<?xml version="1.0" encoding="UTF-8"?><rss version="2.0"
	xmlns:content="http://purl.org/rss/1.0/modules/content/"
	xmlns:dc="http://purl.org/dc/elements/1.1/"
	xmlns:atom="http://www.w3.org/2005/Atom"
	xmlns:sy="http://purl.org/rss/1.0/modules/syndication/"
		>
<channel>
	<title>Comments on: What are Pedigree Laws Trying to Accomplish Anyway?</title>
	<atom:link href="http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/feed/" rel="self" type="application/rss+xml" />
	<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/</link>
	<description>A comprehensive exploration of the intersection between the pharmaceutical supply chain, track and trace technology, standards and regulatory compliance</description>
	<lastBuildDate>Wed, 16 May 2012 10:37:40 +0000</lastBuildDate>
	<sy:updatePeriod>hourly</sy:updatePeriod>
	<sy:updateFrequency>1</sy:updateFrequency>
	<generator>http://wordpress.org/?v=3.3.2</generator>
	<item>
		<title>By: Dirk Rodgers</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-23</link>
		<dc:creator>Dirk Rodgers</dc:creator>
		<pubDate>Fri, 06 Nov 2009 16:35:54 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-23</guid>
		<description>I feel I must comment on the last point made by Anonymous above.  It seems that your experience must have been mainly at pharma manufacturers.  From that perspective, you are correct when you say that the cost of &quot;non-serialized pedigree&quot; becomes very manageable.  The costs to manufacturers are much lower when they do not apply serial numbers at the item level.  But from a full supply chain perspective the costs are not &quot;very manageable&quot;.  Tracing non-serialized items at the wholesale and pharmacy segments is very complex and fraught with potential loss of maintaining the proper history.  Once that history linkage is lost the drugs cannot be sold.&lt;br /&gt;&lt;br /&gt;It&#039;s also a misnomer to call it &quot;lot level&quot; pedigree since only the manufacturer can use the lot as the primary basis for maintaining their supply chain history.  Downstream segments must make use of receipt segregation techniques in addition to the lot/batch.  Since the lot/batch number applied to each package is not machine readable, using it for tracing is inconsistent with a modern, high volume, high speed supply chain.&lt;br /&gt;&lt;br /&gt;It&#039;s interesting to look at how costs are distributed across each segment of the supply chain for different approaches to pedigree.  I&#039;ll try to expand on these thoughts and my observations in a future essay.</description>
		<content:encoded><![CDATA[<p>I feel I must comment on the last point made by Anonymous above.  It seems that your experience must have been mainly at pharma manufacturers.  From that perspective, you are correct when you say that the cost of &quot;non-serialized pedigree&quot; becomes very manageable.  The costs to manufacturers are much lower when they do not apply serial numbers at the item level.  But from a full supply chain perspective the costs are not &quot;very manageable&quot;.  Tracing non-serialized items at the wholesale and pharmacy segments is very complex and fraught with potential loss of maintaining the proper history.  Once that history linkage is lost the drugs cannot be sold.</p>
<p>It&#39;s also a misnomer to call it &quot;lot level&quot; pedigree since only the manufacturer can use the lot as the primary basis for maintaining their supply chain history.  Downstream segments must make use of receipt segregation techniques in addition to the lot/batch.  Since the lot/batch number applied to each package is not machine readable, using it for tracing is inconsistent with a modern, high volume, high speed supply chain.</p>
<p>It&#39;s interesting to look at how costs are distributed across each segment of the supply chain for different approaches to pedigree.  I&#39;ll try to expand on these thoughts and my observations in a future essay.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Anonymous</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-22</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Fri, 06 Nov 2009 05:59:47 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-22</guid>
		<description>The intention of the US pedigree laws is not to set up a firewall between consumers and counterfeiting drugs. They intend to protect consumers by deterring counterfeiters. Essentially pedigree is a tracing mechanism that helps reconstruct the movements of counterfeited drugs after they are detected. With this tracing mechanism, finding the source of counterfeiting drugs becomes quicker and easier; catching and convicting criminals become quicker and easier. Thus the risk and cost to the would-be counterfeiters become higher.  Will pedigree laws completely solve the counterfeiting problems? No. However once fully implemented, they can be very effective in reducing counterfeiting activities.&lt;br /&gt;&lt;br /&gt;Another misconception is that pedigree is costly. From my experience of implementing California pedigree law compliance solutions, pedigree is only a fraction of the cost. It is the item-level serialization which consumes majority of the budget and generates huge amount of data. At the same serialization level, the economic impact of POD model won’t be much less compared to pedigree model. On the other hand, if we decouple pedigree from serialization, the cost of non-serialized pedigree (e.g. lot level) becomes very manageable.</description>
