Tag Archives: EFPIA

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

DSCSA: Congress Should Have Mandated Randomization

iStock_000015967853SmallerCongress should have mandated randomization of drug serial numbers, but they did not, so it is up to each manufacturer to recognize the importance it would bring to the protection of their brands and of the supply chain.  Let me explain.

The text of the Drug Supply Chain Security Act (DSCSA) was developed last year by Congressional staff in consultation/negotiation with various lobbying organizations—primarily the Prescription Drug Security Alliance (PDSA).  The effect of the legislation is to create a way of protecting the U.S. pharmaceutical supply chain that relies primarily on product identifier authentication (PIA) (see “Product Identifier Authentication” and “The Aggregation Hoax and PIA”) for at least the first 10 years and possibly beyond. Continue reading DSCSA: Congress Should Have Mandated Randomization

Product Identifier Authentication (PIA)

iStock_000015985566SmallerIn my last essay I touched on the use of Product Identifier Authentication, or PIA, as an alternative to the collection and distribution of aggregation data to allow wholesale distributors and repackagers to meet the verification requirements of the Drug Supply Chain Security Act (DSCSA).  Starting in November of 2018 for repackagers and in November of 2019 for wholesalers, the DSCSA will require these companies to verify that the standardized numerical identifier (SNI)—commonly referred to as “the serial number”—corresponds with one that the manufacturer originally applied to drugs that are found to be suspect, and for any returned drug that will be resold.

As I pointed out in my previous essay (see “The Aggregation Hoax and PIA”), manufacturers and repackagers may be able to choose to pass on aggregation information that would allow wholesale distributors to meet their requirements, or they might choose to offer a PIA service that would allow these companies to check the authenticity of one or more SNIs via a web service. Continue reading Product Identifier Authentication (PIA)

Randomization—An Interview with Ken Traub—Part 5: Other Approaches

???????????????????This is the last of a five part interview with Ken TraubGS1 standards expert and independent consultant, on GS1 serial number randomization.  The full series includes essays covering:

  1. GS1 Serial Number Considerations
  2. Properties of Randomization
  3. Threat Analysis
  4. Algorithmic Approach
  5. Other Approaches to Randomization (this essay)

This week Ken talks about other approaches to serial number randomization.  – Dirk. Continue reading Randomization—An Interview with Ken Traub—Part 5: Other Approaches

Randomization—An Interview with Ken Traub—Part 3: Threat Analysis

Hacker typing on a laptopThis is the third of a five part interview with Ken TraubGS1 standards expert and independent consultant, on GS1 serial number randomization.  The full series includes essays covering:

  1. GS1 Serial Number Considerations
  2. Properties of Randomization
  3. Threat Analysis (this essay)
  4. Algorithmic Approach
  5. Other Approaches to Randomization

This week Ken introduces the concept of threat analysis.  – Dirk. Continue reading Randomization—An Interview with Ken Traub—Part 3: Threat Analysis

Randomization—An Interview with Ken Traub—Part 2: Properties of Randomization

iStock_000011797297SmallerThis is the second of a five part interview with Ken Traub, GS1 standards expert and independent consultant, on GS1 serial number randomization.  The full series includes essays covering:

  1. GS1 Serial Number Considerations
  2. Properties of Randomization (this essay)
  3. Threat Analysis
  4. Algorithmic Approach
  5. Other Approaches to Randomization

This week Ken introduces three properties of randomization.  — Dirk.

Continue reading Randomization—An Interview with Ken Traub—Part 2: Properties of Randomization

Sponsored: Transatlantic Alignment

Happy Martin Luther King day!  Today we have a special guest blog essay by Mark Davison of Blue Sphere Health in the U.K..   Mark is the author of the book, “Pharmaceutical Anti-Counterfeiting”, published by Wiley in 2011. – Dirk.

BPH.logo-lrg2Pharmaceutical traceability (in its various nuances of serialization, aggregation, track and trace, epedigree etc) has been proposed, debated, boosted and resisted for a very long time. The labyrinthine twists and turns have been examined in near real time on RxTrace and I won’t revisit them here. However, the passing of the Drug Quality and Security Act (DQSA) late last year opens a new chapter.  It means greater transatlantic clarity of future compliance requirements and (whether intentional or not) it also brings near synchrony of some key deadlines. Continue reading Sponsored: Transatlantic Alignment

DQSA: The U.S. Pharma Supply Chain Must Organize, Or Risk Failure

iStock_000021010135XSmallIf there is one overriding lesson exposed by my essays last week it is that the companies in the U.S. pharmaceutical supply chain must quickly organize to work out technology and process issues that stand in the way of an efficient implementation of phase 1 of Title II of the Drug Quality and Security Act of 2013 (see “DQSA: Getting To Electronic Transaction Data Exchange” and “DQSA: Will U.S. Pharma Distributors Mandate Aggregation Data In Phase 1?”).  Title II of the DQSA is the Drug Supply Chain Security Act (DSCSA).

The law gives the FDA one year to publish guidance containing standards for use by companies in the supply chain for the exchange of Continue reading DQSA: The U.S. Pharma Supply Chain Must Organize, Or Risk Failure