The Best Laid Plans…

March 18, 2013 Dirk Rodgers

I attended the California Board of Pharmacy Enforcement Committee meeting last week and several topics came up that I want to write about. Unfortunately I’ve been doing a lot of traveling since then and all of a sudden I started having computer problems a few days ago. My youngest daughter is getting married next month and so the family met up in Chicago this past weekend for several of the events leading up to the big one. There is more travel scheduled for this week.

Travel doesn’t normally interfere with my ability to write on a deadline, but Continue reading The Best Laid Plans… →

GS1 Healthcare US, track and trace, Uncategorized

The New GS1 Healthcare US Track & Trace Guidance

March 11, 2013 Dirk Rodgers

GS1 Healthcare US

GS1 Healthcare US, an arm of GS1 US the member organization (MO) of the global GS1 standards organization, has just published the “preliminary version” of a track & trace implementation guide. The full title is “Implementation Guideline, Applying GS1 Standards to U.S. Pharmaceutical Supply Chain Business Processes To Support Pedigree And Track & Trace, Release 1.0”.

This document contains the accumulation of thought and best practices generated over the last nine years within various working groups of GS1 Healthcare US and from pilots conducted by its members (including the Abbott Labs, McKesson, VA and GHX pilot that I wrote about in “The Significance of the Abbott, McKesson and VA Pilot”). Pulling it all together into a single coherent document turned out to Continue reading The New GS1 Healthcare US Track & Trace Guidance →

California Pedigree Law

The New Grandfathering Provisions Of The California Pedigree Law

March 4, 2013 Dirk Rodgers 1 Comment

At the February 5, 2013 meeting of the California Board of Pharmacy the Board took the final vote to proceed with filing a number of important clarifying regulations–the first since the Ridley-Thomas bill was enacted in 2008 that established the current staggered effective dates. These include the recognition of the FDA Standardized Numeric Identifier (SNI) as the “unique identifier” for use on each drug package, and definition around how supply chain companies can grandfather their existing non-serialized, non-pedigreed stock at the time the law goes into effect.

The official minutes of the meeting are not yet available but the video has been posted for a few weeks now. The pertinent action occurs in the first video of the two day meeting at approximately 2:24:00 (hours:minutes:seconds). (Don’t you just love government meetings on YouTube?) The source text of the pending regulation (which is Continue reading The New Grandfathering Provisions Of The California Pedigree Law →

pedigree software

E-Pedigree Vendor Selection

February 25, 2013 Dirk Rodgers 10 Comments

On Friday after 5pm I received a call from a potential consulting client. At least I thought that’s what they were. It turned out, it was a headhunter looking for warm bodies to work on serialization and pedigree projects to fill a quota he has from the consulting arm of one of the big-4 accounting firms. The people he’s looking for would probably work on projects under the direction of one of their long-term senior consultants. I’m not looking for that kind of opportunity.

My impression is that this is a sign that we are entering the “Y2K” phase of the California E-pedigree deadlines. That is, it is time for lots of “staff augmentation” companies to staff-up to offer “expertise” in droves. Continue reading E-Pedigree Vendor Selection →

RxTrace

New RxTrace Column in Healthcare Packaging Magazine

February 21, 2013 Dirk Rodgers 1 Comment

The February issue of Healthcare Packaging Magazine is out today in digital form and it contains my first contribution as Contributing Editor in my regular column called…wait for it…RxTrace! Check it out here and let me know what you think. Subscribers of the print magazine should receive their copy in the mail soon. This will expose my ideas to an even wider audience and to more traditional readers.

I’d like to thank the great folks at Summit Media Group for extending the invitation and working it out. Particular thanks go to Editor-In-Chief Jim Butschli and Publisher Jim Chrzan. Great work guys. It looks fabulous. Continue reading New RxTrace Column in Healthcare Packaging Magazine →

Falsified Medicines

Well-Intended Report Calls For Global Track & Trace Of Pharmaceuticals

February 18, 2013 Dirk Rodgers 4 Comments

I’ve been reading the Institute of Medicine (IOM) report called “Countering the Problem of Falsified and Substandard Drugs” that was published last week. At 360 pages, it is quite literally a book, and you can buy it that way. But they also allow you to download the “Pre-publication Copy: Uncorrected Proofs” version in a 300 page PDF for free. I’m not sure why they would post uncorrected proofs rather than the final document on their site but I assume the text is in its final edited form and only the formatting might be different between the book and the PDF. I hope so anyway.

I have not yet read the whole thing so this isn’t intended to be a proper review (see the Regulatory Focus article about it). The document offers Continue reading Well-Intended Report Calls For Global Track & Trace Of Pharmaceuticals →

supply chain security

The Supply Chain Provisions Of The FDA Safety & Innovation Act

February 11, 2013 Dirk Rodgers 1 Comment

Secretary of Health and Human Services Kathleen Sebelius, President Barack Obama, Representative Nancy Pelosi

Last fall the U.S. Congress passed the Food and Drug Administration Safety and Innovation Act, or FDASIA, and the bill was signed into law by President Obama. The purpose of the legislation was primarily to re-authorize user fees that are paid by manufacturers of drugs, medical devices and biologics, but the law also contains quite a few other things. Readers of RxTrace will recall that the well-organized attempt to add a nationwide track & trace requirement to the bill failed (see “PDUFA Will Not Include RxTEC”), but a number of very significant supply chain security elements did make it into the law under the title “Title VII—Drug Supply Chain” (see the full text of the law here). A closer look at these provisions is long overdue. Continue reading The Supply Chain Provisions Of The FDA Safety & Innovation Act →

Counterfeit Drugs

InBrief: Illegally Imported Drugs Found To Be Counterfeit…Again

February 6, 2013 Dirk Rodgers

Yesterday the FDA alerted healthcare providers that a cancer drug illegally imported and distributed to medical practices by a licensed pharmaceutical distributor going by the names “Medical Device King” and “Pharmalogical”, and Taranis Medical, is counterfeit. The FDA alert can be found here. Once again, the drug is labeled as Altuzan, a version of bevacizumab which contains the same active ingredient as Avastin. Here is AP story about it. Here is the WSJ article about it.

Avastin was the subject of a counterfeit importation crime about a year ago, (see “How Counterfeit Avastin Penetrated the U.S. Supply Chain“).

It is illegal to import drugs that are not approved by the FDA for sale and use in the U.S., and so even if the drug had not turned out to be a counterfeit version, this would have still been a crime. It makes me wonder if the reason this case came to light was because the drug name on the package was clearly not approved here. What if the counterfeit drug had been Continue reading InBrief: Illegally Imported Drugs Found To Be Counterfeit…Again →

…a comprehensive exploration of the intersection between healthcare supply chains, track and trace technology, standards and global regulatory compliance