Comprehensive Guide to Conducting Print Verification of Labels and Inserts for Medical Devices
1) Purpose
The purpose of this SOP is to define the process for conducting print verification of labels and inserts used in the packaging of medical devices. Print verification ensures that all printed text, symbols, and barcodes on labels and inserts are accurate, legible, and compliant with regulatory requirements before products are released for distribution.
2) Scope
This SOP applies to the verification of all labels and inserts used in the packaging of medical devices at the facility. It includes text, graphics, symbols, barcodes, and other printed elements on packaging materials that must be verified for accuracy and compliance.
3) Responsibilities
– Packaging Development Team: Ensures that labels and inserts meet design and regulatory requirements before printing.
– Quality Assurance (QA): Verifies the accuracy and compliance of labels and inserts, ensuring that printed materials conform to the approved specifications.
– Printing and Packaging Operators: Perform the actual print verification during production, ensuring that labels and inserts are printed correctly.
– Regulatory Affairs: Ensures that all labeling, including inserts, complies with relevant regulatory standards.
– Document Control Team: Maintains records of print verification results, including discrepancies
4) Procedure
4.1 Print Verification Process Overview
4.1.1 Importance of Print Verification
– Print verification ensures that all printed information on labels and inserts is accurate and legible. It is essential to:
– Prevent errors in device identification, labeling, and usage instructions.
– Ensure compliance with regulatory requirements (e.g., FDA, ISO).
– Maintain device traceability through accurate batch and lot numbers, expiration dates, and serial numbers.
4.1.2 Scope of Print Verification
– Print verification covers all printed elements on labels and inserts, including:
– Text: Product name, instructions for use (IFU), warnings, and regulatory statements.
– Graphics and Symbols: Regulatory symbols (e.g., CE mark, sterilization symbol), device images, and safety icons.
– Barcodes/QR Codes: Unique device identifiers (UDIs), lot numbers, and serial numbers.
– Date Codes: Expiry dates, manufacturing dates, and batch/lot numbers.
4.1.3 Frequency of Print Verification
– Print verification should be conducted:
– Before Printing: To check that the artwork and layout meet specifications.
– During Production: At regular intervals during the production run to ensure continuous quality.
– After Printing: To ensure the final print quality and readability of all labels and inserts.
4.2 Pre-Printing Verification
4.2.1 Artwork Approval
– Before any printing takes place, verify that the artwork and design of labels and inserts are correct and have been approved by the relevant departments (e.g., QA, Regulatory Affairs, Packaging).
– Check for Content Accuracy: Ensure that all text, symbols, and images are correct.
– Regulatory Compliance: Ensure that labels and inserts meet regulatory requirements for the market (e.g., FDA, EU MDR).
– Approval Documentation: Ensure that artwork is signed off and documented.
4.2.2 Pre-Printing Sampling
– Perform a sample print test before full-scale production:
– Verify the color, alignment, and layout of the printed materials.
– Ensure that font sizes are legible and consistent with specifications.
– Conduct preliminary barcode scanning to verify that the codes are scannable and meet regulatory standards (e.g., UDI).
4.3 Print Verification During Production
4.3.1 Visual Inspection of Printed Materials
– During the printing process, operators should perform visual inspections to verify that the print quality meets predefined standards. This includes:
– Text Legibility: Ensure that all text is clear and legible without smudging or fading.
– Symbol and Graphic Accuracy: Ensure that regulatory symbols and images are printed clearly and accurately.
– Correct Barcode Printing: Ensure that barcodes or QR codes are readable and properly aligned.
4.3.2 Random Sampling
– At defined intervals, take random samples from the production run and inspect them thoroughly:
– Check for print quality and verify that the labels and inserts match the approved artwork.
– Ensure that no missing or incorrect information is present on any printed material.
4.3.3 Barcode and UDI Scanning
– Use barcode scanners to verify the accuracy and scannability of any printed barcodes or QR codes:
– Scan a sample of barcodes to ensure that they are scannable and that the data matches the corresponding device information.
– Ensure that all batch numbers, serial numbers, and UDI data are correctly encoded.
4.3.4 Monitoring for Print Quality
– Continuously monitor the printing equipment for any issues that may affect print quality:
– Check for ink smudging, fading, or misalignment of printed text.
– Ensure that there are no printing errors such as missing or repeated information.
4.4 Post-Printing Verification
4.4.1 Final Print Inspection
– After printing is completed, conduct a final inspection of all labels and inserts:
– Verify that the final print matches the approved artwork and specifications.
– Confirm that no misprints, missing information, or alignment errors exist.
– Check that all regulatory symbols and text are correctly placed and legible.
4.4.2 Test Barcode and UDI Scanning
– Perform a final scan of all barcodes, QR codes, and UDI labels to ensure that they are scannable and accurate:
– Verify that barcodes correspond to the correct device or lot.
– Test the scannability of labels in various lighting conditions to ensure that they are easily readable by scanning devices.
4.5 Documentation and Record Keeping
4.5.1 Print Verification Records
– Maintain detailed records of all print verification activities, including:
– Results of pre-printing, during production, and post-printing inspections.
– Documentation of any issues found and corrective actions taken.
– Barcode and UDI scanning results, including any failures and rework actions.
– Sampling data, including the number of samples checked and their verification results.
4.5.2 Corrective Actions and CAPA
– If issues are identified during print verification, document the corrective actions taken to address the problems:
– Identify the root cause of printing errors (e.g., equipment malfunction, material defect, human error).
– Implement corrective and preventive actions (CAPA) to address the issue and prevent recurrence.
4.5.3 Record Retention
– Retain print verification records for a minimum of five years or as required by regulatory authorities to ensure traceability and compliance during audits.
4.6 Compliance and Regulatory Requirements
4.6.1 Compliance with Regulatory Standards
– Ensure that print verification activities comply with applicable regulatory standards, including:
– FDA 21 CFR Part 820: Quality System Regulation for medical devices.
– ISO 13485: Medical Device Quality Management Systems.
– EU MDR (Regulation (EU) 2017/745): Medical device regulations for the European market.
– ISO 9001: General Quality Management Systems.
4.6.2 Regulatory Inspections and Audits
– Provide print verification records during regulatory inspections or audits to demonstrate compliance with labeling and packaging requirements:
– Submit records of print verification checks.
– Provide documentation of corrective actions taken for any issues identified during inspections.
5) Abbreviations
– QA: Quality Assurance
– SOP: Standard Operating Procedure
– FDA: Food and Drug Administration
– ISO: International Organization for Standardization
– UDI: Unique Device Identification
– CAPA: Corrective and Preventive Actions
6) Documents
– Print Verification Records
– Barcode and UDI Scanning Logs
– Corrective Action and CAPA Records
– Inspection and Sampling Records
7) Reference
– FDA CFR Title 21, Part 820: Quality System Regulation
– ISO 13485: Medical Devices – Quality Management Systems
– EU MDR (Regulation (EU) 2017/745): General Safety and Performance Requirements
– ISO 9001: Quality Management Systems
8) SOP Version
– Version: 1.0
– Effective Date: DD/MM/YYYY
– Approved by: [Name/Title]
Annexure
Annexure 1: Print Verification Checklist Template
Date | Sample ID | Inspection Type | Verification Results | Remarks |
---|---|---|---|---|
DD/MM/YYYY | Label-001 | Visual Inspection | Passed | All information is legible |
Annexure 2: Barcode Scanning Log Template
Date | Barcode ID | Scanner Used | Scan Result | Operator |
---|---|---|---|---|
DD/MM/YYYY | 1234567890 | Scanner-01 | Pass | Jane Doe |