		<content:encoded><![CDATA[<p>The intention of the US pedigree laws is not to set up a firewall between consumers and counterfeiting drugs. They intend to protect consumers by deterring counterfeiters. Essentially pedigree is a tracing mechanism that helps reconstruct the movements of counterfeited drugs after they are detected. With this tracing mechanism, finding the source of counterfeiting drugs becomes quicker and easier; catching and convicting criminals become quicker and easier. Thus the risk and cost to the would-be counterfeiters become higher.  Will pedigree laws completely solve the counterfeiting problems? No. However once fully implemented, they can be very effective in reducing counterfeiting activities.</p>
<p>Another misconception is that pedigree is costly. From my experience of implementing California pedigree law compliance solutions, pedigree is only a fraction of the cost. It is the item-level serialization which consumes majority of the budget and generates huge amount of data. At the same serialization level, the economic impact of POD model won’t be much less compared to pedigree model. On the other hand, if we decouple pedigree from serialization, the cost of non-serialized pedigree (e.g. lot level) becomes very manageable.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Dirk Rodgers</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-21</link>
		<dc:creator>Dirk Rodgers</dc:creator>
		<pubDate>Tue, 03 Nov 2009 17:23:06 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-21</guid>
		<description>Guy, Adam and Anonymous all make good points.  My essay wasn&#039;t focused on economic impacts, but Guy may be correct about the lower cost of the POD model, assuming the government pays for the central repository and all of the technology needed to make that work.  I agree with Guy&#039;s comment about the ownership of the data held by the &quot;database in the sky&quot; being the biggest drawback of POD.&lt;br /&gt;&lt;br /&gt;Adam&#039;s comment makes several very good points.  I encourage everyone to read his excellent essay regarding the demand side counterfeit drug problem (see the link in his response above).  I was just telling my wife that any action that successfully tightens up the supply chain will cause criminals to focus directly on the pharmacies, and that there will be a need for pharmacies to actually advertise their safe buying practices in a way that allows customers to discriminate appropriately.  But Adam makes an excellent point (made in his essay) that consumers will ultimately have to be given some way of independently checking the authenticity of the drugs they buy from pharmacies so they can feel more confident in their trust.  The pharmacy segment in the U.S. has traditionally been opposed to anything that causes customers to feel less than totally confident in drugs coming from pharmacies (&lt;i&gt;any&lt;/i&gt; pharmacy), but with re-importation looking more and more likely, I wonder if they might change their tune.&lt;br /&gt;&lt;br /&gt;Finally, Anonymous (above) makes a point similar to one I made in my previous post, &quot;&lt;a href=&quot;http://www.rxtrace.com/2009/10/pedigree-models-and-supply-chain-master.html&quot; rel=&quot;nofollow&quot;&gt;Pedigree Models and Supply Chain Master Data&lt;/a&gt;&quot;.&lt;br /&gt;&lt;br /&gt;These three comments demonstrate just how narrow the focus is in my blog.  I don&#039;t cover economics.  Fortunately Adam covers it quite well and he is able to provide that perspective in his  &lt;a href=&quot;http://www.drugchannels.net/&quot; rel=&quot;nofollow&quot;&gt;DrugChannels blog&lt;/a&gt; and in his comments in my blog.</description>
		<content:encoded><![CDATA[<p>Guy, Adam and Anonymous all make good points.  My essay wasn&#39;t focused on economic impacts, but Guy may be correct about the lower cost of the POD model, assuming the government pays for the central repository and all of the technology needed to make that work.  I agree with Guy&#39;s comment about the ownership of the data held by the &quot;database in the sky&quot; being the biggest drawback of POD.</p>
<p>Adam&#39;s comment makes several very good points.  I encourage everyone to read his excellent essay regarding the demand side counterfeit drug problem (see the link in his response above).  I was just telling my wife that any action that successfully tightens up the supply chain will cause criminals to focus directly on the pharmacies, and that there will be a need for pharmacies to actually advertise their safe buying practices in a way that allows customers to discriminate appropriately.  But Adam makes an excellent point (made in his essay) that consumers will ultimately have to be given some way of independently checking the authenticity of the drugs they buy from pharmacies so they can feel more confident in their trust.  The pharmacy segment in the U.S. has traditionally been opposed to anything that causes customers to feel less than totally confident in drugs coming from pharmacies (<i>any</i> pharmacy), but with re-importation looking more and more likely, I wonder if they might change their tune.</p>
