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Below is the guidance we received from the FDA concerning how to barcode
non-licensed products that are prepared at our facility but do not have
codabar numbers assigned.  Hope this helps.



Thank you for your inquiry to FDA's Center for Biologics Evaluation
and Research (CBER) regarding the bar code rule.  CBER, one of six
centers within FDA, is responsible for the regulation of
biologically-derived products, including blood intended for transfusion,
blood components and derivatives, vaccines and allergenic extracts, and
cell, tissue and gene therapy products.  

Local product Codabar codes may be assigned to blood products for which
there are no assigned product Codabar codes.  These products are usually
products that have not been licensed by the FDA since data has not been
submitted to prove that the product is effective and safe.  Local
Codabar product codes may be picked from anywhere in the range of 29600
through 29999.  After you have selected a product code, you can assign
your own product name to the code, e.g., Red Blood Cells Leukoreduced
Additive Solution Removed and  Platelets Pheresis Leukoreduced Saline
Added.

I hope this helpful. 

Adrienne Hornatko-Munoz 
Branch Chief, Manufacturers Assistance & Technical Training Branch
(MATTB) 
OCTMA/CBER/FDA 
HFM-41 
301-827-2000 phone 
301-827-3843 fax 

This communication is consistent with 21 CFR 10.85 (k) and constitutes
an informal communication that represents my best judgment at this time
but does not constitute an advisory opinion, does not necessarily
represent the formal position of FDA, and does not bind or otherwise
obligate or commit the agency to the views expressed. 




-----Original Message-----
Subject: Guidance concerning labeling products

I am trying to determine the proper way to label 2 products that are
manufactured by a transfusion service.  These products are not shipped
to other facilities.  I am hoping you can provide some guidance.

I can not find bar code numbers for the following non-licensed
products:
Additive Solution Removed, Leukoreduced Red Blood Cells and  Saline
suspended Leukoreduced Pheresis Platelets.

We are trying to ensure that we comply with the Bar Code Label
Requirements for Human and Biological Products; Final Rule (Docket
number 2202N-0204) and am unsure how to handle these two products.

Thanks for your help, Kris





Michelle Precourt
LIS Coordinator
The Children's Hospital of Philadelphia
215-590-5466

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