California Pedigree Law, DQSA of 2013

The California Pedigree Law Is Now Officially Inoperative

February 10, 2014 Dirk Rodgers

The California Board of Pharmacy made it official late this afternoon. As required by Section 4034.1 of the California Business and Professions Code (CB&PC), the Board posted a public notice late yesterday indicating that sections 4034, 4163, 4163.1, 4163.2, 4163.4, and 4163.5 of the CB&PC became inoperative due to the enactment of the Federal Drug Quality and Security Act (DQSA) on November 27, 2013 (see “It’s Official, President Obama Signs H.R. 3204, DQSA, Into Law“). These specific sections of the CB&PC comprise what has been referred to in the industry as “the California Pedigree Law”.

The public notice was mandated by California law within 90 days of federal preemption because Continue reading The California Pedigree Law Is Now Officially Inoperative →

RxTrace Traceability Survey

Does The DQSA Require Manufacturers To Provide Aggregation Data? Survey Says…

February 10, 2014 Dirk Rodgers 14 Comments

One of the most intense questions about any serialization mandate is whether or not manufacturers would be required to pass “aggregation data” to their customers. “Aggregation data” is the serial number-based packaging hierarchy of the shipment. That is, a list of the package-level serial numbers that are contained in each serialized bundle, and then which bundles are contained within which serialized cases and then which cases are contained on which serialized pallet, etc.

You can’t expect to give a couple of workers a handheld barcode reader and expect them to produce six sigma aggregation data. It is possible to collected highly accurate aggregation data (see “Pharma Aggregation: How Companies Are Achieving Perfection Today”), but it requires systems specifically designed to do so. The now obsolete California pedigree law did not Continue reading Does The DQSA Require Manufacturers To Provide Aggregation Data? Survey Says… →

RxTrace Traceability Survey

DQSA: Did The Authors Get The Timeline Right?

February 3, 2014 Dirk Rodgers 2 Comments

In the last update by the California Legislature, the timeline for the rollout of the California pedigree law was spread out so that it was to take 2 ½ years from the first manufacturer deadline for serialization of 50% of their product until everything was serialized, pedigreed and wholesalers and pharmacies were making use of the serial numbers and pedigrees. Of course, everyone should be aware by now that the U.S. Drug Quality and Security Act (DQSA) preempted that law and all State and Federal pharma serialization and pedigree laws, and replaced them with new Federal requirements that have a different rollout timeline.

The track and trace provisions of the DQSA are defined within Title II of that act, known as the Drug Supply Chain Security Act (DSCSA). Some of its provisions begin next January. Some start in November of 2017 and some start in 2023. Continue reading DQSA: Did The Authors Get The Timeline Right? →

DQSA of 2013

How the DQSA Will–And Won’t–Protect The Supply Chain, Part 2

January 27, 2014 Dirk Rodgers 5 Comments

Last week I published an overly long essay about how the supply chain provisions of the new U.S. Federal DQSA will and won’t protect the pharma supply chain. Believe it or not, I had more to say on the subject, but because that essay was already too long, I withheld my additional thoughts until now. Part 1 took another look at a number of supply chain crimes that have occurred over the last 5 to 6 years and attempted to determine how the new Drug Supply Chain Security Act (DSCSA) that is contained within the DQSA will add new protections that will or won’t help prevent crimes like them in the future.

In this Part 2 essay I want to look at the issue in a different way. I’d like to compare the approach that Continue reading How the DQSA Will–And Won’t–Protect The Supply Chain, Part 2 →

DQSA of 2013

How the DQSA Will–And Won’t–Protect The Supply Chain, Part 1

January 22, 2014 Dirk Rodgers

The supply chain provisions contained within the Drug Quality and Security Act (DQSA)—themselves known as the Drug Supply Chain Security Act (DSCSA)—mark a significant achievement by Congress and the industry to protect the U.S. pharmaceutical supply chain from criminals. It is the first completed attempt since 1987 when the Prescription Drug Marketing Act (PDMA) was enacted by Congress and signed by President Ronald Reagan. In comparison, the provisions of the DSCSA are much more detailed and extensive than the PDMA and they read as if they were heavily influenced by people who solidly understand the scale and complexity of the legitimate supply chain. Which, they were, based on the contribution of the Pharmaceutical Distribution Security Alliance (PDSA)—made up of key stakeholders in the supply chain—in their development. That should ensure that the industry will be able to adopt the technology and process modifications necessary to meet the new law on time.

But will all this also lead to true protection of the supply chain from criminal activities? Will the DSCSA portion of the DQSA end up presenting new and insurmountable barriers against criminals who game the supply chain to their advantage and thereby putting patients at risk? These are the true measures of the success of this type of legislation. How can we know if the DSCSA will have these positive affects? Continue reading How the DQSA Will–And Won’t–Protect The Supply Chain, Part 1 →

Global Alignment

Don’t Skip The DQSA Definition of Terms Section

January 13, 2014 Dirk Rodgers 1 Comment

Lots of people across the U.S. pharma supply chain are spending their spare time these days trying to read and understand the U.S. Federal Drug Quality and Security Act (DQSA) that was enacted in November and begins to take effect in a significant way next January (see “It’s Official, President Obama Signs H.R. 3204, DQSA, Into Law”). I am one of those people.

I have carried a printout of Title II (the Drug Supply Chain Security Act, or DSCSA) of the DQSA around with me ever since it was passed and it is now so dog-eared and marked up that I am about ready to print out another copy. Only trouble is, I would need most of those markings in the new copy too, so I just keep using the same printout.

My understanding of the law and its implications rises every time I study it. Sometimes Continue reading Don’t Skip The DQSA Definition of Terms Section →

Data analytics, Drug diversion

Detecting Drug Diversion With Data Analytics–An RxTrace Interview With Analytics Expert Kosta Tzavaras

January 6, 2014 Dirk Rodgers 5 Comments

This week I have a special treat to share with RxTrace readers. It is an interview I recently conducted with Kosta Tzavaras, author, publisher, leading data management expert in the pharmaceutical industry and Solutions Manager with Phi Systems in Thousand Oaks, California. Kosta is a consultant to pharma and biotech manufacturers specializing in data analytics using supply chain and reimbursement data to help detect various kinds of drug diversion.

The original interview was conducted last summer and we updated it last week to reflect the recent passage of the Federal Drug Quality and Security Act.

Dirk: Welcome Kosta. Please describe your business…what it is that you do at a high level?

Kosta: Phi Systems is focusing in a niche area within the brand protection business in pharmaceuticals dealing with provider type of diversion, that is where healthcare providers are involved. The two particular areas I’m focusing on are physician office diversion—diversion that is enabled by the actions of certain physicians and their practices—and the second has to do with 340B diversion or PHS (Public Health Services) account diversion. That is diversion enabled, again, by Continue reading Detecting Drug Diversion With Data Analytics–An RxTrace Interview With Analytics Expert Kosta Tzavaras →

RxTrace

Yearly Archives: 2014