The New GS1 US DSCSA Implementation Guidance Suite

A few weeks ago, GS1 US published version 1.2 of the DSCSA implementation guidance that documents how to apply GS1 standards when meeting the U.S. Drug Supply Chain Security Act (DSCSA).  GS1 US is the GS1 Member Organization (MO) in the United States, of GS1, the global supply chain standards organization.  Companies who market drugs in … Continue reading The New GS1 US DSCSA Implementation Guidance Suite

FDA Speaks At GS1 Connect

Last week, Connie Jung, RPh, PhD, Acting Associate Director for Policy and Communications, Office of Drug Security, Integrity, & Recalls, U.S. Food and Drug Administration, spoke about the Drug Supply Chain Security Act (DSCSA) at the GS1 US Connect event in Washington DC.  This was our latest opportunity to get a glimpse of what the … Continue reading FDA Speaks At GS1 Connect

Is A GS1 GTIN Really Usable As An NDC For DSCSA Compliance? Part 2

Part 1 of this essay provided a wealth of hyperlinks into the Code of Federal Regulations (CFR) and FDA guidance documents with content related to placing the National Drug Code in human- and machine-readable form onto drug packages prior to November 27, 2017 (see “Is A GS1 GTIN Really Usable As An NDC For DSCSA … Continue reading Is A GS1 GTIN Really Usable As An NDC For DSCSA Compliance? Part 2

Is A GS1 GTIN Really Usable As An NDC For DSCSA Compliance? Part 1

After November 27, 2017 the U.S. Drug Supply Chain Security Act (DSCSA) requires drug manufacturers (2018 for repackagers) to affix a DSCSA “product identifier” to all drug packages entering the supply chain (see “The DSCSA Product Identifier On Drug Packages”).  According to the DSCSA, that product identifier must be present in both human-readable and 2D … Continue reading Is A GS1 GTIN Really Usable As An NDC For DSCSA Compliance? Part 1

GS1 Publishes Version 16 Of Their General Specifications …And Why You Should Care

Medical device manufacturers have a choice of standards to use when identifying their products for the U.S. market.  The FDA’s Unique Device Identification (UDI) rule allows them to select from any identification standards organization (referred to as a “number issuing” agency) that is accredited by the Agency for that purpose.  So far, three organizations have … Continue reading GS1 Publishes Version 16 Of Their General Specifications …And Why You Should Care

I’ve Changed My Mind, Follow GS1’s HRI Specification

That’s right, I now recommend that you follow GS1’s Human Readable Interpretation (HRI) specification for drug labeling, even when under a serialization regulation.  Previously I recommended against it (see “The DSCSA Product Identifier On Drug Packages”, and “The ANVISA Unique Medicine Identifier (IUM) on Drug Packages”).  Why have I changed my mind?  GS1 modified their … Continue reading I’ve Changed My Mind, Follow GS1’s HRI Specification

Why Does ANVISA Embrace GS1 Standards, Except The Serial Number?

In Brazil, the National Agency of Sanitary Surveillance (ANVISA) has built their pharma serialization regulation around GS1 standards.  They embrace the GS1 Datamatrix and GS1-128, both encoded with GS1 Application Identifiers (AI) and using GS1 Human Readable Interpretation (HRI) (see my previous essay, “The ANVISA Unique Medicine Identifier (IUM) on Drug Packages”, for my thoughts on … Continue reading Why Does ANVISA Embrace GS1 Standards, Except The Serial Number?