Before You Participate in The GS1 US 2015 Readiness Program, Read This

Important Notice To Readers of This Essay On November 27, 2013, President Barack Obama signed the Drug Quality and Security Act of 2013 into law. That act has many provisions, but one is to pre-empt all existing and future state serialization and pedigree laws like those that previously existed in California and Florida. Some or all of the information contained in this essay is about some aspect of one or more of those state laws and so that information is now obsolete. It is left here only for historical purposes for those wishing to understand those old laws and the industry’s response to them.

GS1 US is dedicated to expanding the adoption of GS1 Global’s standards for supply chain interaction in the U.S. market.  Almost every country in the world has a GS1 “Member Organization” (M.O.) that is dedicated to the same thing within their borders.  With the local M.O.’s primary focus on driving adoption, their most valuable tool is that country’s government.  If they can get the government to reference GS1 standards in their laws, their work is much easier.

This isn’t unique to GS1, or course.  All standards organizations know this and they all have various approaches to getting the attention of each country’s government.  There is nothing wrong with this.  In fact, it makes perfect sense since, unlike standards organizations themselves, countries always have very large enforcement wings.

But what happens when those governments are too big to sway easily?  What if it costs too much and takes too long to get them to see the light?  This is when a standards adoption organization needs to get creative.  In my opinion, that’s what has led GS1 Healthcare US to create the “2015 Readiness Program”.  It was out of frustration with the California State Government and with the U.S. Food and Drug Administration (FDA) and their, so far, unwillingness to create laws and regulations that mandate the use of GS1 standards.  Let me explain. Continue reading Before You Participate in The GS1 US 2015 Readiness Program, Read This

A Semi-Centralized, Semi-Distributed Pedigree System Idea

Four years ago the GS1 EPCglobal Software Action Group (SAG) Drug Pedigree Messaging Work Group was wrapping up the standard specification for the GS1 Drug Pedigree Messaging Standard (DPMS, aka GS1 Pedigree Ratified Standard).  That standard was developed through collaboration between U.S. pharmaceutical supply chain members, industry associations, solution providers and GS1.  DPMS 1.0 was ratified by the EPCglobal Board in early January 2007.

DPMS has many benefits.  It results in a self-contained, self-secure electronic document that clearly shows the chain of ownership and/or custody of a given drug package (or a set of packages if they all have the same history).  It works equally well with serialized and non-serialized products.  The security of DMPS documents comes from within the electronic documents themselves rather than just from a security layer wrapped around a given server.  A self-contained, self-secure document model should work well as evidence in a criminal trial.

But even before DPMS was ratified people were raising questions and concerns about it.  Those concerns were Continue reading A Semi-Centralized, Semi-Distributed Pedigree System Idea

Stop Claiming that 10% of Drugs Worldwide are Counterfeit

There was a flurry of discussion last week over a recent Wall Street Journal blog by their “Numbers Guy”, Carl Bialik, regarding the often quoted “estimate” that 10% of drugs worldwide are counterfeit. On September 10, Bialik posted an essay titled, “Dubious Origins for Drugs, and Stats About Them“. The next day he published an article on the topic called “Counterfeit Drug Count Is Tough to Swallow“.  Both essays call into question the origins and the accuracy of the “estimate”.  On September 13, Dr. Adam Fein posted an essay titled, “The Counterfeit Counterfeit Drug Count” on his DrugChannels blog, citing the WSJ essays and providing some additional insight.

Don’t miss the many comments left by readers of Bialik and Fein’s postings.  It’s surprising how Continue reading Stop Claiming that 10% of Drugs Worldwide are Counterfeit

Masterpiece: GS1 Tag Data Standard 1.5

GS1 EPCglobal ratified and published the most recent version of the Tag Data Standard (TDS), 1.5.  I have always been a fan of TDS, but earlier versions served as much to expose embarassing disconnects in GS1 standards as they did to explain how to apply GS1 identifiers in an Radio Frequency IDentification (RFID) context.  Earlier versions of TDS tightly bound the concept of the Electronic Product Code (EPC) to RFID, and that’s just wrong.  “EPC”, even as defined in those earlier versions of TDS, is a way of uniquely identifying objects on a global basis.  It’s purely a globally unique identifier standard.  That’s a hugely important and relatively new concept.  RFID–a simple data carrier technology that’s been around for many years–is almost insignificant in comparison.

