Yearly Archives: 2018

DSCSA

3 DSCSA Requirements You Can Totally Ignore

The Drug Quality and Security Act (DQSA) was constructed back in 2013 by Congressional staff, with input from the FDA, members of the industry and who knows who else.  There was one bill in the House of Representatives and a different bill in the Senate.  Once these bills passed their respective houses, they formed a conference committee who merged the two bills into the final text that we know today as the DQSA (see “It’s Official, President Obama Signs H.R. 3204, DQSA, Into Law”).  Chapter 2 of that act is the Drug Supply Chain Security Act (DSCSA).  Most readers of RxTrace haven’t forgotten that history but it is important to look back at that history to explain why most companies can ignore certain requirements in the law.  That’s right.  There are requirements in the law that you can ignore because they will not be enforced by anyone.  They are the result of the disjoint way the DQSA was written.  Let me explain. Continue reading 3 DSCSA Requirements You Can Totally Ignore →

Data Exchange, DSCSA

EDDS: The New Data Exchange Requirements

The Enhanced Drug Distribution Security (EDDS) phase of the Drug Supply Chain Security Act (DSCSA) is due to begin on November 27, 2023.  That’s the first day that the US pharma supply chain is supposed to fully operate with serial numbers.  Yes, serial numbers in human readable and encoded into 2D barcodes will be on every drug packaged after November of this year, but there is only limited use of those serial numbers in the supply chain until 2023.  But when the EDDS starts, everything changes.  From that point on, every Transaction Information (TI) document must include the full DSCSA Unique Identifiers—including the serial numbers for the first time—that are physically included in the shipment, the Transaction History (TH) no longer needs to be exchanged, and the data exchange requirements change.  Let’s focus in on those data exchange changes. Continue reading EDDS: The New Data Exchange Requirements →

DSCSA, FDA

2018: The Year of FDA DSCSA Public Meetings

Happy New Year, 2018 is here!  Last year, the FDA announced a series of three Drug Supply Chain Security Act (DSCSA) Public Meetings (see “FDA Announces New DSCSA Pilot Program and Public Meeting Series”).  So far they have held two (see “FDA DSCSA Public Meeting #1 Exposes Gulf In Goals” and “FDA DSCSA Public Meeting #2, Still A Gulf”).  One more is left in that series, to be held on February 28, 2018. Continue reading 2018: The Year of FDA DSCSA Public Meetings →