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L, A, S, C
Hi Dirk,
I got a kick at your sub-title for this article! I know you’re aware of this, but …
Maybe this is a case of “the journey is more important than the destination”. While it might seem that the DSCSA law and industry is attempting to solve the problems of 2003 in 2017, it also seems the industry has implemented practices that have improved supply chain integrity as they have confronted counterfeit, diversion and theft issues together.
As we worked through the early years of the Florida, Nevada and California laws leading up to the DSCSA, the wholesale industry moved from trading based on price arbitrage (an incentive for diverters and counterfeiters) to trading on a fee for service basis. Meanwhile, regulators and industry moved from licensing and selling to anyone who claimed to be a wholesaler to stricter licensing and trading with “Authorized Trading Partners”. Remember the days when “you could get a wholesale license if you had $750 and a refrigerator”? These and a lot of other changes have created a safer, more self-scrutinized supply chain.
So, while it may be true that the DSCSA and all its requirements, will provide a tremendous amount of data documenting the safety of the supply chain, it’s due to the business practices that regulators and industry have put in place that have increased vigilance and better secured the supply chain. I’m not sure what would happen to all of that if the DSCSA was to be removed. Would things remain at this higher state of vigilance, or would other concerns and pressures lead us to take our eye off the ball?
Lastly, it’s hard not to be saddened at the tremendous cost that has and will be absorbed by the industry, regulators and patients solely because people exist (counterfeiters, diverters and thieves) that would gladly turn a profit on other’s misery.
Keep up the good work!
Bob