Even the name “Tag Data Standard” reflects this wrong-headed binding of EPC to RFID by seeming to place the RFID “Tag” at the center of the “standard”.  Yes, there is a need for a “Tag Data Standard”, to show how to encode an EPC into an RFID tag, but it is wrong to Continue reading Masterpiece: GS1 Tag Data Standard 1.5

Yifan “Ivan” Shen (1962–2010)

Ivan in happier times

I received news last night that my friend and co-worker, Ivan Shen, passed away on Sunday after losing a five month battle with cancer.  During his career Ivan worked for serialization and pedigree companies including Oat Systems, Reva Systems and SupplyScape (now TraceLink).  Many RxTrace subscribers are current or former co-workers or former customers of Ivan. Continue reading Yifan “Ivan” Shen (1962–2010)

Estimated Rise In Serialized Drugs In The U.S. Supply Chain

Back in 2005 I created a line graph of my personal prediction of the percentage of pharmaceuticals in the U.S. supply chain that would be unit-level serialized by the manufacturer and I circulated it among my co-workers at the time.  I based it purely on guesses that were “supported”–very flimsily–by the number of large pharmaceutical manufacturers who were participating in the GS1 EPCglobal Healthcare and Life Sciences (HLS) Business Action Group (BAG) (the group is now defunct), and the existence of an early version of the California Pedigree Law.  The graph included a high and low line that formed a band that I thought would be where the reality would fall.  In that prediction I didn’t think most manufacturers would achieve 100% serialization of their products until sometime between 2010 (high) and 2015 (low).

In my analysis at that time, I theorized that the actual percentage would start out following my “low” estimate line, but at some unpredictable point, something would happen that would cause the percentage to jump up to the “high” estimate line.  At the time, I assumed the event that would cause that jump would be the U.S. Federal government issuing some kind of pedigree regulation that included a unit-level serialization requirement.

As it turned out, things moved slower than I had guessed.  Here it is 2010 and the percentage of drugs in the supply chain with unit-level serial numbers on them is so small that it’s tough to give it a percentage.  But I think my estimate from way back in 2005 was not bad for its time (but notice I’m not publishing the actual graph).  After all, the California Pedigree deadline has been pushed out at least three times since then (from 2007 to 2009, to 2011, to 2015/1016).

I think the future is a little less murky now because, since 2005, Continue reading Estimated Rise In Serialized Drugs In The U.S. Supply Chain

RxTrace, One Year Retrospective

RxTrace is now one year old.  There are 34 essays that together amount to a true liberal exploration of the intersection between the pharmaceutical supply chain, track and trace technology, standards and regulatory compliance…as promised.

My personal favorite essays from the past year, in chronological sequence are:

Since late January I have been collecting some statistics on page views on RxTrace and here is the list of the essays in the sequence of page views since that time. Continue reading RxTrace, One Year Retrospective

The “Normal Distribution” Concept

Important Notice To Readers of This Essay On November 27, 2013, President Barack Obama signed the Drug Quality and Security Act of 2013 into law. That act has many provisions, but one is to pre-empt all existing and future state serialization and pedigree laws like those that previously existed in California and Florida. Some or all of the information contained in this essay is about some aspect of one or more of those state laws and so that information is now obsolete. It is left here only for historical purposes for those wishing to understand those old laws and the industry’s response to them.

 

Understanding the concept of “Normal Distribution” is important in understanding the status of pedigree regulations in the United States pharmaceutical supply chain.  The term itself didn’t exist back in the late 1980’s when the federal Prescription Drug Marketing Act (PDMA) pedigree provisions were originally enacted by Congress but the concept is built into that law as the “Authorized Distributor of Record” (ADR) concept.  When states began enacting their own pedigree legislation back in the early 2000’s, the term “normal distribution channel” was defined to describe the path of drugs when they move through the most common–or “normal”–sequence of supply chain owners.  It’s a concept that is explicitly defined in most state pedigree legislation.

When a pedigree law is a “normal distribution” law, it generally means that pedigrees are not needed for any shipment or change of ownership where the drugs do not leave this common/typical/normal path as defined in the law.  But as soon as a change of ownership or custody occurs where the drug leaves this “normal” path, a pedigree is then necessary.

Typically, when a pedigree is required outside the “normal distribution channel”, that pedigree must Continue reading The “Normal Distribution” Concept

DISCLAIMER: RxTrace contains some of the personal thoughts, ideas and opinions of Dirk Rodgers. The material contained in RxTrace is not legal advice. Dirk Rodgers is not a lawyer.
The reader must make their own decisions about the accuracy of the opinions expressed in RxTrace. Readers are encouraged to consult their own legal counsel
and trading partners before taking any actions based on information found in RxTrace. RxTrace is not a vehicle for communicating
the positions of any company, organization or individual other than Dirk Rodgers.

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