<p>Finally, Anonymous (above) makes a point similar to one I made in my previous post, &quot;<a href="http://www.rxtrace.com/2009/10/pedigree-models-and-supply-chain-master.html" rel="nofollow">Pedigree Models and Supply Chain Master Data</a>&quot;.</p>
<p>These three comments demonstrate just how narrow the focus is in my blog.  I don&#39;t cover economics.  Fortunately Adam covers it quite well and he is able to provide that perspective in his  <a href="http://www.drugchannels.net/" rel="nofollow">DrugChannels blog</a> and in his comments in my blog.</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Anonymous</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-20</link>
		<dc:creator>Anonymous</dc:creator>
		<pubDate>Tue, 03 Nov 2009 14:53:40 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-20</guid>
		<description>Great post.  In my experience people continue to try and wish away the requirements of the laws for some technical elegance or other agenda.&lt;br /&gt;&lt;br /&gt;If a &#039;solution&#039; doesn&#039;t satisfy the requirements, its not really a solution, is it? ;-)</description>
		<content:encoded><![CDATA[<p>Great post.  In my experience people continue to try and wish away the requirements of the laws for some technical elegance or other agenda.</p>
<p>If a &#39;solution&#39; doesn&#39;t satisfy the requirements, its not really a solution, is it? <img src='http://www.rxtrace.com/wp-includes/images/smilies/icon_wink.gif' alt=';-)' class='wp-smiley' /> </p>
]]></content:encoded>
	</item>
	<item>
		<title>By: Adam J. Fein, Ph.D.</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-19</link>
		<dc:creator>Adam J. Fein, Ph.D.</dc:creator>
		<pubDate>Tue, 03 Nov 2009 12:18:31 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-19</guid>
		<description>Dirk,&lt;br /&gt;&lt;br /&gt;Very thoughtful post.&lt;br /&gt;&lt;br /&gt;Your point about POD may be valid, but pedigree laws could also increase the presence of counterfeits. The administrative burden of pedigree could tempt some pharmacies to engage in unsafe buying practices, especially if any type of importation law gets passed by Congress. &lt;br /&gt;&lt;br /&gt;So, I think it&#039;s very hard for a technical solution to protect us from a &quot;demand-side&quot; counterfeiting problem. See my 2006 blog post for more: &lt;a href=&quot;http://www.drugchannels.net/2006/09/our-demand-side-counterfeit-drug.html&quot; rel=&quot;nofollow&quot;&gt;Our Demand Side Counterfeit Drug Problem&lt;/a&gt;.&lt;br /&gt;&lt;br /&gt;Plus, pedigree laws are often driven by the personal whims of a few volunteers at underfunded state boards of pharmacy. Florida&#039;s law tries to make up for an asleep-at-the-switch Board of Pharmacy prior to 2003. The result has been a crazy patchwork of inconsistent laws and regulations. &lt;br /&gt;&lt;br /&gt;Adam</description>
		<content:encoded><![CDATA[<p>Dirk,</p>
<p>Very thoughtful post.</p>
<p>Your point about POD may be valid, but pedigree laws could also increase the presence of counterfeits. The administrative burden of pedigree could tempt some pharmacies to engage in unsafe buying practices, especially if any type of importation law gets passed by Congress. </p>
<p>So, I think it&#39;s very hard for a technical solution to protect us from a &quot;demand-side&quot; counterfeiting problem. See my 2006 blog post for more: <a href="http://www.drugchannels.net/2006/09/our-demand-side-counterfeit-drug.html" rel="nofollow">Our Demand Side Counterfeit Drug Problem</a>.</p>
<p>Plus, pedigree laws are often driven by the personal whims of a few volunteers at underfunded state boards of pharmacy. Florida&#39;s law tries to make up for an asleep-at-the-switch Board of Pharmacy prior to 2003. The result has been a crazy patchwork of inconsistent laws and regulations. </p>
<p>Adam</p>
]]></content:encoded>
	</item>
	<item>
		<title>By: guy weiss</title>
		<link>http://www.rxtrace.com/2009/11/what-are-us-pedigree-laws-trying-to.html/comment-page-1/#comment-18</link>
		<dc:creator>guy weiss</dc:creator>
		<pubDate>Tue, 03 Nov 2009 10:59:34 +0000</pubDate>
		<guid isPermaLink="false">http://rxtrace.com/?p=17#comment-18</guid>
		<description>Above all, US Pedigree has an economic impact by far higher than POD scenario.&lt;br /&gt;POD is feasible regardless of wholesaler and distributor&#039;s investment but the biggest drawback remains the ownership of information gathered in a central database.</description>
		<content:encoded><![CDATA[<p>Above all, US Pedigree has an economic impact by far higher than POD scenario.<br />POD is feasible regardless of wholesaler and distributor&#39;s investment but the biggest drawback remains the ownership of information gathered in a central database.</p>
]]></content:encoded>
	</item>
</channel>
</rss>

<!-- Performance optimized by W3 Total Cache. Learn more: http://www.w3-edge.com/wordpress-plugins/

Minified using disk: basic
Page Caching using disk: enhanced
Database Caching 18/27 queries in 0.197 seconds using disk: basic

Served from: www.rxtrace.com @ 2012-05-18 19:04:39 -->
