The Pharmaceutical Distribution Security Alliance (PDSA) is a coalition of companies and organizations dedicated to the safety and integrity of the U.S. pharmaceutical supply chain. When the Drug Supply Chain Security Act (DSCSA) went into effect on November 27, 2013 the PDSA began to serve as a voice for its members in communications with the U.S. FDA. Their preferred way of communication is through formal letters signed by their legal advisor, Vince Ventimiglia. PDSA letters to the FDA are really interesting because they do an excellent job of providing recommendations for the FDA to consider as they prepared to publish the four guidance documents that were due back on November 27, 2015. The FDA has still not published those documents. Continue reading In Absence Of FDA Guidance, Follow PDSA Recommendations
All posts by Dirk Rodgers
Ken Traub (1963 – 2017)
Like all of you, I was incredibly shocked and sad to hear that my friend and occasional collaborator Ken Traub passed away on Sunday. My heart and prayers go out to his wife and son. Ken will be remembered for a long time by people all over the world because of the depth of his technical knowledge, the clarity of his writing, the impact of his succinct speaking, the creativity of his thinking, the passion he had for solving complex problems, and the love in his heart.
According to Brezniak-Rodman Funeral Directors, the memorial service will be held at Temple Isaiah, 55 Lincoln Rd., Lexington, on Wednesday, April 5, 2017 at 11:00 am. Memorial contributions may be made to any cancer charity.
I’ve known Ken for a few Continue reading Ken Traub (1963 – 2017)
Can Anyone Buy Non-Serialized Drugs After 11-27-2019?
Well over a year ago, my good friend Kevan MacKenzie, Director, Serialization Technology with McKesson, pointed out a really interesting discrepancy contained in the Drug Supply Chain Security Act (DSCSA) regarding the sale of non-serialized drugs. I’ve been meaning to write about it since then. The topic finally bubbled up to the top on my list.
What Kevan pointed out is that there are two sections of the DSCSA that contain slightly conflicting requirements. This leaves companies Continue reading Can Anyone Buy Non-Serialized Drugs After 11-27-2019?
Sponsored: How To Properly Define GTINs For Your NDCs
RxTrace readers are well aware that the deadline is this November 27 for applying unique serial numbers within GS1 DataMatrix 2D barcodes to prescription drugs distributed in the United States under the Drug Supply Chain Security Act (DSCSA). Once that happens, most prescription drugs entering the U.S. supply chain will be identified by 14-digit GS1 Global Trade Item Numbers (GTIN-14) for the first time (see “Anatomy of a GTIN”). That’s because, you can’t fit the drug’s National Drug Code (NDC) along with the serial number, lot number and expiration date into a data matrix barcode, as required by the law, without first encoding it into a GTIN-14 (see “Anatomy Of The National Drug Code”, and “Depicting An NDC Within A GTIN”). This fact forces companies to encode their NDCs into GTIN-14s, many for the first time. Continue reading Sponsored: How To Properly Define GTINs For Your NDCs
DSCSA Serialization: What Wholesalers Expect
Recently, several of the larger U.S. wholesale distributors have sent letters to their suppliers to review what they expect from them relative to the Drug Supply Chain Security Act (DSCSA). You may recall that these companies have provided requirements in advance of earlier DSCSA deadlines (see “U.S. Drug Wholesale Distributors Provide Direction To Manufacturers“). These expectations are aimed at the November 27, 2017 serialization requirements and beyond. Continue reading DSCSA Serialization: What Wholesalers Expect
My Handshake With Germany
Our industry is international by nature. Protecting patients from counterfeit drugs is partly a humanitarian mission and partly a business. Consequently, I don’t worry much about who is looking for information on RxTrace. I have happily fielded queries from Russia, China and even Iran, countries who are not always political “friends” of my beloved country.
But what if a counterfeiter is seeking information Continue reading My Handshake With Germany
Pharma Serial Number Randomization Under The Falsified Medicines Directive
Drug companies who serve markets within the European Union (EU) have until February 9, 2019 to add serial numbers within a Data Matrix barcode to their drug packages, among many other specific requirements (see “The ‘Unique Identifier’ in the EU Delegated Act”). The specific requirements are outlined in the EU Delegated Regulation (EUDR). I’ve written a lot about the EUDR over the last few years (see RxTrace: Delegated Regulation). Today I want to highlight and explain a problem that may be brewing in the implementation of the system of repositories as established by the non-profit European Medicines Verification Organization (EMVO). The potential problem is related to the way the EMVO Continue reading Pharma Serial Number Randomization Under The Falsified Medicines Directive
Sponsored: Pharma Traceability
Pharmaceutical serialization and traceability laws continue to be developed all over the world. In any one market, it takes several years to progress from the initial stirrings to the publication of full, workable regulations. As we have seen, several countries have had to take a few steps back, make adjustments and then move forward again (see “Brazil Gets Rational With Their New Pharma Traceability Law” and “China’s Retreat From Pharma Serialization: Will This Become A Global Trend?”). In fact, I think those countries that do, will end up with a much better approach.
What that means to you is Continue reading Sponsored: Pharma Traceability
