CBER Presentation

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Example of AB positive label with bar codes

Bar Code Requirements

Diane Maloney
Associate Director for Policy
CBER
January 20, 2006


Bar Code Rule

  • Blood -Before the Bar Code Rule
  • Bar Code rule
    • Background
    • Blood and blood components
    • Other biological products


Before the Bar Code Rule

  • Re: Blood and blood components
  • Old regulation said:
  • The container label may bear encoded information in the form of machine readable symbols approved for use by the Director, CBER
  • In 1985, FDA recognized the use of Codabar
  • In 2000, FDA accepted the use of one version of ISBT 128


Bar Code Rule

  • For blood and blood components- machine readable information mandatory
  • Required bar codes on most Rx drugs and some OTC drugs
  • Not applicable to devices


Bar Code Rule

  • Finalized: February 26, 2004
  • Effective Date: April 26, 2004
  • Products approved after effective date must comply within 60 days of approval
  • Products approved before the effective date must comply within 2 years of effective date


Products covered by rule

  • Most prescription drugs (including biological drugs)
  • Certain over-the-counter drugs
  • Blood and blood components


How bar coding can prevent medication errors

  • Patient gets bar-coded ID bracelet
  • Hospital uses scanner linked to the hospital's medical records
  • Healthcare worker scans bracelet and drug
  • Computer compares medical record to drug
  • If no match- error message


Types of Errors Detected

  • Wrong patient
  • Wrong dose of drug
  • Wrong drug
  • Wrong time to administer drug
  • Patient chart updated and prescribed medicine has changed


What blood components must bear bar codes?

  • All blood and blood components for transfusion -including splits units, pooled units, pedi-packs and syringes
  • Bottom line: If it's a blood or a blood component and it goes to the patient's bedside it must bear machine readable information.


Blood Establishments Must Comply

  • Blood Establishments that:
    • Manufacture, process, repackage, or relabel blood and blood components
    • Intended for transfusion
    • And regulated under the FDC or PHS Act
    • Are subject to the rule


Blood and blood components

  • At a minimum, the label must contain:
  • Unique facility identifier(e.g. registration #)
  • Lot number relating to the donor
  • Product code
  • Blood type (ABO) and Rh of the donor


Blood and blood components

  • Label must be unique to the product
  • Info must be surrounded by sufficient blank space so can be scanned correctly
  • Info must remain intact under normal conditions


What blood components do not have to bear machine readable information

  • Blood collected from a patient intraoperatively and transfused to that patient in the operating or the recovery room
  • Autologous preparations of fibrin sealants or platelet sealants manufactured and used during surgery
  • Drainage collected in the ER or operating room as part of trauma care for that patient


Requirements for other blood products

  • Source Plasma used to manufacture plasma-derived therapies -SP not intended for transfusion - so does not need to bear machine readable information. However, the resulting products would be subject to the bar code rule
  • Plasma derivatives (e.g. IGIV) are subject to the bar code requirements for drug products (see 21 CFR 610.67 and 201.25)


What about devices?

  • E.g.
  • filters and apheresis kits
  • Rule DOES NOT apply to devices
  • Devices present different regulatory issues and challenges
  • Unlike drugs, devices don't have a standardized unique ID system like NDC
  • FDA will continue to consider issue


What about "Tissues"?

  • Human cells, tissues, and cellular and tissue based products subject to premarket approval (351 products) are subject to the bar code rule
  • HCTPs regulated only under 361 of the PHS Act are not subject to the bar code rule


Exemptions from the bar code requirement

  • FDA may exempt a product from the bar code requirements
  • Factors:
    • Compliance would adversely affect safety, effectiveness, purity or potency or not technologically feasible
    • Alternative regulatory program renders bar code unnecessary for patient safety


Thank You.


 
Updated: June 7, 2006