at the bottom of this page. The list in the guidance document may not reflect devices newly identified as needing to be tracked, since the last time the guidance document was updated.

The tracking provision is intended to ensure that manufacturers can expeditiously remove potentially dangerous or defective devices from the market and/or notify patients of significant device problems.

Tracking augments FDA’s authority to order mandatory recalls and require notification of health professionals and patients regarding unreasonable risk of substantial harm associated with a device.

Manufacturers of a tracked device must establish a written standard operating procedure (SOP) which includes a method for tracking the device throughout distribution and a quality assurance program including audit procedures. Final distributors of these devices will be required to provide manufacturers with patient information.

Device tracking is required for the useful life of the device.

The types of Medical devices subject to a tracking order may include any Class II or Class III device:

  • the failure of which would be reasonably likely to have serious adverse health consequences;
  • which is intended to be implanted in the human body for more than one year; or
  • which is intended to be a life sustaining or life supporting device used outside a device user facility.

Patients who received a tracked medical device may refuse to release, or refuse permission to release, their name, address, social security number, or other identifying information for the purpose of tracking.

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