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Lot traceability and record-keeping for perinatal products

A practical explanation of what lot traceability means for perinatal tissue and exosome products, and the records a clinic should keep to support recalls, audits, and patient-level documentation.

Reviewed 2026-10-27

Why lot traceability starts before the product reaches your clinic

Each tissue lot carries a unique identifier. Request the traceability record for the product; do not assume one donor or one run per lot.

Traceability becomes operationally important the moment a lot is placed on hold, recalled, or flagged during routine supplier surveillance. A clinic that cannot immediately match its inventory, and its patient records, to a specific lot number has no fast way to know whether it used the affected material. The practical test is simple: if your supplier called tomorrow about a lot number, could you say within minutes whether you have it, used it, and on whom?

  • Lot or batch identifier printed on the vial and outer carton
  • Recovery or manufacture date
  • Quarantine and release status
  • Ship date and carrier tracking number

What a lot-specific certificate of analysis should tell you

A certificate of analysis (COA) is the document that ties a given lot's testing results to its lot number. For these product categories, request that the COA include the lot identifier, a summary of sterility testing performed by a third-party laboratory, and the storage condition the lot was released under. Request a COA for every lot you receive, not just the first shipment from a new supplier.

Samples from each lot are sent out for sterility testing, and the lot is held in quarantine until testing is complete and internal release criteria are met. That sequence, test first, release second, is the reason a COA should be dated before or at shipment, not produced after the fact. If a supplier cannot produce a lot-specific COA on request, treat that as a documentation gap worth resolving before you order again.

Connecting the lot number to the patient record

Supplier-side traceability only closes half the loop. The other half happens inside your clinic: recording which lot number was used for which patient, on which date, by which clinician. This is what allows you to answer a recall or inquiry in the other direction, from patient back to lot, not just lot forward to shipment.

The format does not need to be complex. A dedicated field in your EHR, or a simple log maintained alongside your inventory record, is enough as long as it is used consistently and backed up.

  • Patient identifier
  • Product name and format (vial size)
  • Lot number
  • Date of use
  • Clinician of record
  • Vial disposition: used, wasted, or returned

Cold chain documentation for cryopreserved and lyophilized formats

Cryopreserved products ship overnight on dry ice in validated containers, and the condition of that shipment on arrival is part of the traceability record, not a separate concern. Document dry ice presence, any temperature indicator included in the shipment, and the general condition of packaging at receipt, and file that note against the lot number.

Lyophilized formats are described by the supplier as shelf-stable without cryogenic storage, which simplifies receiving but does not remove the need for a record. Note the receipt date, and review the insert supplied with the lot for the applicable storage and handling instructions.

How long to keep lot records

Retention periods for HCT/P-related documentation are something your clinic should settle with its own recordkeeping policy and, where relevant, regulatory counsel. The federal framework governing these products establishes recordkeeping expectations for establishments handling human cells and tissues, but the retention schedule that fits your clinic depends on your broader compliance posture.

If your clinic aligns lot-record retention with its general medical-record retention schedule, consider organizing records by lot number first and patient second, so either direction of lookup, lot to patients or patient to lot, is fast.

Questions to ask your supplier about traceability

Before adding a new product line, ask how the supplier structures lot-level documentation and what happens if an issue is identified with a lot after it has shipped.

  • Will a lot-specific COA accompany or precede every shipment?
  • Is the lot number printed on both the vial and the outer packaging?
  • What is your process for notifying accounts if a lot is placed on hold after distribution?
  • How quickly can you reproduce documentation for a lot we received months ago?
FAQ

Frequently asked questions

What is a lot number, and why does it matter for a clinic that only orders a few vials at a time?+

A lot number identifies a specific production lot and the testing and documentation associated with it. Request the traceability record for the product to confirm what a given lot number represents; do not assume a single donor or a single run per lot.

How long should we retain lot-level records?+

There is no single number that applies to every clinic. If your clinic aligns lot-record retention with its general medical-record retention policy, confirm the specifics with regulatory counsel, since requirements can vary by state and by the clinic's own compliance program.

What should we do if a shipment arrives without visible dry ice or an intact cold pack?+

Document the condition on arrival, do not use the product, and contact the supplier before taking further action. A cold chain concern should be resolved and recorded against the lot number before that lot is used on any patient.

Can we request documentation for a lot we already used?+

Yes. A supplier working with verified accounts should be able to produce lot-specific documentation, such as a certificate of analysis, after the fact. It is better practice to request it before use, but retroactive requests are normal and reasonable.

Sources

  1. 21 CFR 1271.10 - Are my HCT/Ps regulated solely under section 361 of the PHS Act ↗eCFR
  2. Consumer alert on regenerative medicine products including stem cells and exosomes ↗FDA