Tag Archives: cGMP

DSCSA, Repackaging

Who Is A DSCSA Repackager?

????????????????????????A while back I posted an essay called “Who Is A DSCSA Dispenser?”.  I don’t think many actual dispensers read it because about half of the dispensers I run into think the earliest they have to do anything is July of next year.  The other half don’t think there is anything in the Drug Supply Chain Security Act (DSCSA) about them at all.  Too bad.  Both are wrong.

Fortunately I think repackagers know better.  At least they should, because the DSCSA contains a lot of specific requirements for them.  Repackagers have most of the same requirements that manufacturers do, plus they have many of the wholesale distributor requirements.  A double whammy.

Most people in the industry know what a repackager is.  Typically they are companies that buy drugs from a manufacturer or a wholesale distributor and then open the packages and put the drug into a new package type.  This can include putting the drug into a larger or smaller quantity package, or from bottles into blister cards or even unit dose packs for use in an automated picking machine.  It can also include companies who Continue reading Who Is A DSCSA Repackager? →

RFID

The Case Against RFID In Pharma

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iStock_000001225482SmallerIt is pretty clear that there is not much interest in the use of Radio Frequency IDentification (RFID) in the pharmaceutical supply chain because every time I publish an essay in RxTrace about some aspect of it, there is a drop in readership.  So at the risk of taking another hit in readership, let’s take a look at the case against the use of RFID in the pharma supply chain.

Back in 2010 I published an essay that really rattled my friends in the RFID vendor community (see “RFID is DEAD…at Unit-Level in Pharma”).  Since that essay was published, the two or three drug companies that were previously shipping drugs with package-level RFID tags on them have ended that practice, replacing the RFID tags with 2D barcodes.  This includes Purdue Pharma and Pfizer, the two flag carriers for RFID in pharma back in the late 2000s Continue reading The Case Against RFID In Pharma →