820.160 Distribution.

(a) Each manufacturer shall establish and maintain procedures for control and distribution of finished devices to ensure that only those devices approved for release are distributed and that purchase orders are reviewed to ensure that ambiguities and errors are resolved before devices are released for distribution. Where a device`s fitness for use or quality deteriorates over time, the procedures shall ensure that expired devices or devices deteriorated beyond acceptable fitness for use are not distributed.

(b) Each manufacturer shall maintain distribution records which include or refer to the location of:

(1) The name and address of the initial consignee;

(2) The identification and quantity of devices shipped;

(3) The date shipped; and

(4) Any control number(s) used.

Interpretation:

Quality System section 820.184, Device History Record (DHR), requires manufacturers of devices to maintain basic records for:

• dates of manufacture,
• the quantity manufactured,
• quantity released for distribution,
• acceptance records,
• primary identification labels and labeling used, and
• any device identification and control number used.

Section 820.160, Distribution, requires the following records:

• name and address of the initial consignee,
• identification and quantity of devices shipped,
• date shipped, and
• any control number used.

Some of the above information necessary for the distribution records is a duplicate of Device History Record (DHR) requirements. These duplications may be copied or transferred electronically from the DHR. If appropriate, a manufacturer may combine the records by adding the distribution information to the DHR.

In addition to the above requirements, manufacturers of implantable devices and life sustaining devices, the failure of which during use could result in significant injury to the user, are required to establish and maintain procedures for identifying with a control number each unit, lot, or batch of finished devices and, where appropriate, components (820.65). A partial list of traceable devices that meet this definition is printed at the end of this chapter.

Distribution records may be the same as, or part of, the normal business records. Generation of a separate record is not required unless the business records are not readily available, e.g., not maintained at the same establishment as the device history record and not readily retrievable electronically. Many manufacturers, also keep distribution records for billing and market survey purposes.

Manufacturers of radiological electronic products listed in 21 CFR 1002.1, Record and Reporting Requirements By Product, shall maintain distribution records that will enable them to trace specific products or production lots to distributors, or to dealers in those instances in which the manufacturer distributes directly to dealers (See 21 CFR 1002.30, Records to be Maintained by Manufacturers).

Distribution records shall be kept for a period of time equivalent to the design life and expected life of the device, but in no case less than two years from the date of release for commercial distribution by the manufacturer [820.180(b)]. The intent of this requirement is support for potential repairs, corrective actions and recalls. Each manufacturer should make a prudent decision whether to discard records or keep all, or part, of them for a longer period. When requested, distribution records shall be made available to FDA investigators for review and copying during normal business hours.

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Reference: www.FDA.gov

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