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Checklist Plug-and-play starting point Quality Assurance

Checklist: USP <87>/<88> and ISO 10993-17:2023 Biocompatibility Transition Readiness

A plug-and-play checklist for the two plastics and device-constituent biocompatibility transitions landing three weeks apart at the end of 2026: USP <87>/<88> retiring the Class I-VI plastics scheme, and FDA's ISO 10993-17:2002 recognition closing, with pass/fail/NA items, references, and a filled specimen.

Document type: Checklist

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use checklist for two biocompatibility standards transitions that land inside the same three-week window: USP <87>/<88> becomes official 1 December 2026, retiring the legacy Class I-VI plastics classification, and FDA’s transition period for the withdrawn ISO 10993-17:2002 toxicological risk assessment method closes 20 December 2026. Replace every <<FILL: ...>> placeholder, work the checklist against your actual material and device-constituent inventory, and route the completed record through document control. A worked filled specimen follows the template. Verify each cited standard against the current source before you rely on it.

Control header

FieldEntry
Checklist number<<FILL: CHK-EL-ID>>
Product(s) / material(s) in scope<<FILL>>
Performed by / date<<FILL>>
Reviewed by (Quality) / date<<FILL>>
Approved by / date<<FILL>>

Background: what is changing and when

  • USP <87> Biological Reactivity Tests, In Vitro and <88> Biological Reactivity Tests, In Vivo are revised, official 1 December 2026. The revision retires the Class I-VI plastics classification (in practice only Class VI certificates were still being requested) and replaces it with a “Pharmaceutical Grade Polymeric Materials” designation evaluated under expanded in vitro <87> methods, with <1031> as the risk-based framework for any further biological evaluation. The animal-based <88> testing that used to anchor a Class VI claim is largely retired.
  • ISO 10993-17:2023 (second edition, the Toxicological Screening Limit method) was recognized in part by FDA on 18 December 2023. Declarations of conformity to the withdrawn 2002 first edition are accepted only until 20 December 2026, after which only the 2023 edition is recognized.

Neither is a device-only concern. Any drug, biologic, or combination product with a plastic or elastomer product-contact material, or a device constituent carrying its own toxicological risk assessment, is in scope for one or both.

Items

#ItemPass / Fail / N/AEvidenceComments
1A current inventory exists of every product-contact plastic and elastomer material and every device constituent with its own toxicological risk assessment
2For each material in scope, the current supplier certificate of analysis or specification has been reviewed for a “USP Class VI” citation
3Where a “USP Class VI” citation was found, the supplier has been contacted for an updated certificate referencing the revised <87>/<88>/<1031> framework
4Internal component specifications, incoming inspection criteria, and supplier quality agreements have been reviewed for a “Class VI” requirement and updated to cite the revised chapters
5Purchasing and supplier quality templates (RFQs, supplier questionnaires, audit checklists) that ask for a “Class VI certificate” have been updated
6For each device constituent with a toxicological risk assessment, the assessment has been checked for a citation to ISO 10993-17:2002
7Where a 2002-edition citation was found, the risk assessment has been reworked to the 2023 TSL method (screening exposure against the Toxicological Screening Limit before a full margin-of-safety calculation)
8The reworked risk assessment’s exposure basis (assumed vs. experimental release kinetics) is documented and consistent with the leachables data actually available
9Any submission, technical file, or design history file referencing either retired scheme has been identified for an update on its own regulatory timeline
10Change control records exist for every specification, certificate, or risk assessment updated as a result of this checklist
11Quality Assurance has confirmed no open item remains past its transition date without a documented, risk-justified interim rationale

Acceptance criteria

  • Every product-contact material and device-constituent assessment in scope has been checked against both transitions, not just the one that happens to be top of mind.
  • Every “Fail” or open item has an owner, a target date, and a change control record, and no target date falls after the relevant transition date without a documented interim rationale reviewed by Quality.
  • The checklist itself, once completed, is retained as evidence that the transition was actively managed rather than discovered after the fact.

References

USP General Chapters <87>, <88>, and <1031> (revised biological reactivity and biocompatibility framework, official 1 December 2026). ISO 10993-17:2023, Biological evaluation of medical devices, Toxicological risk assessment of medical device constituents, and the FDA recognition transition for the withdrawn 2002 first edition (transition closes 20 December 2026). See Extractables and Leachables for the underlying framework and the worked AET calculation.

Confirm the current version and effective date of each standard before you rely on it; official dates for chapters still in ballot can move.


Filled specimen

The following shows the checklist completed for an example prefilled syringe combination product. Values are illustrative.

#ItemPass / Fail / N/AEvidenceComments
1Material inventory existsPassMaterial inventory MI-EL-014, rev 3Plunger stopper, needle shield, barrel coating
2Certificates reviewed for “Class VI”FailPlunger stopper COA dated 2023 cites Class VINeeds updated certificate
3Supplier contacted for updated certificatePassSupplier RFQ SQ-2026-441 sent 2026-09-10Response due before 1 Dec 2026
4Internal specs updatedFailSpec SPEC-COMP-0231 still cites Class VIChange control CR-2026-118 opened
5Purchasing templates updatedPassRFQ template rev 5 references <87>/<88>/<1031>
6Toxicological risk assessments checked for ISO 10993-17:2002FailTRA-DEV-009 cites 2002 editionRework required
7Risk assessment reworked to 2023 TSL methodIn progressToxicology draft due 2026-11-15Screening against TSL expected to clear 2 of 3 flagged constituents
8Exposure basis documentedPassExperimental release kinetics from leachables study LS-2025-07 used
9Submissions/DHF checkedPassNo open submission references either retired scheme
10Change control records existPassCR-2026-118, CR-2026-119
11QA confirms no undocumented open itemPassInterim rationale not needed; both items on track to close before their dates

Interpretation: two genuine gaps were found (item 2/4 and item 6/7), both already have an owner, a change control record, and a target date ahead of the relevant transition date. This is what “actively managed” looks like on inspection: not zero findings, but every finding tracked to closure before the standard actually changes underneath the product.

Common inspection findings this checklist prevents

  • A supplier certificate or internal specification still citing “USP Class VI” months after the revised chapters became official, with no record that anyone checked.
  • A device-constituent toxicological risk assessment left on the withdrawn ISO 10993-17:2002 method past the FDA transition date, discovered only when a reviewer asks about it.
  • The transition treated as the supplier’s problem to solve unprompted, with no internal review of specifications, RFQ templates, or existing assessments.

How to adapt this checklist

  1. Set your checklist number and list every product and material in scope.
  2. Work through the 11 items against your actual inventory, specifications, and risk assessments, not from memory.
  3. Open a change control record for every gap found, with an owner and a target date ahead of the relevant transition date.
  4. Have Quality Assurance confirm closure, or a documented, risk-justified interim rationale, before the transition date arrives.
  5. Retain the completed checklist as evidence of active management for the next audit or inspection.
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